Compliance verification activity type: Field Inspection
Team:
Regulated company: Trans Mountain Pipeline ULC
Operating company: Trans Mountain
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Environmental inspection of TMEP at Spread 4B to assess pre-construction preparedness / early construction. Completed with Indigenous Monitors representing the IAMC.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Additional Project-specific requirements or conditions:
Observation 1 - General Observations
Date & time of visit: 2020-09-21 08:00
Discipline: Environmental Protection
Categories:
Facility:
Observations:
Tuesday 22 September, 2020 Morning meeting at Vavenby Construction Office
Compliance tool used: No compliance tool used
Observation 2 - IR 1 - Hazardous Materials Storage (small volumes)
On 24 September, 2020, IOs and IMs observed small containers of products such as motor oil and glycol, and a crate of acetone being stored in the middle of the yard on a rig mat. IOs asked questions about the requirement for secondary containment of smaller volumes of individual products while on site.TMPU representatives provided the following reference with respect to secondary containment (Pipeline EPP, page 30, bullet 128): When using portable storage devices (e.g., bulk tanks containing petroleum or allied petroleum products or other hazardous materialsas applicable) exceeding 1,000 L (or 1 m3), single-walled bulk tanks will be housed within secondary containment (e.g., bermed arealined with an impervious polyethylene liner) or another form of secondary containment. The secondary containment will bedesigned and sized in accordance with applicable Provincial and/or Federal requirements. Tertiary containment will not be required forbulk tanks with integral secondary containment. Ensure that collected surface water (e.g., snow melt, rain water) is removed ina timely manner to maintain sufficient containment if a spill occurred. If there is visible hydrocarbon sheen, the water in thecontainment structure will be collected for proper storage and disposal at a Trans Mountain-approved waste disposal facility andin accordance with the Waste Management section (see Appendix G) and the Spill Contingency Plan (see Appendix B).
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
1) Please specify which Environmental Protection Plan (EPP) Trans Mountain is using for the Vanvenby Construction Yard.
Due date: 2020-11-05
Date closed: 2021-05-05 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 - IR 2 - Biosecurity, Level 3 Cleaning - Equipment Exemption List
On 23 September, 2020, IOs and IMs observed a piece of equipment (4R8-401) on the RoW with a Level 3 equipment cleaning sticker which stated "EXEMPT".
1) Please provide a description of TransMountain's procedures for expemting vehicles and equipment from level 3 cleaning (i.e., how does TransMountain determine that a vehicle or piece of equipment is exempt from level 3 cleaning).
Observation 4 - Indigenous Monitor Observations (Whispering Pines)
Discipline: Indigenous Monitoring
Additional observations recorded by IAMC Indigenous Monitors participating in the CER inspection. Any compliance-related observations that require specific regulatory follow-up have been recorded above.09/21/2020
09/22/2020
Biosecurity
Observation 5 - IR 3 - Clearing activities adjacent to watercourse crossings
At Nahalliston Creek, IOs observed trees taken down at the creek edge but the site has not been grubbed. TMPU representative stated that the pipe was to have been installed already, however, due to birds nesting along the edge of the crossing site, the contractor missed the construction window (July 22 - August 15) and construction is delayed until next year.
Condition 71, Riparian Habitat Management Plan (Table 5.2-1) states that “Clearing activities will be limited in buffers adjacent to watercourse crossings until just before construction”.1. Please provide the date clearing was completed at Nahalliston Creek.2. With respect to spread 4B, please provide the names of the watercourses where clearing has been completed and construction has been delayed. 3. At watercourse crossings where clearing has occurred and construction has been delayed, please provide the anticipated dates that construction will resume.
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