Compliance Verification Activity Report: CV2122-362 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2641

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Environmental Protection
• Indigenous Monitoring

Rationale and scope:

Environmental inspection of TMPU's flood response work along the Coldwater River.

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)
• BC AND WASHINGTON STATE FLOOD RESPONSE - ENVIRONMENTAL PROTECTION PLAN

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2021-12-07 10:30

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Soil Handling
• Chemical Spills/Releases
• Surface Water Management
• Surface Water Management Plan
• Water Bodies - Fish-bearing
• Sedimentation/Turbidity
• Destruction/Loss of Habitat
• Disturbance
• Reclamation
• Erosion
• Vegetation
• Destruction of Vegetation
• Air Quality
• Emissions Control/Monitoring
• Housekeeping
• Waste Management

Facility:

• Mainline (Pipeline)

Observations:

7 December 2021 

KP 955 – Britton Creek

• ~ 100m exposure
• TM Representative stated that access to the site only opened-up 3 to 4 days ago.
• Pipeline exposure isolated from the river. Existing berm used to protect pipe. TM Representative stated that Riprap is locally sourced. Logs from log jam were used to armour bank.
• TM Representative stated that the site shuts down around 4 pm. Generator watch at night and medic staged for night shift.
• IO observed removal of boom and equipment from the secondary control point (CP 6, KP 954.8). TM Representative noted that the equipment was being removed prior to freeze-up.
• IO observed secondary containment under a light stand and pump. Fuel was stored in secondary containment except one fuel container that had been recently used and was situated in the back of a side-by-side (spill contain was present). Fire extinguishers were on site. Excavation area identified with rope and flagging.
• Dewatering occurring at the site; water from pumps discharged on to cobble to prevent erosion and sedimentation. Screens present at the end of pump hoses. EI on site monitoring water quality. TM Representative stated that there is currently no instream work; work to commence once final site design completed by Matrix. Fish salvage occurring; three passes using electrofishing, two passes with net on each side of pipe. No fish were found.
• TM Representative stated that coating from pipe girthwelds and PPE used to remove coating is sealed in secondary containment bags and labelled. Asbestos containing material will be removed as per Trans Mountains procedures and will be disposed of at a Trans Mountain approved facility (Secure Kamloops).

KP 973+260 – Coquihalla Park

• Trans Mountain Representative stated that a small exposure (~ 1 m) had just been identified that day and will be reported to CER. No visible damage was observed. IO observed a small exposure (only top of pipe) which was covered with silt/sand.
• Trans Mountain Representative stated that an isolated channel had formed during the highwater event. Trans Mountain is currently building-up a rockwall with locally sourced riprap from a quarry intended for emergency use. Fish salvage occurred the previous day within the isolated channel, electro fishing was not conducted. Fish salvage is ongoing; four rainbow trout and 1 red legged frog were recovered.
• TM Representative stated that Interim site design being used for the winter, final plan to be developed.

KP 969+260 – Coquihalla Park

• TM Representative stated that the bank had eroded approximately 7 meters and pipe was exposed. Site repair was completed that morning. Native river material was used as back fill. Impacted bank was armoured with locally sourced riprap from a nearby emergence quarry. key-in is permanent and reclamation assessment to be undertaken in the spring. Fish salvage did not occur at this site.

KP 969+000 – Coquihalla Park

• TM Representative stated that there was a minor exposure and repair work had been completed. A berm was built to divert water away from the pipe. Where exposure had occurred, area was sloped to decrease run off towards the river. No in water work had been conducted, only around the edge of the river. Riprap was sourced locally.
• Trees where roots were undermined by highwater were cut down and stored adjacent to the river. BC Parks was notified of the tree removal, Trans Mountain is awaiting further instructions. 

8 December 2021

KP 1000+3 -  Coquihalla River Crossing

• IO, IMs, and Company representative drove from Merritt to KP 1000+300. There were major delays getting to and from site due to weather (snow conditions), damage to Coquihalla Highway (e.g., landslides, washed out bridges); required to use diversions around damaged infrastructure and repair work. Damage to the Coquihalla was significant south of the Coquihalla summit and in the area of Hope, BC. Only a short period of time was spent on site due to the conditions noted above and limited daylight.
• Upon arrival, IO observed that the site was heavily impacted by the flooding event, a large portion of vegetation/riparian area was removed.
• Trans Mountain Representative stated that only the top portion of Line 1 was exposed. 
• Coquihalla No. 15 Replacement and Trans Mountain Expansion Pipeline were recently completed; work was delayed due to a previous highwater event. TM Representative stated that the bell hole south of the river was flooded and the bell hole north of the river was full sediment, work was underway to remove sediment.
• TM Representative stated that the south bank of the Coquihalla River had been armored; additional riprap was added to riprap that was already in place. TM Representative further stated that riprap was sourced locally from a pit near Hope, BC.  
• Fish bearing water course - TM Representative stated that fish salvage was conducted; 42 fish were recovered.

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: