Compliance Verification Activity Report: CV2021-204 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-204
Start date: 2020-10-13
End date: 2020-10-16

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Kinder Morgan Canada Inc

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Environmental inspection of Trans Mountain Expansion Project (TMEP), Spread 5A in British Columbia. The scope of the inspection was primarily focused on the Kamloops Urban Area (KUA) where the majority of the work was occurring. Specifically, where Horizontal Directional Drilling (HDD) was staged to cross the Thompson River, at both the entry and exit pads; at Lac du Bois Grassland; at Kenna Cartwright Park; and the Kamloops Airport/Suncor terminal – contaminated site. Construction on the ROW is minimal beyond the KUA, however additional work has occurred in the KUA since the previous inspection. Additional scoping focused on surveying and staking/flagging, with some clearing commencing approximately 40 KM south of Kamloops. The KUA is within Kamloops city Limits, and paralleling the existing Trans Mountain Pipeline. Several species at risk and rare ecological communities have been identified within Lac du Bois Grassland and Kenna Cartwright Park, and the topography is characterized by steep slopes transitioning into the Thompson River Valley. The Kamloops Airport is associated with a high risk contaminated site near the Suncor terminal.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2020-10-13 17:15

Discipline: Environmental Protection

Categories:

Facility:

Observations:

The inspection occurred primarily within the Kamloops Urban Area (KUA). The KUA is within the TMEP corridor and parallels the existing Trans Mountain Pipeline. Over the course of three field days, the Inspection Officers (IO) and the IAMC Indigenous Monitor (IM) made the following general observations, and/or verified actions through discussion with TMEP and contractor crews:

Cando Construction Yard

Horizontal Directional Drill (HDD) Entry PadHDD Exit PadInspectors Meeting at Cando Yard – Oct 14Discussion with Company Indigenous MonitorsDiscussion with Triton Aquatic Monitoring TeamLac du Bois GrasslandKenna Cartwright ParkKamloops Airport - Contaminated SiteBlack Pines Pump StationMoore Creek – KP 888.90

Compliance tool used: No compliance tool used

Observation 2 - CNC1 - Cigarette Butts on ROW

Date & time of visit: 2020-10-13 17:15

Discipline: Environmental Protection

Categories:

Facility:

Observations:

While inspecting the HDD exit pad/ROW, the inspection team found cigarette butts on the ROW. The butts were not located near an approved smoking area.
 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The Company will collect the cigarette butts on the ROW, and properly dispose of the butts in accordance with Trans Mountains Waste Management Plan. 

In addition, a memo will be delivered to all construction relevant personnel, reminding work crews about the use of designated smoking areas on the project footprint.

Due date: 2020-10-14

Date closed: 2020-10-19
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

Observation 3 - CNC2 - Vehicle Idling

Date & time of visit: 2020-10-14 15:57

Discipline: Environmental Protection

Categories:

Facility:

Observations:

During the week of the inspection, several vehicles were observed idling and unmanned. The doors were locked and no employees were near the vehicles. The average temperature during the week was 10 degrees Celsius; well above the Project requirement, and non-compliant to municipal bylaw regulations.  
 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

In compliance to the EPP and applicable Kamloops Municipal Bylaws, the Company will ensure employees and contractors are adhering to the requirements to restrict the duration of idling vehicles and equipment, unless air temperature is less than 0 degrees Celsius.

A memo will be delivered to Company and contractor personnel reminding them of this requirement, as well as subsequent confirmation in the form of documentation (e.g., FLHA, inspector meeting minutes) that the message has been relayed to staff and employees.  
 

Due date: 2020-10-16

Date closed: 2020-10-16
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

Observation 4 - CNC3 - Trespass at Lac du Bois Grassland: ~KP 838.9

Date & time of visit: 2020-10-14 11:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

During the inspection at Lac du Bois Grassland, the Inspection Team observed an instance of soil trespass beyond the approved workspace/ROW. The following observations were noted:

In communication with the Company EI, an informal information request was delivered to obtain further information to determine if the area of suspected trespass was accurately delineated. During a follow up meeting, the EI confirmed that trespass had occurred.   
 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The Company must remove the soils from beyond the ROW and stockpile the soil within the approved project boundary.
 

