Compliance Verification Activity Report: CV1920-275 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-275
Start date: 2020-01-28
End date: 2020-01-30

Team:

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

This is an environmentally focused inspection of NGTL North Central Corridor Loop (North Star Section 1) – 31 km of new 48 NPS pipeline construction occurring approximately 25 KM northwest of Manning, AB. This Project Parallels the existing North Central Corridor for approximately 98% of the length, beginning at the existing Meikle River Compressor Station, and extends to a valve site adjacent to the Chinchaga forestry road. The Project was approved in October 2019 - Access and clearing activities started in November, followed by stripping and grading in December. The Project is located entirely on crown land (Green Area), including a small portion in the White Area, in the county of Northern Lights and Clear Hills County. This area is characterized by Dry-mixed wood and lower boreal Highlands sub-regions of Alberta. Vegetation surveys identified two species of rare plants (i.e., Reindeer Lichen and Cat-tongue Liverwort) in five locations, three occurrences of three noxious weed species, namely: Leafy spurge; creeping/perennial thistle; and spike/northern watermilfoil. The pipeline route crosses 12, Class C, unnamed tributaries to the Hotchkiss River - no SARA fish species have been identified; beavers ponds and dams have been documented. Approximately 29 KM of the Project is located within the Chinchaga Grizzly Bear Secondary Zone and the Chinchaga Caribou Range for Approximately 14.9 KM and parallels existing disturbance for 100% of its length within the range. The Historical Resource Act applies to the entire length of the Project.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - General Observations on Project Right-of-Way

Date & time of visit: 2020-01-29 09:22

Discipline: Environmental Protection

Categories:

Facility:

Observations:

The field portion of this inspection began at the middle point of Right-of-Way (ROW), starting at KP 14+330 - 30+800, where work was ongoing. NGTL stated that the reason they started construction at this location was to complete the section where Caribou Range exists before the Restricted Activity Period (RAP) starts.

Watercourse Crossings and Wetlands

KP 14+330 – NWC 7 Unnamed Watercourse Crossing (WCC)

 
KP 15+370 - NWC 8 Unnamed WCC 
KP 18+900 – NWC-10 and Wetland 
KP 25+600 – Beaver Pond / Wetland
  KP 5+200 - NWC 3 Unnamed Watercourse 
Traditional Land Use (TLU) Sites

KP 21+500 – TLU
KP 6+760 – TLU 
KP 6+975 – TLU
Other Observations

KP 8+020 – Rare Plant Site 
KP 16+200 – Chinchaga Caribou Range 
KP 21+370 – Rare Plant Plot 
KP 30+800 Noxious Weed Site 
KP 0+250 – Road Bore Site 
KP 1+900 – Access Road Crossing 
General ROW


 

Compliance tool used: No compliance tool used

Observation 2 - NGTL / Midwest Construction Yard

Date & time of visit: 2020-01-28 14:35

Discipline: Environmental Protection

Categories:

Facility:

Observations:

CER IO's inspected the lay down yard (equipment and materials storage area). The following observations were made:

Oil and Lubricant Hazardous Waste Area
- Motor oil, gear oil and lubricants were stored at this location.
- Used and opened drums and pails were stored within secondary containment.
- Used lithium vehicle batteries stored in a labelled, wooden storage bin.
- Two large steel cylinders were being used for temporary storage of used oils and lubricants; hazardous waste storage - Refer to CNC 2

Fire Incident Site - Mechanical Tent Shed
- One of the mechanical shops on site caught fire prior to CER IO's inspecting the construction yard. The tent was a weather haven style shelter, constructed with a metal frame and white polymer canvas. Company personnel stated that the fire originated in the shop. Employees immediately took action to extinguish the flames, but the fire was beyond their control. RCMP and local fire departments responded to the blaze. Investigation is ongoing. 
- The incident site was appropriately closed off with ropes installed around the perimeter of the building. Installed signage indicated that this was a potentially hazardous area.    

Waste Material Storage Bins
- Waste bins were labelled for material segregation (i.e., metal, wood, cardboard, plastics).
- Contaminated soil bin appropriately labelled and weather protection in place.
- Some materials have been improperly discarded - Refer to CNC 1.

Equipment On Site     
- CER IO's inspected randomly selected heavy equipment in the yard. IO's observed the correct requirements for equipment in place, including spill kits, up to date fire extinguishers, and equipment cleaned stickers visible and up to date - Refer to IR for further information.
- Secondary containment and spill kits located at light stands.

General
- Housekeeping – the site was clean and tidy.

Compliance tool used: No compliance tool used

Observation 3 - Information Request (IR) – Biosecurity and Documentation

Date & time of visit: 2020-01-29 10:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

During the inspection, CER Inspection Officers randomly selected multiple pieces of heavy equipment in order to verify compliance to the biosecurity plan in place for the project. The equipment is required to have up to date stickers attached to the equipment, and the Company must have cleaning records available. The following equipment numbers were field and log verified (6 total):

1 Excavator - EX 434
3 Bull Dozers - DR 811, DR 803, DR 617 
2 Side Booms - SB 820, SB 925 
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

The Company will provide CER Inspection Officers with the requested log book information, detailing the dates of cleaning, type of cleaning and verify who approved the activitiy.  

Due date: 2020-01-31

Date closed: 2020-01-31
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 (CNC) 1 – Improper Storage of Used Hazardous Waste Products

Date & time of visit: 2020-01-28 14:35

Discipline: Environmental Protection

Categories:

Facility:

Observations:

While inspecting the construction laydown yard, CER Inspection officers observed the following Non-Compliance to the Environmental Protection Plan (EPP), and subsequent Chemical and Waste Management Plan:

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The Company will comply with the Chemical and Waste Management Plan and correct the deficiencies identified during the time of the inspection. Specific action is required where residual oil leaks and stains have been observed on the outer wall of the storage tank, near the opening lid. A method of containment will be placed at the base of the storage tank to catch any residual hydro-carbon sources that may occur. Photographic evidence of the corrective actions will be supplied by Company personnel.

Due date: 2020-01-30

Date closed: 2020-01-30
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 5 - Corrected Non-Compliance (CNC) 2 – Waste Bin Management

Date & time of visit: 2020-01-28 15:22

Discipline: Environmental Protection

Categories:

Facility:

Observations:

While inspecting the construction laydown yard, CER Inspection officers observed the following non-compliance to the Environmental Protection Plan (EPP), and subsequent Chemical and Waste Management Plan:

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The Company will ensure waste bin receptacles contain only the correct materials as labelled on the outside of the bins to comply with the Chemical and Waste Management Plan. Photographic evidence was requested by CER Inspection Officers to confirm corrective actions.

Due date: 2020-01-31

Date closed: 2020-01-31
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 6 - Corrected Non-Compliance (CNC) 3 – Housekeeping on ROW

Date & time of visit: 2020-01-29 11:32

Discipline: Environmental Protection

Categories:

Facility:

Observations:

At approximate KP 26+700, CER inspection Officers observed the following non-compliance to the Environmental Protection Plan (EPP), and subsequent Chemical and Waste Management Plan.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The Company will collect all of the waste materials and dispose of these in accordance with the Chemical and Waste Management Plan. Photographic evidence of corrective action must be sent to the CER IO.

Due date: 2020-01-31

Date closed: 2020-01-30
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