Compliance Verification Activity Report: CV2122-114 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2122-114
Start date: 2021-07-26
End date: 2021-07-30

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 inspection of spread 5B construction focusing on implementation of mitigation measures committed to in the EPP and management plans. Areas of focus included migratory bird mitigation and related corrective actions specified in IO Order DLB-001-2021, as well as erosion and sediment control measures outlined in the TMEP water management plan.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Migratory bird mitigation

Date & time of visit: 2021-07-27 10:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Meeting notes from interview with TMEP Chief Environmental Inspector (CEI) and Lead Environmental Inspector (LEI) regarding Investigation Report conducted in field: 

Field Inspection observations:

Compliance tool used: No compliance tool used

Observation 2 - Watercourse Crossings

Date & time of visit: 2021-07-27 14:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

     

Compliance tool used: No compliance tool used

Observation 3 - Sensitive environmental features and project specific mitigation

Date & time of visit: 2021-07-27 12:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

   

Compliance tool used: No compliance tool used

Observation 4 - NNC 1 - Sediment Fence Installation at the Coquihalla River

Date & time of visit: 2021-07-27 13:14

Discipline: Environmental Protection

Categories:

Facility:

Observations:

While inspecting the Sediment Fence at Coquihalla River, CER IOs made the following observations:
 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company shall provide:

  1. Confirmation via photograph that the sediment fence on the east side of the Coquihalla River crossing was installed as per specification dwg 687945 on 29 July 2021;
  2. A record of refresher training to be conducted as soon as possible for the SP5B workforce that will include those people accountable for supervising, inspecting, installing, and maintaining sediment fences.  Include the date, time, location and attendees; and
  3. Confirmation that the training includes and is not limited to the requirements of the CVA 2021-205 Water Management Plan, and the EPP Sediment Fence Drawing 687945.

Due date: 2021-08-16

Date closed: 2021-08-16
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 - Indigenous Monitor #1

Date & time of visit: 2021-08-16 19:49

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

July 27 2021
Visitor orientation hosted at the TMEP/Macro environmental trailer the safety advisory representative was very informative with use multimedia video as well for vocal communication for the orientation for tmx-tmep spread 5b project.

The one concern there was no information shared of cmt’s, tlu’s, archeological sites, heritages sites along and within the tmep spread 5b.

It was nice to know that 2 tmep indigenous monitors working on the tmep spread 5b project, though the thoughts in my mind there shall be more indigenous monitors to equal the amounts of the damage prevention inspectors that those that hold those job titles shall work together side by side during the work activities, site assessment’s, sensitive monitoring during ground disturbance’s as well for any earth works.

From my perspective that there was hesitations from documents being shared from tmep on request from c.e.r., I had seen that there was no clear clarification’s shown from tmep representatives during open questions and discussion hosted in the tmep board room.

As for the migratory bird mitigation will need more proactive measures as well more employees during peak seasons for birds nesting from April to August.

July 28 2021

Bird mitigation was very communicated from the RSLB meeting in the tmep board room. Mitigation measures was well presented for employees that work on the tmep spread 5b project.

There was a communication barrier breakdown that will need improvement from tmep, in regards of communicating migratory bird mitigations from their offices to prime contractors through to sub-contractors. The comment made from tmep environment that it is not there responsibility to communicate to sub-contractors of migratory bird mitigation it is up to macro to communicate those mitigation’s. With that being said that is very concerning and that may lead into un wanted non compliances on behalf tmep, macro, sub-contractors as no correct information of migratory bird mitigations communicated in person, digitally, hard copies issued.

C.E.R. and I.M.’s visited work sites along with TMEP environmental reps for spread 5b, the site safety rep. was very informative, and the confidence expressed was backed up with the knowledge of the work activities.

Though I had observed that the word given from the site safety and environmental rep onsite that all environmental measures were in place, which majority of the environmental measures were followed through. My suggestion for each work site site safety and environmental must periodically check the work completed by workers to ensure the environmental mitigation measures are completed properly.

July 29 2021

We, C.E.R. and I.M’s had visited more work sites along with TMEP environmental reps. We had seen CMT’s, OGM area, as well a wild life habitat of mountain beaver which great mitigation was shared by the RSLB onsite of catching and relocating mountain beavers, RSLB shared that the mortality rate was good of the relocation of mountain beavers as there was food habitat and that mountain beaver’s live in the avalanche chute areas. We also had seen the newly updated bird nesting mitigation’s of corrugated plastic placards posted per buffer as well with candy striped ribbon orange/black along with neon green ribbon, buffer stated in metres as specified to bird species, mitigation of only walk through the buffer when authorized by RSLB.


 

Compliance tool used: No compliance tool used

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