Compliance Verification Activity Report: CV2122-364 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2194

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Environmental Protection
• Indigenous Monitoring

Related events:

• CV2122-345
• CV2223-135

Rationale and scope:

Inspection of repair work from the November 2021 floods. Follow up to the 2122-349 inspection as well as sites not inspected during that time.

Compliance tool(s) used:

• None

Facility details

Facilities:

• Mainline

Facility Types

• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• Plans And Procedures
• Project-specific Environmental Protection Plan (EPP)
• Flood Response EPP

Observations (no outstanding follow-up required)

Observation 1 - General Observation

Date & time of visit: 2022-02-28 16:00

Discipline: Environmental Protection

Categories:

• Water Bodies - Non-Fish-bearing
• Sedimentation/Turbidity
• Erosion
• Water Bodies - Fish-bearing
• Sedimentation/Turbidity
• Destruction/Loss of Habitat
• Erosion

Facility:

• Mainline (Pipeline)

Observations:

On November 14^th and 15^th 2021, flood events over the South Coast and Thompson/Okanagan Regions caused scour erosion and exposures of the Trans Mountain pipeline. In response to the flooding events, Trans Mountain (TM) has been conducting emergency works to maintain the integrity of the pipeline. Construction has occurred at numerous locations including, temporary and permanent river diversions, bank restoration and armouring, channel stabilization, bridge construction/removal, slope stabilization, log debris removal and fish salvage. Operation and Maintenance Notifications were provided to the Canada Energy Regulator at locations where instream works were being conducted.

TM representatives stated:

• an Environmental Impact Assessment for offsetting will be conducted after spring freshet as well as the development of final reclamation plans. Final reclamation will be completed in the summer of 2022.
• BC Oil and Gas Commission (BCOGC) has issued an Interim Approval for Changes In and About a Stream permit for any activities below the natural highwater mark.
• Only clean, inert riprap and structural materials were used from an approved source.
• A hydrotechnical engineering consultant has provided mitigation designs for these flood damaged sites.

• Qualified Environmental Professional assessments were completed to provide fish and fish habitat information and potential effects as well as mitigations and reclamation measures.
• The Environmental Protection Plan (EPP) is updated biweekly and mitigation measures have been applied and adhered to during construction.
• Determination of the Harmful Alteration, Disruption or Destruction (HADD) of fish habitat associated with project components was completed by TM following design finalization, completion of works and implementation of the measures to protect fish and fish habitat.
• All fish salvages and water quality monitoring were conducted by a Qualified Environmental Professional.

General Observations:

• Clear span temporary bridges were clean with wingwalls to prevent sedimentation within the watercourse or riparian areas.
• At some locations coarse woody debris remained on site for future reclamation.
• Site isolation and bypass measures were adequately installed and maintained to provide natural flow.

• All pumps were fitted with fish screens with a maximum mesh size of 2.54mm and all hose outlets had energy dispersion diffusers on to prevent scour.
• Spare hoses and pumps were on site where required and spill kits were present at active locations.

• Water quality monitors were observed at active sites recording turbidity levels and they indicated levels remained consistent with the EPP requirements.
• Exclusion fences were observed to prohibit fish from moving back into the work areas.
• Secondary containment was used for generators and jerry cans to meet the requirements in the EPP.
• All sites were clean and free of garbage, waste and debris.

KP 939.37 (Site 19) Coldwater River

• Log jam was removed and the right bank was lined with riprap for pipe erosion protection prior to the inspection.
• A spur was installed at the top of the riprap for bank erosion protection.
• TM representatives stated the Kettle Valley Rail Trail Bridge will be removed by BC Ministry of Forests, Lands, Natural Resource Operations and Rural Development.
• Banks were re-enforced with riprap and straw wattles.
• TM representatives stated reclamation assessments would be completed after freshet and final clean-up would occur during the summer months.
• TM stated there are 2 approved locations they have been getting riprap from for this area.

KP 949.36 (Site 8) Juliette Creek

• The creek was diverted to isolate the workspace to allow for pipe inspection and repairs.
• The isolation berm was constructed using boulders and gravel from the site and the creek bed was lined with polyethylene sheeting to prevent water from flowing back into the work area.
• TM representatives stated they had difficulties with subsurface flow entering the workspace but placing crushed rock underneath the pipe and pumping water above the work area has solved the issue. The workspace was dry at the time of the inspection.
• A rock riffle was constructed along the left bank to provide local grade control and to maintain fish passage. It was currently being used for dewatering. The creek bed was lined with geotextile material, boulders and straw wattles to slow the flow of water to allow for sediment to settle out before joining the main channel. Four temporary sediment settling tanks were previously used but TM representatives indicated they were overflowing and freezing up.
• There were (5) 6” and (2) 4” hoses used to dewater and maintain flow. Back up pumps and hoses were observed on site and TM representatives stated personnel are on site 24 hours to monitor the equipment. All hose outlets had energy dispersion diffusers on to prevent scour.
• TM representatives stated a fish salvage was conducted and turbidity levels maintained within acceptable limits as per the EPP. A fish fence was present, and screens were placed on all pumps to prevent fish from being impinged on the intake.
• Ministry of Transportation and Infrastructure were working on bridge repairs upstream causing intermittent turbidity spikes.
• CER Inspection Officers noticed a sheen on the ground near parked equipment and TM representatives stated they would investigate and follow spill response procedures in the EPP. They also indicated refueling was done using automatic nozzle shut-off and two people to prevent over filling or accidental spills.

KP 952.8 (Site 21) Coldwater River

• The work at this site included bank protection to mitigate scour that was eroding a service road and encroaching toward the TM pipeline. The pipeline is located between the Coquihalla highway and the Coldwater River. Erosion has occurred on the outside bend towards the pipeline. The pipe was not exposed at this area, but precautionary measures were put in place prior to spring freshet.
• A riprap revetment with boulder clusters was observed.
• TM representatives stated snow plugs and turbidity curtains were used to minimize turbidity levels. They also indicated that fish salvage was not feasible but scare passes were conducted. No instream work was completed at this site, but they will isolate cells when they reinforce the toe of the bank this spring.

KP 955 (Site 7) Coldwater River

• After the flood the pipeline was exposed from floodwaters and covered with woody debris.
• Pipeline repair was complete, and the area was backfilled.
• Course woody debris was removed, and the bank was armoured with riprap.

KP 954.36 (Site 15) Coldwater River

• During the flood event large woody debris blocked the Coldwater River downstream of the pipeline at this location. The debris jam forced a portion of the flow to be diverted along the right-of-way (RoW) for approximately 1 km prior to rejoining the Coldwater River. TM representatives stated the debris jam was about 140m long and across the RoW. 
• The debris jam was considered a fish barrier and most of it was removed offsite. The remaining course woody debris on site provides erosion and sediment control and potential fish habitat.
• Construction activities were completed at the time of the inspection and TM representatives stated:

- The contractor had completed work approximately 2 weeks prior to the inspection and the work took approximately 17 days.

- Requirements in the DFO Fisheries Act Authorization were met and no fish mortalities were observed.

- Fish salvage and water quality monitoring plans were followed, and turbidity levels were recorded during the removal of the log jam. There were some spikes as expected but no high exceedances.

- A company Indigenous Monitor was on site during construction actives.

- Potential offsets will be determined this spring.

- Additional sediment and erosion control measures were not required.

- A large berm was constructed using a degradation of rocks to protect the left bank and equipment accessed the area using a temporary bridge. Temporary fording did not occur at this location.

KP 963.2 (Site 22) Coquihalla River

• Erosion on the left bank caused bank slumping and failure at the bend in the river.
• TM representatives indicated:

- The pipeline was approximately 6 m from the encroachment and some trees had fallen into the river creating a dam.

- A fish salvage was completed prior to construction activities and turbidity levels were monitored.

- The deposited trees were removed and the bank was lined with riprap to prevent further scour. 

-There was no instream work only bank armouring with infill above the former high-water mark to align with pre-flood channel conditions.

• To access the site TM installed 2 temporary clear span crossing structures across two fish bearing tributaries to the Coquihalla Lakes.

KP 962 (Site 14) Unnamed Tributary to the Coquihalla

• During the flood event, the uppermost layer of the riprap apron downstream of the pipeline destabilized and was carried downstream.
• This site was designed to have exposed concrete river weights after an exposure was identified in 2008. Repairs were made to the riprap apron and to restore the channel gradient.
• A road ford crossing downstream of the pipe was repaired.
• At the time of the inspection the contractor was observed cleaning out the fines of the newly replaced creek bed at the ford crossing location.
• TM representatives stated a fish salvage was completed and water quality monitors were observed on site collecting turbidity data.
• Fish screens were observed and diffusers were used on the end of the hoses. No scour was observed. A mesh cage was around the intake pump as per the EPP.
• Site had back up pumps and hoses and TM stated the site was monitored at night.

KP 990.8, 990.58 and 990.3  (Sites 12, 24 and 28) Coquihalla River

• Up to 15 m of the right bank was eroded along a moderate left bend in the river and caused failure to Siwash Road along a 70 m section. The pipeline was approximately 4.5 m from the top of the bank.
• TM representative said the reconstruction of the armoured rock wall was constructed to the height above the expected water level for a large flood event. The riprap revetment was keyed into the bank to avoid localized erosion.
• Two culverts were installed across the pipeline RoW and Siwash Road and drainage channel improvements were made to manage surface runoff.
• Restoration and bank armouring with boulder clusters at KP 990.3 has been proposed but has not yet been completed. Rock trucks were observed offloading infill and rocks for bank armour and reclamation.  A culvert was observed under the TM pipeline at this location.

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: