Compliance Verification Activity Report: CV1920-166 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-166
Start date: 2020-03-09
End date: 2020-03-13

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Environmentally focused field inspection of the Trans Mountain Expansion Project’s (TMEP), Spread 2, which spans from Edmonton City limits, and extends to a point near Hinton, AB; ranging approximately 288 kilometers, and parallels Alberta Highway-16. The spread moves through the Boreal Forest Natural Region and the Foothills Natural Region, which is characterized by Central Mixed-wood and Dry Mixed-wood sub-regions of Alberta. The Inspection Officer was accompanied by two Indigenous Monitors representing the Indigenous Advisory and Monitoring Committee (IAMC), pursuant to subsection 102(5) of the Canadian Energy Regulator Act (CERA). The inspection targeted ongoing work activities on the Right-of-Way (ROW) and temporary work spaces (TWS), including Access Roads to the ROW. Other areas of interest included wildlife mitigation, wetland and watercourse crossings, waste management, storage and handling of hazardous materials, traditional land & resource use, heritage resource sites, invasive species and biosecurity management, and erosion and sediment controls.

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 - General Observations

Date & time of visit: 2020-03-12 16:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

General Observations

Compliance tool used: No compliance tool used

Observation 2 - Watercourse Crossings

Date & time of visit: 2020-03-10 10:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 3 - Corrected Non-Compliance (CNC) #1 - Hydraulic Fluid Leaks

Date & time of visit: 2020-03-10 10:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

CER Inspection Officers observed evidence of hydraulic fluid leaks on sheet metal pilings as well as on the hydraulic pile driver attachment on excavator working at the Bench Creek crossing as well as on a button top loader parked near Cache Percotte creek. Upon bringing this to the attention of TMEP personnel the equipment was voluntarily shut down until repairs could be made, and absorbant rags were used to mitigate any risk of the fluid contacting the ground. TMEP indicated that the hydraulic fluid used in these pieces of equipment was vegetable based non-toxic hydraulic fluid.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

TMEP will repair the leaking attachments on this equipment and clean up any spilled hydraulic fluid in these areas.

Due date: 2020-03-13

Date closed: 2020-04-28
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 4 - IAMC Indigenous Monitor Observations #1

Date & time of visit: 2020-03-12 16:00

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

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.

Observations

• At the March 9th kick-off meeting with CER Inspection Officers (IO) and IAMC IMs, the LSAM IAMC IM noted the following topics are of particular interest to her and the community: TLU sites, crossings of fish bearing watercourses, Whirling Disease,
paleontology sites, rare plant / plant gathering sites, wildlife and species at risk sites, and their associated mitigation measures.
• At watercourse crossings, stumps and root systems consistently were being used as natural sediment and erosion control, reducing the use of silt fencing.
• Signage, staking and flagging was visible and well maintained with good signage throughout (environmentally sensitive areas, heritage sites, watercourse crossings, buffer zones, wetlands, and biosecurity).
• Dewatering was good at inspection sites: designated crews monitor, replace and remove dewatering bags.
• Secondary contamainment, drip trays and spill kits were used consistently at inspection sites.
• Seperation in soil windrows was good, with signs of animal use.
• Information requested and questions asked by the IAMC IMs or CER IO were provided or addressed promptly.
• TMX representatives were very informative at inspection sites, helping broaden the 2 understanding of what has been done or what will be done regarding the different stages of construction.
• TMX has incorporated preventative measures a level above required regulations pertaining to biosecurity on Spread 2.
• TMX IMs work alongside EIs with the option to learn more about areas that interest them- soils, water, HDD etc.
• Transparency, communication and connection were key components during the inspection.
Several issues were observed and corrected during the inspection:
• At the Bench Creek watercourse crossing (KP 226+400), a pile driver was observed to be operating at the time of inspection with wet oil stained hoses, indicating a leak. To correct this, the equipment was shut down and a new sight glass is needed. Subsequent to the observation being made, TMX informed the inspection team that a plug was put in for the sight glass and that a loose fitting had been tightened. A Corrected NonCompliance (CNC) is to be issued.
• At the Cache Percotte Creek (KP 315) location, a button top loader, not in use at the time, showed signs of a hydraulic fluid leak. Oil spots were observed on the equipment and the ground. TMX representatives placed absorbant pads under the leak, replaced the O-ring, tightend the fitting and submitted a spill report. A CNC will be issued.
• At KP 226+400 the inspection team observed that five gallon buckets of hydraulic fluid were being used without secondary containment and asked TMX representatives about this. The TMX representative provided an MSDS sheet specifying biodegradable hydraulic fluid is non-hazardous and therefore does not require secondary containment at a watercourse. Drip trays, however, were put in place under the five gallon buckets and the TMX representative will follow up internally to suggest making secondary containment of biodegradable hydraulic oil standard at watercourses as a good practice.

 

Compliance tool used: No compliance tool used

Observation 5 - IAMC Indigenous Monitor Observations #2

Date & time of visit: 2020-03-12 16:00

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

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.   

 CER-IAMC-TMX
Spread 2 Environmental Inspection

March 9-12-2020

Attended the inspectors 6am meeting following through with an opening meeting with the trans mountain EI's introduction were around the table including the IAMC IM's and CER IO's talk about daily activities that are happening along with the spread, clearing, access striping, grading bores to isolation, talk about the safety of driving due to warmer weather conditions, 

Right of way inspection:

  

 

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