Due date: 2020-10-16

Date closed: 2020-10-19
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

Observation 5 - CNC4 - Waste Segregation at Black Pines PS

Date & time of visit: 2020-10-15 11:37

Discipline: Environmental Protection

Categories:

Facility:

Observations:

While touring the Construction yard site at Black Pines, the Inspection Team observed improper segregation of hazardous materials in the bin labelled, Oily Rags and Absorbants.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Trans Mountain and/or the contractor will remove the plastic oil containers and properly segregate the hazardous waste materials into the appropriate bins in accordance with the Waste Managemnt Plan.

Due date: 2020-10-18

Date closed: 2020-10-19
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

Observation 6 - NNC1 - Personal Protective Equipment for Level 3 Cleaning

Date & time of visit: 2020-10-14 06:30

Discipline: Safety Management

Categories:

Facility:

Observations:

In accordance with Trans Mountain's Biosecurity Plan, the Company is required to ensure all equipment has been cleaned and sanitized before entering onto the project foot print. The Inspection Team observed several heavy equipment vehicles and other equipment on the ROW. The following equipment numbers were spot checked to verify compliance:

Upon review of the requested information, IO’s identified multiple instances of non-compliance to company safety measures for cleaning and disinfecting equipment at wash stations. Specifically, workers observed performing cleaning of equipment were not wearing one or more peices of required personal protective equipment (PPE) that is required to perform such duties. Required PPE, as per interim Trans Mountain safety measures, include:  i. Eye goggles, face splash guards, and/or, eye protection with side shields, ii. Task appropriate (I.e., impervious) gloves, clothing that covers any exposed skin (long-sleeved shirts).

 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Preamble,
In CV2021-191, an Implementation Assessment Meeting which assessed this same non-compliant issue, the Company stated in their response to corrective actions for NNC1, “Trans Mountain is providing further direction and confirmation to its contractors or sub-contractors concerning safe work practices within the construction footprint, for both onsite and related offsite activities, that will be implemented for worker protection when handling a diluted bleach/disinfectant solution. Trans Mountain interim direction includes, but is not limited to, the following items: a. Review of Job Hazard Assessment for any additional PPE requirements; b. Review of Cleaning Station safe work procedures; c. Review of Safety Data Sheets (SDS) and First Aid Treatment; d. Review of minimum additional PPE required for activity, based on SDS, including: i. Eye goggles, face splash guards, and/or, eye protection with side shields, ii. Task appropriate (I.e., impervious) gloves, clothing that covers any exposed skin (long-sleeved shirts)."

Corrective Actions to be completed:

1) For the records provided and referenced in this observation, the Company will confirm they have implemented the corrective actions committed to in CV2021-191. Supply the Inspecting Officers with the revisions to the internal documents for updates to PPE requirements that were to be completed by August 3, 2020.  

2) Provide evidence that employees who performed cleaning of equipment (e.g., Cordy unit #88, ST-18050, EX229, EX266, SB225) post August 3, 2020 completed the following steps: a) reviewed Job Hazard Analysis (JHA) for additional PPE requirements, b) reviewed the Safety Data Sheets (SDS) and First Aid Treatment, and c) confirm if the JHA was signed by the employee performing the clean.
 

Due date: 2020-11-24

Date closed: 2021-02-10
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

Observation 7 - NNC2 – Black Pines PS: Threats/Intimidation concerning CER Inspection Officer/Violation of Worker Code of Conduct

Date & time of visit: 2020-10-15 12:50

Discipline: Safety Management

Categories:

Facility:

Observations:

On 15 October 2020, CER Inspection Officer (IO) and IAMC Indigenous Monitor (IM) observed workers at Black Pines Pump Station whom were not in compliance with the Covid-19 Protocol requirement to wear masks when working within 6 feet of each other while on TMEP work sites (see NNC3 regarding COVID-19 protocol compliance).

