Compliance Verification Activity Report: CV2122-200 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector In Training T
• Inspector 2275

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Environmental Protection
• Indigenous Monitoring

Rationale and scope:

Environmental Inspection of NGTL Edson Mainline Expansion Project, during construction. The compliance verification activity focused on the implementation of mitigation measures required by the Environmental Protection Plan and related management plans. Specific attention was given to watercourse crossings, erosion and sediment control mitigation and sites of Indigenous significance.
 

Compliance tool(s) used:

• Corrected Non-compliance (CNC) (1)

Facility details

Facilities:

Facility Types

• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Plans And Procedures
• Project-specific Environmental Protection Plan (EPP)
• ENVIRONMENTAL PROTECTION PLAN FOR THE PROPOSED NOVA GAS TRANSMISSION LTD. 2021 NGTL SYSTEM EXPANSION PROJECT November 2020

Observations (no outstanding follow-up required)

Observation 1 - Observations from Indigenous Monitor

Date & time of visit: 2022-03-14 09:00

Discipline: Indigenous Monitoring

Categories:

• General
• General

Facility:

Observations:

Archeological
One of the TK inspections was the “Prayer Tree”, we met up with the ACPP monitors
coordinator for the ACPP group and discussed traditional knowledge and explained that
the “Prayer Tree” was a sacred site (this site was roped off even though it was on the rite
away) the coordinator and FN group allowed us to visit the site. They explained the
significant spiritually of the site. We made a offering of tobacco then we left the site in
peace. he ACPP has excellent working relationship with the proponent and the contractor
they are involved with inspections and implementing the ERR & ERP plans their main
priority is the environmental pipeline footprint and the care of the land is always a priority.

The second TK inspection was at KP 16 +500. All signage was in place.

Vegetation
Inspection of a noxious weed site (Canada Thistle).
Discussed the removal of leaning trees as a safety practice

Water Crossings
KP 4+800 inspection of silt management and erosion control. Spoke to the foreman about
Elk River WC024 +795. Reviewed JSA and signed. Reviewed mitigation for the
installation of pumps to move the water on the up-stream side around the area to be open
cut to the down stream side. Each pump can move one cubic meter of water per second,
new hoses are used on each stream cut to avoid contamination.

Bridges used for crossing over a water are scrapped clean of mud and derbies 2 times a day
to avoid foreign material from falling into the stream down below. lnspect procedure for
installing silt fence, where there is a overlap in the material it must overlap 36 inches.

At KP 8-700 inspected creek crossing and discuss reclamation procedures inspect silk
fence installation at WC 4KM 15 + 300 inspect steep slope mitigation, and silt retainment
along water course.

At KP 35+9 the Nordegg River crossing we inspected dewatering, the natural rock used as
water flow buffers.

At KP 43+920 inspected silt pond. Reviewed and signed the FLHA and tailgate safety
meeting. Inspected KP 44+291 water crossing, there we inspected the dewatering creek
method, the water discharge filter bag , discuss equipment hazards and incident reporting

At KP 39+851 unnamed creek inspect creek bank reclamation. At KP 30+84 WC 12
inspect stream bed reclamation and discuss chance find ( buffalo Jaw and tooth
estimated 8000 to 10000 years old).

Wildlife
At the Elk River WC-02 4+759, discussed SARA critical habitat area.

Other Observations
At KP 27+5 HDD site, reviewed the FLHA and ERP. Inspected fuel supply tank. One had a
nozzle drip this was corrected immediately. We also inspected the propane storage tanks and
storage shed. Inspected the under-ground bore rig, genset set fuel storage, mud pumps for
diesel and oil leaks, oil storage, underground reamer, inspect tool crib, inspect tool crib,
inspect fire extinguishers, boiler and discuss boiler safety and use of boiler compound, waste
is separated and put in appropriate bins all cans ,plastic ,and plastic pails are recycled.

The rig personnel if it is your area you own it you respect it. The HDD crew and manager
were knowledgeable of their equipment answered all our questions. They took pride in
their work. All safety barriers were in place and site was clean
 

Compliance tool used: No compliance tool used

Observation 2 - Observations from Indigenous Monitor

Date & time of visit: 2022-03-14 08:00

Discipline: Indigenous Monitoring

Categories:

• General
• General

Facility:

Observations:

