Compliance Verification Activity Report: CV2223-207 - Steel Reef Pipelines Canada Corp.


Compliance verification activity type: Field Inspection

Activity #: CV2223-207
Start date: 2022-10-11
End date: 2022-10-14


Regulated company: Steel Reef Pipelines Canada Corp.

Operating company: Steel Reef Infrastructure Corp.

Province(s) / Territory(s):


Related events:

Rationale and scope:

Field inspection to assess implementation of environmental protection measures during construction of the Sinclair Pipeline Project. The Project consists of a new compressor station Near Sinclair Manitoba, and a 20.7-km-long pipeline (NPS 6) that will connect to an existing pipeline near Antler, Saskatchewan. 

Compliance tool(s) used:

Facility details


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: 2022-10-13 12:00

Discipline: Environmental Protection




Compliance tool used: No compliance tool used

Observation 2 - Notice of Non-Compliance - Mitigation for Environmental Features

Date & time of visit: 2022-10-13 12:00

Discipline: Environmental Protection




The sites of several sensitive environmental features, including watercourses, wetlands and rare plant sites, were observed during the inspection and in many cases the mitigation outlined in the EPP was not fully implemented.

Signage was missing at many of the features, including signs identifying the presence of the sites as well as signage prohibiting re-fuelling within 100 m of watercourses and wetlands. 

The EPP also outlines flagging and staking requirements, which were observed inconsistently in the field.

In addition, Project personnel included an Environmental Monitor, a position not addressed in the EPP. The Environmental Monitor was undertaking work that the EPP indicates would be undertaken by the Chief Inspector (e.g., cleaning station inspections). 

The closing meeting included a discussion of the CER's expectations related to the implementation of mitigation, documentation of decision-making processes (e.g., narrowing up the RoW) and roles and responsibilities. 

No environmental harm was observed and Steel Reef began implementation of additional measures (e.g., signage installation), before the inspection was completed.

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

Regulatory requirement:

Relevant section(s):

Company action required:

1. Develop and provide to the Inspectors a draft Plan outlining how Steel Reef will improve and maintain the environmental mitigation measures for sensitive features. 2. Provide a description of the implementation of the Plan from part 1), including any changes to the draft Plan.

3. Provide a series of 8-10 photos showing the implementation of the Plan.

4. Clarify the roles and responsibilities of Project personnel related to enviromental matters.

Due date: 2022-10-18

Date closed: 2022-10-19
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:

- 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