Compliance verification activity type: Field Inspection
Team:
Regulated company: Trans Mountain Pipeline ULC
Operating company: Trans Mountain Pipeline ULC
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Environmental inspection of construction activities on Spread 7of the Trans Mountain Expansion Project. The inspection focused on implementation of mitigation measures specified in the Environmental Protection Plan and other documents, with attention to the Fraser River HDD and to sites of Indigenous significance (SIS).
Compliance tool(s) used:
Facilities:
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Additional Project-specific requirements or conditions:
Observation 1 - Information Request No.1
Discipline: Environmental Protection
Categories:
Facility:
Observations:
During research for conducting the inspection, the Officer required additional information for developing the scope and itineray of the inspection. The information that is required is comprised of information not found in the EPP and directly related to environmental protection, engagement with Indigenous communities and health.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
The following information was requested via email prior to conducting the field inspection.
Due date: 2021-03-31
Date closed: 2021-07-06 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 2 - Information Request No. 2
Based on further research of regulatory requirements, documents were requested from Trans Mountain at the Opening Meeting to assist in verifying compliance to environmental mitigation measures, and for notification of activites to that may impact heritage resources and the environment of value to Indigenous communities.
During the field portion of the inspection at the Opening Meeting, the Officer requested the following information:
Due date: 2021-06-09
Date closed: 2021-07-07 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 3 - Information Request No. 3
Based on observations during the inspection, addtional documents were required to assist in verifying compliance to environmental mitigation measures, and for the notification of activites that may impact heritage resources and the environment.
The following information was requested at the Closing Meeting to verify compliance to regulatory requirements:
Due date: 2021-06-22
Observation 4 - Information Request No.4
For IR 2, Trans Mountain submitted the General Construction Notification for work to be conducted on Spread 7 of the TMEP project. In addtion, the company submitted the list of Indigenous communities contacted for Spread 7, and a record of the email correspondence specific to potential harveting activities on the contruction site adjacent to the Fraser River. The construction dates provided to Indigenous communities may no longer be accurate.
Please provide:
Due date: 2021-07-12
Date closed: 2021-09-01 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.
Observation 5 - Fraser River Horizontal Direction Drill - North Side of the River
Date & time of visit: 2021-06-08 15:30
Fraser River HDD Exit – North Side, KP 1168.05 to KP 1168.88
Compliance tool used: No compliance tool used
Observation 6 - Hope Redwoods Natural Area - Potential Culturally Modified Tree Site KP 1150
Date & time of visit: 2021-06-09 15:22
Observation 7 - Fraser River HDD Entry, South – KP 1175
Please confirm that the contaminated soil encountered during preparation for setting up the HDD was/is being managed according to Condition 46. This condition includes a commitment to reporting discovered contamination to the CER (Section 6.3) according to the Remediation Process Guide. To demonstrate that this contaminated site has been reported, provide either:a) the remediation # generated for the site from the CERs Online Event Reporting System (e.g., REM2021-050); orb) provide the date by which the CER can expect to see this contaminated site reported via a Notice of Contamination
Due date: 2021-07-21
Date closed: 2021-08-18 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 8 - Construction Work Package (CPW) 95, KP 1614
Date & time of visit: 2021-06-11 12:03
Observation 9 - Construction Work Package (CPW) 98, KP 1175
Date & time of visit: 2021-06-11 12:57
Construction Work Package (CPW) 98, KP 1175
Observation 10 - CPW89 Brunette River, KP 1173.451 to 1173.488
Date & time of visit: 2021-06-11 11:45
CPW 89, Brunette River, KP 1173.451 to 1173.488
Observation 11 - Indigenous Monitor #1
Date & time of visit: 2021-06-08 09:00
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.
IM observations:I attended this inspection with the CER and my observations have been appropriately captured by the inspection officer observations. I have nothing further to add at this time.
Observation 12 - Indigenous Monitor #2
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.TO BE ADDED WHEN RECEIVED
Observation 13 - Information Request No. 5
KP 1175, Fraser River HDD Exit - South SideA lot of soil material was transported off site in order to construct the entry pad for the HDD. The soil was tested for contaminants and transported to a location authorized to receive the contamination – general characterization would be hydrocarbons and metals.
Please confirm that the contaminated soil encountered during preparation for setting up the Fraser River HDD was/is being managed according to certificate OC-065, Condition 46. This condition includes a commitment to reporting discovered contamination to the CER (Section 6.3) according to the Remediation Process Guide. To demonstrate that this contaminated site has been reported, provide either:
a) the remediation # generated for the site from the CERs Online Event Reporting System (e.g., REM2021-050); or
Date closed: 2021-08-19 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.
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