The IO requested the Contractor’s (Worley Parsons-Cord) HSE Representative for the site immediately notify the foreman of the workers to comply with the safety requirements.  The IO, IM and TMEP’s Field Regulatory Advisor observed an individual make multiple threatening gestures with his hands which implied choking someone, shooting himself in the head, and aggressively shooting at the ground when he was reminded by the HSE Representative of the requirement to wear masks.

When the HSE Representative returned to the group, the IO asked the HSE Representative if the gestures were directed at/about the IO.  The response from the HSE Representative did not confirm who the target of the aggression was towards, rather they stated the IO would need to speak to the individual directly.  The IO requested the HSE Representative have the individual return to the group so the IO could speak to the individual directly.  When the individual met with the IO and TMEP’s Field Regulatory Advisor, he appeared tense and agitated, and when asked if the threatening gestures he had made were towards the IO he stated that he had not directed the gestures at the IO but rather he was talking about another topic.

The IO and IM are of the opinion that the gestures were made in relation to the IO, despite what the individual stated. Regardless of who the aggression was intended towards, the behaviour is considered by the IO and IM to be threatening and one of intimidation. This type of behaviour is considered to be inappropriate, regardless of the circumstances, especially where there is a diversity of gender and race.

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Demonstrate how the Worley Parsons-Cord worker code of conduct is consistent with the requirements set out in Condition 59 and state why Trans Mountain’s oversight of its contractor failed in ensuring its contract worker abide by these requirement.
  2. Demonstrate how Trans Mountain’s leadership/management addresses breaches to company worker code of conduct when instances of bullying, intimidation, discrimination, threats and harassment are identified and reported. Further state how company leadership holds itself accountable to such breaches.
  3. State actions Trans Mountain has taken to re-evaluate its contractor qualification process with respect to contractor ability to adhere to regulatory and company requirements and expectations for appropriate workplace behaviors.
  4. Demonstrate that all employees and contractors on the Project are aware of and committed to adherence of company workplace harassment, violence and respect requirements.
Trans Mountain states in its response to Corrective Action 4, that Trans Mountain's "employees and owner group contractors are required to review Trans Mountain’s Respect in the Workplace Policy" during the onboarding process. In Trans Mountain's Respect in the Workplace Policy provided in the response, it states: "It is the responsibility of management supervising the activities of other employees to take immediate and appropriate action to report or deal with incidents of harassment, violence and discrimination of any type brought to their attention or personally observed. Under no circumstances should a legitimate complaint be dismissed or downplayed nor should the complainant be told to deal with the matter personally."

It is unclear to the IO if this policy would have applied to WorleyParsons-Cord (WPC) staff and management working at Black Pines PS.

Provide the following information:
  1. Explain what Trans Mountain means by "owner group contractors" and confirm whether this policy, including the "Responsibilities of Management" applies to the Contractors site management and staff (i.e., WPC management and staff).
  2. If the Policy does apply to WPC management and staff, explain:
    1. Why the WPC HSE Representative did not "take immediate and appropriate action to report or deal with incidents of harassment, violence and discrimination of any type brought to their attention or personally observed."
    2. Why the WPC HSE Representative told the IO they would need to speak to the indivudal directly, when the requirements states that "Under no circumstances should [...] should the complainant be told to deal with the matter personally".

