Compliance Verification Activity Report: CV2122-190 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2122-190
Start date: 2021-07-05
End date: 2021-07-09

Team:

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

NGTL 2021 - Karr Section: Work camps and temporary accommodation and RoW; Assess field implementation of worker accommodation strategy per Condition 7; company implementation COVID-19 safety protocols. NGTL 2021 - Karr Section: The Karr section consists of approximately 57 km of 1,219 mm (NPS 48) outside diameter (OD) pipeline, mainline block valves, associated crossover assemblies and launcher/receiver assemblies. The Karr Section begins at NW 28-63-01 W6M and ends at NE 26-67-05 W6M. Assess field implementation of construction safety manual and project specific safety plans for ongoing construction activities; worker tasks including identification of hazards and appropriate controls relevant to the job tasks via hazard assessments; company implementation COVID-19 safety protocols; company oversight of contractors - training & competence, monitoring, supervision and accountability; assess execution of work per applicable procedures and documented work practices.

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 -1 - Karr Worker Camp

Date & time of visit: 2021-07-06 09:30

Discipline: Safety Management

Categories:

Facility:

Observations:

Observations -1- Karr Camp and TC Energy/SMJV Field Office

Orientation:Karr Camp Exterior GroundsKarr Camp (Interior)
COVID-19 Protocols included:HousekeepingPermitsFood SafetyElectricalFire

Compliance tool used: No compliance tool used

Observation 2 - General Observations - 2 - Karr Laydown Yard

Date & time of visit: 2021-07-06 12:00

Discipline: Safety Management

Categories:

Facility:

Observations:

General Observation - 2 - Karr Laydown Yard


DelineationHousekeepingPipe HandlingEquipment PlacementLifting and Hoisting 

Compliance tool used: No compliance tool used

Observation 3 - General Observations - 3 - Karr Spread, Gold Creek Compressor Station Construction

Date & time of visit: 2021-07-07 08:00

Discipline: Safety Management

Categories:

Facility:

Observations:

General Observations - 3 - Karr Spread, Gold Creek Compressor Station

Gold Compressor Station 

Slit Trenching

Damage Prevention processes were described including:Hydrovacing crews were observed to have displayed appropriate signage and all but one was observed to be wearing appropriate hearing protection and fall protection (See CNC 4).

Pipe StorageLifting and Hoisting

Compliance tool used: No compliance tool used

Observation 4 - General Observation - 4 - Excavation Safety and Pipeline Crossings

Date & time of visit: 2021-07-07 11:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Road 27 – Hotline Crossing

Compliance tool used: No compliance tool used

Observation 5 - General Observation - 5 - HDD of Smokey River

Date & time of visit: 2021-07-07 10:30

Discipline: Safety Management

Categories:

Facility:

Observations:

HDD of Smokey River

Team 2 CER IO and IM's toured the HDD site - drilling was on-going

Compliance tool used: No compliance tool used

Observation 6 - IR 1 - Indigenous Monitoring

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

Pre-inspection information request.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Company action required:

Please have hard copies of the following available for review during the morning meeting prior to inspecting the right of way on Wednesday July 7th.

Due date: 2021-07-07

Date closed: 2021-07-23
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 7 - IR 2 - On-Water and Near-Shore Safety Plans

Discipline: Safety Management

Categories:

Facility:

Observations:

IR - 2 - Smoky River HDD

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Please provide to the Inspection Officer for review, the available On-Water Safety Plan, specific to water monitoring at the Smoky River HDD site.

Due date: 2021-07-20

Date closed: 2021-07-21
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 8 - NNC - 1 - Royal Camps. Karr Camp, site and grounds, visible litter and garbage

Date & time of visit: 2021-07-07 14:00

Discipline: Safety Management

Categories:

Facility:

Observations:

NNC-1 

  1. CER IO observed various garbage, food containers and other waste debris around the Royal Camp grounds site on the initial day of inspection (July 6). Despite sharing these observations with Camp Management and TC Representatives, garbage and litter was still visible around the camp on the next day (July 7)(Photos attached), warranting a Notice of Non-Compliance to the Environmental Protection Plan. 
    1. Due to there not being a perimeter fence around the Karr Camp location to prevent bears and other wildlife from entering the site, the severity of the garbage and waste hazard is elevated and a risk to camp attendees. 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

TC Energy is to ensure the Karr Camp site and grounds are cleaned up of all litter, waste and garbage; and are to provide to the CER Inspection Officer for review, an applicable process, procedure, standard or checklist, that demonstrates a regular and routine program of oversight of the Royal Camp yard and grounds is occurring, and that site inspections are documented which prevent, eliminate and manage waste, litter or garbage that may accumulate and spread around the Royal Camp, Karr Camp site area.
 

Due date: 2021-08-13

Date closed: 2021-08-26
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 9 - IR 3 - Electrical Safety

Discipline: Safety Management

Categories:

Facility:

Observations:

An electrical panel was observed to be modified.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Describe how the modification to the electrical panel meets all TC specifications including commitments to industry standards (e.g.. CSA-Z462 follow CSA-C22.1-18, Canadian electrical code). Include in your response:

Due date: 2021-08-30

Date closed: 2021-09-02
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 10 - IR 4 - Fire Safety

Discipline: Safety Management

Categories:

Facility:

Observations:

Fire hoses left in cabinets at the Karr camp were described as non-functional.



 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Describe how the Karr camp is compliant with all fire suppression requirements. Consider in your response the fire hoses that have been left in fire cabinets but described as non-functional by camp management. Include descriptions of primary and secondary fire suppression equipment/methods.
 

Due date: 2021-08-30

Date closed: 2021-09-02
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 11 - CNC 1 - Housekeeping at SMJV Laydown Yard

Date & time of visit: 2021-07-06 11:30

Discipline: Environmental Protection

Categories:

Facility:

Observations:

A dumpster was opened and garbage was extracted by birds on site.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

IO requested company collect and dispose of the garbage.

Due date: 2021-07-06

Date closed: 2021-07-20
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 12 - CNC 2 - Fasteners in Breaker Panel

Date & time of visit: 2021-07-06 11:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Fasteners were observed to be missing from a breaker panel.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

IO requested fasteners be replace where missing.

Due date: 2021-07-06

Date closed: 2021-07-20
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 13 - CNC 3 - Safe Equipment Storage

Date & time of visit: 2021-07-06 11:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Side boom arms were stacked in what appeared to be a position susceptible to collapse.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

IO requested equipment stack be adjusted to a more stable position.

Due date: 2021-07-06

Date closed: 2021-07-20
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 14 - CNC 4 - Personal Protective Equipment

Date & time of visit: 2021-07-07 09:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Hydrovacing worker was observed to be working without required fall protection.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

IO requested worker be advised to don fall protection equipment as per company requirement.

Due date: 2021-07-07

Date closed: 2021-07-20
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 15 - CNC 5 - Unprotected Excavation

Date & time of visit: 2021-07-07 10:00

Discipline: Safety Management

Categories:

Facility:

Observations:

A group of worker were observed adjacent to an unprotected excavation edge.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company was directed to mark a safety zone around the excavation with spray paint and advise workers of the hazard of congregating unnecessarily at excavation edge.

Due date: 2021-07-07

Date closed: 2021-07-21
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 16 - General Observations - Indigenous Monitoring

Date & time of visit: 2021-07-07 17:00

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

Additional Observation recorded by Indigenous Monitors participating in the CER Inspection.  Any compliance related observations that require specific regulatory follow-up have been recorded in stand alone observations.


Indigenous Monitor Observation Report CV 2122-190
Jonathan Wright – Sucker Creek First Nations Indigenous Monitor
July 6th and july 7th, 2021
 
Glossary
CER – Canadian Energy Regulator
IM – indigenous Monitor
IR – Information Request
NNC- notice of Non-Compliance
CNC- Corrected Non-Compliance
FN – First Nations
TLU – Traditional Land Use
HDD – Horizontal Directional Drill
DTA – Department of Transportation of Alberta
KP – Kilometre Point
 
Introduction:
Inspection was completed on July 6th and 7th on the KARR section of the NGTL pipeline. Inspection was completed by two safety inspectors from the CER and two Indigenous Monitors from Sucker Creek First Nation & Montana First Nation. The CVA consisted of inspection of the Karr camp, the ROW, the company IM program and because it was the kickoff of the pipeline construction period, we looked in the chance find protocol & TLU site mitigations, awareness and training.
 
Observations/Inspection: Karr Camp KP 44
We walked the grounds of the camp to ensure safety measures were in place for the protection of its residents. We also looked at environmental protection measures, wildlife mitigations and socio-economic concerns.
 
Approach:

  
Outcome/recommendations: 
Observations/Inspection: HDD Smokey River – KP 53+500
Inspected the entire site for all safety, environmental and TLU concerns. Note that on inspection of perimeter common TLU plant was present in abundant numbers, noted to company IM.
 
Approach:
All safety issues were dealt and noted by CER IO’s. Tried to talk with water quality monitor personnel to go over safe work plans & protocols. Were unable to do so in field so an IR was issued to look over the documents pertaining to water quality monitors work procedures and safe work plan for installing and demobilizations of water quality equipment from river. Also, safe work plan & procedures of hand water quality testing in river. IR is currently under review.
 
Outcomes/recommendations: 
Observations/Inspection: closing meeting with NGTL Indigenous Program personnel & environmental team 
Approach: 
Outcomes/Recommendations:  
Conclusion:
It was a very informative and well received CVA. NGTL staff were all very hospitable and open. I do note that project is just in its early stages of construction but is off to good start, have a great basis to compare future CVA and to judge that conditions 10, 11 & 16 are in compliance. I do believe that is measures and standards stay in place that TLU/SIS sites, issues and community concerns will be met and mitigated effectively. I would like to note that indigenous perspectives & representation are being looked at carefully on the project not only by company monitors but by that the project is currently at 30% indigenous companies working on the project with a promise to keep that standard up. I look forward to future CVA’s with the NGTL team.

CER SCFN Indigenous Monitor
 

Compliance tool used: No compliance tool used

Observation 17 - IR 6 - Cultural Resource Discovery Contingency Plan (CRDCP)

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

NGTL notes the ACPP Plan, as filed with the CER per Condition 10 of the Project, denotes involvement of ACPP participants where the Cultural Resource Discovery Contingency Plan (CRDCP) is implemented.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Company action required:

Provide a copy of the Cultural Resource Discovery Contingency Plan (CRDCP).

Due date: 2021-08-20

Date closed: 2021-09-03
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 18 - IR 7 - Berm Mitigation and Water Erosion Control

Discipline: Environmental Protection

Categories:

Facility:

Observations:

IM Identified one section of Karr Camp perimeter that appeared to have insufficient berm mitigation and water erosion control. IM also noted at the same location that it was becoming a natural drainage area, so in an instance of a major spill or flood it would be the weak point of area of drainage. Also noted that at the opposite end of the perimeter had excellent textbook drainage & beam mitigations.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Company action required:

Provide evidence that mitigations are suffecient or evidence of corrective measures.

Due date: 2021-08-20

Date closed: 2021-09-03
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

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