Compliance Verification Activity Report: CV1920-163 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-163
Start date: 2020-02-20
End date: 2020-02-21

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Field inspection of the Burnaby and Westridge Terminals focused on environmental protection. The scope of the inspection includes works relating to the following: - Westridge Marine Terminal (OC-065, MO-042-2019). - Burnaby Terminal (OC-065, AO-002-XO-T260-010-2019). - Burnaby Terminal Facility Piping Relocations (XO-T260-003-2017). - Decommissioning of Facility Piping at Burnaby Terminal (MO-066-2018).

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 - Westridge Marine Terminal

Date & time of visit: 2020-02-20 11:01

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Westridge Marine Terminal

Activities occurring at the Westridge Terminal include:

GeneralBird Deterrents and Dolphin Pile Cap MitigationsHeritage Resource Discovery Contingency Plan

The Westridge Marine Terminal Environmental Protection Plan (EPP) states: All project activities will occur on reclaimed foreshore lands with the exception of a small portion of land located between the railway and shoreline. The company representatives stated the current land use at this facility site is industrial with some previously disturbed and undisturbed lands. They indicated an archeological monitor was on site during the excavation under the Canadian Pacific Railway as required. The Heritage Resource Discovery Contingency Plan was discussed and the company representatives appeared to understand the procedure and protocol requirements if a discovery was made.Water Management and Treatment/Erosion and Sediment Control DB General BargeDB Columbia Barge

Compliance tool used: No compliance tool used

Observation 2 - Burnaby Terminal

Date & time of visit: 2020-02-21 09:47

Discipline: Environmental Protection

Categories:

Facility:

Observations:

At Burnaby Terminal, all observations during the day were observed to be compliant and consistent with mitigations in the EPP. 
General

Water Management and Treatment/Erosion and Sediment ControlNoise MitigationsWildlifeSoil HandlingWaste Segregation

Compliance tool used: No compliance tool used

Observation 3 - Indigenous Monitor Observations 1

Date & time of visit: 2020-02-20 08:30

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Additional Observation recorded by IAMC Indigenous Monitors participating in the CER Inspection.  Any compliance related observations that require specific regulatory follow-up have been recorded above.

Indigenous Monitor Observations
Date and Time of Visit: February 20, 2020 at 0830
Facility: Westridge Terminal
Observations:
 
Proper PPE was observed. Double hearing protection required for pile driving and for the Hydrovac truck. Lifejackets within 3m of water. Opening meeting started with a safety share. CP Flaggers on site to signal when safe to cross.
All spills are recorded in company records no matter how small.
Secondary containment is used for vehicles and engines. A plant nappy is used to contain any spills from vehicles and engines.
Spill kits are found all over the site, and all vehicles have spill kits.
On February 19, 2020, there was 125 mL of Hydraulic Fluid spilled on the foreshore. The spill was all on land and was cleaned up and disposed of properly.
While on the site, the company Indigenous Monitor noticed a sheen on the road. This was rectified, and they had someone clean up the spill immediately. An inspection was also conducted on the dump truck to figure out what had caused the spill. They think that it was due to the angle of the road and the vehicles bleeder valve.
All waste is labelled and separated into their proper bins. Hazardous waste has secondary containment.
Water on site is diverted to the water treatment and treated before leaving the site.
Sediment control is important on site. They use silt fences that are properly installed. Straw erosion blankets are used to help with sediment control.
Sand bags are used to control water and sediment if soil needs to be disturbed.
There were 2 new sump pumps being installed on the site to divert the water to water treatment.
Turbidity curtains are used in water for sediment control.
There was a crow’s nest observed on site. There are no rules to protect crows; Therefore, the nest is left in place.
On the site there was an eagle’s nest that was blown down from a tree. Transmountain had built a nest to replace the old one. The next year the Eagles returned to the new nest. There are currently eagles flying around the site. Transmountain and their Biologist has not been able to find the new nesting location but believe it to be on site. The Biologist has been trying to locate where the birds are carrying the sticks to build the nest. They have not implemented their mitigation plan due to not knowing the nest locations. A buffer is needed 100 m around the nest, as well as the height of the nest.. FLNRO issued the permit.
There are bird deterrents on site. They have placed cones to deter nesting of eagles on site which have been successful. They have put up bird spikes and reflectors to keep the birds from getting caught on their fencing in the water. If dolphin piles are not being worked on within 24 hours, they must put a cap on them. There were some seagulls that had died from falling into the piles.
Due to the deaths of the herrings on site there were changes to the bubble curtain. The bubble curtain had kinks in the line. The materials in the line have been changed to be more stable.
The bubble curtain is about 3 inches away from the pile. Each pipe on the bubble curtain is 10m apart.
Environmental monitors use hydrophones to monitor the underwater noise levels.
There was a fish salvage when the site was sealed off. They caught the fish and returned them to the ocean.
There is a marine mammal monitor on site. They need to stop pile driving for half an hour after a seal is spotted, and one hour after a whale is spotted.
If there is a chance find they use McTavish Archeology, indigenous monitors, and the archeology branch from Coquitlam Band. Trans Mountain has Contract Qualification Specifications for the experts they use.

