Compliance verification activity type: Field Inspection
Team:
Regulated company: NOVA Gas Transmission Ltd.
Operating company: TransCanada PipeLines Limited
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Environmental Inspection of NGTL 2021 Edson South Section (Robb, Dismal and Brewster). This project is under construction at the time of inspection.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - General Observations - Robb spread
Date & time of visit: 2021-11-30 09:40
Discipline: Environmental Protection
Categories:
Facility:
Observations:
KP 4+254 - observed watercourse crossing 7, critical habitat for Athabasca Rainbow Trout - clear span bridge installed - frost packing on RoW to minimize disturbance such as rutting or compaction - sediment fencing in place, one post had fencing falling off. NGTL EI added the item to the defiency list for repair. - flagging present to mark buffer zone for critical habitat KP 3+756 - observed watercourse crossing 6, critical habitat for Athabasca Rainbow Trout - clear span bridge installed -spill kit present at watercourse crossing -signage in place noting critical habitat -RoW was cleared within 30m of critical habitat riparian buffer and soil is stored within buffer. No Fisheries Act authorization was obtained for these construction activities. NGTL reported this non-compliance as an incident to the CER and this incident is being followed up through Incident Number INC2021-195. NGTL stated that the encroachment into critical habitat in the absence of applicable approval was also reported to DFO. -NGTL noted that the critical habitat riparian buffer was thought to be at the top of steep bank, during clearing activities. Upon measurement, the buffer was determined to be further from the top of the slope than considered during clearing. KP 6+ 578 -Observed watercourse crossing KP 6+578, also critical habitat for Athbasca Rainbow Trout -buffer flagging in place for Athabasca Rainbow Trout KP 6+792 - topsoil pile stored in wetland with noxious weeds. The soil in the pile was cleared from the wetland area. KP 33+321 -Recreational trail crossing (RLU-03) -NGTL stated trail most commonly used for snowmobiling -Gaps observed in windrow to allow for crossing -Snow fencing was installed to direct trail users to the trail and prevent travel on the RoW -Signage on both side of the trail was installed Mud sumps 1-6 -NGTL stated that no liner is required under sumps as soil testing confirmed that the soil met the criteria for which secondary containment is not required. Soil has a high clay content. -When consctruction activity is complete such that sumps are no longer required, the drilling mud will be mixed with natural soil in a 1:3 ratio. -Excavation walls appeared stable and well maintained. Egress in place. -Lamps in sump area contained secondary containment and spill kits were present KP 40+350 -HDD exit site for McLeod River -Sling in one of the trailers was removed for inspection and maintenance, or disposal if deemed to be not fit for service -CER IO observed MSDS sheets for drilling mud constituents -The emergency response equipment was observed to be kept in an outdoor crate with no covering. The crate was full of snow raising the concern that the equipment would be not immediately available, if frozen in place. NGTL placed a cover over the equipment, as seen in a photo sent to the CER Inspection team. -CER inspection team requested and was provided The Crossing Company's Environmental Management Plan. KP 41 + 498 - heritage sensitive area mitigation measures observed to be compliant with drawing provided by NGTL
Compliance tool used: No compliance tool used
Observation 2 - CNC1 - Watercourse Crossing 006 - Silt Fencing
Date & time of visit: 2021-11-30 10:45
KP 3+ 756 -watercourse Crossing 006, critical habitat for Athabasca Rainbow Trout -soil was stored within buffer area at the top of tributary bank -gap in windrow present and silt fencing was installed at the bottom of the soil pile on one side of the windrow gap but there was no silt fencing installed on other side of windrow gap. The lack of silt fencing presented potential for soil run-off down the slope and into the tributary.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Install appropriate mitigation to prevent soil run off from the windrow, that is within the critical habitat riparian buffer, into the tributary (WC 006).
