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):
Rationale and scope:
Spread 5A field inspection of construction on spread 5A of the Trans Mountain Expansion Project. Focus on watercourse crossings, implementation of erosion and sediment control measures, and dewatering requirements.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
IR from CER (Information Request sent from CER to company) IR No. 1 Erosion and Sediment Control Measures
Legislative Requirement : Onshore Pipeline Regulations (OPR) 2020-03-16
Sections of the Act
Theme and Categories
Due Date : 2023-10-31
Review Response Acceptable
Follow-up Action None
Observation 1 - General Right-of-Way (RoW)
Date & time of visit: 2023-10-17 09:00
Discipline: Environmental Protection
Categories:
Facility:
Observations:
Note – all Kilometre Posts (KPs) are approximate. KP 838.70 -A crew was just starting the Cryptogamic crust replacement process, there are seven separate locations in spread 5a where the crust will be replaced. Crust at this site was collected and labelled in 2020. This process included delivering all stored/tarped boxes to the site of replacement, crust material was put thru a sifter (crumble it down a bit, remove some rocks, and break up finely), raked the replacement area (roughening up surface with rake to mix in with topsoil), then hand broadcast in the replacement area as evenly as possible (with rakes, and harrow if needed), then rake/mix crust back in to soil. Trans Mountain representatives (Trans Mountain) mentioned that a broadcast seeder may be required for replacement in some larger areas if needed. -Cryptogamic crust replacement is anticipated to last 2 weeks to replace the collected material. -Trans Mountain mentioned that the crust is dormant and the goal is for it to start growing in the spring, however may not see crusting in a year as reclamation success may take up to 5 years. Bunchgrass will also be replanted through the area as this was part of the normal landscape pre-disturbance. -Snake hibernacula was observed in this area. Trans Mountain mentioned that Thompson Rivers University students are doing research on older and newly constructed dens. KP 851.900 Jacko Lake area Horizontal Directional Drill (HDD) entry side -Two company Indigenous Monitors were onsite at time of inspection. -Site was graded and matted, and work crews were setting up HDD structures. -Archaeological (ARKY) site avoided by narrowing up the RoW, also it was fenced and signage installed. -Double fencing (i.e. sediment fencing and metal fencing) installed around the RoW perimeter. -Secondary containment in place underneath equipment (e.g. light stands). KP 852.556 Jacko Lake HDD exit side -Drag pipe section strung on pallets and pipe end caps installed. -Culturally modified tree and an ARKY site was avoided, fenced, roped, and signed. -RoW was graded. -Double fencing (i.e. sediment fencing and metal fencing) installed around much of the RoW perimeter. -Secondary containment in place underneath equipment (e.g. light stands).
Compliance tool used: No compliance tool used
Observation 2 - Watercourse Crossings
Date & time of visit: 2023-10-18 09:00
KP 821.60 Lanes Creek -Log rollback and several berms installed on approach slopes. -Vegetation infilling on both sides of the watercourse. South slope was reclaimed this past spring, north slope last year. No signs of erosion in the area. A tackifier material added to soils. -Pipeline identification markers in place on both sides of the watercourse. KP 870.600 Droppingwater Creek -This area was part of the inaccessible RoW due to forest fires (approximately a month ago). Trans Mountain mentioned that this has delayed further reclamation to approximately next week. A supplemental planting program will be undertaken in the fall or spring. -Rock was installed along watercourse, log cribwall installed along both side banks, log rollback installed, also coir matting and seeded riparian area was observed. -Some cattle pugging was observed in the area. -IOs requested information on the plan for potential post-fire danger trees. Trans Mountain reviewed an updated assessment/progress report on this matter with the inspection team CER Inspection Officers (IOs) and Indigenous Advisory Monitoring Committee Indigenous Monitors (IAMC IMs), no concerns. -A small hole was observed in the side geo-wrap along the travel lane. Trans Mountain committed to add this to its deficiency list. The hole was likely due to emergency fire crew access along the RoW. KP 983.950 Mine Creek -Trans Mountain stated that this location may be part of their reforestation program. -Coarse woody debris stored and labeled. -Rock armoring installed on both sides of the creek, geo-textile wingwalls installed along the travel lane. KP 984.540 Non Classified Drainage (NCD) -The NCD outflow area requires straw wattle repair, and cleanup of resulting off-RoW sediment. See CNC No. 1, and IR No. 1. -Topsoil pile labeled along the RoW. -Watercourse crossing signage installed. 957.20 Kingsvale Creek -Several berms and log rollback installed along both slopes. -Trans Mountain mentioned that the riparian area was recently seeded and coconut matting installed. -Log crib walls installed on both sides of the creek, along with some rock armoring. Willows were planted along both crib walls. -Trans Mountain mentioned that the vegetation will be monitored next year, but the site is otherwise considered completed. KP 957.290 NCD -Erosion and sediment control (ESC) measures installed included staked straw wattles, coconut matting alongside the drainage area, and sediment fencing. Trans Mountain stated that crews are working along the RoW towards this location and may install a small pit for increased water containment (i.e. small water containment structure) or other measures to deal with increased water flow across the RoW. -Berms installed along the slope and grade cut area, and a dike alongside of the RoW. KP 962.150 BC-556 NCD -ESC measures included a rock wall