Compliance Verification Activity Report: CV1920-276 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2619

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Environmental Protection

Rationale and scope:

Environmental construction inspection of NOVA Gas Transmission Ltd. (NGTL)'s Northwest Mainline Loop No.2 Bear Canyon North Section, part of the North Path Delivery Project. The NPS 36 non-sour natural gas pipeline is approximately 28 km long and runs from a location near Spirit River, AB to Clear Hills County, AB. Work activities observed included final clean-up of the right-of-way (RoW) and two camp sites, as well as two stopple bypasses on either side of the Peace River. The inspection focused on weed management (including equipment cleaning) and reclamation at watercourses and wetlands.

Compliance tool(s) used:

• Corrected Non-compliance (CNC) (1)

Facility details

Facilities:

• NORTHWEST M/L (BEAR CANYON NORTH SECTION) - NPS 36

Facility Types

• Pipeline
• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Act (NEBA) 2016-06-19
• Plans And Procedures
• Project-specific Environmental Protection Plan (EPP)
• Environmental Protection Plan for the Nova Gas Transmission Ltd. North Path Delivery Project
• Standard Operating Procedure or Plan (SOP)
• TransCanada Harassment Free Workplace Policy
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• XG-N081-030-2018

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2019-07-30 09:00

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Chemical Spills/Releases
• Restoration
• Surface Water Management
• Containment and Drainage Structures
• Surface Water Management Plan
• Water Bodies - Non-Fish-bearing
• Reclamation
• Water Bodies - Fish-bearing
• Reclamation
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation
• Access Control
• Training and Documentation
• Documentation Available/Up to Date

Facility:

• NORTHWEST M/L (BEAR CANYON NORTH SECTION) - NPS 36 (Pipeline)

Observations:

General Observations

• Final clean-up has been completed on the majority of the North side of the Peace River (with the exception of the stopple bypass site), and crews were working from the South side of the Peace River towards kilometer post (KP) 0. Several days of wet weather have hindered clean-up efforts.
• Work was underway at the North stopple bypass site during the inspection, and NEB Inspection Officers (IOs) also visited the South stopple bypass site. 
• Company Representatives provided information about bird surveys that were conducted prior to the commencement of clean-up activities. They indicated that no nests were located.
• NEB IOs checked random pieces of equipment (approximately 8-10). All equipment checked had stocked spill kits, fire extinguishers with current inspection tags, and cleaning stickers. No leaks were observed on any piece of equipment checked. Two inspection tags were observed on each piece of equipment, one from the contractor and one from the company.
• Good housekeeping practices were observed at the stopple bypass sites. Some construction waste was observed in active areas (i.e., in the immediately vicinity of work crews) and these pieces of waste were immediately picked up and disposed of by Company Representatives.
• A small area of staining (approximately 10 cm diameter) was observed in a graveled area immediately adjacent to the blow-down valve at the South stopple bypass at approximately KP 24. The staining was immediately addressed by Company Representatives and a spill report was provided to NEB IOs. No non-compliances were observed with respect to the response and documentation of the spill.
• NEB IOs observed several dewatering sites, which were located in well-vegetated areas. No erosion was noted in these locations.
• Company Representatives stated that all non-merchantable timber was burned. Salvaged merchantable timber was given to third parties when possible and all remaining timber is stockpiled in log decks to be used for access control on the South slope of the Peace River crossing.
• The former HDD camp sites on the North and South sides of the Peace River crossing were visited. The South site has not yet been reclaimed, and work was underway at the North site during the inspection. Landowners have requested gravel pads at both locations.

• Stinkweed was abundant on topsoil piles throughout the right-of-way (RoW), and Canada thistle infestations were noted both on and off-RoW in several areas.
• A single scentless chamomile plant was observed on the RoW and immediately hand-pulled by a Company Representative. The Environmental Inspector (EI) was observed photographing and noting the location and indicated it was for weed management and tracking purposes.
• A topsoil pile labeled “noxious weeds” was observed along the RoW near watercourse crossing #2 (approximately KP 12). Company Representatives indicated that topsoil from previously identified locations of noxious weeds (i.e., pre-construction) are segregated and that equipment handling noxious weed topsoil is cleaned prior to moving to a new location. NEB IOs reviewed cleaning records for equipment handling topsoil at known noxious weed locations.
• Canada thistle was observed near watercourse crossing #2 (approximately KP 12) and was noted by the EI who indicated that an additional round of chemical weed management was scheduled for the near future. Canada thistle was abundant off-RoW at this location.
• Dead weeds were observed in multiple locations along the RoW; Company Representatives indicated that herbicide application had occurred within the last two weeks.
• At the North HDD camp location, Company Representatives indicated that scentless chamomile was observed on a topsoil windrow during clean-up, which was underway at the time of the inspection. They further indicated that the plant was removed, the location noted, and that the equipment would be cleaned prior to leaving that location.

