Compliance Verification Activity Report: CV2223-133 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2194

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

• Alberta
• British Columbia

Discipline(s):

• Environmental Protection
• Indigenous Monitoring

Related events:

• CV1819-436
• CV1920-158

Rationale and scope:

An environmental inspection was conducted to assess reclamation work of the O&M reactivation section in Jasper National Park and Mount Robson Provincial Park. Focus was on measures at the major watercourse crossing replacements as well as nearby dig sites. Also assessed work on the installation of the fibre optics line through the park.

Compliance tool(s) used:

• None

Facility details

Facilities:

• TMX Anchor Loop
• TRANS MOUNTAIN EXPANSION PROJECT

Facility Types

• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Construction
• Operations
• 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 plan or procedure
• Environmental Protection Plan for the Trans Mountain Pipeline ULC GAPS Connection Project May 2022
• Project-specific plan or procedure
• Environmental Plans Volume 6 Reactivation Environmental Protection Plan for the Trans Mountain Pipeline ULC January 2021
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• OC-065
• OC-2

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2022-09-21 08:00

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Reclamation

Facility:

• TMX Anchor Loop (Pipeline)

Observations:

Trans Mountain representatives stated:

• Supplemental plantings were completed in riparian and upland areas after construction.
• All supplemented plants were grown in greenhouses from seeds collected in Jasper National Park.
• All access roads were matted for construction.
• The Chetamon Wildfire in Jasper National Park caused access restrictions and burned much of the planting completed along the RoW in the spring of 2022. Plans to replant this area will be completed in the future.
• Post-construction Environmental Monitoring Program will begin the year following the completion of all reclamation activities. The program will continue for the third and fifth year with a continuation past that date if required. The monitoring program will include documenting final reclamation, recovery of disturbed areas, and the success or re-establishing equivalent land capability. If issues are identified remedial work will be conducted where required.
• Most of the work site for the pipe replacement areas involve disturbing the previously reclaimed landscape of the TMX Line 1 RoW.
• There are 6 remaining dig sites left to be completed due to nesting birds and associated mitigation measures.
• Site specific seed mixes were developed by Jasper National Park personnel for reclamation and are used within the construction footprint.

Compliance tool used: No compliance tool used

Observation 2 - Watercourses

Date & time of visit: 2022-09-21 08:00

Discipline: Environmental Protection

Categories:

• Water Bodies - Fish-bearing
• Reclamation

Facility:

Observations:

Minaga Creek KP 389.00

• Pipe replacement was completed at this watercourse in March 2022.
• A temporary bridge remains over Miette River for access during hydrostatic testing.
• Various species were planted and course woody debris was observed along the RoW.
• The riparian area was well vegetated with planted birch stakes.
• Trans Mountain representatives stated:
  • Low growing plant species were selected to be planted over the pipe and a variety of tree species were planted outside of the 5 meter pipeline buffer. Vegetation selected created a variety of species growing in the area.
  • Weeds were given a pre-disturbance treatment and maintained after construction by spot treating (outside of riparian buffer) and hand picking.
  • The RoW was matted up to the watercourse leaving the root system in place to minimize disturbance.
  • The deciduous rootballs were successful but the coniferous were not at this location.

• This crossing was completed in March 2021 and parallels the 36” pipeline.
• The riparian area had minimal regrowth and most of the staking was unsuccessful. The rip rap lined the watercourse bed and banks and extended well into the riparian area. (See IR #1).
• Trans Mountain representatives stated:
  • The riparian area was seeded but there wasn’t much for staking or rootballs to salvage.
  • British Columbia has restrictions on collecting seeds and require approval from Mount Robson Provincial Park. Seeds were collected within proximity of the area.

• The valve site was located on the northside, and access is still in place.
• River rock and cobble was observed covering the pipe causing shallow water depths.
• The riparian area was lined with erosion control blanket and shrub staking.
• Trans Mountain representatives stated:
  • The pipe at this crossing was not replaced and only required additional cover allowing for minimal disturbance.
  • Access to the site was matted during construction and matting has been removed.
  • Planting at this location has not yet been completed but is planned in the near future.
  • Sediment fence on the north side is documented in the issues tracking list to be removed.
  • The disturbed riparian area was seeded with a native grass seed mix collected within the park.
  • Shrub staking has about a 50% success rate and they try to match vegetation species and densities off RoW.

• The side channel of the creek was dry at the time of inspection.
• A diversion berm was constructed in the riparian area to prevent sediment laden water from flowing directly into the watercourse.
• Rollback and course woody debris was observed along the RoW.
• Rip rap was placed on the bank and riparian area with some large boulders.
• Salvaged rootballs were observed within the riparian area with low transplant success.
• Trans Mountain representatives stated:

• This area floods during spring freshette and has high flows during the summer months.
• Pipe replacement was completed at the end of 2021.
• Riparian area was planted with a variety of shrub species and seeded with native seed.

• Various plantings were observed along the RoW and riparian area including deciduous and coniferous trees as well as a variety of shrubs.
• Shrub stakes were planted in the coir wrapped soil.
• On the southside of the river the water withdrawl site, side channel and test point valve location were observed. Final reclamation has not occurred on that side because the workers will still need to access the area for hydrostatic testing.
• Sleeve 5A and 6 were also observed at two unnamed watercourses at approximately KP360. The vegetation in the area is well established and the willow staking in this area was successful.
• Trans Mountain representatives stated:
  • Pipe replacement was conducted 2 years ago, and this crossing was the first site to be completed.
  • Access is limited to the area from the nearby fires.
  • The sediment fence installed is no longer required and it will be removed soon when workers can access the area.
  • Salvaged coniferous and shrub species with intact rootballs were replanted in random groupings after construction to replicate the natural off RoW vegetation.  These plantings occurred within and outside of the riparian area.
  • An approved native grass seed was placed in the riparian area.
  • Additional planting is scheduled to occur next year and was delayed due to availability.
  • Soil conditions are dry and rocky which have made it difficult to plant in the area.
  • Weeds in the area were spot treated after construction.

