Compliance Verification Activity Report: CV1819-526 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1819-526
Start date: 2018-12-17
End date: 2018-12-20

Team:

Regulated company: NOVA Gas Transmission Ltd.

Operating company: NOVA Gas Transmission Ltd.

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Inspection of NGTL North Montney spread 3. Inspection will focus on verification of the implementation of environmental commitments and mitigation approved. North Montney is a 306 km construction of NPS 42 pipe and related components in northeastern BC.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2018-12-18 10:06

Discipline: Environmental Protection

Categories:

Facility:

Observations:

The following environmental protection measures were found to compliant at all locations visited by the NEB Inspectors during the inspection:
  • Erosion and sediment controls were in place at watercourse crossings, wetlands, and slopes.
  • Soil storage, labelling and segregation.
  • Secondary containment where appropriate.
  • Narrowed right-of-way (RoW) to avoid sensitive environmental features.
  • General good housekeeping on RoW.
  • Wildlife breaks in soil windrows.
  • The limits of the RoW were clearly marked with flagging or similar visual aids.
  • Signage for identification of sensitive environmental features, including:
    • Wetland – No Fueling.
    • Watercourse – No Fueling.
    • Game Trail.
    • Mineral Lick.
    • Historical Resource Sites - No Entry
  • Spill kits and fire extinguishers were present on each piece of heavy equipment.
  • Stickers denoting that equipment has been cleaned and inspected were observed. At Kick-off, TransCanada personnel explained the details of equipment inspection including the company’s system used to track the information. Inspectors spot checked the following pieces of equipment, with stickers and cleaning records; no issues were noted:
    • Dozer (D109) at KP 143 + 900.
    • Side Boom (SB-119) at KP 152+800.
    • Excavator (BH-119) at KP 152+800.
Inspectors observed activities and/or met with the following crews on the RoW:
  • Indigenous monitors (see below for additional information).
  • Bending crew at KP 152 + 800.
  • Coating crew at KP 175 + 70.
  • Ditching/Borehole crew at 139 + 645.
Kilometer Post (KP) 163 to KP 170:

In the area of approximately KP 163 to KP 170, black electrical tape was observed to be coming loose from the pipe in some areas.  Officers and TransCanada representatives discussed this observation on the RoW, and the company confirmed plans for work crews to work towards this area to collect and dispose of the tape.  These observations are considered compliant. 

Yards:

NEB Inspectors verified compliance at the Banister and Haystack Yards, focused on fueling and storage areas.  No issues noted with the exception of the “metal only” waste container at the Haystack Yard, where Inspectors observed incorrectly segregated wastes (see CNC #2).

Indigenous Monitors:

At 11:25 AM on 18 December 2018, NEB inspectors met with the local indigenous monitors that were working on Traditional Ecological Knowledge (TEK) oversight of the project.  The monitors did not raise any concerns to the Officers at the time of the inspection. 
 

Compliance tool used: No compliance tool used

Observation 2 - CNC 1 - Unsafe Driving on the RoW

Date & time of visit: 2018-12-19 10:30

Discipline: Safety Management

Categories:

Facility:

Observations:

A pickup truck on RoW was observed to be travelling at approximately the same speed as the vehicle of the inspectors, which was travelling on a road parallel to the RoW at approximately 50 kilometers per hour (KPH).  Pipe was strung in this area, and workers were present in nearby areas.   

The NEB Inspector’s vehicle was travelling at approximately 25 KPH south on the RoW, where a pickup truck passed the NEB inspectors vehicle.  Inspectors were concerned that the vehicle was travelling above the RoW speed limit.    
Inspectors were concerned that each of these vehicles may have been travelling faster than the RoW speed limited of 25 KPH listed in the North Montney Safety Plan).  

This is considered Corrected Non-Compliance #1 (CNC #1). 
 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Communicate to project workers that a non-compliance was observed by NEB Inspectors, including a reminder of the importance of safe driving on the RoW. 

Due date: 2018-12-20

Date closed: 2018-12-21
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 - Chemical and Waste Separation

Date & time of visit: 2018-12-19 15:05

Discipline: Environmental Protection

Categories:

Facility:

Observations:

At the Haystack Yard, Inspectors observed non-compliant separation of waste.  Cardboard and plastic had been misplaced into a bin labelled Metal Only.  Three empty canisters labelled Methanol, which TransCanada confirmed to be hazardous waste, were observed in the same bin. 
This is a non-compliance to Bullet 3, Section 1.3.3.1.4 – Waste and Chemical Storage of the EPP.  

TransCanada corrected the issue during the inspection and send documentation in the form of photographs to Inspectors.
This is considered CNC #2.


 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Materials found to be misplaced in the wrong waste bins are to be adequately segregated and disposed of at the appropriate locations. After all materials have been properly sorted, TransCanada representatives will provide NEB inspectors with photographic evidence that the task has been completed.

Due date: 2018-12-21

Date closed: 2018-12-21
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

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