Compliance Verification Activity Report: CV2223-155 - Trans-Northern Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2463
• Inspector In Training 3042T

Regulated company: Trans-Northern Pipelines Inc.

Operating company: Trans-Northern Pipelines Inc. (TNPI or Company)

Province(s) / Territory(s):

• Ontario
• Quebec

Discipline(s):

• Environmental Protection
• Damage Prevention
• Safety Management
• Standard Condition

Related events:

• CV1920-221
• CV2021-270
• CV2122-164
• CV2324-152
• CV2425-189

Rationale and scope:

The purpose of these inspections is to verify compliance with the Canadian Energy Regulator Act, the Canadian Energy Regulator Onshore Pipeline Regulations, CSA Z662, and any other relevant plans, manuals, and procedures.

The primary focus area of these inspections will be the Environmental Protection Program, its implementation at facility operations, as well as operations & maintenance activities (O&M Activities), primarily integrity dig sites and reclamation of those sites.

The scope of these inspections will include, but may not be limited, to pre-disturbance planning for O&M Activities, surface water management at facility sites, deactivated facilities, and follow-up to previous CVAs having occurred in 2019, 2020 and 2021, as well as the general state of regulated facilities.   

 

Compliance tool(s) used:

• None

Facility details

Facilities:

• Saint Clet Transition
• FARRAN'S POINT STATION
• Mainline
• PRESCOTT STATION
• BELLEVILLE STATION
• DESERONTO STATION
• MIRABEL AIRPORT TERMINAL
• STE-ROSE JUNCTION

Facility Types

• Pipeline
• Electrical facility
• Meter station
• Pipeline
• Pipeline right of way (ROW)
• Pump station
• Terminal
• Valve site

Life-cycle Phases

• Deactivated
• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Occupational Health and Safety Regulations (COHSR) 2021-07-01
• Canada Labour Code (CLC) 2021-12-29
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Canadian Energy Regulator Pipeline Damage Prevention Regulations – Authorizations
• Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies
• Plans And Procedures
• Standard Operating Procedure or Plan (SOP)
• Environmental Protection Program Manual
• Project-specific Environmental Protection Plan (EPP)
• Site Specific Environmental Protection Plan for MP114.70
• Project-specific plan or procedure
• Site Specific Environmental Protection Plan for MP113.22
• Project-specific plan or procedure
• Pre Disturbance Environmental Screening Checklist - MP114.82
• Project-specific plan or procedure
• Pre Disturbance Environmental Screening Checklist - MP113.22
• Project-specific plan or procedure
• Pre Disturbance Environmental Screening Checklist - MP113.36
• Project-specific plan or procedure
• Potable Water Maintenance Monitoring and Sampling Procedure
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems
• CSA Z246.2 - Emergency Preparedness and Response for Petroleum and Natural Gas Industry Systems

Observations (no outstanding follow-up required)

Observation 1 - Stations - General - Environment

Date & time of visit: 2022-09-07 08:00

Discipline: Environmental Protection

Categories:

• Surface Water Management
• Containment and Drainage Structures
• Surface Water Management Plan
• Water Bodies - Non-Fish-bearing
• Chemical Spills/Releases
• Vegetation
• Vegetation Control
• Invasive Plant Management
• Groundwater
• Monitoring and Testing
• Housekeeping
• Waste Management

Facility:

• Saint Clet Transition (Facility)

Observations:

CER Officer inspected several stations on TNPIs System, including the:
Saint Clet Transition
Farran's Point Station
Prescott Junction
Belleville Meter Station
Deseronto Pump Station
Ste Rose Junction

The main themes of observations are summarized below, grouped by subject.

