Compliance Verification Activity Report: CV2223-125 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2223-125
Start date: 2022-11-28
End date: 2022-12-02

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company:

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

TMX Spread 3/4A - Assess field implementation of the environmental protection plan and association resource specific plans for ongoing construction activities; verify mitigation measures at watercourse crossings, specifically adequacy of erosion and sediment control measures.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Information Request

IR from CER (Information Request sent from CER to company)
IR No. 1 – Watercourse Crossing Checklist

Legislative Requirement : Project-specific Environmental Protection Plan (EPP)

Applicable Wording from Legislative Document
2. Ensure completion by the Contractor of the on-site checklist for pipeline and vehicle crossings provided in Appendix D for each classified watercourse and wetland prior to, during and following construction. These checklists will be approved by a QAES/QEP. Retain these checklists as a permanent record of pipeline watercourse and wetland crossing installation

Theme and Categories

Environmental Protection
  • Water Bodies - Fish-bearing
    • Direct Mortality of Fish
    • Sedimentation/Turbidity

Due Date : 2023-01-13

Review Response
Acceptable

Follow-up Action
None

Observations (no outstanding follow-up required)

Observation 1 - General Construction Observations

Date & time of visit: 2022-11-29 11:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

General observations:


 

Compliance tool used: No compliance tool used

Observation 2 - Watercourse Crossings

Date & time of visit: 2022-11-29 11:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

BC-275 Mad River Crossing KP 678+830


BC-249 Sagar Creek Crossing KP 659+810
BC-201 Finn Creek Crossing KP 633+900
BC-286 Montanna Creek Crossing KP 687+300
BC-248 Unnamed Channel KP 658+60

Compliance tool used: No compliance tool used

Observation 3 - CNC1- Failure to use provided washroom facilities

Date & time of visit: 2022-12-01 11:30

Discipline: Safety Management

Categories:

Facility:

Observations:

At KP686+600 IAMC IM observed a contractor not using the toilet and instead urinating in the snow behind the portable toilet, and brought this to attention of CER IO. CER IO confirmed the non-compliance which was brought to the attention of company representatives. Trans Mountain issued a bulletin the next morning to remind crews of the requirement to use washroom facilities. 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Explain how Trans Mountain will prevent reoccurrence of this matter, and provide documentation that this has been completed.


 

Due date: 2022-12-02

Date closed: 2022-12-02
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 4 - CNC2 - Missing Drip Catcher on Fuel Nozzle

Date & time of visit: 2022-11-29 11:22

Discipline: Environmental Protection

Categories:

Facility:

Observations:

CER IO inspected contractor truck #131042 and observed Diesel slip tank nozzle not installed within drip catcher receptacle. Trans Mountain personnel rectified the issue to the satisfaction of the IO and replaced nozzle in an appropriate manner.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

CER IO brought the non-compliance to the attention of company representatives, and required the matter be rectified with an appropriate drip catching receptacle, and requested photographic evidence of completion.

Due date: 2022-11-29

Date closed: 2022-11-29
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