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):
Related events:
Rationale and scope:
Environmentally focused field inspection of the Trans Mountain Expansion Project’s (TMEP), Spread 2, which spans from Edmonton City limits, and extends to a point near Hinton, AB; ranging approximately 288 kilometers, and parallels Alberta Highway-16. The spread moves through the Boreal Forest Natural Region and the Foothills Natural Region, which is characterized by Central Mixed-wood and Dry Mixed-wood sub-regions of Alberta. The Inspection Officer was accompanied by two Indigenous Monitors representing the Indigenous Advisory and Monitoring Committee (IAMC), pursuant to subsection 102(5) of the Canadian Energy Regulator Act (CERA). The inspection targeted ongoing work activities on the Right-of-Way (ROW) and temporary work spaces (TWS), including Access Roads to the ROW. Other areas of interest included wildlife mitigation, wetland and watercourse crossings, waste management, storage and handling of hazardous materials, traditional land & resource use, heritage resource sites, invasive species and biosecurity management, and erosion and sediment controls.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - General Observations: Right-of-Way
Date & time of visit: 2020-02-19 10:30
Discipline: Environmental Protection
Categories:
Facility:
Observations:
General observations on the ROW occurred over a two day period. The Inspection Team attended the 6:30 AM company/contractor inspectors meeting both field days. Based on activities scheduled in the daily work plan, the team decided to start from the most easterly point where work was ongoing and move westward, selecting a variety of activities to observe. The ROW had been cleared in several areas and the inspection convoy was able to drive on the right of way, however, some locations were inaccessible at this time and required access by foot. The following observations were made: Biosecurity Measures Car wash – Biosecurity Cleaning for CER Vehicle
Compliance tool used: No compliance tool used
Observation 2 - General Observations: Construction & Lay-down Yards
Date & time of visit: 2020-02-18 15:00
The Inspection team inspected both Trans Mountain and Midwest construction yards on two separate days during the inspection week. On Tuesday, February 18, at the lay-down yard where the Trans Mountain and Midwest management trailers are located was inspected. On Friday, February 21, the Midwest construction yard was inspected. The following general observations were made: Trans Mountain/Midwest Lay down Yard
Observation 3 - Corrected Non-Compliance 1: Sediment Control Structures
Date & time of visit: 2020-02-19 14:03
While inspecting the pipeline Right-of-Way, near kilometer posting (KP) 198+800 and WT-446 (wetland feature), the inspection team observed access clearing activities through multiple wetland features, most of which are seasonal. Heavy equipment was present in the area, however work crews were observed as inactive. The following observation were made:KP 198+800
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
TMPU will provide evidence demonstrating they have achieved compliance with the legislative requirements, and have corrected the issues with sediment control near KP 189+800, and in the vicinity of wetland 446.To assist in achieving compliance, photographic evidence will be provided to the CER to confirm corrective actions.
Due date: 2020-02-21
Date closed: 2020-02-21 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 2: Management of Waste Receptacles
Date & time of visit: 2020-02-21 10:02
While inspecting the Midwest construction yard, the Inspection Team observed several of the waste receptacles containing improperly segregated materials. The following observations were made:
TMPU must demonstrate how their management of waste materials is in compliance with the legislative requirements in the EPP and Appendix G – Waste Management Plan, with respect to waste segregation. Correcting the issues of improperly segregated waste materials will be completed with the measures provided under section 3.1.2 – Waste Disposal, which states:1. All waste materials will be disposed of in accordance with Federal and Provincial legislation and TransMountain policy, as required.2. All waste must be characterized and classified so that it may be properly recycled or disposed of. It isthe Contractor’s responsibility for characterizing and classifying any waste generated for theirspread/work site prior to storage, transport and disposal.TMPU will provide the CER with evidence, photographs and documentation, to confirm the waste has been segregated into the appropriate waste streams.
Date closed: 2020-02-24 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.
Observation 5 - Notice of Non-Compliance: Release of Hydrocarbons on the ROW
Date & time of visit: 2020-02-20 15:19
At a location near Hinton, AB, the Inspection Team accessed a site of higher elevation where access to the ROW was matted to mitigate compaction and rutting. When at an area of active clearing operations, on a slope and near a watercourse, the following observations were made:
Compliance tool used: Notice of Non-compliance (NNC)
TMPU will confirm the following measures have been undertaken to bring the issues of unsecured fuel nozzles, including containment requirements, back into compliance:
Due date: 2020-04-14
Date closed: 2020-04-24 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.
Observation 6 - IAMC, Indigenous Monitor Observation 1
Date & time of visit: 2020-02-19 09:00
Additional Observation recorded by IAMC Indigenous Monitors participating in the CER Inspection. Any compliance related observations that require specific regulatory follow-up have been recorded above.Spread 2 of the Trans Mountain Expansion Project (TEMP) Opening Meeting at Laydown Yard, West of Edson
Observation 7 - IAMC, Indigenous Monitor Observation 2
Additional Observation recorded by IAMC Indigenous Monitors participating in the CER Inspection. Any compliance related observations that require specific regulatory follow-up have been recorded above.SPREAD 2 - TMX
Feb 18-21. 2020
Opening remarks introduced CER io iamc IM’s , cci ltd and trans mountain staff
Went overspread 2 orientation for the ones that were first time on spread still attended to take part in the orientation. Following up on an environmental inspection on the Midwest yard (Edson) observed the yard and looked at secondary containments and gas fuelling station. Waste management’s containers were all button-up and were properly stored materials. Labeling and drip trays were where they needed to be in place so that was cool to see. Biosecurity cleaning will be done before heading to the row (right of way) also attended the 6:30 AM company. inspectors meeting took place at Mid-west yard (Edson) got a rundown on activities that are actively working mostly continued accesses and bore push welds and stringing activity’s right down to clearing and stripping/grading.
Right of way inspection:
Midwest wash bay yard (Edson) observed secondary containments for fueling up stations were label and signage in visual approach and stored chemicals stored in proper containers, labeling and drip trays were used and put out in the right places. garbage contaminants were all button-up, just a little few items stored not in the proper container but was taken care of properly, also took a look at the wash bay station that's beside the other midwest yard. workers were busy cleaning machines and were properly wearing the right PPE for the wash bay
Observed the biosecurity level one station workers brushing off the dirt (soil) off of tires and wheel well and bumpers, boots finally signing off on the paper that they did the proper thing in a good manner and also we went through it and brushed off our boots and crews vehicles signed off before we go observe clearing, I thought that was pretty cool and a good practice measure that the workers take it seriously.
went to observe the mulching machine from a safe distance breaks up the topsoil real nice and fine leaves with no big clumps of dirt. Stripping and grading were ongoing, Active stockpiling was also observed by crew. Soils being staked. signage was in proper places
the crew went to observe the burning pit signed off on the FLHA. was also pleased that trans mountain on sending loads of wood to communities. It also was cool to see them backfill the completion of the fire pit, that was cleared and soil was properly backfilled that was cool.
observed the bore push under the roadway was awesome and pleased to know that the optic fabric wire runs along the pipeline can detect leaks or anything in that matter along the stretch of the project. fencing was in place around open ditch areas
observed placing of wooden mats down to gain access to wetland features. fabric was used underneath the mats proper signage was visible, that was cool to see.
was interesting observing the heavy machinery towing large tires to compact the ground right equipment was used for activities
Observed TLU Site it has been mitigated with local indigenous communities. mitigation measures were explained to IMs. very good job they are doing throughout the spread
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