Compliance verification activity type: Field Inspection
Team:
Regulated company: Trans Mountain Pipeline ULC
Operating company: Trans Mountain Pipeline ULC
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Environmental Inspection to follow up on Incident Number: INC2020-057 (Sumas Station EOS Release). CER staff attended the company Incident Command Post and the pump station release site to inspect environmental impacts, the extent of the released product and the site contamination, and ongoing recovery and cleanup.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - General Observation at Sumas Pump Station (incident site)
Date & time of visit: 2020-06-15 15:00
Discipline: Safety Management
Categories:
Facility:
Observations:
On-site at the Sumas Station, Inspection Officer (IO) and Indigenous Monitors for the Indigenous Advisory and Monitoring Committee (IAMC IMs) received site-specific safety information and COVID-19 prevention specific measures. An information board containing information related to the incident was displayed. Safety Data Sheets (SDS) were posted for the released product. A general overview of the cleanup process was given by the on-site manager.
Activities observed were in alignment with acceptable practices.
Compliance tool used: No compliance tool used
Observation 2 - General Observation from Incident Command Post (ICP)
Date & time of visit: 2020-06-16 12:00
Discipline: Environmental Protection
The inspection team reviewed the relevant Incident Action Plan (IAP). The IAP review included: Groundwater Monitoring Plan; Waste Management Plan; and Wildlife Management Plan. All activities onsite appeared to be in accordance with the IAP.The inspection team met with the Environmental Unit Leader and discussed the Groundwater Monitoring results. The results at the time of the meeting indicated that the current incident did not impact the groundwater. Tours had been organized for the community members of the local First Nations (FN). Tours included overview of the spill area from outside Division A or the manifold area (hot zone), an overview of the Division B or the pasture area and Division D on the west side of the station.During a tour with Sumas FN representatives on 13 June 2020, an area with high archeology potential was identified. The area was designated as Division D and was fenced off to prevent inadvertent disturbance. Division D was not impacted by the release.
Observation 3 - Division A - Manifold area
Date & time of visit: 2020-06-16 09:40
Division A was located in the manifold area of the station. The inspection team observed:
Observation 4 - Division B - Pasture area
Date & time of visit: 2020-06-16 10:50
Division B was located in the pasture area south of the station fence. The inpsection team observed:
Observation 5 - IAMC Indigenous Monitor Observations
Date & time of visit: 2020-06-15 12:00
Discipline: Indigenous Monitoring
The following observations were recorded by an IAMC Indigenous Monitor who accompanied the CER Inspection Officer during inspection. These observations related to compliance can be found above in previous observations. IAMC Monitor Report for Sumas Pump Station Incident Pre-Inspection Observations:- Travel to Abbotsford June.14/2020 Inspection Day June.15/2020Site overview and initial size up observations:- We parked our vehicles outside the stations. (station is in a generally open field with tree patches adjacent to site.)- Public and media were seen onsite.- Extra security guard.- The smell of oil product was very evident.- Many Vac trucks and personnel on site.Safety- Site Safety briefing was thorough included Covid-19 Specific points as well as emergency protocol.- Briefing was division and operation specific.- Made aware of audio emergency protocols.- TMX employee would monitor air quality while onsite. (Did not require masks.)- ICP INFO board Shared.- Rehab stations for workers to eat and drink and manage fatigue. Operations: - Decontamination teams in both divisions using three separate tubs with brushes, sprayers, absorbent pads for boots. Accompanied by extra clothing and bags for transport of contaminated clothing or personal protective equipment. Zones from hot to cold were established to identify your level of contamination and decontamination needs.- Staging area manager for each division to organize and manage equipment resources arriving and departing, (vac trucks, low beds) and ensure all personnel have PPE.-Heavy Equipment Create a temporary road into field following all TM (Trans-mountain) Safety ground disturbance plans and procedures to allow transport trucks on to site to carry hazardous waste away to approved facilities.-Safety Vitals Monitoring teams were established to monitor air quality for hydrocarbons 24hrs a day in addition to personal monitors. Only people directly stirring or moving soil required a mask. Community Ambient Air quality monitoring was also in place and producing safe readings.-Oil recovery was very complex and dynamic various methods used to trap product most being mechanical in nature. The main resource being utilized for recovery was human power in conjunction with hydro vac trucks, creating a series of ditches and small sumps for the product to pool and create opportunity to recover. Absorbent pads and bundles were in place anywhere surface flow could potentially reach storm drains as well as surrounding some residual pools in division B.- Waste Management was in place and expanding as the incident progressed. Hazardous waste was being managed, identified by a technician, and sent to multiple facilities for further attempts of product recovery or proper disposal. General waste and recycling were also being managed and expanded.-Soil monitoring was planned after initial spread was identified to better scope soil content and potential penetration relative to all sites of incident. BTEX the chemical’s benzene, toluene, ethylbenzene, and xylene.Petroleum Hydrocarbons (PHC’s) F1-F2Extractable Petroleum Hydrocarbons (EPH)Light & Heavy Extractable Petroleum HydrocarbonsMethyl tert-butyl ether (MTBE)Polycyclic aromatic hydrocarbons (PAH’s)MetalsGrain Size- Water quality monitoring was already partially in place due to the site’s history with product release. The historic and current data will help monitor any change in readings for the existing 20 plus wells in place surrounding the station. Further well installations will occur in the field or division B when more data is retrieved from the field to best place the new ground water wells.BTEX the chemical’s benzene, toluene, ethylbenzene, and xylene.Petroleum Hydrocarbons (PHC’s) F1-F2Volatile Petroleum Hydrocarbons (VPH)Light & Heavy Extractable Petroleum HydrocarbonsPolycyclic aromatic hydrocarbons (PAH’s)Dissolved Metals-Archelogy was present in division B form of an archaeologist where natural soil disturbance was occurring and Indigenous monitors on site. One potential archaeology site was identified already and was fenced off with temporary fence and was well away from operations. TM stated monitors would be near all ground disturbance.-Wildlife Management was in place with a biologist on site to evaluate habitat and potential impacts on surrounding eco systems and species. A quick conversation with field technicians provided some findings and plans to create no work zones and buffer areas for high potential or established eco systems or species. TM assured that the Information was to be represented on the following operational periods maps and Incident action plan. Ongoing wildlife impacts were discussed as well as possible plans for long term wildlife deterrents if needed. Small herd of livestock was moved to adjacent field. Concerns:-During the incident, no soil analysis or drill logs for the established wells was present to help extrapolate the spread of product to my knowledge. Clay layer was used and thanked and referred to as a barrier. A liner purpose made is hopefully being implemented in high risk areas. A best practice approach versus acceptable practice should be implemented in spill prevention site considerations.-The Incident Command post should integrate a Cultural heritage Unit in the plans section to help the ICP (incident Command Post) prepare and communicate possible First nations Archaeology, Cultural, environmental, and socio economic impacts that may not be public or common knowledge.-Rehabilitation was not represented.-Existing infrastructure outdated or not upgraded with station growth in capacity and flow increase volume of potential product release or complexity of recovery due to infrastructure.
Observation 6 - IAMC Indigenous Monitor Observations
The following observations were recorded by an IAMC Indigenous Monitor who accompanied the CER Inspection Officer during inspection. The observations related to compliance can be found above in previous observations.Incident Command Post (ICP) was setup in a hotel in Abbottsford, BC.
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
