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:
This inspection was undertaken to oversee Trans Mountain's response to an incident that occurred during watercourse crossing construction at the Coquihalla River for both the Trans Mountain Expansion Project as well as a replacement of the existing Line 1 crossing (Order XO-006-2020). High flow overwhelmed the isolation, resulting in flooding of the right-of-way to the south of the river.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - General Observations
Date & time of visit: 2021-09-19 13:00
Discipline: Environmental Protection
Categories:
Facility:
Observations:
Members of the Inspection Team arrived onsite the day following the flood. Upon arrival, the water extended approximately 150 m at down the south end of the right-of-way (RoW). Several pieces of equipment were partially submerged, including three generators and a light tower. Company Representatives indicated that smaller pieces (e.g., hoses, pumps) were also submerged and that a fuel tank had been recovered downstream the previous day.Response efforts at that time were focused on cleaning up diesel that had entered the water. Personnel working in or near water were wearing personnel floatation devices and swift rescue personnel were on-site.When the Inspection Team arrived the following day clean-up work was ongoing and additional personnel had arrived on site. The generators were removed from the water using an excavator and ground-based access. The light tower was removed by a heavy lift helicopter.Water levels had visibly receded when the Inspection Team arrived the third day. Crews were working to clean up and restore the site as well as developing plans to complete the installation of the watercourse crossing.
Compliance tool used: No compliance tool used
Observation 2 - Document Review
Date & time of visit: 2021-09-20 10:00
Trans Mountain provided several documents, including permits, the site-specific watercourse crossing execution plan, and response plans. These documents were reviewed by the Inspection Officer.
Observation 3 - Information Request (IR) No. 1 - Traditional Land Use (TLU) Site
Discipline: Socio-Economic
An excavator was used to remove the generators from the flooded right-of-way. Company Representatives indicated that landowner permission was obtained for the off-RoW activity. During the removal of the generators, the excavator was positioned within approximately 3 m of a sign indicating the presence of a Traditional Land Use (TLU) site. Discussions with Company Representatives indicated that the TLU site was a trail. The Resource-Specific Management Table (RSMT) outlines points where the trail intersects with the Project Footprint. As the excavator was positioned on private land (i.e., off Footprint), the details of the TLU site in that area are unclear based on the RSMT. Based on observations and discussions in the field, it is unclear whether the TLU site was delineated or otherwise considered prior to positioning of the excavator. In addition, although a Trans Mountain Indigenous Monitor (IM) was at this work location earlier that day, the IM was not observed during work in proximity to the TLU site. Additional information is required to verify compliance.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
Due date: 2021-09-27
Date closed: 2021-10-29 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
Observation 4 - Corrected Non-Compliance - Use of Absorbent Booms
Date & time of visit: 2021-09-19 14:00
Absorption booms were observed in several (~4-5) locations around the RoW in areas where a diesel sheen was observed on the water.In some areas, the booms were connected together end to end, leaving a gap through which spilled product could flow. In other areas they were installed correctly, with overlapping ends.The installation was corrected while the inspection team was in the field.
Compliance tool used: Corrected Non-compliance (CNC)
Re-install absorbent booms correctly at locations observed by the inspection officer.
Due date: 2021-09-19
Observation 5 - IR No. 2 - Spill Response
As outlined in CNC No. 1, absorption booms were incorrectly deployed in some areas in response to the spilled diesel. The Environmental Protection Plan (EPP) includes the following information in the Spill Contingency Plan:
The Emergency Response Plan (ERP) includes the following information about spill response
The ERP states, in Section 4.4, training requirements "during orientation, KBTP will provide workers with training in internal and external reporting protocols and and the general emergency response procedures to be followed in the event of an emergency" The Inspection Officer was unable to find information in either document detailing procedures or methods for correct deployment of absorbent booms.
1. Provide the spill report(s) generated from this incident. If not already included, also provide a list of notifications (internal and external), including time/date of notification and who (by title) was notified. 2. Provide the orientation slides use to train workers in the general emergency response procedures (ERP Section 4.4). 3. Provide the KBTP Environmental Management Plan (ERP Section 8.4). 4. Provide a discussion and if appropriate supporting documentation, outlining any other emergency response training provided to workers, particularly as relates to a spill into a waterbody. 5. Given that both the ERP and EPP appear to contain general information and cross-reference one another, explain where/how workers can easily (i.e., in a timely manner) obtain detailed spill response information.
Due date: 2021-12-03
Date closed: 2022-02-03 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.
Observation 6 - IM Observation
Date & time of visit: 2021-09-20 12:00
Discipline: Indigenous Monitoring
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.
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
