Compliance Verification Activity Report: CV2021-121 - Many Islands Pipe Lines (Canada) Limited

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-121
Start date: 2020-11-02
End date: 2020-11-04

Team:

Regulated company: Many Islands Pipe Lines (Canada) Limited

Operating company: Many Islands Pipe Lines (Canada) Limited

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Construction inspection for the Pierceland Supply Project. MIPL(C)L proposes to construct an approximate 30.9 kilometre long, 508 mm (20-inch) OD non-sour, natural gas pipeline extending from a riser adjacent to a new NGTL meter station in Alberta to a tie-in point adjacent to an existing TransGas Limited compressor station in Saskatchewan. There will be 1.7 km of pipeline in Alberta, and 29.2 km in Saskatchewan. The Project also includes a new MIPL(C)L compressor station to be constructed just inside the Saskatchewan border. Assess compliance with the OPR (Environmental Management Program), and construction EPP.

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: 2020-11-03 09:26

Discipline: Environmental Protection

Categories:

Facility:

Observations:

General observation:

Tuesday November 3, 2020

KP 30+272 (Kick-off location) to ~KP28+900

KP 27+900 (Entry pad) KP 23+176KP22+461 (Beacon Lake area)KP19+106Construction YardCompressor Station (KP 2+150)Wednesday November 4, 2020

Met with company IM in the morning. IM stated: Construction Yard

Compliance tool used: No compliance tool used

Observation 2 - Document Review

Date & time of visit: 2020-11-03 12:15

Discipline: Environmental Protection

Categories:

Facility:

Observations:

The Inspection officers reviewed documents held in the construction trailer / office.  

Compliance tool used: No compliance tool used

Observation 3 - CNC 1 - Equipment fire extinguisher missing

Date & time of visit: 2020-11-03 09:35

Discipline: Environmental Protection

Categories:

Facility:

Observations:

IOs conducted spot check of a side-boom (PLR00524); no fire extinguisher was present. 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

MIPL is required to provide confirmation (photographic evidence) that the fire extinguisher was installed on the side-boom. 

Due date: 2020-11-04

Date closed: 2020-11-06
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 4 - CNC 2 - Equipment spill kit missing

Date & time of visit: 2020-11-03 09:35

Discipline: Environmental Protection

Categories:

Facility:

Observations:

IOs conducted spot check of a side-boom (PLR00524); no spill kit was present. 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

MIPL is required to provide confirmation that spill kit was installed (photographic evidence) on the side-boom. 
 

Due date: 2020-11-04

Date closed: 2020-11-04
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 5 - CNC 3 - Bulk Fuel Tanks in yard - fire extinguishers

Date & time of visit: 2020-11-03 15:50

Discipline: Safety Management

Categories:

Facility:

Observations:

Construction yard

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Under Section 6 of the Onshore Pipeline Regulations, the Company is required to ensure that all legal requirements applicable to matters of safety, security and protection of the environment are monitored, and the Company is in compliance with them. 
Saskatchewan adopts the National Fire Code by regulation under the provisions of the Saskatchewan Fire Safety Act.  
Under the National Fire Code is the requirement: 

4.4.11.4. Portable Extinguishers
1) One 80-B:C rated portable extinguisher or two 40-B:C units shall be provided in the vicinity of pumps and ancillary equipment used for the transfer of flammable liquids or combustible liquids.  


Therefore, the Company is required to ensure that the Project is in compliance with the requirement for the presence of fire extinguishers in the vicinity of the fuel pumps, as required under the National Fire Code.   

Due date: 2020-11-06

Date closed: 2020-11-06
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 6 - Information Request 1 - Waste Management

Discipline: Environmental Protection

Categories:

Facility:

Observations:

At the yard leased by the contractor, Inspectors examined waste containers.  
There was a bin for metals, which was seen to only contain metallic wastes.  
There was a bin for general wastes, which was not examined closely.  
On the ground between the two large bins was a drip tray which contained several garbage bags, said to contain contaminated soil from spills that occurred during clearing.   There was no moisture in the drip trays, nor was there any evidence of staining on the ground around.  Company representatives were unable to state how long the contaminated materials had been sitting in the bin, if any precipitation had collected in the bins, and how any collected liquids had been disposed of.  
  

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

In order to assess appropriate handling and disposal of contaminated materials, MIPL is required to provide the following: 

  1. spill reports for the materials being stored as spill clean-up materials / contaminated soil at the time of the inspection;
  2. confirmation of the appropriate disposal of the contaminated materials; and
  3. confirmation of the arrival of designated bins for the disposal of contaminated soil materials.  


 

Due date: 2020-12-14

Date closed: 2020-12-16
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.

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