Compliance Verification Activity Report: CV1920-443 - Trans Mountain Pipeline ULC


Compliance verification activity type: Field Inspection

Activity #: CV1920-443
Start date: 2019-08-19
End date: 2019-08-22


Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):


Related events:

Rationale and scope:

Response to frac-out at North Thompson Crossing HDD (KP 593.9) 52.07 Lat, -119.32 Long On 17 August 2019, the Board was notified of a terrestrial drilling fluid release on the Trans Mountain North Thompson River Crossing No. 6 Replacement Pipeline Project. While operating a Horizontal Directional Drill (HDD), a release of drilling fluid (bentonite) occurred into a seasonal, low gradient unnamed tributary (S2 fish bearing watercourse) of the North Thompson River at approximately KP 594.1. The release occurred outside of the Project’s temporary work space. The release of drilling fluid was contained to the tributary, which only had intermittent pools of water and was isolated from the North Thompson River. Notifications were made to the Emergency Management British Columbia (EMBC), the British Columbia Oil & Gas Commission (BCOCG) and to the Simpcw First Nations. An additional eighteen indigenous communities were notified. NEB Inspection officers deployed to the site 22 August 2019.

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - Did Not Follow Own Procedure for Drilling Resumption - NNC

Date & time of visit: 2019-08-21 16:48

Discipline: Environmental Protection




The NEB received a phone call from the Transportation Safety Board of Canada (TSB) at 19:00 on August 17, 2019. The TSB indicated that Trans Mountain had contacted them regarding a frac-out of drilling fluid onto land adjacent to the North Thompson River.  Trans Mountain also immediately contacted the Province and notified local First Nations (Simpcw First Nation). Trans Mountain indicated that Simpcw First Nation has not expressed any immediate concerns.

The NEB called the company and received additional details as follows: A frac out of an unknown volume of bentonite drilling fluid occurred during Horizontal Directional Drill (HDD) operations at an O&M site adjacent to the North Thompson River. Frac out location is on exit side of drill, occurred on land and flowed into a seasonal tributary channel of the North Thompson River. The tributary channel has been isolated and is not flowing, but still contains water from when water levels in the river had receded. Trans Mountain is not aware of any immediate impacts to wildlife at present time.

On 19 August 2019, the BCOGC issued an interim authorization to access land outside of the Project’s Temporary Work Space to clean up the release. TM resumed drilling on 19 August 2019; however, they were required to suspend drilling until a revised permit was issued by the BCOGC to allow them to proceed with operations. On 20 August 2019, the BCOGC issued a revised permit and TM resumed drilling shortly thereafter.  At no time did the company request or receive approval from DFO to resume drilling operations after the frac-out occurred. 

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

Regulatory requirement:

Relevant section(s):

Company action required:

TM did not have approval from a DFO Fisheries Biologist prior to resuming drilling operations as required per the EPP's Directional Drilling Procedures and Drilling Mud Release Contingency Plan.  Provide a root-cause analysis of the non-compliance and documentation that the non-compliance has been discussed internally with TM staff and contractors to ensure procedures as identified in the EPP are complied with.

Due date: 2019-09-10

Date closed: 2019-09-10
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 2 - Document Review

Date & time of visit: 2019-08-23 09:00

Discipline: Environmental Protection




The following documents were reviewed:

  1. Email correspondence between BCOGC and TM re: OGC permit revisions - August 19 and 20
  2. Figures of North Thompson 6 Water Quality Monitoring Sites
  3. Sommerville Drill Fluid Control Plan
  4. TerraHDD Solutions Mud Disposal Plan
  5. Sommerville Emergency Response Plan
  6. BC Wildlife Act Permit
  7. BC Fish Collection Permit
  8. DFO Fish Salvage Permit
  9. Estsek Environmental Memo to TM re: Frac-out Aquatic Assessment & Recomendations - August 19, 2019
The company and contractors were following conditions outlined in documents 1-8 (permits and plans).

The recommendations in document 9 contradict the EPP's Directional Drilling Procedures and Drilling Mud Release Contingency Plan.  This discrepancy is to be addressed in the NNC.

Compliance tool used: No compliance tool used

Observation 3 - Drilling Mud to Surface Release - Unnamed Seasonal Tributary to North Thompson River

Date & time of visit: 2019-08-21 17:00

Discipline: Environmental Protection




Two areas approximately 110 x 10 m and 60 x 8 m were cleared to access the location of the release. Trans Mountain (TM) Staff indicated that the site was not cleared ahead of time. TM attempted to use 2 inch trash pumps prior to clearing; however, due to the viscosity of the mud, their attempt was unsuccessful.

Upon arrival to the site, TM Staff were in the process of reaming. TM Staff stated that it was not feasible to change the drill path as it could cause further instability.  

Prior to clearing, the route was discussed with Simpcw. Sensitive habitat was considered and a caribou habitat survey was completed; the shortest path was chosen and a bend was incorporated to reduce line of site.

Two vac trucks were on standby near the site entry, a third vac truck was located near the tributary where the surface release occurred.

Top soil was not cleared and rig matting was in place to protect top soil. Cleared trees and brush were piled adjacent to the route.

TM Staff indicated that a total of 74 m3 of drilling fluid was lost; approximately 30 m3 released to surface and 44 m3 is still in the formation. Approximately 30 m3 was recovered and returned to the rig for re-circulation.  TM Staff indicated that the initial review of mud and water reports from the drilling contractor indicated that the concentrations of the additives used in the drilling fluid were below the toxicity threshold and not toxic to fish.

At the release site, NEB IOs observed drilling mud self-contained within an isolated pool of the channel.  The impacted area is approximately 40 m in length and 3 to 5 m in width. Primary and secondary isolation dams were present upstream and downstream of the release to prevent further migration. The mud did not appear to migrate beyond the barriers. Hay bails used for the dams were locally sourced and visually inspected for weeds. The channel did not have free flowing water and contained several pools of standing water.  

TM Staff indicated that 1 dead and 1 stressed juvenile Coho Salmon were identified on 19 August 2019. Five additional deceased juvenile Coho Salmon were later identified. Fifteen Coho Salmon were salvaged. Appropriate Fish Collection Permits were acquired.

Water quality monitors were present in the North Thompson River both upstream and downstream of the HDD site at the time of the incident. No changes in water quality were detected. Water quality is being monitored continuously during drilling operations. Frac-walks were expanded and the frequency was increased. In order to prevent another drilling fluid release, the viscosity of the drilling mud was decreased. The addition of a “pill” to the drilling mud was not required.

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:

- 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