Compliance tool used: No compliance tool used

Observation 3 - Reactivation Dig Sites

Date & time of visit: 2022-09-22 08:00

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Soil Handling
• Biosecurity
• Restoration
• Surface Water Management
• Containment and Drainage Structures
• Water Bodies - Fish-bearing
• Sedimentation/Turbidity
• Erosion
• Groundwater
• Monitoring and Testing
• Wildlife
• Species of Concern

Facility:

Observations:

Traditional Land Use Site -Dig Site 43B/44 Fraser River KP 428.000 to KP 427.843

• A temporary bridge was in place with sediment and erosion control measures.
• The sediment fence in the vegetated riparian area was not functioning and required repair. At the time of the inspection the sediment fence was not required because the riparian area was well vegetated and sloped upward toward the river. Trans Mountain representatives stated they would replace the fence prior to any excavation work.
• Spill kits, fire extinguishers and life preservers were observed on site.
• Salvaged rootballs were stored at the edge of the RoW and were covered in a shade tarp for insulation.
• Riparian and upland topsoil, rollback and course woody debris piles were labeled.
• Trans Mountain representatives stated:
  • This section of pipe replacement is 17m long and is located within an oxbow of the river.
  • This area has a very shallow water table and will require a significant amount of dewatering. Three large dewatering structures were constructed in well vegetated areas 50 meters off RoW. Sediment bags will be used inside the structures.
  • A specialized dewatering company will be working to assist in water management prior to and during construction. They had 27 well points to monitor the groundwater levels for 3 days prior to construction.
  • The RoW in this area had not been cleared for 30 years and trees were growing over top of the pipeline.
  • Pipe replacement in this area was planned earlier but was held up from nesting bird activity in the immediate area.

• Trans Mountain representatives stated:
  • Construction in this areas was delayed due to active bird nests. After the area was cleared for construction the contractor had installed access matting. During this time Western Toads were observed crossing the RoW during fall migration in the area. This area was not identified as a Western Toad area and the Wildlife Contingency Plan was enacted which included stopping all activity and contacting a Resource Specialist. Long-toed Salamanders were also observed on the RoW.
  • Pitfall traps would be closed at night during expected freezing temperatures and in order for them to proceed with construction activities, the traps would need to be empty for 3 consecutive days.
  • The RoW at this location is shared with the ATCO powerline.
• CER IO reviewed the company amphibian salvage plan and all the required amphibian permits including the Parks Canada Special/Restricted Activity Permit.
• Approximately 600m of frog exclusion fencing was being installed.
• Resource specialists and company Indigenous Monitors were observed onsite setting up pitfall traps inside and outside of the exclusion fencing.

Compliance tool used: No compliance tool used

Observation 4 - GAPS Connection Project

Date & time of visit: 2022-09-22 13:00

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Handling
• Restoration

Facility:

Observations:

Trans Mountain is installing a fiber optic leak detection system to enhance the integrity monitoring systems and help identify hazards and potential leaks of product from the pipeline. The Project is generally located in Japer National Park between KP 326 to KP 406 and Mount Robson Provincial Park between KP406 and KP 468. The plastic conduit installed is approximately 1.5 by 1 inch and is installed using a tracked rear vibratory plow unit that trenches and installs the cable at the same time. This method has minimal impact and does not require topsoil salvage. A small excavator travels behind the plow to smooth out the surface. Environmental documentation including the GAPS Connection Project Environmental Protection Plan (EPP) was onsite with the foreman and they appeared familiar with the site specific mitigation measures and locations.
Trans Mountain representatives stated:

• Boxes will be installed every 2 km to install the communications fiber and test the conduit.
• A mini excavator comes in behind for soil reclamation.
• Drip trays are placed under mobile equipment when stopped.
• Resource specialists survey the area ahead of the conduit installation and flags off any environmental features.
• The GPS system located in the plow allow the contractor to know the exact location of the conduit within 1 cm. The survey equipment is used to identify where the pipe is located.
• A variety of methods will be used at watercourse crossings but so far all have been drilled underneath using a punch bore or horizontal directional drill. These methods have also been used for road crossings.
• The Environmental Feature Tables in the EPP appendix with site specific mitigation measures is reviewed daily with the construction crew.

Compliance tool used: No compliance tool used

Observation 5 - Slope Stabilization KP 424.85

Date & time of visit: 2022-09-22 15:00

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Reclamation

Facility:

Observations:

The inspection team observed reclamation completed at a steep slope along the TMX Anchor Loop RoW at KP 424.85. Trans Mountain representatives stated:

• In 2018 the area was observed to be unstable and eroding above the CN railroad tracks. In the spring 2019 a technical assessment was completed, and additional erosion control measures were installed following an engineered design. This design included installing a high density of poplar stakes spaced approximately one foot across the entire slope. These stakes were installed up to 1m deep and has successfully stabilized the area. A watering program was developed to increase the survival rate of the stakes. Some stakes have not survived but still provide stability to the slope and the area is expected to naturally regenerate over time.

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: