Compliance Verification Activity Report: CV2021-306 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-306
Start date: 2021-02-19
End date: 2021-02-26

Team:

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Inspection of NGTL's 2021 Expansion Project, the construction of 350 km of 1,219 mm (NPS 48) outside diameter (OD) pipe. This inspection is limited to early works on the Elmworth and Valhalla spreads and focuses on various construction locations between Grande Prairie and Calgary, AB. Inspection will Assess compliance with the project specific Environmental Protection Plan and the OPR (Environmental Management Program).

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, Elmworth

Date & time of visit: 2021-02-23 15:35

Discipline: Environmental Protection

Categories:

Facility:

Observations:

 

Observations
  • Stripping, grading, and trenching activities were underway at the time of the inspection.  The Inspection Team did not go to any areas of active welding.  
  • RoW boundaries were staked and flagged.
  • Spoil piles were staked and labeled; topsoil was separated from subsoil.
  • Gaps in windrows and strung pipe were observed.
  • Several pieces (~3-5) of equipment checked for spill kits, fire extinguishers and biosecurity stickers. No concerns were noted.
  • Burn piles were monitored.  
  • Signs indicate wetlands, watercourses, and prohibition on refueling in those areas.
  • No construction waste was observed on the RoW.
  • The road bore trench at Road 10 was not entirely fenced off, although the material was present, when the Inspection Team was first present at approximately 14:30.  The fence was completed when the Team drove past the site one hour later.  
  • The Inspection Team signed onto Field Level Hazard Assessments and were given safety briefings at several locations when in proximity with work.  
  • At the Wapiti River HDD exit site, the Inspection Team observed site preparation pilings, a fuel storage tank with spill kit, no concerns at that site.  
  • An old wooden cabin was seen in an area being cleared.  Company representatives indicated that it was being avoided in order to preserve potential historical value.   
  • A paleontologist was on site and examining trench materials at the Beaverlodge River, which was being prepared for an open cut crossing at the time of the inspection.
  • There were no portable toilets between KP9+500 and KP16, although there were work crews along the RoW in between.  See CNC#1.
  • Several trucks with tanks were checked for spill kits.  No concerns were noted.   Trucks do not have inspection records for biosecurity.  See IR#1.  
  • The sediment fence in the northwest corner of the access bridge over the Beaverlodge River appeared to be under strain from material behind it.  The Inspection Team requested the deficiency list for more information.  See IR#2.  

 

Compliance tool used: No compliance tool used

Observation 2 - General, Valhalla

Date & time of visit: 2021-02-25 10:45

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Observations
  • Clearing and burning activities were underway at the time of the inspection.
  • Topsoil was stripped so that burning took place on mineral soil with low organic content.  No other topsoil stripping on this spread. 
  • RoW boundaries were staked and flagged, no trespass noted.  
  • Several pieces (~3-5) of equipment checked for spill kits and biosecurity stickers. The Inspection Team also requested records of cleaning of some equipment. 
  • No construction waste was observed on the RoW.
  • At the Beaverlodge River crossing area, the Inspection Team met and spoke with some of the participants in the Aboriginal Construction Participation Program.   
  • At KP13+600 there were wooden mats at the entrance to the RoW.  Company personnel indicated that equipment is bleached on those mats prior to entering the RoW, at the landowner's request.  The mats are also bleached upon arrival, and marked to show that they have been bleached.  
  • The only portable toilets were located near KP2+700, although there was work at KP1+100, 4+450, and near KP13.   See CNC#1.
  • The Inspection Team had walked and driven on the Elmworth spread in the MD of Greenview, and no measures were taken to sterilize vehicle tires or boots prior to doing the same on the Valhalla spread in the County of Grande Prairie.  See IR#1.  

Compliance tool used: No compliance tool used

Observation 3 - Construction Yard

Date & time of visit: 2021-02-24 14:25

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Observations: 

Compliance tool used: No compliance tool used

Observation 4 - Indigenous Monitor Observation

Date & time of visit: 2021-02-25 13:00

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

Tuesday, Feb. 23/2021
Attend Audio Conference with CER and TC Energy Personnel @ 6:30 am, Safety Meeting with Day’s Activity meeting, combined. Meet with TC Energy Personnel, assigned to be our “guides” on this Inspection, 4 in total, at the Midwest Construction Yard, in Grande Prairie. Orientation meeting was done and Covid19 Declaration Protocol sheets were signed. Travel to “Take Off” site, on the “Elmworth Spread”, on the pipeline Right of Way (see Photo #1). Sign on to site FLHA, at Foreman’s request.
Observations

