Compliance Verification Activity Report: CV2021-189 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-189
Start date: 2020-08-17
End date: 2020-08-20

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Kinder Morgan Canada Inc

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Environmental protection inspection of operations and maintenance (O&M) activities on the Trans Mountain mainline (Line 1) in Jasper National Park, Alberta. The segment of NPS 24 pipeline undergoing O&M activities was deactivated in 2008 when the Anchor Loop pipeline project (i.e., Line 2) was completed. The O&M activities were largely completed in winter and spring 2020, and the focus of this inspection was reclamation at these sites, including the Snaring River. This inspection was conducted in conjunction with Indigenous Monitors representing the Indigenous Advisory Monitoring Committee.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2020-08-18 12:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

The following sites were integrity digs and other maintenance activities that occurred in early 2020 (winter/spring). No active construction was occurring at the time of the inspection.
Dig 16 ~KP 350.282

Dig 16 Access Road
Dig 18Dig 10Sleeve 4Dig 26,Sleeve 10Dig 27Sleeves 11, 12, 28Dig 25Dig 24
Sleeve 8Dig 23Sleeve 7Cottonwood Boulders

Compliance tool used: No compliance tool used

Observation 2 - Weed Management

Date & time of visit: 2020-08-19 12:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 3 - Jasper Yard

Date & time of visit: 2020-08-20 09:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 4 - Information Request No. 1 - Snaring River

Discipline: Environmental Protection

Categories:

Facility:

Observations:

North Bank

South Bank
Plants (stems)/haWoody Species
635Black cottonwood
1300Buffaloberry
1400White spruce
950Silverberry
500Wild rose
150Willow
 
Although the north bank is still an active site, reclamation activities have occurred on the south bank and the island. Additionally, the work on the north bank is, according to Company Representatives, separate from the Snaring River Pipe Replacement (valve replacement as described above).  Officers observed some spruce (with approximately 70%) survival and some willows on the south bank but other species outlined above were not observed. The island was inaccessible due to high water levels.

Additional information is required to verify compliance.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Provide a summary of woody species planted to date, including planting densities. If not all species outlined in the above table have been planted, provide justification.
  2. Provide a timeline for any additional planting that is required at all parts of the Snaring River (south bank, island, north bank).
  3. Outline the targets for survival of planted woody species and whether additional plantings will occur given the mortality of spruce observed at the site.

Due date: 2020-09-16

Date closed: 2020-10-26
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observation 5 - Information Request No. 2 - Dig 31A and Culturally Modified Tree

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Dig 31A

Culturally Modified Tree
At Dig site 31A, an IM from the IAMC identified what was believed to be a Culturally Modified Tree (CMT). This was pointed out to Trans Mountain Representatives who indicated that they were unaware of any known culturally significant sites in the area and that this finding triggered the Traditional Land Use Discovery Contingency Plan, and that a Trans Mountain’s Aboriginal Monitor (AbM) would examine the tree the following day.

Officers and IMs met with the AbM the following day, who confirmed that it is a CMT, and had been blazed with an axe, but the age cannot be determined without damage to the tree, which is currently healthy. The AbM indicated that given it is historical (possibly from construction of the original Trans Mountain Pipeline) and not recent, it is not considered a chance find.

Company Representatives confirmed that the CMT is off the pipeline RoW and they will check current records and will notify Parks Canada if it is previously unrecorded.

Additional information is required to verify implementation of the Traditional Land Use Site Discovery Contingency Plan for this discovery. 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Provide documentation demonstrating how the steps outlined above were implemented, including details such as dates, Indigenous group(s) notified and any measures taken. If any steps were not followed, explain why they were not warranted.
  2. Provide confirmation of whether Parks Canada was notified, and when. If not, explain.

Due date: 2020-09-16

Date closed: 2020-10-26
Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.

Reason closed: Requirement met

Compliance achieved: Yes

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to:

- the condition of an authorization document that requires the implementation of that plan or procedure; or

- the relevant section of the regulations that requires implementation of that plan or procedure including those sections that require implementation of plans or procedures as a part of a Program