Began the work day with covid testing, visitors orientation to follow. C.E.R, i.m’s ,
DFO and company representatives were in attendance.
Kp 4+800 Elk river observed site looks great as per construction work currently at
site
Kp8+700 steep slope sara critical habitat area. Sediment fencing erosion control
measures in place and looks good.
Kp 14+800 water course crossing sara critical habitat crossing.
Layout overall very nicely installed.
Kp 16+500 water course crossing site. Well kept and maintened
Traditional knowledge site at this location signage posted.
Kp 33+700 Prayer Tree- met the ACPP program monitors was nice meeting and
hearing there knowledge about the prayer tree buffers in place mitigation
measures met within the footprint of the project.
Kp 35+6 water course crossing observed water stream looks good site looks great.
Kp 27+5 observed site fuel tank was showing some signs of leak was brought to
tc’s attention was cleaned up while we were on site. Tool crib is in good order.
Waste and recycling station look great. Used Oil containment nicely stored.
Kp 43+920 water course crossing active construction site erosion control is setup
great overall good looking site
Kp39+851 creek bank reclamation stage observed excellent work to rebuild the
bank. Work was completed days prior to inspection very nice and clean.
Kp30+200 tlu site off ROW buffer in place. Identified in the EPP looks good
undisturbed.
Overall was a very good inspection I appreciate the time the company
representatives and ACPP program monitors took to show us around to sites. It
was great meeting and listening to the ACPP individuals sharing there knowledge
and wisdom. Great work
 

Compliance tool used: No compliance tool used

Observation 3 - General construction observations

Date & time of visit: 2022-03-15 08:00

Discipline: Environmental Protection

Categories:

• Water Bodies - Non-Fish-bearing
• Sedimentation/Turbidity
• Erosion
• Water Bodies - Fish-bearing
• Sedimentation/Turbidity
• Species of Concern
• Erosion
• Wildlife
• Species of Concern

Facility:

Observations:

Water crossings
Kp 4+759 WC02

• Company contractor described vehicle crossing construction as well as watercourse crossing execution plan to inspection team. No issues noted.
• Company representative indicated hoses are all brand new for each water crossing to minimize whirling disease contamination. Extra hoses, pumps and equipment notes on site for redundant capacity. Clean, drain, dry methodology indicated for equipment which does contact water and will be reused on the project.
• Water quality monitoring being conducted by aquatics resource specialists on site at time of inspection. Monitoring plan described by company contractor. No issues noted.
• Dewatering location observed. No issues noted.
• Soil piles in area appropriately staked and included appropriately staked and segregated riparian soils.
• Secondary containment in place beneath small volume hazardous products and mobile equipment.
• Erosion and sediment control (ESC) measures at site include sediment fence installations and keyed edge.
• RoW is narrowed at watercourse crossing location.
• Inspection team observed coir waddles being installed by the contractor in a method that differed from EPP specifications. Although this method didn’t appear to differ significantly in functionality, the company environmental inspector corrected the contractor laborer crew and coir waddles were observed appropriately installed before the inspection team left the site.
• No mitigation issues at this site

• Watercourse crossing and SARA listed species critical habitat signage observed in place.
• ESC measures on site included diversion berms and ditch plugs as well as sediment fence, which company representatives indicated would be amended to further protect watercourse.
• Vehicle crossing is geotextile wrapped with wingwalls in place. Organized tool stand in place for vehicle crossing deck cleanup.
• Company representative indicated rollback and salvage material to be utilized for fish habitat offset management plan shading and cover on watercourse, with aim to regulate temperature and improve habitat value.
• RoW is narrowed at watercourse crossing location.

• Log walls/tree revetments and boulder clusters along riparian zone observed installed at this crossing location. Boulders have also been placed strategically in river to create habitat for the fish. Company representative indicated this was completed in consultation with Qualified Aquatic Environmental Specialist (QAES). Company representative indicated an addition 2-3 log walls are to be installed at this crossing location.
• Company representative indicated grade and cleanup will be completed after breakup to minimize risk of slumping.
• RoW has been narrowed up in this area, however several danger trees in the area have been high-stumped to mitigate risk.
• Company representative indicated fish salvage had been previously completed which recovered three fish, with zero mortality.
• Company representative indicated no increase in turbidity was observed during downstream water quality monitoring at time of isolation.
• Clear span bridge installed for vehicle crossing, which was being cleaned at time of inspection in preparation for demobilization.

• Vehicle crossing is geotextile wrapped with wingwalls in place. Organized tool stand in place for vehicle crossing deck cleanup.
• Sediment fences appropriately keyed in on site.
• Fisheries authorization permit available on site.
• RoW is narrowed at watercourse crossing location.
• Rilling and erosion of RoW subsoil observed beginning to occur at time of inspection with increasing temperature and melting snow. Sediment laden melt water observed travelling down to vehicle crossing location and pooling on vehicle crossing bridge. Company environmental inspector took action to design and implement an interim ESC plan until such time as the crossing was complete. Photos were provided the following day to the inspection team which showed construction of an additional berm and sediment fence to divert water and protect the watercourse. Water was also pumped off the crossing structure to an appropriate dewatering location. CER inspector is of the view that this issue was appropriately managed by the company.