 
Indigenous Monitor Observations
Date and Time of Visit: February 20, 2020 at 0815
Facility: Burnaby Terminal
Observations:
 
Proper PPE was observed. Wind socks observed in multiple areas. Steel posts have mushroom caps. Opening meeting started with a safety share.
There is constant water testing. There are Nephelometric Turbidity Units (NTU) and Total Suspended Solids (TSS.) The maximum TSS is 20mg/L, this is approximately 34 NTU. Weekly grab samples are done, and they will also do grab samples when there is a lot of rain. There is constant monitoring at the top and bottom of Eagle Creek Tributary. There is a monitor at the bottom of the Tertiary Containment Area (TCA) and one at the bottom of Silver Creek Tributary. Monitors at the top of Eagle Creek Tributary keep record of the quality of water that enters and leaves the site.
All water on the site is treated then sent to the TCA before leaving the site through the tributaries. If there is an excessive amount of water on the site then the water is rerouted to other water treatment facilities on site.
Non-contact water rerouted through a culvert into the TCA.
Sediment control is very important at this site. They use swales and dikes to slow the water down to improve the possibility of sediment fall out in the water.
Exposed soil was tarped, erosion blankets and/or hydro seeding was added. Permanent erosion blankets are changed from plastic netting to sisal netting.
Intermediate Storm Water Retainment Area (ISWRA) is being built for the east side of the site.
If there is an excessive amount of water in the area, the water is diverted to the other water treatment areas on site before entering the TCA.
The water treatment goes through 3 steps to clean the water.
Currently building sub drainage system.
There was a sound wall built to reduce sound to the neighbors in the surrounding areas. A water tank or straw erosion blankets are placed between work and the community to reduce sound.
There are 4 sound receptors; one at the main gate, one at the Aubrey gate, one at the northwest corner, and one off-site in the community.
They use the creek to equalize the fire pond.
Sicel webbing is used for final reclamation as opposed to plastic webbing in the straw erosion blankets.
Plant nappies are used as secondary catchment. They catch hydrocarbons but allow water to pass through.
Tank 74 was decommissioned to make room for 3 new tanks.
Silver Creek Tributary is in a culvert through most of the site. They will be putting Eagle Creek Tributary into a culvert as well.
Vertex is the on-site soil contamination specialists. Contaminated soil on-site is regulated through Canadian Council of Ministers of the Environment (CCME). When soil is shipped off-site it is then regulated through British Columbia Contaminated Site Regulations (BCCSR). There are 2 samples tested every 250m.
There will be Archaeological Impact Assessments (AIA) done for both ends of the tunnel and for any work done under the railway.
Wildlife that they look out for are Red-Tail Hawk, Bald Eagles, Garter Snakes, and Tree Frogs.


 
 

Compliance tool used: No compliance tool used

Observation 4 - Indigenous Monitor Observations 2

Date & time of visit: 2020-02-20 08:30

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Additional Observation recorded by IAMC Indigenous Monitors participating in the CER Inspection.  Any compliance related observations that require specific regulatory follow-up have been recorded above.

Indigenous Monitor Observations
 
Date: Feb 20/20
Discipline: Environmental Protection
Categories: Erosion control


 
 

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