Compliance verification activity type: Field Inspection
Team:
Regulated company: NOVA Gas Transmission Ltd.
Operating company: TransCanada PipeLines Limited
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Environmental oversight of construction activities of NOVA Gas Transmission Ltd. (NGTL) Clearwater West Expansion Project Grand Prairie Mainline Loop No. 3 (Elmworth Section 1-23.7km) and Loop No. 2 (Huallen Section-13km). The focus of the inspection was to verify compliance with the Clearwater West Project Environmental Protection Plans, the relevant portions of the Environmental Manual for Construction Projects in Canada (3rd Edition) and applicable legislation. The scope of the inspection included, but was not limited to, erosion and sediment control, mitigation measures implemented for Key Wildlife Biodiversity Zones, waste management, archaeological and traditional ecological knowledge sites, and wetlands and watercourse crossings.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - General Right-of-Way Observations
Date & time of visit: 2019-12-03 12:00
Discipline: Environmental Protection
Categories:
Facility:
Observations:
CER Inspection Officers (IOs) and the accompanying Indigenous Monitor (IM) made the following general observations on the Huallen Section (White Area), and Elmworth Section 1 (Green Area), of the Project while observing a variety of construction operations and activities.Observations occurring on 3 December 2019:Attend Inspectors meeting -6:30 AM
Compliance tool used: No compliance tool used
Observation 2 - CNC #1 –Elmworth1 KP 2+355 Equipment Within 100m of a Waterbody
Date & time of visit: 2019-12-04 11:11
While inspecting an Unnamed Tributary to Campbell Creek and a wetland at KP 2+355, IOs observed a piece of heavy equipment parked roughly ~80 m from the banks of the waterbody without secondary containment. A spill kit was not present inside or outside the cab and the fire extinguisher attached had not been inspected since September 2019.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
1) Move the piece of equipment outside of the 100m buffer of the wetland boundary. If repairs are required for mobilization place a spill tray under to catch possible leaks.2) Check the out-of-date fire extinguisher and update the tag.3) Provide IOs with photographic evidence confirming the issues have been resolved.
Due date: 2019-12-06
Date closed: 2019-12-06 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 - CNC #2 –Erosion and Sediment Control Elmworth 15+400 Wetland WL001a
Date & time of visit: 2019-12-04 16:16
While inspecting Big Mountain Creek, IOs observed dewatering activities associated with the DPI work. Upon closer observation of an area located on the middle bench of a slope where the water storage tanks were held, IOs observed ESC fencing with a wing wall that was down. There were no work crews in the immediate area and light snow fall had covered the fence.
TC/NGTL are required to re-erect the ESC at the site and provide photographic evidence to confirm corrective actions have been implemented.
Date closed: 2019-12-16 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.
Observation 4 - CNC #3 Topsoil Off RoW -Huallan KP 11+300
Date & time of visit: 2019-12-05 14:49
On 5 December 2019, at KP 11+300, the IOs identified topsoil outside of the temporary workspace boundary that had rolled from the top of the topsoil pile. The area of the soil off RoW was approximately 2 m x 0.5 m in a canola field.
TC/NGTL is required to pullback the topsoil that has migrated past the temporary workspace boundaries and provide photographic evidence of the corrective action.
Observation 5 - IR - Misrepresentation of Data Associated with Environmental Alignment Sheets and Environmental Protection Plan
Date & time of visit: 2019-12-04 08:00
During preliminary, desktop document review, IOs noticed inaccurate information displayed between the Environmental Alignment Sheets (EAS) and the Environmental Protection Plan (EPP). Discrepancies in the EAS were noted on both the Huallen and Elmoworth1 sections. Specifically, on the Huallen section - the watercourse crossings titled, "Beaverlodge River" and "Harold Creek", did not indicate that a watercourse crossing was present. According to the GIS Legend, water course crossings are to be indicated by a blue "X" that was not present on the applicable sheet. On the Elmworth1 section - Resource Mitigation Codes for certain features (e.g., wetlands and woodlands) in the EAS were not accurately representing features when used in conjunction with the EPP and GIS data on the alignment sheets. Furthermore, woodlands were delineated as wetlands in the EAS, and the legend data did not accurately reflect the applicable topography.
Compliance tool used: Information Request (IR)
Provide an explanation as to why the inaccurate information was overlooked and how the environmental consultant that developed the EAS would prevent such discrepancies in the future.
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