Due date: 2021-01-29

Date closed: 2021-02-01
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

Observation 8 - NNC3 - Black Pines PS – Compliance with COVID-19 Protocols

Date & time of visit: 2020-10-15 12:50

Discipline: Safety Management

Categories:

Facility:

Observations:

On 15 October 2020, CER IO and IAMC IM observed a group of workers at Black Pines Pump Station (PS) who were working within 6 feet of each other wearing appropriate PPE (including coveralls, gloves and safety glasses) but were not wearing masks, as required by Trans Mountain’s COVID-19 protocols. IO asked the Contractor’s (Worley Parsons-Cord) HSE Representative who was responsible for ensuring compliance with ensuring masks are worn and COVID-19 protocols are followed at this site. The HSE Representative stated that the individuals being observed were from a sub-contractor and therefore mask compliance for those individuals falls to the foreman of that crew. The IO requested the HSE Representative for the site immediately notify the foreman of the workers to comply with the safety requirements. One of the individuals was observed returning to the trailers, and when asked by the IO the HSE Representative stated that the individual had forgotten his mask in the trailer and was going to retrieve it.

While at the Black Pines PS, the IO and IM observed the lunch room trailer and the orientation trailer, which company representatives stated is sometimes used as an alternate break room to ensure social distancing.  Both trailers appeared unclean and untidy, indicative of poor housekeeping practices. The IO and IM observed dirty dishes, condiment bottles and personal items left on multiple tables. Site Representative stated that cleaners circle through the trailers at site multiple times per day and wipe the tables down. Representative stated that the cleaners are not responsible for moving personal items but will remove garbage left behind.  IO and IM spoke with the cleaner who said she goes to the break trailers 2-3x per day and moves dirty dishes to wipe the tables down.
 
Following the field aspect of the inspection, Trans Mountain emailed a copy of the COVID-19 section of the Contractor’s Project Specific Safety Plan. Trans Mountain also stated that a protocol review of the COVID-19 protocols was completed at the 17 October 2020 morning meeting and all workers were required to sign off and agree to adhere to the protocols for TMEP, Cord and/or any subsidiary of either. 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Provide the following: when the first COVID-19 protocol review was completed at Black Pines PS; to date, what frequency have the workers at site reviewed/been reminded of the COVID-19 protocols and by what means; whether or not the frequency and method of protocol reviews will change going forward.
  2. Explain how TM ensures that the lunch room hygiene, sanitary and housekeeping practices complies with Trans Mountain’s Site and Site Trailer Cleaning Protocol and the role of individuals who utilize the lunch room in carrying out such practices.
  3. Demonstrate how the Worley Parsons-Cord Covid Protocol is consistent with the requirements set out in Trans Mountain’s COVID-19 Response Plan and state why Trans Mountain’s oversight of its contractor failed in ensuring its contract workers abide by these requirements.
  4. Demonstrate how leadership/management at the Black Pines PS (both Trans Mountain’s and Cord’s) addresses breaches to Trans Mountain’s COVID-19 protocols when workers are not complying with the requirements. Further state how Company leadership holds itself accountable to such breaches.
  5. State actions Trans Mountain has taken to re-evaluate its Contractor qualification process with respect to Contractor’s ability to adhere to regulatory and company requirements and expectations with respect to the Trans Mountain COVID-19 Response Plan.

Due date: 2020-11-24

Date closed: 2021-02-17
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

Observation 9 - NNC4 - Spread 5A - COVID-19 Protocols

Date & time of visit: 2020-10-15 15:20

Discipline: Safety Management

Categories:

Facility:

Observations:

On 15 October 2020, CER IOs and IAMC IM inspected clearing and staking activities taking place near KP 888.9.  Upon arriving and parking outside of Stump Pump Station, two workers were observed off-loading a buncher, and the workers were working within 6 feet of each other without wearing masks for approximately 3 minutes.  Workers, when spoken with individually, stated they forgot because they were rushing to get out of the CER’s way, and were able to produce their COVID-19 self-assessment form when asked. Workers each had masks on their person and confirmed they will don them appropriately going forward.
 
Later, a group of 3 workers were observed building an access ramp and not wearing masks appropriately when working within 6 feet of each other. Workers immediately donned their fabric masks (e.g. bandanas/buffs) when asked.
 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Demonstrate how the SMJV’s COVID-19 Protocol is consistent with the requirements set out in Trans Mountain’s COVID-19 Response Plan and state why Trans Mountain’s oversight of its contractor failed in ensuring its contract workers abide by these requirements.

Due date: 2020-11-24

Date closed: 2021-02-17
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

Observation 10 - NNC5 - Inclusion of Indigenous Monitors at Facility Construction Sites

Date & time of visit: 2021-01-08 15:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

This issuance of this NNC stems from the analysis of IR 2, where the Company has been found to be in non-compliance to Condition 98, relating to both AO-001-XO-T260-008-2016 (Line 1 PS Order) and AO-001-XO-T260-009-2016 (Line 2 PS Order). During the analysis of the response received on November 20, 2020, it is evident that there had been no inclusion of Indigenous monitors at facility construction sites prior to CV2021-204, which occurred October 13 – 16, 2020.
 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Upon evaluation of the Company's response to IR 2, Trans Mountain stated IMs have participated in inspections at 6 pump stations (of the 10 pump stations currently under construction); 5 of which were after the CV2021-204 inspection. Based on the information provided, it appears Company IMs had not been to the Black Pines Pump Station (PS) site prior to the CV2021-204 inspection, nor at other locations mentioned below.
 
Trans mountain will provide the following:

  1. Prior to the CV2021-204 inspection (October 13-16, 2020), confirm whether Company IMs had participated in inspections/construction activities at the following Pump Stations: Black Pines, Hinton, Gainford, Blackpool, McMurphy, Wolf, Blue River, and Kamloops.
  2. Provide documentation to demonstrate that prior to, 13 October 2020, Company IMs: a) were explicitly informed that they had the freedom to participate in inspections of Pump Stations; or b) met with WorleyCord to discuss activities at any of the Pump Stations they are constructing.
  3. Provide a plan to be implemented by the Company and its Contractors which will ensure participation of Indigenous Monitors at Black Pines PS, and other pump stations moving forward.



 

Due date: 2021-01-29

Date closed: 2021-02-05
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

Observation 11 - IR1 - Wildlife Sweeps at Black Pines Pump Station

Discipline: Environmental Protection

Categories:

Facility:

Observations:

During the inspection of Black Pines Pump Station, the Inspection Team met with the facility EI to discuss wildlife sweeps for American Badger dens that are documented to be in the surrounding area of facility construction. The Facility EI stated the following:

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

To ensure the Company and contractors are proactive is assessing the area for presence of American Badgers, an endangered species in British Columbia, Trans Mountain will provide to the following documentation:

Due date: 2020-11-20

Date closed: 2020-11-27
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

Observation 12 - IR2 - Indigenous Monitor Inclusion at Facility Construction Sites

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

While inspecting the Black Pines Pump Station construction site, the Inspection Team inquired about the participation of Company Indigenous Monitors (IM) during site active site construction. The Company could not provide an answer at this time, but identified that there has been no consistent IM participation at the facility construction site to date.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

As per Condition 98 requirements, the Company is required to maintain a plan which describes participation by aboriginal (i.e., Indigenous) groups in monitoring activities. This requirement is in place Project wide and must be implemented at all construction locations, including facilities (e.g., Pump Stations) to adequately ensure the protection of Traditional Land Uses.

The Company will provide the following information, and/or documentation:

  1. Confirmation whether or not Company Indigenous Monitors have participated in any activities (either pre-construction or during construction) at Black Pines PS. 
  2. Justification why there has been no consistent participation of Company Indigenous Monitors at Black Pines PS to date;
  3. Documentation demonstrating the Company and site Contactor's approach to inclusion of Indigenous Monitors during pre-construction and construction of facilities;
  4. A Plan to be implemented by the Company and its Contractors which will ensure participation of Indigenous Monitors at Black Pines PS moving forward.
  5. Confirmation whether or not Company Indigenous Monitors have participated in activities at other pump stations located in Spread 5A and across the Project.

 

Due date: 2020-11-20

Date closed: 2021-01-08
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

Observation 13 - IR3 - Inconsistent Reporting on Biosecurity Records

Discipline: Environmental Protection

Categories:

Facility:

Observations:

While reviewing the biosecurity records submitted for spot checks of equipment listed in NNC1, the IO has concerns regarding consistency in documentation for biosecurity records provided to the inspecting officers. The summary of inconsistencies is provided below:

TMEP report
For the Cordy Unit #88 – The document indicated a level 2 and 3 cleaning. Does not have inspector signatures on the document.

Unknown provider report, generated by Fulcrum (Blackpool)
For ST-18050 (Camera Tower) – The document indicates a level 3 cleaning. Has inspector signature.  

SMJV reports
For EX229 – The report indicates a level 2 and 3 cleaning, with descriptions of pressure washing and bleach being applied. Does not have inspector signature.

For EX266 – The report indicates a level 2 and 3 cleaning, with descriptions of pressure washing and bleach being applied. Does not have inspector signature.

For RT923 – No indication of level of cleaning completed with no descriptive requirement. Has inspector signature on the document.

For DZ189 – There are two reports for this unit:

For SB225 - The report indicates a level 2 and 3 cleaning, with descriptions of pressure washing and bleach being applied. Does not have inspector signature.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the following:

  1. Describe the responsibilities of the employees conducting cleaning of equipment, specifically in regards to obtaining inspection signatures and approvals for biosecurity records?
  2. Explain the process to ensure consistency amongst Company and contractor reporting requirements? 
  3. Describe any review or approval process biosecurity records receive. Are the documents reviewed and evaluated for completeness, and do the reports require approval from an authoritative person(s) before being entered into Trans Mountain's records system?

Due date: 2020-11-24

Date closed: 2021-02-18
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

There are no observations with outstanding follow-up

Observation 14 - IAMC Indigenous Monitor (Upper Nicola) Observations

Date & time of visit: 2020-10-16 09:20

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Additional observations recorded by IAMC Indigenous Monitors participating in the CER inspection. Any compliance-related observations that require specific regulatory follow-up have been recorded above.


Date: Oct 13-16 2020
Environmental protection Preconstruction, Heritage and TLU
Spread 5A Kamloops

 
Open meeting Oct 13th. Security check point on-site. Temp check on-site. Everyone following the Covid protocols on-site. Wearing masks and using had sanitizer before going to get temp check. Discussed areas to inspect. 2 new IM’s

Airport – construction happening. Have 2 workers sifting on-site, Arch site #5. Any findings they record. Couple heritage sites at the airport are fenced off for a no work zone. IM’s do go on-site and involved. Idling vehicles at site. Cigarette butts found in none smoking area

Lac Du Bois – Clearing has been done. They had the rattlesnakes being caught and removed. The rattlesnakes pit was fenced off and still being removed. The rattlesnakes will be returned after clean-up. The cryptogamic crust has been removed and stored.

Black Pines – orientation on-site. Archaeologists on site. No IM’S on-site during this time. Asked why no IM’S ? asked when they will IM’S? NO response yet on the IM’. Badgers and Burrowing Owls and Heritage resource at north end of site. Asked if they will have a resources specialist come in for the badgers and owls? The areas are fenced off and a no work zone. Asked again if IM’s will be involved with the heritage and badger and burrowing owls? Unknown if they have IM’s on-site.  High percentage of the workers not following the covid protocol. High percentage was not wearing masks and working closer than 6’. IO asked that the foreman and crew to comply with the safety protocols and asked for the crew to be reminded and to wear masks. The group of IO’s, and TMEP’s and myself observed an individual make threatening gestures with his hands which implied choking someone, shooting himself in the head, and shooting at the ground when he was reminded to wear a mask.
 
 Moore Creek – clearing has started. IM’s have been on-site. Moore creek is fish bearing. IR on 870C buncher cleaning record. Crew working on-site following covid protocols and wearing masks.
 

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:

- 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

Observation 15 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail

This information has been redacted pursuant to Section 144(5) of the Canada Labour Code