Compliance Verification Activity Report: CV2223-185 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2659

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Environmental Protection
• Indigenous Monitoring

Rationale and scope:

Groundbirch Mainline Loop Sunrise Section. NGTL anticipates mainline construction to commence in Q2/Q3 of 2022 in order to meet the April 2023 in-service date. This project was previously delayed with the latest update filed as C13197.

Compliance tool(s) used:

• None

Facility details

Facilities:

• GROUNDBIRCH MAINLINE LOOP (SUNRISE SECTION)

Facility Types

• Pipeline
• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16

Regulatory instrument number(s):

• XG-029-2019

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2022-12-06 10:00

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Soil Handling
• Housekeeping
• Waste Management

Facility:

• GROUNDBIRCH MAINLINE LOOP (SUNRISE SECTION) (Pipeline)

Observations:

Construction Yard and Warehouse

• NGTL requirement for secondary containment in the yard is that all hazardous chemicals are stored in secondary containment.  There is no requirement for non-hazardous chemicals to be stored in secondary containment in the yard.
• Secondary containment structures were emptied of snow
• NGTL representative stated that warehouse staff visually checked secondary containment daily, and recorded any that needed to be emptied of snow or water.
• The yard was not constructed by NGTL and the pre-existing yard is ditched on four sides with a discharge area.

• Piles of topsoil, subsoil and transition soil were stored separately, staked and marked 
• Small pile of soil containing weeds was placed separately from the other piles outside of wetland boundary.
• NGTL pointed out that topsoil was salvaged and stored separately where listed weed infestations are found. NGTL representative showed the IMs and the CER inspectors this mitigation onsite.
• Silt fencing in place to stop run off from the temporary work space
• Under snow, bridge was constructed using layers of geotech fabric, matting, geotech fabric and clay.  
• Stripping was minimized in this section to over trenchline

• Watercourse Crossing WC-1 (Coulee Creek)
• Spill barrels placed on both sides of creek.  One barrel was checked for contents.  Contents appeared to be in good condition.  An inventory list of contents could not be located.  NGTL representative states that spill kits barrels would be checked and inventory lists added to ones that were missing lists.
• Geotech over plywood sides were at least 30cm on the bridge crossing.
• Silt fencing was observed to be in good condition
• Riparian area was marked on all sides.  RoW was stripped and graded within riparian area to prevent sloughing of soil from the area between the bridge and the ditch
• A berm was constructed at the top of the stripped area and the land was graded away from the watercourse
• NGTL representative stated that there was no running water in the creek at the time of construction
• Three beaver dams are located in close proximity to the bridge crossing in Coulee Creek.  The dams are being left in place and will not be disturbed during construction activities
• Signage was observed on both sides of the watercourse crossing

• Geotech on the piles of topsoil were observed.  NGTL stated that geotech is placed over topsoil piles when the piles are located next to the boundary of the RoW to prevent soil run off into the area off the project footprint. 
• Gaps in windrows for wildlife were observed.  Evidence of wildlife tracks using the windrows was observed.
• NGTL representative stated that wildlife gaps are not left in pipe that is already welded in order to minimize the time needed for ditching and, overall construction time, to lessen the disturbance to wildlife from construction disturbances.  This applies in agricultural land with fencing on both sides.

• Snow fencing was placed around rare ecological community (REC-42) to reinforce the boundary for no disturbance

• Observed trenching activity using ditch wheel.  Ditch wheel is used in flat terrain as it is faster than excavation and produces a finer soil suitable for backfilling.

• Rare plant (RP-02) was observed to be marked and staked
• Temporary work space was constructed in WET25.  Topsoil from wetland was stored in the temporary work space with no silt fencing to prevent runoff into the wetland. NGTL representative stated that silt fencing is constructed based on the need to prevent run off and the workspace was graded to direct runoff away from the wetland, preventing heavy run off into the wetland. (See IR #1)
• A snow ramp was constructed for crossing over WET25.

• Yard appeared to be well organized and clean.
• The HDD yards are lined with an impermeable barrier, although the EPP does not specify the yard must be lined.
• Drilling mud additives are not stored in secondary containment as they are not considered hazardous materials
• Archeology site (GkRe-12) mitigation was observed, with the area staked,marked and surrounded by snow fence.
• NGTL confirmed that HDD  yard personnel conduct an inspection for drilling mud release every 2 hours during daytime and as needed, during the night hours.