Surface Water Management and Containment Systems (swales, berms, sumps, oil water separators)

• TNPI Representatives demonstrated awareness of TNPI’s procedures for discharge sampling and permitting requirements both in Quebec and Ontario.
• Spill containment systems were inspected at all stations visited. In general, CER Officer observed concrete berms in a maintained state, in that cracks (when present) had been filled.
• New secondary containment system in place at Belleville Pump Station. Liners within the bermed area and drainage/sloped systems designed to direct surface water and potential releases into the oil/water separator was also generally observed in well-maintained condition.
• Pump buildings having floor drainage present, was confirmed by TNPI Representatives to be directed towards the oil/water separators with the exception of the Farrans Point Station.
• Farrans Point Station did not have floor drainage present at its pump building or a secondary containment measure for that building. CER Officer is of the understanding that this is one of the remaining buildings from the initial construction of the TNPI system facilities (ca. 1950s). This pump building is within the catchment area for the surface run off separation system but the berm ends at the pump house building so full containment within the building has not been achieved. However, having reviewed the Surface Run Off Separation System Drawing and the Site Grading and Surface Runoff Separation System Details Drawing, the CER Officer is of the view that although secondary containment is not present within the pump building, a potential spill at that building would be sufficiently contained and prevented from migrating off-site to environmental receptors by the surface drainage control measures in place at the Station. 
• Discharge areas for oil/water separator systems observed were in appropriate locations (ditches) and no erosion concerns were noted.
• For Metering Stations, CER Officer observed facility piping for provers to be located within secondary containment consisting of liners within the bermed area and drainage/sloped systems designed to direct surface water, potential leaks and releases, into the oil/water separator.
• The above ground portion of sump tanks were observed during inspections of the stations and below ground portions discussed with TNPI Representatives. The TNPI representatives demonstrated a thorough knowledge of the testing (monitoring) and maintenance program in place for ensuring underground sump tanks are functional and are not leaking. 
• TNPI Representatives provided all the requested documents (e.g. permits, procedures) quickly and efficiently, no concerns noted.

• At Farrans Point Staton, Deseronto Station, Belleville Meter Station, Mirabel Meter Station and Ste Rose Junction, groundwater monitoring well(s) are present.
• Observed groundwater monitoring wells (when present) have appropriate caps and were locked/secured.
• At Deseronto Pump Station, damaged slotted PVC piping was observed sticking out of the ground that looked similar to a groundwater monitoring well screen. TNPI originally understood this to be a monitoring well attributed to the historical abandonment of a diesel supply line. Upon further investigation by TNPI's environmental consultant it was confirmed that it was actually debris that had been stuck into the ground and was not in fact a groundwater monitoring well and that there was no risk to the groundwater aquifer from surface infiltration.

• Storage and disposal of hazardous materials were observed at various facilities during the inspection. In general, hazardous chemicals were observed to be stored and disposed of appropriately across the sheds and yards inspected.
• Appropriate chemical storage cabinet in place at sample shack.
• Assemblies of pipes transferring hazardous substances, valves and pumps were colour-coded or labelled to identify product, and when appropriate the direction of flow identified.
• Spill kits present in storage containers at Farran's Point Station, Belleville Meter Station, and Deseronto Pump Station.
• Pump Stations inspected do not have barrel or hazardous materials storage areas. TNPI Representatives explained that hazardous materials are only kept and stored at specific facilities and that any hazardous materials and associated wastes are only brought to site when specific maintenance activities required.
• Storage areas and storage containers at Pump Stations inspected did not have stored hazardous materials.  

• Vegetation at stations adequately managed within gravelled yards, with no weedy vegetative growth identified.
• Stations also have an approximately 1m zone extending past the facility boundary fencing, observed to be maintained free of vegetation.

Compliance tool used: No compliance tool used

Observation 2 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail

This information has been redacted pursuant to Section 144(5) of the Canada Labour Code

Observation 3 - Mirabel Station

Date & time of visit: 2022-09-08 09:00

Discipline: Administrative

Categories:

• Regulatory Instrument
• Condition

Facility:

• MIRABEL AIRPORT TERMINAL (Facility)

Observations:

• Bilingual (French / English) facility signage present indicating the station name, address, operating company, number to call in case of an emergency, as well as pictograms for required personal protective equipment (PPE) to enter the site as well as other prohibitions.
• No trespassing signage present at facility boundaries.
• There is no power provided at the site.
• Manhole with cover present on oil/water separator.
• Pipeline identification markers present along RoW adjacent to the Station.
• No unmitigated potential hazards to the environment (eg infiltration of contaminants into the groundwater) and potential safety hazard (tripping hazards) for employees or those persons granted access to the site were identified.
• Observed groundwater monitoring wells at the site are adequately covered and secured.  
• Signs of vegetation management activities having occurred are evident for weedy species throughout the gravelled site.  
• Above ground decommissioned infrastructure has been removed in accordance with Exemption Order XO/XG- 100-2008 and generally, site is consistent with information and photographic evidence provided by TNPI to the CER Officer in response to IOO LMR 2021-001.   
• Cones and/or paint (hi-visibility orange) marks buried infrastructure protruding from the ground that could represent a tripping hazard.   
• No non-compliances to OPR paragraph 4(1)(d), CSA Z662 Clause 10 were identified.
• Sufficient perimeter protection measures, as well as external and internal corrosion controls for piping exposed to the atmosphere.
• Cathodic protection is in place for deactivated pipeline riser.

Compliance tool used: No compliance tool used

Observation 4 - Maintenance Activities

Date & time of visit: 2022-09-07 14:30

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Handling
• Soil Integrity
• Crowns/Subsidence
• Chemical Spills/Releases
• Restoration
• Surface Water Management
• Containment and Drainage Structures
• Water Bodies - Non-Fish-bearing
• Reclamation
• Vegetation
• Vegetation Reclamation
• Crop Productivity
• Housekeeping
• Temporary Structures
• Wildlife
• Habitat Restoration/Offsets

Facility:

• Mainline (Pipeline)

Observations:

Operations and Maintenance Activities (O&M)were observed at four locations, each at a different stage of the process. Before the inspection began, the CER Officer requested TNPI's O&M schedule to assist with planning, which TNPI Representatives provided as requested and required. 

The first O&M site inspected was a series of digs which had been completed in the last year with the site reclaimed to its pre-work conditions.

• This site was through a forested area.
• A rock pile was left at the site along the edge of Right-of-Way (RoW). TNPI Representatives stated this was left in place/rebuilt and confirmed it was a snake den.
• No subsidence or trench crowning on trench line.
• Pipeline identification signage present in appropriate strategic locations.  
• Vegetative growth (primarily grasses) with an estimated 80% + establishment rate.  The site clean-up completed with contours reestablished and returned to its pre-work conditions.

• Upon arrival TNPI Inspector reviewed with the CER Officer and inspection participants the Field Level Hazard Assessment (FLHA) and Safe Work Permit in place for ongoing activities.  
• Observed appropriate signage and personal protective equipment (PPE) being utilized by workers.
• Wooden matting was being installed to protect soil and enable equipment and vehicle access to dig locations.
• Muster points identified with signage and located near roadway entrance. Personnel portable sanitary facilities and medical kit present, and smoking area in place with appropriate signage.
• Snow fencing and signage around open hydrovac holes where pipeline was day-lighted.
• TNPI Inspector explained the three-person refuelling system within 100 m of a watercourse. 
• Survey and flagging have been completed.
• Access and temporary workspace (TWS) is flagged with pink ribbons and stakes.
• CER Officer requested the Site-Specific Environmental Protection Plan (EPP) and pre-dig inspection checklist. Both were produced and activities observed at the site were consistent with EPP requirements.
• The TNPI Inspector demonstrated familiarity with TNPI’s procedures for environmental monitoring and requirements and specifics of the applicable environmental protection measure and plans.

• Upon arrival TNPI Inspector reviewed with the CER Officer and inspection participants the FLHA and Safe work permit in place for ongoing activities.
• The dig was open during the inspection visit.
• Observed workers preparing supports for a pipe riser and valve. Cement truck and subsequent cement pour were scheduled to occur later in the day.
• Temporary fencing with t-post and end caps in place.
• Small generator, grounded, with secondary containment provided and nearby spill kit in place.    
• The TNPI Inspector noted that impacted soil was encountered during the dig and had been excavated for offsite disposal at an approved landfill. TNPI Representatives confirmed that soil exceedances remained in the wall of the excavation and that a NOC would be submitted to the CER as required.
• TNPI Inspector indicated that water seepage into the excavation was pumped into a frac tank and tested by TNPI's environmental consultant prior to discharge into the adjacent field. Applicable permits were noted. Discharge area located in adequately vegetated area and sediment bag was in place.
• Goal posts with flagging in place at site entrance from the roadway from limits of approach from overhead electrical hazard.

• The site was in an agricultural field (pastureland).
• Vegetation regrowth was equivalent to the surrounding lands and dig locations not apparent with similar vegetative regrow at dig location compared to off RoW conditions.
• No signs of crowning or subsidence over trench line.
• Pipeline identification signage present at road crossing.

• TNPI’s pre-screening procedures, Environmental Protection Plans (EPP) for O&M works, and also the Environmental Compliance Specialist’s oversight at O&M sites were discussed with TNPI Representatives.
• TNPI Representative exhibited awareness of TNPI’s requirements and processes, and sound technical awareness of the environmental issues that arise at O&M works.
• CER Officer notes that upon review of other site-specific EPPs for upcoming O&M digs, that the format, usability, and detailed mitigative measures show improvement from those previously reviewed in recent CER related compliance verification activities. 
• No concerns noted at the O&M sites inspected or in documented EPPs for upcoming digs.

Compliance tool used: No compliance tool used

Observation 5 - Pipeline Right-of-Way (RoW) - General

Date & time of visit: 2022-09-08 13:30

Discipline: Damage Prevention

Categories:

• RoW Maintenance
• Access
• Vegetation
• Damage Prevention Program
• Monitoring
• Pipeline Identification
• Signs
• Watercourses
• Railway and Road RoW
• Locate Markings
• Vehicle or Mobile Equipment Crossings
• Authorization and Consent
• Temporary Crossings
• Locates and Information
• Locate Requests
• Duty to Inform
• Ground Disturbance
• Authorization and Consent

Facility:

• Mainline (Pipeline)

Observations:

Work in Prescribed Area

• 3^rd Party (Municipal contractor) work ongoing near pipeline within a prescribed area.  
• CER Officer discussed ongoing activities with the crew Foreman. 3^rd Party Foreman provided for CER Officer's review a copy of the Prescribed/Controlled Area Agreement issued by TNPI.
• Pipeline location in the area flagged, marked and staked.
• 3^rd Party Foreman demonstrated an understanding of equipment allowed, restrictions on activities, as well as the prohibition of crossing the pipeline with equipment.
• Work spaces delineated and restricted with construction cones and flagging.
• Pipeline identification signage present along RoW located in residential yards west of 3^rd Party activities, and in the adjacent municipal parkland.

• Vaulted block valve site located in parkland on the western side of the watercourse crossing. Vault secured with appropriate signage in place.
• TNPI Representatives stated it was a non navigable watercourse.
• Pipeline identification signage present on both sides of the watercourse.
• Recent vegetation management activities (brushing) had occurred at the western shore/slope of the watercourse. Woody species completely removed over trench line and larger woody species (trees) removed on RoW at shoreline. Willow and other shrubby vegetation remain as appropriate. 
• Parkland on the west side of the river, residential on the east side of river.
• TNPI Representatives confirmed they have pipeline depth of cover information from recent assessments.
• No concerns noted.

• Forest on west side of river, residential on the east side of the river.
• TNPI indicated they have pipeline depth of cover information from a recently completed assessment.
• Navigable watercourse signage indicating anchoring and dredging prohibited « ancrage et dragage interdit » in place on both shores of river. TNPI representatives indicated that although the watercourse is not a listed commercially navigable watercourse that the high frequency of recreational boating in the area warranted additional hazard identification and signage as a mitigative measure.
• Signage is in French only.
• RoW is overgrown with trees. TNPI demonstrated that as part of their surveillance and monitoring program that vegetation management activities are planned for the coming year.

Compliance tool used: No compliance tool used

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: