Compliance Verification Activity Report: CV2122-112 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2122-112
Start date: 2021-09-21
End date: 2021-09-22

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Kinder Morgan Canada Inc

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Spread 4B construction [Environmental inspection of the construction of spread 4B]

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: 2021-09-21 08:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Level 3 cleaning station at 9:15

HWY 5 Road Bore (BC342) KP 763+250

HWY 5 Road Bore (BC342) KP 763+250 to Darlington creek (BC-343) (KP 763+781)Darlington creek (BC-343) (KP 763+781)Lindquist Creek (BC-344) (KP 764+079)Unamed Creek (BC-342) (KP 763+207)KP 761+520 Nehaliston Creek (BC-331) (KP 746+440)Lemieux Creek (BC-330) Area (KP 744+500 to 745+500)  Mann Creek Exit (BC-315) (KP 730+500)Mann Creek Entry (BC-315) (KP 730+250) Wednesday 22 September 2021

8:05 Tailgate meeting/Safety orientation for IM

~8:30 Cleaning station to disinfect IM truck

Weather – Steady rain in the morning

Clearwater River DPI – KP 721+200 (BC 312) (KP 734+450 to 736+480)
NCD (BC-322) (KP 735+200)Raft River (BC-309) (KP 714+020)Section of pipe installed by SAE in Summer of 2020 (KP 714+770 to 715+900) and School Creek (KP 715+500)Peavine Creek (BC 269) (KP 697+590)

Compliance tool used: No compliance tool used

Observation 2 - Information Request No.1 - Subsidence at Mann Creek HDD Entry

Discipline: Environmental Protection

Categories:

Facility:

Observations:

On 21 September 2021, IO observed subsidence on the ditch line at the entry of the Mann Creek Horizontal Directional Drill (HDD). Depth of subsidence ranged from ~1 to 6 meters. The pipeline did not appear to be exposed. The affected areas were fenced off with signage. Trans Mountain representative indicated that the HDD was completed around the end of June 2021 and that the contractor became aware of the issue upon removal of the access mats (entry pad was fully matted). 
 
On 22 September 2021, Trans Mountain provided a Corrective Action Log with open actions items as of 22 September 2021. Subsidence at the Mann Creek HDD was identified as a deficiency.
 
The following was noted in the Corrective Action Log with respect to the deficiency:

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:


Request:

  1. Provide the date the access mats were removed.
  2. Provide the date the subsidence was identified.
  3. How is Trans Mountain ensuring the pipe is still supported from below in the areas where there is subsidence?
  4. How is Tans Mountain ensuring that this subsidence is localized to only the areas that are presently showing?
  5. How will Trans Mountain mitigate these areas of subsidence?
  6. Given the failure of fluid returning to surface at the drill location, can Trans Mountain confirm that it hasn’t returned to surface offsite?
  7. What is the pipe depth at the subsidence locations (provide the depth of cover per design, the depth of cover due to subsidence, and the current depth of cover).
  8. Was there any damage to the pipe and the abrasive coating? Provide photos of the pipe at the exit location.

Due date: 2021-11-05

Date closed: 2022-04-11
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 - Information Request No. 2 - Erosion and Sediment Control

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Section of pipe installed by SAE in Summer of 2020 (KP 714+770 to 715+900), including School Creek (KP 715+500)

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:


Request

  1. Provide photographic evidence showing repairs to the entire slope SE of School Creek, including removal of sediment.
  2. Provide photographic evidence showing maintenance and/or replacement of erosion and sediment control measures along the entire SE slope.
  3. Given the soft sand/silt soils in this area, provide a plan to prevent and mitigate further erosion and sedimentation issues in this location.
  4. For all sections of pipeline installed by SAE, provide the anticipated dates for reclamation.

Due date: 2021-11-05

Date closed: 2021-12-15
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 - Information Request No. 3 - Subsidence at Mann Creek HDD Entry

Discipline: Environmental Protection

Categories:

Facility:

Observations:

On 21 September 2021, IO observed subsidence on the ditch line at the entry of the Mann Creek Horizontal Directional Drill (HDD). Depth of subsidence ranged from ~1 to 6 meters. The pipeline did not appear to be exposed. The affected areas were fenced off with signage. Trans Mountain representative indicated that the HDD was completed around the end of June 2021 and that the contractor became aware of the issue upon removal of the access mats (entry pad was fully matted). 
 
On 22 September 2021, Trans Mountain provided a Corrective Action Log with open actions items as of 22 September 2021. Subsidence at the Mann Creek HDD was identified as a deficiency.
 
The following was noted in the Corrective Action Log with respect to the deficiency:

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide an update on the status of repair work at the entry of the Mann Creek Horizontal Directional Drill (HDD) including a description of the work completed.

Due date: 2022-01-21

Date closed: 2022-04-11
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