installed alongside a hill/grade cut, sediment fencing, staked sand bags, and rock armoring along the drainage. -Two spill kits were located onsite. The IO team checked on of the spill kits and it contained appropriate spill equipment including a boom. -Signage installed containing information on no re-fuelling within 100 m of watercourse. -Signage installed on acid rock pile and this pile was contained separately from other soils. On one side of the rock pile a tarp had come down slightly in some areas. Trans Mountain mentioned that this was likely due to soils previously being put up against this pile and subsequently removed for replacement. Acid rock pile was tested and is a class 5 material which allows it to be buried onsite with cap material placed on top. AK 16.87 Salem Creek -This site is in the middle of a cattle feedlot. -Sediment fencing installed on both sides of the creek. -Coconut matting installed, and seeded riparian area was starting to emerge through the matting. AK 5.4 Lemoto Creek -ESC included wingwalls installed along the RoW travel lane, seeding implemented, coconut matting in place, also sediment fencing and berms installed. IOs observed that some cattle pugging was evident around the watercourse, which can lead to ESC damage. Trans Mountain and IOs discussed that some minor ESC "freshening"/repair will be required prior to spring freshet. Trans Mountain committed that this work will be undertaken prior to spring. KP 929.05 Spanish Creek -Pipeline identification signage in place. -Straw wattles and coconut matting installed. The RoW area was seeded and vegetation is emerging but may need some attention/re-seeding in the future as the vegetation was slightly sparse on the north bank. Trans Mountain committed to monitoring. -Almost one full growing season has passed since completion of reclamation work in this area. KP 925.50 Hamilton Creek -Coconut matting installed and vegetative growth was observed. Trans Mountain mentioned that the landowner re-seeded the area. Some cattle pugging was evident along the RoW. -Pipeline identification markers in place. KP 927.70 Godey Creek -Two-step log cribwall installed on the north side of creek. -Coconut matting installed, emergent vegetation was observed. -Sediment fencing was installed along north and south banks leading to the watercourse. -Pipeline identification markers installed. KP 915 Shuta Creek -Trans Mountain mentioned that the south slope contained emergent weedy vegetation, therefore they went back in to do some more work including removing weeds and recent re-seeding. Observed evidence of emergent vegetation growth along the north and south banks, including more dense vegetation infill along the riparian area. -On the south side of the creek, a two-step log crib wall was installed, along with some rock armoring. One-step log crib wall was installed on the north side. -Log rollback installed on both sides of the watercourse, and also on the approach slopes. -Some minor cattle pugging was evident in the area. -No riparian shrub/tree planting was evident along the watercourse. Trans Mountain mentioned this site may be included in their reforestation program. -Trans Mountain provided information on the post-construction instream assessment for this creek. No concerns. KP 912.60 Clapperton Creek -Rock armoring installed along the watercourse banks. -Trans Mountain mentioned that this site will likely be included in their reforestation program. -Log rollback installed on both slopes, area is seeded, and berms and straw wattles installed on south slope (there is an access road located at the bottom of the south slope). -Pipeline identification signage installed. KP 908.950 Zoht Creek -The main channel of this creek parallels the RoW. -Trans Mountain mentioned that they will be re-working a small side channel which presently contains little water and little to no evidence that this channel crosses the RoW. -There is evidence of cattle pugging in this area. KP 889.370 Moore Creek -This creek was crossed utilizing a Boring method, therefore the riparian area was mostly undisturbed. -Installed ESC included check dams, sediment fencing, settling pit, sandbags, and berms. -Temporary bridge contains side curbs. -Sediment fencing was in disrepair (fallen down) in two small areas, however there are no signs of erosion or sedimentation. Trans Mountain representatives provided temporary fencing repairs immediately, and informed the contractor that additional repairs will be required. Significant cattle pugging was evident in area, and it appears as though cattle travelled through the sediment fencing. -Rough grading on steep slope leading to the creek was underway at time of inspection.
Observation 3 - Safety
Date & time of visit: 2023-10-17 12:00
Discipline: Safety Management
Jacko Lake area HDD entry side KP 851.900 -Worker with wire holding his work boot together was identified on site, foreman was informed of the issue. -During the unloading of some of the large HDD modules at the Jacko Lake site, a worker was spotted running out of a pinch point when the module was pushed into place against a rocker table. The foreman was informed and the issue was brought up at the following day morning safety meeting.
Observation 4 - Corrected Non-Compliance No. 1 - Sedimentation Off-right-of-way
Date & time of visit: 2023-10-18 09:30
At ~KP 984.540 NCD BC-580, ESC measures in place included sediment fencing, installed rock, water retention pits, several berms, and geotextile wingwalls along the travel lane. While some ESC measures in the area were functioning as intended, others (including straw wattles) were in disrepair, resulting in sedimentation off-RoW.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
NCD outflow area requires ESC (e.g. straw wattle) repair, and cleanup of resulting off-RoW sedimentation.
Due date: 2023-10-19
Date closed: 2023-11-02 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
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