 
Wednesday, Feb. 24/2021
Meet with CER at 08:00 am to review previous day’s activities and go over plan for the day. Travel to Right of Way (ROW) to the point where we left off the previous day, to meet TC Energy personnel. KP 14+750: Attend Field Safety Orientation and sign off on the Field Level Hazard Assessment (FLHA) for this worksite. Also visited Wapiti River crossing site (KP 24+300), attended field safety orientation and signed off on the FLHA for the area. Afterwards, travelled to the Midwest Main Construction yard in Grande Prairie, signed into Visitor’s Log at the main warehouse and inspected waste management bins. 
Observations 
Thursday, Feb. 25/2021
Meet at 8:00 am with CER to plan day’s activities. TC Energy personnel joined us at the Hotel Parking Lot to guide us out to the “Valhalla” Spread, on the ROW, 1.5 h NW of Grande Prairie.  After the Valhalla Spread, travelled to the Beaverlodge River crossing and signed on the FLHA for the area.Friday, Feb. 26/2021
Attend virtual meeting (pre-wind up) with CER at 8:00 am. Attend Wind-up meeting at 8:30 am with CER and TC Energy to Close Out the Inspection. 

Compliance tool used: No compliance tool used

Observation 5 - Information Request (IR) #1 Weed control and biosecurity

Discipline: Environmental Protection

Categories:

Facility:

Observations:

The Inspection Team inquired about weed-control measures and equipment cleaning stations. 
Company representatives indicated that the cleaning stations are not permanent, but are locations where cleaning occurs as required, for topsoil handling equipment in agricultural areas. 
Company representatives also indicated that equipment being used in the Municipal District of Greenview would be cleaned before being used in Grande Prairie County, due to potential clubroot concerns.  Such equipment would be cleaned mechanically, and then a bleach solution applied to tracks.  
The Company indicated that this bleach cleaning was required only for topsoil handling equipment, and was not applied to equipment that does not handle topsoil, to trucks, all-terrain vehicles, or the boots of people moving from one municipal area to another, except at landowner request.  However, the EPP specifically includes mats in the list of equipment to be sanitized.  Omitting trucks, ATVs and boots from the requirement appears inconsistent.  

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Question 1.1
The Company is required to provide information that shows the risk assessment that was conducted to determine the level of cleaning required, and the vigilance required to maintain biosecurity when equipment, vehicles and other materials move from one municipality to the other. 
This should include an assessment of:

  1. equipment that does not handle topsoil
  2. vehicles
  3. boots
  4. all-terrain vehicles
  5. other items (light stands, air compressors, portable toilets, etc) that may be in contact with topsoil. 

Question 1.2
The Company is to provide cleaning records for the following equipment:  

Note that there are two pieces of equipment noted as Ken-Co unit 300.  The Company is to provide clarification as to how the records are kept to distinguish them.   

Due date: 2021-03-12

Date closed: 2021-03-18
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 6 - IR #2 Sediment Fencing at Beaverlodge River Crossing

Discipline: Environmental Protection

Categories:

Facility:

Observations:

The sediment fence in the northwest corner of the access bridge over the Beaverlodge River appeared to be under strain from material behind it.  The Inspection Team requested the deficiency list for more information. 
The strained sediment fencing had been added to the deficiency list provided on 26 February, but no documentation to indicate if and when it would be addressed was provided.  

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

The Company is to provide:

Due date: 2021-03-12

Date closed: 2021-03-18
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 7 - Corrected Non Compliance (CNC) #1 Portable Toilets

Date & time of visit: 2021-02-23 15:00

Discipline: Safety Management

Categories:

Facility:

Observations:

At the Elmworth section, the inspection team noted that along the Right of Way, there were portable toilet facilities at KP 9+500, and that crews were working between that point and approximately KP16, with no access to other toilet facilities.   There was not hand-cleaner available in four of the five portable toilets visited on the Elmworth section.  
At the Valhalla section, the only toilet facilities were at KP2+700, although there were workers at KP4+450 (completing burning and in the process of demobilizing) and further along the right of way with access at KP13+700.  No issues noted with respect to hand sanitizer in the facilities on the Valhalla section.   

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The Company is required to provide sufficient bathroom facilities at locations where there are workers, or within easy access of workers.  

Due date: 2021-02-26

Date closed: 2021-02-26
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 8 - CNC #2 Spills in Construction Yard

Date & time of visit: 2021-02-24 14:25

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The Company is to provide evidence that the spills near the waste oil tank have been cleaned.  

Due date: 2021-03-05

Date closed: 2021-03-01
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