Compliance Verification Activity Report: CV2223-183 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2194
• Inspector In Training T

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Environmental Protection
• Indigenous Monitoring

Related events:

• CV1819-472

Rationale and scope:

Field inspection of the NGTL North Montney Construction Project: Aitken Creek and Kahta Sections reclamation. Construction of the Project was initiated in August 2018, with final clean-up finishing in April 2021. Post-construction monitoring was initiated in 2021 in the first full growing season following final clean-up. The North Montney Mainline, Aitken Creek Section and Kahta Section includes approximately 206 kilometres (km) of 1,067 millimetre (mm) outside diameter (OD) (NPS 42 inch) pipeline. Tree planting occurred in summer 2021 and seed collection in fall 2021. Native shrub planting was completed in 2022 and the first year PCMR was filed Jan 2022. The focus of the inspection included: vegetation growth, surface water drainage, erosion, access control, line of sight effectiveness, and watercourse reclamation.
 

Compliance tool(s) used:

• None

Facility details

Facilities:

• NORTH MONTNEY MAINLINE (NPS 42 2017) AITKEN CREEK SECTION
• NORTH MONTNEY MAINLINE (NPS 42 2017) KAHTA SECTION

Facility Types

• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Post-Construction (Reclamation)

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
• Plans And Procedures
• Project-specific Environmental Protection Plan (EPP)
• Environmental Protection Plan For The Proposed North Montney Project
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• GC-125

Information Request

IR from CER (Information Request sent from CER to company)
IR#1 Erosion Control Measures

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

Applicable Wording from Legislative Document
Page 89. The Company will record locations of concerns identified during construction related to weeds, vegetation establishment, general right-of-way conditions, water crossing stability, and reclamation success. This issues list will be used to measure success of mitigation measures used during construction of the Project, and to ensure outstanding issues are investigated, resolved and reported during the PCMP for the Project.

Theme and Categories

Due Date : 2022-10-21

Review Response
Acceptable

Follow-up Action
None

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2022-09-01 08:00

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Crowns/Subsidence
• Restoration
• Water Bodies - Non-Fish-bearing
• Sedimentation/Turbidity
• Reclamation
• Water Bodies - Fish-bearing
• Sedimentation/Turbidity
• Reclamation
• Erosion
• Wildlife
• Access Control/Lines of Sight
• Habitat Restoration/Offsets
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation
• Access Control

Facility:

• NORTH MONTNEY MAINLINE (NPS 42 2017) AITKEN CREEK SECTION (Pipeline)

Observations:

Aitken Creek and Kahta Sections

• Rollback along the RoW appeared to be as per the specifications in the Access Management Plan.
• Erosion control blankets and diversion berms observed on moderate and steep slopes seemed to be functioning well. Some were lined with rip rap to divert or slow surface water.
• Cattle observed between KP 61 and 72 were causing some issues with reclamation including pugging and damage or removal of pipeline markers. NGTL representatives said they monitor this area and continuously make repairs throughout the year.
• Vegetation growth was evident for most of the Right-of-Way (RoW) observed but various areas were lacking cover and may take additional time for vegetation establishment. NGTL representatives stated that these soil conditions were most likely caused by shade trees and the areas would be monitored with future additional measures if required.
• Some weeds were observed during the inspection and NGTL representatives stated that there are some dense patches along the RoW. This year mechanical removal methods were used in the spring and summer with some hand picking and bagging. NGTL representatives stated they are anticipating the permit for chemical application possibly this fall. They also indicated that weeds on the project will continue to be monitored and infested areas will be documented.
• Pooling and drainage issues were not observed but some large gullies were seen throughout the project RoW. These areas were documented in the first Post-construction Monitoring Report and NGTL representatives indicated they will be repaired or continued to be monitored.  
• Project related garbage or construction debris was not observed along the RoW.
• Timing of sediment fence removal along the RoW was discussed with NGTL representatives. They stated assessments are completed in early spring and if the rootmass is sufficient with no recent sedimentation they get scheduled to be removed. All sediment fence locations have been documented.
• Pipeline identification signage was observed at all road crossings and watercourse crossings.
• Kahta section appeared to have more sparsely vegetated areas and gully erosion than Aitken Creek section. Crowning in some areas was observed. NGTL representatives indicated that some repairs were completed last year including adding rip rap to line gullies. Additional documented deficiencies will either be repaired or monitored. 