• Section of pullback pipe was observed on the side of the RoW prior to entry into the HDD  yard.  Pipe was being prepared for hydrotesting.
• The site of the November frac outs were observed, outside the perimeter, but in close proximity, to the HDD yard.  
• Culverts have been installed to enable vacuuming out the released mud before the majority of it reaches the surface
• A lined horseshoe structure was installed to capture mud that was released to the environment to prevent run off down the slope to the river
• NGTL noted that frac out cleanup was completed but mitigation measures remained in place in case further surface release occurred during the HDD, and a site assessment will be completed to determine if any further cleanup is required
• The contents of the  emergency response trailer next to the HDD yard were observed to be clean and organized such that they could be accessed in a timely manner.

• Location of watercourse crossing (WC-3).
• Reclamation activities initiated at this watercourse prior to ground freeze up.
• Watercourse banks were staked and wrapped with coir matting. NGTL representatives stated coir matting was also placed on the banks under the snow and the area was seeded.  Small willows were observed to have been planted
• Gradual roaching was observed over the pipe path.
• NGTL representatives informed IOs that the watercourse was slightly widened in areas to prevent bend scour as the banks were becoming undercut prior to reclamation activities.

Compliance tool used: No compliance tool used

Observation 2 - Indigenous Monitor Observations

Date & time of visit: 2022-12-06 09:00

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Handling

Facility:

Observations:

INTRODUCTION

The week of December 5th 2022 , the Canadian Energy Regulator (CER) conducted a Environmental Inspection Compliance Verification Activity (CVA) on the NGTL Groundbirch Section. The emphasis of the inspections scope is the proponent’s construction activities and environmental compliance activities.

Safety program requirements, other issues of non-compliance related to other program
requirements will be appropriately addressed.

2.0 OBSERVATIONS

2.1 Construction Safety Practices and Safety Plans

Orientation at Surerus Murphy Joint Venture (SMJV) construction yard for introduction and to discuss daily activities happening on the Right of Way (ROW). Project footprint is 95% free hold and 5% on crown land.

Inspection of SMJV yard and warehouse, where the solar farm sea can was set up. This solar farm supplies the mobile warehouse with most of its power using a back up generator if needed. Great idea for reducing greenhouse gas and emissions on a project. No deficiencies to report in yard.

Travel to kick off point to start main line environment audit. We walked around laydown area of the ROW and found two deficiencies. First was a pipe end cap off ROW. Project owner retrieved and placed in truck for disposal. The second deficiency was that noxious weeds were not stored in an isolated area. CER lead indicated that the EPP should be referenced.

2.2 Wetlands and Water

Travelled ROW to water course one (WC-1) where the construction company installed a clear span bridge over water crossing. The construction crew did an amazing job on this bridge installation.

Stopped at the exit side of the HDD drill site to observe the Frac out just off the HDD drill pad. Site was setup with mitigation measures to protect if frac out happens again. Approximately 35,000 liters of drill mud was recovered, set to a disposal facility. Berms and
poly remain on the field as frac out clean up is incomplete.

Travelled water course three (WC-3) where the construction company performed open trench and reclamation on water course. A member of the project owner explained the reclamation process and how the riparian was contoured further away from the water course
for spring run off.

2.4 Vegetation and Soil

Continuing down the ROW we stopped to observe the blue listed shrub isolated for safe keeping. This shrub is a rare willow plant.

2.6 Traditional Knowledge/Traditional Land Use

This section of the project has archeological areas and one traditional land use site identified but is approx. 85m off the ROW and is only in the Environmental Protection Plan (EPP) in case a temporary workspace is needed.

3.0 NON-COMPLIANCES/COMPANY FOLLOW-UP REQUIRED

No non-compliance issues.

4.0 SUMMARY

Close out meeting. CER auditor opened meeting with how well the project looked and there were only a few topics to discuss. Two positive highlights were expressed during the meeting.

An information request was issued for the definition of the word “separation” in the EPP. A question was then asked about the timeline for burying pipe. This due to the lengthy stretches of welded pipe which do not have wildlife breaks in it nor do they conjoin with the animal breaks in the berm. The CER auditor stated there is a good case for returning during reclamation and when snow is gone to evaluate the Frac out at HDD drill site. The owner and audit team determined that the EPP is a cut and paste document and really needs to be more specific to the demographic area.

The owner did suggest we get a copy of the construction companies SITE SPECIFIC ENVIRONMENT PLAN for future reference. Cultural and archeology site criteria need to be more specific to each topic as well. Both owner and contractor have a nice, clean, and well-maintained project and was a delight to see. Wildlife has maintained its footprint on the project and remains in the area.







 

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: