Compliance Verification Activity Report: CV2223-224 - Foothills Pipe Lines (South B.C.) Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2223-224
Start date: 2022-09-14
End date: 2022-09-15

Team:

Regulated company: Foothills Pipe Lines (South B.C.) Ltd.

Operating company: Foothills Pipe Lines (South B.C.) Ltd.

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

This project consists of approximately 12.5 km of NPS 48 steel pipe, ILL launcher and receiver facilities.
The Project is an approximately 12.5 km 1,219 mm diameter (NPS 48) natural gas pipeline loop located near Yahk British Columbia. The Project crosses Crown (81%) and freehold (19%) lands and will parallel existing disturbances for approximately 42% of the route. The proposed route starts at the Foothills Valve Site XR-014 in b-53-H/82-F-1 and will tie-in to the existing NPS 36 in b-72-B/82-F-1 at the existing connection with the East Kootenay Lateral. The Project includes a variable width right-of-way (ROW), requiring a 32 metre (m)-wide construction footprint with additional temporary workspace (TWS) where required.
The Inspection focused on field implementation of construction environmental protection plan and associated resource specific plans, particularly watercourse crossings, acid rock drainage/metal leaching mitigation, soil handling and work on steep slopes, as well as heritage resource features.  At the time of inspection approximately 8 km of the project had been graded, though 12.5 km had been cleared.  The inspection included various sites along the 8km graded portion of the right of way, plus the launcher (KP 0) and receiver (KP 12.5) sites. 

 

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: 2022-09-15 14:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

The inspection focused on accessible portions of the RoW.  Overall, no concerns regarding implementation of the EPP and management plans were identified during the inspection. Observations of note include:

General Observations:


Weed/Invasive species mitigation: Acid Rock Drainage/Metal Leaching : Watercourse Crossings: Heritage Resource Sites

Compliance tool used: No compliance tool used

Observation 2 - CNC # 1: Containers for Diesel Exhaust Fluid (DEF)

Date & time of visit: 2022-09-14 14:00

Discipline: Safety Management

Categories:

Facility:

Observations:

At the receiver site (KP 12.5) observed four blue jugs in secondary containment, near jerry cans that were presumably holding fuel. The blue plastic containers that were used stated "Potable Water," however two of the four had DEF clearly written on them in felt marker, and IOs concluded that these jugs did not contain potable water.  Discussed with the representative who indicated these jugs likely contained diesel exhaust fluid (DEF) given the DEF markings.  The IOs raised concern regarding the labeling of the jugs and the potential for confusion regarding what was contained in the jugs, particularly given that the plastic jugs themselves stated Potable Water.  Requested a copy of the SDS for 'DEF.' While in the field, the representatives re-marked the jugs with 'DEF' using felt markers. 
Additional corrective actions were taken as cited in the next section.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The complany completed the following actions: 
Representatives immediately re-marked the containers with markers in the field identifying 'DEF' on all containers (blue jugs) observed at the receiver site.  
Later, labels that covered the potable water markings were added to the containers the IOs identified (temporary WHMIS label), the company ordered permanent label/sticker and raised the issue across the project and informing foremen to remove all DEF containers site-wide and label them with the temporary WHMIS label while awaiting the permanent labels. 
Photographs of the re-labeled jugs were provided to the IOs.  The SDS was provided as requested.

Due date: 2022-09-15

Date closed: 2022-09-16
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