Due date: 2021-12-03
Date closed: 2021-12-03 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 3 - General Observations -Dismal Creek spread
Date & time of visit: 2021-12-01 10:30
KP 8 + 578-access through wetland is on road that has geotextile installed under subsoil-as this spread has multiple wetlands in close proximity, refueling of equipment always requires two people, one at the pump and one at the valve site.KP 9 +058-watercourse crossing 048-tributary contained running water, not frozen to bottom-spill kits observed on both sides of watercourse crossing-silt fencing installed and well maintained-no refueling near watecourse signage in placeKP 9 +618-wetland-matting installed for access on RoW as the weather has not been cold enough to freeze the ground- NGTL stated that RoW cleared by feller buncher through this section- silt fencing installed to separate disturbed ground from undisturbed wetlandKP 13 + 660- Dismal Creek watercourse crossing- crossing method to be isolated trenched- steep banks on both sides of watercourse- silt fencing installed 10m from watercourse - riparian buffer flagged-watercourse crossing signs installed on both sides of watercourse- clear span bridge construction not yet startedKP 30 +114- cultural feature (TU-03) mitigation measures observed to be compliant- buffer clearly marked and grubbing was avoided within marked area
Observation 4 - General Observations - Brewster spread
Date & time of visit: 2021-12-02 10:45
KP 19 + 229 - watercourse crossing 057 - watercourse runs perpendicular across RoW. RoW adjacent to older, lightly vegetated, TC Energy pipeline RoW - RoW sloped in area, diversion berms installed from access road to creek for drainage - reclamation at Chambers Creek is complete. Coco matting, silt fencing and willows installed in two layers on creek bank - this section of RoW is very heavily accessed by recreational users. Recreational trails are evident on the RoW - due to heavy recreational use, fill was imported to stabilize the creek banks - banks are seeded with rye followed by natural revegetation - NGTL stated that weather conditions had been favorable for re-vegetation of creek bank. KP 24 + 832 - watercourse crossing 073, critical habitat for Saskatchewan-Nelson Rivers Bull Trout - fish salvage complete, crossing currently under construction - water quality (turbidity) being monitored by Triton upstream and downstream of construction activities, as required for all SARA listed species crossings. - discharge for isolated open cut is on opposite side of the stream in plywood covered by geotextile to prevent erosion - SARA 30 m critical habitat buffer and 10 m riparian buffer is flagged - diesel generators for discharge pump contains secondary containment. - CER inspection team requested and was provided the equipment cleaning logs for machines working on site. NGTL stated that all equipment that arrives on site from British Columbia is bleached prior to start of construction activities. Equipment bleaching is also an effective measure within the red zone for whirling disease - offset measures include storing mature trees that were cleared from the RoW to use for placement in creek with the goal of restoring natural habitat faster than would occur otherwise - three NGTL Aboriginal Construction Program Participants (ACPP) individuals were present on site and recounted their experiences with the program. Emphasized the importance of TLU/TK studies being completed prior to construction KP 32 + 198 - watercourse crossing 090, critical habitat for Saskatchewan-Nelson Rivers Bull Trout - fish salvage complete, crossing currently under construction - SARA 30 m critical habitat buffer and 10 m riparian buffer is flagged - the CER inspection team noted that watercourse crossings signage was difficult to read, being placed far from the road - no refueling within 100m of watercourse crossing signage installed - silt fencing installed and well maintained - clear span bridge construction complete - rollback storage for reclamation of SARA watercourse crossing KP 26 + 643 - CER inspection team could not visit the traditional land use site (CAB-01) as access was down a steep slope that was unsafe in the deep snow at the time of the inspection. The area that contained the cabin was viewed from a distance and the CER inspection team noted that a tree buffer appeared in place between the cabin and the RoW.
Observation 5 - CNC2 - Watercourse crossing 090 - Secondary containment of chemicals on truck bed
Date & time of visit: 2021-12-02 16:16
- watercourse crossing 090 is critical habitat for Bull Trout- CER inspection team observed that a vehicle parked within the temporary workspace near this watercourse crossing had multiple containers of chemicals on the wooden deck bed that were not stored in secondary containment. Chemicals were stored in liner that contained snow and was in need of repair.
-Provide secondary containment for storage of chemicals on the observed vehicle that meets the criteria for secondary containment in the Chemical and Waste Management Plan.
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