• WET-1 and WET-2 are classified as seasonal graminoid marshes, and are located within hay land near the South Peace River crossing. Company Representatives indicated that both wetlands were farmed through pre-construction, and organics at the sites were stockpiled separately and labelled as wetland topsoil.
• WET-3 is located immediately adjacent to the RoW on the North slope of the Peace River, and was not impacted by construction activities. Company Representatives indicated that the wetland was fenced off during construction.
• WET-6 is located at the former North HDD camp site. The wetland was not stripped as it was not in the way of the camp, and Company Representatives indicated that sediment fencing and snow fencing was placed around it while the camp was active. Signage was still in place at the wetland.

• Signage was observed on the approach to the watercourse prohibiting refueling.
• Company Representatives indicated that a fish salvage was conducted prior to watercourse crossing construction (open cut crossing method) and that no fish were captured.
• Company Representatives indicated that the crossing was completed in late fall 2018, and reclamation activities occurred immediately after the pipeline was installed.
• The restored channel appeared consistent with channel morphology on either side of the RoW.
• Bank restoration included soil wraps using erosion control blankets, and seeding with a riparian seed mix. At the time of the inspection, the South bank was approximately 60% vegetated and the North bank was approximately 20% vegetated.
• Sediment fencing was installed along the riparian buffer area.

• The Peace River was crossed using a horizontal directional drill (HDD).
• The HDD entry (North side) and exit (South side) pads were located near the base of each of the slopes approaching the river.
• Company Representatives stated that no issues were noted during the HDD.

• Topsoil replacement had largely been completed on the South slope, although some work remains. Company Representatives indicated that seeding had not yet occurred.
• Temporary diversion berms were in place along the slope and appeared to be effective. Sediment fencing was placed downslope of the drainages, some minor sediment run-off was noted past the fencing into the treed area but did not appear to have migrated past the RoW boundary.

• Clean-up activities on the North slope were mostly completed at the time of the inspection.
• Permanent diversion berms were in place along the slope. Company Representatives indicated that ditch plugs were installed along the slope, and a weeping tile drain was observed above a berm.
• Company Representatives indicated that the slope was seeded approximately one week prior to the inspection. Seeds were observed but no grasses. The slope was largely vegetated with stinkweed. Company Representatives indicated that a herbicide would be applied to target the weeds but allow the seed mix (grasses) to grow.
• Approximately 20 cattle were observed grazing on the slope across the RoW near WET-3. Company Representatives indicated that they would discuss this with the landowner, and would develop a plan in the event the cattle hindered re-vegetation efforts. Company Representatives also stated that a fence will be installed along the RoW boundaries to prevent cattle grazing.

• contractor site-specific environmental management plan;
• Peace River North and South slope clean-up plan;
• cleaning logs for equipment upon initial arrival at site; and
• cleaning records for equipment handling topsoil in known areas of noxious weeds.

Compliance tool used: No compliance tool used

Observation 2 - Corrected Non-Compliance (CNC) - Workplace Conduct

Date & time of visit: 2019-07-31 11:30

Discipline: Management System

Categories:

• Policy and Committment
• Leadership Accountability

Facility:

• NORTHWEST M/L (BEAR CANYON NORTH SECTION) - NPS 36 (Pipeline)

Observations:

At the stopple bypass on the north side of the Peace River, NEB Inspection Officers (IOs) observed a member of a work crew with an inappropriate (i.e., sexually suggestive) hardhat sticker. The matter was discussed with the Company Representatives and the sticker was immediately removed from the hard hat.

Company Representatives indicated that additional corrective action would be taken, including a discussion the following morning with Inspectors and the Contractor. NEB IOs do not require any additional follow-up.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Standard Operating Procedure or Plan (SOP)
• TransCanada Harassment Free Workplace Policy

Relevant section(s):

• TransCanada fosters a respectful and safe work environment where harassment is not tolerated. Harassment means any unwelcome behaviour, comment, gesture or contact, including of a sexual nature, which creates an intimidating, demeaning, embarrassing, humiliating, threatening or hostile work environment.

Company action required:

Company Representatives shall ensure that the sticker is removed from the hardhat and demonstrate how they intend to communicate TransCanada's Harassment Free Workplace Policy to workers on the Project.

Due date: 2019-07-31

Date closed: 2019-07-31
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: