Compliance Verification Activity Report: CV2122-164 - Trans-Northern Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2738
• Inspector 2463

Regulated company: Trans-Northern Pipelines Inc.

Operating company: Trans-Northern Pipelines Inc. (TNPI)

Province(s) / Territory(s):

• Ontario
• Quebec

Discipline(s):

• Environmental Protection
• Safety Management
• Standard Condition

Related events:

• CV1920-221
• CV1920-457
• CV2021-270
• CV2122-002

Rationale and scope:

This field inspection is focused on follow-up to NNCs observed along TNPI's Mainline during the May 2019 inspection (CV1920-221) and fall 2020 (CV2021-270), namely TNPI's management of Bird protection (bird windows) during operations and maintenance works, aboveground facilities (surface water management systems) and management of contaminated sites. The purpose of these inspections is to verify compliance with the Canadian Energy Regulator Act, the Canadian Energy Regulator Onshore Pipeline Regulations, CSA Z662, and any other relevant plans, manuals, and procedures. The primary focus area of these inspections will be the Environmental Protection Program and implementation at Facility Operations as well as Operations & Maintenance Activities (O&M Activities). The scope of these inspections will include but will not be limited to pre-disturbance planning for O&M Activities, surface water management at facility sites, deactivated facilities, and follow-up to CER CVAs having occurred in 2019 & 2020.

Compliance tool(s) used:

• Notice of Non-compliance (NNC) (1)
• Inspection Officer Order (IOO) (1)
• Information Request (IR) (1)
• Assurance of Voluntary Compliance (AVC) (1)

Facility details

Facilities:

• COMO STATION
• LANCASTER STATION
• CORNWALL STATION
• OTTAWA STATION
• IROQUOIS
• MALLORYTOWN
• KILBIRNIE STATION
• KINGSTON STATION
• MIRABEL AIRPORT TERMINAL
• Mainline
• Ottawa Lateral
• Dorval Lateral
• Mirabel Lateral
• MAITLAND STATION

Facility Types

• Pipeline
• Electrical facility
• Meter station
• Pipeline
• Pipeline right of way (ROW)
• Station piping
• Valve site

Life-cycle Phases

• Deactivated
• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Labour Code (CLC)
• Canada Occupational Health and Safety Regulations (COHSR) 2016-06-14
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Act (NEBA) 2016-06-19
• Plans And Procedures
• Standard Operating Procedure or Plan (SOP)
• Environmental Protection Program manual (Document No.: 0998) - 20 June 2020
• Project-specific Environmental Protection Plan (EPP)
• EPP for Dig at MP 142 & MP 147
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Stations General

Date & time of visit: 2021-05-24 09:00

Discipline: Environmental Protection

Categories:

• Surface Water Management
• Containment and Drainage Structures
• Vegetation
• Vegetation Control
• Invasive Plant Management
• Groundwater
• Monitoring and Testing
• Air Quality
• Emissions Control/Monitoring
• Housekeeping
• Waste Management
• Training and Documentation
• Documentation Available/Up to Date
• Inspections

Facility:

• COMO STATION (Facility)

Observations:

CER Officer inspected several stations on TNPIs system, including the:
Como Station
Lancaster Station 
Cornwall Station (Deactivated)
Ottawa Meter Station
Iroquois Station
Maitland Pump Station
Maitland Meter Station
Mallorytown Station
Kilbernie Station
Kingston Pump Station

The main themes of observations are summarized below, grouped by subject.

Environment General

• CER Officer spot checked for local permits for discharge of water from the oil/water separator systems. TNPI Representatives demonstrated awareness of TNPI’s procedures for discharge sampling and permitting both in Quebec and Ontario.
• Spill containment systems were inspected at all stations visited. In general, for Pump Stations, CER Officer observed concrete berms in a maintained state, in that cracks had been filled. Liners within the bermed area and drainage/sloped systems designed to direct surface water and potential releases into the oil/water separator were also generally observed in well maintained condition.
• Pump buildings having floor drainage present, was confirmed by TNPI Representatives to be directed towards the oil/water separators.
• Discharge areas for oil/water separator systems observed were in appropriate locations (ditches) and no erosion concerns were noted.
• For Metering Stations, CER Officer observed facility piping for provers to be located within secondary containment consisting of liners within the bermed area and drainage/sloped systems designed to direct surface water, potential leaks and releases, into the oil/water separator.
• The above ground portion of sump tanks were observed during inspections of the stations and below ground portions discussed with TNPI Representatives. The TNPI representatives demonstrated a thorough knowledge of the testing (monitoring) and maintenance program in place for ensuring underground sump tanks are functional and are not leaking. Tanks are predominantly double walled tanks. Where single walled tanks were present, CER Officer completed record checks of monitoring data and integrity testing (vacuum tests).
• TNPI Representatives provided all the requested documents quickly and efficiently in the field, no concerns noted.
• Station backup generators observed to have drip caps in place for re-fueling.
• Vegetation at Stations adequately managed within graveled yards, with no observed weedy vegetative growth identified.
• Stations also have an approximately 1m zone extending past the facility boundary fencing, observed to be maintained free of vegetation.
• Verified waste disposal bins with appropriate materials (trash) for that stream of waste generated at a Station (i.e. no hazardous materials).

• At the Ottawa Meter Station and the Kilbernie Station, groundwater monitoring wells are present.
• For the Ottawa Meter Station, TNPI Representatives indicated that contamination monitoring was ongoing by others and their understanding was that monitoring occurring at this site was being completed for known contamination emanating from the adjacent lands and would be for third-party contamination.
• For the Kilbernie Station, TNPI Representatives were unaware of any specifics with regards to any ongoing groundwater monitoring program, however, TNPI Representatives indicated this is a known site.  
• Observed groundwater monitoring wells (when present) have appropriate caps and were locked/secured.   
• CER Officer indicated that the CER has recently updated the Remediation Process Guide. As the updated process may require notification to the CER of third-party contamination a copy of the 2020 Remediation Process Guide was provided to TNPI Representatives.

• Storage and disposal of hazardous materials observed at various facilities during the inspections.
• In general, hazardous chemicals were stored and disposed of appropriately across the warehouses, sheds, storage containers and yards inspected.
• No 'weeps' or minor spills were observed at station pipping, nor stained gravel at valves and piping flanges, operator, or connections.
• Secondary containment provided for barrels and canister storage.
• Cabinets for flammable materials storage observed with functional doors, sealed (not vented to the exterior) and with appropriately stored hazardous materials present in cabinets.
• All hazardous materials observed to be stored in appropriate locations and stored in separate containers / buildings outside of the pump buildings.
• Spill kits observed in is storage sheds/containers at all Pump/Prime Mover Stations inspected.
• CER Officer spot checked waste bins across the stations inspected. Oily rags were observed to be disposed of separately from generic waste and labels were in place where necessary.

• All sites and building observed were found to be tidy and well-kept with appropriate housekeeping.
• Examined fire extinguishers observed to have up to date monthly inspections and annual certifications, located in appropriate areas, and of appropriate class and size.
• Safety related pictograms/signage for First Aid, Eye Wash, Fire Extinguishers, High Voltage, exits (in buildings) observed to be present in appropriate locations at and around the facilities visited.
• Product and flow direction identified on station piping, within buildings, and in yards.
• Racking in buildings and storage cans observed having load bearing capacity identified.
• Older buildings with walls/ceilings containing asbestos fibers are identified with appropriate signage.
• Facility signage is present at all stations inspected and included operating company, station name, emergency number, as well as pictograms for prohibitions and hazards hazards, as well as required personal protective equipment (PPE).
• All stations observed to have either water supplied eyewash stations (municipal water supply) or 15+ minute wall mounted eyewash stations (well water supply) with current valid inspection tags and identified expiration dates.
• Electrical control rooms with appropriate signage at doorways, emergency exit signage and markings for safety.
• Water systems in place at stations having groundwater wells as a supplied water source have ultraviolet lights and filters in place.
• Signage is in place at stations where the water supply is from a groundwater well indicating 'Do NOT drink the water'. TNPI Representatives indicated that bottled water is provided as a drinking water source at these stations.
• Toilet paper is provided where toilets are present.
• Soap dispensers are present and supplied at washbasins in toilet rooms and personal washing and food preparation areas.
• Mobile lifting equipment (Lancaster Station Warehouse) with equipment pre-use inspection logbook in place.
• Billboard present (Lancaster Station Lunchroom) with appropriate health and safety information posted including applicable legislation and health and safety committee meeting minutes.
• Mezzanine (Lancaster Station Warehouse) with load rating identified and posted.
• Egress gates present at stations. Verified egress gates were functional and opened to an appropriate escape area.
• Control room buildings equipped with toilet rooms, eye wash stations, first aid kits, and wash basins.
• Observed permanent stairways, ladders, and walkway stairs over pipe, have appropriate guardrails.
• Electrical substations have appropriate signage posted.
• Verified overhead cranes in pump buildings as well as in the Lancaster Warehouse, have pre-use inspection logs as well as valid annual certifications. TNPI Representatives provided all the requested documents quickly and efficiently in the field, no concerns noted.

Compliance tool used: No compliance tool used

Observation 2 - Mirabel Meter Station - General

Date & time of visit: 2021-05-18 09:33

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs

Facility:

• MIRABEL AIRPORT TERMINAL (Facility)

Observations:

General

• Mirabel Meter Station signage present at facility entrance. Signage includes name, address, operating company, emergency contact number, as well as pictograms for required personal protective equipment (PPE) to enter the site and other prohibitions.
• No trespassing signage present at facility boundaries.
• There is no power provided at the site.
• Manhole with cover present on oil/water separator.
• Pipeline identification markers present along RoW adjacent to the Station.
• TNPI Representatives provided for review records of the most recent operations and environment inspections of the Station to the CER Officer. Work details for the operations inspections are extremely limited, and only state a few items to be verified, associated with the security of the site, and emergency contact information. Environment inspection template covers broad themes of Authorizations, Chemicals, Wastes, Housekeeping, Surface Drainage, Sampling / Reports, Overall Findings & Recommendations.

Compliance tool used: No compliance tool used

Observation 3 - Notice of Non-Compliance (NNC) - Mirabel Station - Ground Water Well(s) - (CV2122-164 NNC#1)

Date & time of visit: 2021-05-18 09:30

Discipline: Environmental Protection

Categories:

• Groundwater
• Monitoring and Testing
• Chemical Spills/Releases

Facility:

• MIRABEL AIRPORT TERMINAL (Facility)

Observations:

At TNPI’s Mirabel Station, a water monitoring well having a broken casing (cover) is present. This is the same well that had been identified in CVA 2021-270 and has not yet to be addressed. In the closing meeting, TNPI Representatives indicated the ownership of the groundwater well(s) was unknown and could have been installed under TNPI's direction or could have been completed for and under the direction of a third party. The CER Officer is of the view that regardless of ownership, TNPI controls this workplace and the Mirabel Meter Station. Therefore, it is incumbent upon TNPI to ensure unmitigated potential hazards to the environment (eg infiltration of contaminants into the groundwater) and the potential safety hazard (tripping hazards) for employees or those persons granted access to the site be corrected. Maintenance of groundwater wells remains a best management practice related to water management and the prevention of contamination into a groundwater aquifer and is required pursuant to section 48 of the OPR as per Clause 3.5.4 of TNPI's Environmental Protection Program Manual. 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

• Standard Operating Procedure or Plan (SOP)
• Environmental Protection Program manual (Document No.: 0998) - 20 June 2020

Relevant section(s):

• TNPIs EPP (June 2020) page 17/32. S 3.5.4 Water Management: “TNPI must comply with federal, provincial and municipal standards and guidelines, and aims to meet industry best management practices related to water management.” OPR s. 48 A company shall develop, implement and maintain an environmental protection program that anticipates, prevents, manages and mitigates conditions that could adversely affect the environment Groundwater Catchment Regulation Quebec Environment Quality Act 15. A person who installs a catchment work must cover it safely so as to prevent contaminant infiltration. The owner of the work shall ensure that the integrity of the well cover is constantly maintained. 46. Every person who installs an observation well must cover it safely so as to prevent contaminant infiltration. The owner of the work shall ensure that the integrity of the well cover is constantly maintained.

Company action required:

TNPI will ensure that the identified groundwater monitoring well, as well as any others located within its facility perimeter, and therefore under TNPIs control, are adequately covered and secured. TNPI shall provide photographic evidence once completed. 

Due date: 2021-06-30

Date closed: 2021-05-31
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 - Inspection Officer Order (IOO) - Mirabel Metering Station - Deactivated vs. Decommissioned - (CV2122-164 IOO LMR 2021-001)

Date & time of visit: 2021-05-18 09:33

Discipline: Administrative

Categories:

• Regulatory Instrument
• Condition

Facility:

• MIRABEL AIRPORT TERMINAL (Facility)

Observations:

General​

• Overgrown vegetation of weedy species is pervasive throughout the graveled site. New weedy vegetative growth present withing graveled Station yard and establishing from weed seed. Observed vegetative grown is consistent with growth expected over recent weeks in this 2021 growing season. Other matted vegetation is dry and dead. TNPI Representatives indicated that herbicides had previously been applied to manage and control vegetation in graveled area at the Station. The amount of dead vegetation present poses a potential fire hazard by providing a fuel load for grassfires. Weeds on site are not managed to a similar standard observed at other TNPI Stations. This is in non-compliance to the OPR paragraph 4(1)(d), CSA Z662 Clause, 10.5.8, and Clause 6.6.
• Older (rusted) garbage dumpster present on site. TNIP Representatives noted it for further follow-up and removal.   

• Temporary fencing present which completes the remaining existing perimeter fencing of the facility. Fencing remains temporary. TNPI representatives indicated that they were aware of an estimate had been received but that no contract / purchase order (PO) had yet been awarded. From discussion with TNPI Representatives CER Officer is of the understanding that there are no intrusion detection systems in place at this time. TNPI was unable to demonstrate it had established plans for a permanent solution for physical security of the site nor were they able to demonstrate clear timelines for its completion. This is in non-compliance to the OPR, paragraph4(1)(e), CSA Z246.1, Clause 9.3.2 and 9.3.5 and OPR, paragraph4(1)(d), CSA Z662, Clause 10.2.5.
• Piping exposed to the atmosphere is corroded, coating is unmaintained, cathodic protection has not been maintained, disconnected piping is stored on the ground next to facility piping. This is in non-compliance to the OPR, paragraph.4(1)(d), CSA Z662 Clause 9.1.4, Clause 9.1.5, Clause 9.1.6. Clause 10.15.1.1, Clause 10.15.1.2
• Walkway (stairs, platform, guardrail) over piping is unsafe for use, flagged with caution tape as a temporary measure. CER Officer is of the view that this measure is insufficient for the medium to long term, only sufficient on a temporary basis and remain a non-compliance to the OPR, section 27, and paragraph 4(1)(d), CSA Z662, Clause 10.2.4.
• Areas with uneven ground posing a potential tripping hazard are flagged off with caution tape as a temporary measure. CER Officer is of the view that this measure is insufficient for the medium to long term, only sufficient on a temporary basis and remain a non-compliance OPR, section 27 and paragraph 4(1)(d), CSA Z662, Clause 10.2.4.
• Conduits with exposed wiring cut off at or above ground level are present in several areas near facility piping throughout the Station. CER Officer is of the view that these constitute unmitigated hazards to the safety of those accessing the site and remain a non-compliance to section 47 of the OPR, and paragraph 4(1)(d), CSA Z662 Clause 10.2.4 CSA Z662.
• Some of the facility components and site infrastructure have been previously decommissioned and removed, notably the control building, and the underground sump tank. TNPI Representative indicated this had occurred some years previous. Supports, and foundations, however, were not removed and remain in place. This is in non-compliance to ORDER MO-01-2005 which requires the Mirabel Station to be maintained in a deactivated state.   

• CER Officer observations at the Station show that although TNPI was made aware of maintenance compliance matters identified in CV2021-270 for operating (in this case, deactivated) facilities, several compliance issues have not been addressed, although, the more immediate hazards to people and wildlife were corrected in follow-up to CV2021-270 NNC#. However, the Metering Station is not being maintained as required for deactivated pipelines.
• To the knowledge of the CER Officer, TNPI does not have a CER approval for decommissioning in accordance with the requirements of the OPR. TNPI Representatives indicated that the company is working towards a Decommissioning Project in association with a Remedial Action Plan (RAP) being developed for known contamination at the site.
• CER Officer provided information to TNPI representatives with regards to the Exemption Order XO/XG-100-2008 (Decommissioning Streamlining Order), which should be examined to possibly conduct certain Operations and Maintenance Activities to decommission piping no longer in use and not currently maintained in a deactivated state at the Station.
• The Mirabel Station continues to be out of compliance with the requirements to be maintained in a deactivated state as per as per ORDER MO-01-2005, paragraph 4(1)(d) of the OPR requiring applicable clauses of CSA Z662. Requirements for maintenance and management of deactivated facilities currently in non-compliance include but are not limited to: perimeter protection measures, intrusion and detection systems, external and internal corrosion controls for piping exposed to the atmosphere, inspection of such piping, maintenance of cathodic protection, vegetation control, environmental effects (aesthetics, protection of vegetation and wildlife).
• The status of the Pipeline and related surface equipment, aboveground pipelines, and pipeline related facilities at the Mirabel Station do not meet the operation and maintenance expectations of the CER for a deactivated facility. The Mirabel Station has regulated facilities under ORDER M0-01-2005 and is therefore expected to be operating or maintained in a deactivated state, as per the definition “operate” in the OPR. Facilities at the Mirabel Station are, in actuality, in a partly decommissioned state akin to the “decommission” definition in the OPR without the approval of the Commission of the Canada Energy Regulator (Commission), as required pursuant to section 45.1 of the OPR.

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 4. General
    • (1) When a company designs, constructs, operates or abandons a pipeline, or contracts for the provision of those services, the company shall ensure that the pipeline is designed, constructed, operated or abandoned in accordance with the applicable provisions of
      • (a) these Regulations;
      • (d) CSA Z662, if the pipeline transports liquid or gaseous hydrocarbons; and
      • (e) CSA Z246.1 for all pipelines.
  • 45.1 Decommissioning
    • (1) If a company proposes to decommission a pipeline or part of one, the company shall submit an application for the decommissioning to the Board.
    • (2) The company shall include in the application the reasons, and the procedures that are to be used, for the decommissioning.

Company action required:

No later than 31 August 2021, TNPI shall:

(a) Provide notice to the undersigned CER Officer including the Decommissioning Project description and scope of work TNPI will be using to determine if they are eligible to proceed pursuant to Exemption Order XO/XG-100-2008 (Decommissioning Streamlining Order).

OR

b) File with the Commission an application pursuant to section 45.1 of the OPR for the Decommissioning Project.

If (a), then also:

i. Fourteen (14) days prior to the commencement of the Decommissioning Project, provide the Construction Schedule, the Site-Specific Environmental Protection Plan, as well as the Site-Specific Safety Plan for the
Decommissioning Project; and 

ii. Complete the Decommissioning Project and associated activities in accordance with the Decommissioning Streamlining Order in the fourth quarter of the 2021 calendar year and no later than 31 December 2021.

Due date: 2021-12-31

Date closed: 2021-10-23
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 - Information Request (IR) - Ottawa Station Water Well - (CV2122-164 IR#1)

Discipline: Environmental Protection

Categories:

• Groundwater
• Monitoring and Testing

Facility:

• OTTAWA STATION (Facility)

Observations:

At TNPI’s Ottawa Meter Station, a water well having a casing that is consistent with those normally used for water supply is present. TNPI Representatives present during the field inspection were unable to confirm its purpose and stated that the Station had a municipal water supply in use for potable water at the Station.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 6.5 Management System Processes
    • (1) A company shall, as part of its management system and the programs referred to in section 55,
      • (c) establish and implement a process for identifying and analyzing all hazards and potential hazards;
      • (d) establish and maintain an inventory of the identified hazards and potential hazards;
      • (e) establish and implement a process for evaluating and managing the risks associated with the identified hazards, including the risks related to normal and abnormal operating conditions;
  • 48. A company shall develop, implement and maintain an environmental protection program that anticipates, prevents, manages and mitigates conditions that could adversely affect the environment.

Company action required:

Please provide additional information on the observed water well at the Ottawa Station, its historic and/or current use (if any), any future need for it or plans to decommission it, as well as any other pertinent information.

Due date: 2021-05-26

Date closed: 2021-05-31
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

There are no observations with outstanding follow-up

Observation 6 - Pipeline Right-of-Way (RoW) - General

Date & time of visit: 2021-05-24 14:00

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs
• Watercourses
• Railway and Road RoW
• Monitoring and Reporting
• Patrols, Inspection and Field Observations
• Vehicle or Mobile Equipment Crossings
• Authorization and Consent
• Temporary Crossings

Facility:

• Mainline (Pipeline)

Observations:

Ottawa Lateral Valve Site - Large asphalt removal equipment staged in TNPI's graveled site adjacent to cropped lands. Painted markings observed in the graveled yard near this equipment. TNPI Representatives were able to confirm with the local TNPI Land Representative that permission to stage this equipment in this area over TNPI's RoW and Prescribed area had been granted.
  
Ottawa River Crossing - Landowner / homeowner accompanied CER Officer in the inspection at this property. Landowner indicated this sign had been installed in the past year. Navigable Waters signage present on the southern shore of the TNPIs Ottawa River Crossing along the shoreline. Signage indicates operating company, emergency contact information, and prohibition for anchoring and dredging. Signage is only in French.
 
Rideau River Crossing - Navigable Waters signage present on both the southeastern and northwestern shores of the TNPI's Rideau River Crossing. Signs are newer and TNPI Representatives indicated that Navigable Water signage along the system has been updated in the past year as part of a signage replacement project. Signage indicates operating company, emergency contact information, and prohibition for anchoring and dredging. Signage is only in English.
 
General RoW - Observed in various urban and rural locations as well as at water course crossings. Water course crossings observed by CER Officer were indistinguishable from the surrounding environment, banks were stable having similar vegetative cover to areas adjacent to RoW. No concerns noted at agricultural land uses of the RoW observed.
 
Road Crossings - Pipeline identification signage observed at road crossings and in other relevant / required areas along the Pipeline RoW, primarily in areas adjacent to TNPI Stations inspected.
 
Vegetation Management – In several areas inspected, notably along RoW near the Ottawa River Crossing, the Rideau River Crossing, Iroquois Station, Mallorytown Station, several forested areas observed to have mature vegetation present. For several areas, vegetation had clearly been allowed to grow without intervention from TNPI maintenance and no brushing activities (vegetation management) had been completed in several years. TNPI Representatives showed awareness of vegetation management requirements associated with access for maintenance, in the event of an emergency, for surveillance and patrols, and for damage prevention requirements. TNPI Representatives indicated that there is currently ongoing planning and updating of procedures and requirements specific to RoW vegetation management needs, their implementation, and in scheduling brushing activities along TNPI's system.
 
Agricultural land – near one Operations and Maintenance (O&M) activity site in agricultural lands along the Pipeline RoW, TNPI Representatives and CER Officer had a brief discussion with a Landowner. In that conversation, the Landowner described the location of a site of historic unauthorized activity on the Pipeline RoW. CER Officer, accompanied by TNPI Representatives and inspected the area in question. Pipeline identification markers observed in pasture / wetlands area and signs of ditch trenching within the prescribed area of the Pipeline. No signs of recent ground disturbance were identified. Nonetheless, TNPI Representatives were able to retrieve records and provide information to the CER Officer with regards to a historic unauthorized activity having occurred at this location. CER Officer is satisfied of the preventative and corrective action taken at the time by TNPI for this site. No further follow-up required.

Compliance tool used: No compliance tool used

Observation 7 - Valves Sites - General

Date & time of visit: 2021-05-24 14:00

Discipline: Safety Management

Categories:

• Permanent Structures
• Signage

Facility:

• Mainline (Pipeline)

Observations:

Three (3) valve sites were inspected, Cornwall, Rideau River, Ottawa Lateral.
Cornwall Valve

• Cornwall Valve Site is located within the boundaries of a deactivated station which had formerly been a metering station (Cornwall Station), the station piping associated with the metering is currently in a deactivated status under ORDER MO-009-2021. Valve located at a riser adjacent to disconnected and deactivated prover piping.

• Rideau River Valve located on upstream side of the Rideau River crossing (southeast side of the river).
• This valve is located within a vault. Vault is locked, appropriate signage and railings/guards in place. Associated electrical cabinets for remote operation of the valve are locked and have appropriate signage in place. 
• TNPI pipeline identification markers in place at vault and along RoW.

• The Ottawa Lateral Valve Site is in a graveled area adjacent to a roadway on the edge of cropped lands.
• This valve is located within a vault. Vault is locked, appropriate signage and railings/guards in place.
• Associated electrical cabinets for remote operation of the valve are locked and have appropriate signage in place. 
• TNPI Representatives indicated that historically this site had once been a booster station.

Compliance tool used: No compliance tool used

Observation 8 - Operations and Maintenance (O&M) Activities

Date & time of visit: 2021-05-24 14:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Fire Protection
• Flammable and Combustible Liquids
• Hazard Assessment
• Temporary Structures
• Temporary Stairs, Ramps and Platforms
• Signage

Facility:

• Mainline (Pipeline)

Observations:

Three (3) sites part of TNPI's ongoing Integrity Dig Program were observed, each at a different stage of the process. Prior to these inspections CER Officer requested TNPI's spring O&M schedule to assist with planning, which TNPI provided as requested. 

The first O&M location inspected had been recently completed.

• The site clean-up completed with contours reestablished and returned to its pre-work condition.
• This site is in urban commercial/industrial area.
• TNPI Representatives indicated that reclamation activities at this location had been completed earlier that day with hydro-seeding.
• CER Officer observed the site to have appropriate erosion control measures completed by hydro-seeding with a tackifier. No concerns noted.
• TNPI Representatives indicated this O&M site would be re-visited and monitored for vegetation establishment as part of environmental monitoring requirements of its EPP.  

• TNPI Representative provided a review of the applicable:
  • Field Level Hazard Assessment (FLHA);
  • Safe Work Permit (SWP);
  • Job Safety Analysis (JSA);
  • Dig Package information including procedures, excavation checklist and trench inspection; and
  • Ground disturbance permit, One Call Ticket, and Locates.  
• Observed spotter being utilized in backing up vehicles.
• Smoking area established and identified with signage near worksite and near roadway entrance.
• Muster points identified with signage and located near roadway entrance.
• Temporary fencing and t-posts with caps in place along perimeter of workspace.
• Two ladders are in place on the western side of the hotline in the excavation although main access and egress to the ditch/pipeline is a dug-out slope allowing easy walk-down access.
• Emergency Response Plan, first aid kit, fire extinguishers, and other relevant information available onsite.
• CER Officer observed appropriate signage and personal protective equipment (PPE) being utilized by workers. 
• Temporary work space (TWS) limits identified with appropriate pink flagging, staking, and temporary fencing.
• Access matting is in place from roadway.
• Topsoil temporarily stored separately from subsoils and identified with signage.
• CER Officer reviewed Environmental Protection Plan (EPP) for the dig site, relevant permits, and required mitigation included in TNPI's Dig Package.
• The TNPI Inspector and contractor crew members demonstrated familiarity with TNPI’s procedures for environmental monitoring and requirements.

• Survey and flagging have been completed.
• Access and temporary work space TWS (TWS) is flagged with pink ribbon and stakes.
• TNPI Representatives provided CER Officer with the site-specific EPP for review.
• Recently completed bird sweeps identified one active nest at this site. Third-party avian consultant recommended delaying mobilization to site. TNPI representatives were able to demonstrate though documentation, the deferral of planned activities for this O&M activity in accordance with EPP mitigation and consultant recommendations.   

• TNPI’s pre-screening procedures, Environmental Protection Plans for O&M works, and also the Environmental Compliance Specialist’s oversight at O&M sites were discussed with TNPI Representatives.
• TNPI Representative exhibited awareness of TNPI’s requirements and processes, and sound technical awareness of the environmental issues that arise at O&M works.
• CER Officer notes that upon review of other site specific EPPs for upcoming O&M digs, that the format, usability, and detailed mitigative measures show improvement from those previously reviewed in recent CER related compliance verification activities. 
• No concerns noted at the O&M sites inspected or in documented EPPs for upcoming digs.

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:

Observation 9 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail

This information has been redacted pursuant to Section 144(5) of the Canada Labour Code