• Multiple line-of-sight structures were constructed along the width of the RoW.
• Rollback and mounding on access were observed as required in the Access Management Plan.
• Erosion control measures were installed including diversion berms with rip rap to manage surface run-off.
• NGTL representatives stated the Indigenous communities were given aerial and ground tours and had no concerns with reclamation at the time.
• NGTL representatives stated tree planting at access locations, line-of-sight areas, and riparian zones were completed in June 2021. Additional planting will be done by the end of this year. They also stated Indigenous communities were consulted on plant species and location of planting.

• Rollback was observed at access locations and vegetation growth appeared to be well established in the wetland and surrounding area.
• NGTL representatives said the dunes were bored at this location and all dunes except for one were only cleared for equipment access. In between the dunes it appeared the working side of the RoW was matted leaving the root mass intact.
• The RoW was narrowed during construction as per the Old Growth Management Area requirements and NGTL representatives indicated all the planting was completed in this area.

• There were 3 sections on Spread 3 that final clean-up was delayed due to saturated soil (KP 156+900 to 156+600, KP159+000 to KP159+675 and KP 161+200 to KP 162+900). NGTL representatives said final clean up and reclamation would likely be completed by the end of November 2022.
• At KP 159+000 to KP 159+600 soil had previously travelled off RoW for approximately 20m from heavy rain in the area. Crews retrieved most of the soil back onto the RoW and the area was seeded.
• Multiple diversion berms were installed, and sediment blanket covered the entire area.
• The entire area was seeded, and rollback was spread across the RoW in one section.
• NGTL representatives said they would monitor the reclaimed areas and add additional if necessary.

Compliance tool used: No compliance tool used

Observation 2 - Watercourses and Wetlands

Date & time of visit: 2022-09-01 08:00

Discipline: Environmental Protection

Categories:

• Water Bodies - Non-Fish-bearing
• Sedimentation/Turbidity
• Reclamation
• Erosion
• Water Bodies - Fish-bearing
• Sedimentation/Turbidity
• Reclamation
• Erosion

Facility:

• NORTH MONTNEY MAINLINE (NPS 42 2017) AITKEN CREEK SECTION (Pipeline)

Observations:

The following watercourse crossings were visited during the inspection:
-Moberly River KP 31+300
-Tributary to Mackie Creek KP 84+400
-Groundbirch Creek KP 104+550
-Tributary to Groundbirch Creek KP 104+250
- Tributary to Groundbirch Creek KP 105+616
-Kobes Creek KP 111+800
-Cameron River KP 133+100
-Townsend Creek KP 149+854
-Blueberry River KP 174+242
-Tributary to Blueberry River KP 173+850

• All watercourse riparian areas were stable with vegetated banks or rip rap and erosion control blanket.
• Some watercourse crossings had riparian willow staking and instream boulders as specified in the reclamation plans.
• Erosion control measures were in place where required including straw wattles, diversion berms and sediment fences. Sedimentation in the watercourses was not observed.
• Most banks contained coir wrap and revetment posts that were stable and functioning. Overall riparian vegetation growth was well established but, in some cases, desired target species were not present.
• At Moberly River (KP 31+300) and Groundbirch Creek (KP 104+550) the side cut grade was unable to be put back to the original contours which has caused a significant amount of sloughing and erosion. Water seepage is also causing instability and the slopes at both locations will require additional measures to stabilize the area. NGTL representatives stated there is more vegetation on the slopes this year than last but will still require some additional measures including seeding and willow staking (See IR #1). Groundbirch Creek also has sediment accumulation almost to the top of the diversion berm and will need to be cleaned out. Rip rap was spread on the slope which has assisted to slow down the flow of water and filter out sediment. Sediment was not observed entering either of the watercourses.
• Wetlands observed from the helicopter appeared to be well vegetated.

• Tributary to Groundbirch Creek at KP 104+250 contained sandbags in the channel to divert the water but are not currently functioning.  NGTL representatives stated they would be removed. ATV tracks were also observed through the watercourse causing some rutting. NGTL representatives stated the tracks were not project related and staff is directed to not cross if the ground is soft or if it will cause destruction to the environment.
• Groundbirch Creek at KP 104+550 was missing willow staking on the northside as required in the reclamation plans. NGTL representatives stated they would be installed.

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: