Compliance verification activity type: Field Inspection
Team:
Regulated company: Trans Mountain Pipeline ULC
Operating company: Kinder Morgan Canada Inc
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
TMEP Spread 4B construction inspection. Scope is to assess field implementation of the environmental protection plan and associated resource-specific plans and mitigation for construction activities. Focus areas for environmental protection will be to verify erosion and sediment control measures (particularly at watercourse crossings), and mitigation measures to protect birds.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - General Construction Observations
Date & time of visit: 2022-05-17 09:00
Discipline: Environmental Protection
Categories:
Facility:
Observations:
Biosecurity
Compliance tool used: No compliance tool used
Observation 2 - Watercourse Crossings
Date & time of visit: 2022-05-17 11:00
Peavine Creek KP 697+610 (Fish-Bearing)
Observation 3 - Indigenous Matters
Date & time of visit: 2022-05-18 09:00
Discipline: Socio-Economic
Indigenous Monitoring Program - Met with company Indigenous Monitors and Indigenous Monitor Coordinator - The focus was the Company IM’s and what they do in a day, and following up on observations made during a previous IAMC IM-led inspection (CV2021-193). - Company IMs stated they travel up and down the spread stopping at areas of interest a few days apart making sure they are not being disturbed and mitigation is being applied as needed. - Inspection Officers and Company IMs and EI observed an area of focus to the IMs where there was a Eagles nest and a buffer of 200 meter away from the site. - Officers asked questions about the capacity building of the IMs on the spread. Discussions indicate that Trans Mountain supports the training that would help develop the skills and careers of the Trans Mountain Indigenous Monitors. Discussed with the company IMs the training they were receiving from Trans Mountain and if they wanted to build their capacity, whether they had a person to reach out too. The company noted there was a designated EI for IMs to ask questions and relay concerns. Training was offered and recent courses taken included Sediment and Erosion Control, nesting birds training, and 4x4 training. The company and IM noted the IM was on the path to become a junior EI, which would increase oversight to all things covered in the EPP rather than focusing primarily on sites of Indigenous significance. - Confirmed that quarterly meetings are being held with the TM IM Coordinator and the IMs, as required. Site of Indigenous Significance - Over the course of the inspection, observed TLU, and other sites of indigenous significance that were marked and avoided. Discussed TLU sites and the mitigation that was applied. - Observed an Heritage Resource site being actively monitored by an archaeologist. Oral confirmation about the area is that there were lithic flakes and land forms in the area. Discussed that there maybe other Heritage Resource sites in the area. - The Company IM shared stories about the people that previously migrated in the area.This indicates the area is of Indigenous significance.
Observation 4 - CNC 1 Food Waste on RoW
Date & time of visit: 2022-05-18 14:00
In the area of KP 744, SF24, Inspection Officers noted pistachio shells on the RoW and a steak and baked beans on the ground next to the portable toilets. Inspection Officers note that construction crews only three kilometres down the right-of-way at KP 741+600 said they saw a lone black bear and a mother and two cubs at their work location that day. EI picked up food waste for proper disposal.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
The Environmental Inspector immediately removed the steak and beans for proper disposal and committed to talking about food waste at the morning meeting the next day.
Due date: 2022-05-18
Date closed: 2022-06-03 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 - CNC 2 Sediment Fence in Disrepair Nehalliston Creek.
Date & time of visit: 2022-05-18 13:00
At Nehalliston Creek (KP746.440) sediment fencing was broken in multiple places. Fencing was erected next to the travel lane which was close to the meandering creek in places.
Repairs were made that day and photos of the repaired site were shown to Inspection Officers prior to the end of the day.
Date closed: 2022-05-18 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.
Observation 6 - CNC 3 Secondary Containment at Lindquist Creek
Date & time of visit: 2022-05-19 11:30
Two water pumps within 100 m from the watercourse at Lindquist Creek (KP764.234) crossing did not have secondary containment.
Trans Mountain shared a photo of the orange pump with secondary containment in place and provided confirmation that the green pump (not in use) had been moved >100 m from the watercourse.
Due date: 2022-05-19
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