• Isolated open cut water crossing in place at time of inspection.
• Dewatering pig pens inspected however dewatering was not observed at time of inspection due to effectiveness of isolation.
• Spill kits in place at crossing.
• Plywood and geotextile in place at downstream discharge location to deenergize water and mitigate erosion/siltation.
• Water quality monitoring occurring at time of inspection. No exceedances of parameters were reported.
• Subsoil stored on topsoil frost layer. Company representative indicated this will be replaced within two days and if longer term storage is required, geotextile is used for segregation layer.
• TK site 04 flagged – by design, signage does not reveal that it is a TK site.

• Isolation underway at this water crossing. Plywood diffuser observed installed at downstream discharge. Extra pumps on site for redundant capacity if needed.
• Company indicated that fish salvage was done the day before.
• Dewatering location inspected for trench greywater, filter bag in place. No scouring or sedimentation observed. No issues noted.

• Company indicated ESC measures are in interim state of construction and that additional installation of silt fence will be extended along the creek once they are done with reclamation in this area for spring break up.
• Log walls with coir matting and willow staking used in reclamation at this location. Gravel bed installed in creek bed at crossing location. 
• Company indicated fall rye seeded under coir wraps on slopes in this area. 
• No issues noted.

• Melting snow had resulted in sediment laden water entering onto ice covered watercourse. The issue was already being managed by the contractor upon inspection team arrival at site. Work underway included removal of sediment laden snow and ice from watercourse as well as amendment and repair of sediment fences to control source of sediment laden water. CER inspector is of the view that this issue was appropriately managed by the company.
• Company representative indicated higher splash guards are going to be installed on vehicle crossing ramp in this area.

• Drilling tailings stored in mud containers on site until removal from site for disposal, which company representatives is done in accordance with provincial directives.
• Inspection team observed diesel staining on diesel storage tank Unit # 10367 and leaking drip catcher containment receptacle. The staining on tank and rig mats was cleaned up by contractor personnel upon being brought to the attention of the company, and the leaking drip catcher was repaired. Please refer to CNC #1.
• Company representatives indicated entire drill pad site is lined with geotextile beneath rig mats.
• Small volumes of hazardous products stored in secondary containment.
• SDS available on site for drilling mud additives and constituents.
• Spill kits available on site.
• Waste storage area inspected with labelled waste storage bins for garbage, wood and metals with appropriately segregated waste streams.
• Wildlife not observed on site at time of inspection.

• This site of Indigenous significance was a chance find during stripping and grading, a flagged buffer was made to protect the tree’s root system and ditch line was shifted to accommodate buffer zone.
• Site was flagged and left unmarked to respect privacy and to deter people from entering the area.  
• The Elder onsite allowed inspection team members to visit the site and provided an offering of tobacco to respect the site.

• Discussions held with ACPP Indigenous inspectors revealed that they are feeling heard, respected, and included on this project.
• ACPP Indigenous inspectors indicated they are enjoying the knowledge and technology sharing on both sides of the project and note both sides are growing together which make the program and work environment better for everyone.
• The company has implemented cultural sensitivity training, which includes a cultural appropriation awareness component.
• Indigenous Inspectors had positive feedback about the ACPP program.
• ACCP Indigenous inspectors indicated that TK sites are flagged but left unmarked to keep people out of the sites.

Compliance tool used: No compliance tool used

Observation 4 - Corrected Non-Compliance (CNC #1) - Diesel drip at HDD fuel storage

Date & time of visit: 2022-03-16 14:00

Discipline: Environmental Protection

Categories:

• Water Bodies - Fish-bearing
• Chemical Spills/Releases

Facility:

Observations:

Inspection team observed diesel staining on diesel storage tank Unit # 10367 and leaking drip catcher containment receptacle. 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Project-specific Environmental Protection Plan (EPP)
• ENVIRONMENTAL PROTECTION PLAN FOR THE PROPOSED NOVA GAS TRANSMISSION LTD. 2021 NGTL SYSTEM EXPANSION PROJECT November 2020

Relevant section(s):

• 8.0 PROJECT CONSTRUCTION 8.1 General Environmental Protection Measures 74. The Contractor will ensure equipment is monitored regularly and free of fluid leaks

Company action required:

Company will control source of leaking diesel as well as cleanup released product in this area.

Due date: 2022-03-16

Date closed: 2022-03-16
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: