Compliance verification activity type: Field Inspection
Team:
Regulated company: NOVA Gas Transmission Ltd.
Operating company: TransCanada PipeLines Limited
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Environmental field Inspection of NGTL 2021 Expansion Project. Inspection focused on Edson South spreads including Robb, Dismal Creek, and Brewster. This area is almost entirely within the Alberta Green Zone, and characterized by forested terrain within the Foothills and Rocky Mountain Natural Regions. Main activities occurring at the Robb and Dismal Creek spreads were clearing operations (i.e., mulching and grubbing) and some stripping and grading on the Right-of-Way (ROW). Brewster was further along in construction progress and preparing for spring mitigations. No water courses had been disturbed at this time. Access mitigation measures were observed for all spreads. The Project was still in the early stages of construction.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - Robb - General Observations
Date & time of visit: 2021-03-16 10:00
Discipline: Environmental Protection
Categories:
Facility:
Observations:
The Right-of-Way (ROW) was not able to support a convoy of vehicle traffic during the time of the inspection. Instead, the inspection team was able to observe activities at selected points of interest. General observations were made under the following categories:Right of Way
Compliance tool used: No compliance tool used
Observation 2 - Dismal - General Observations
Date & time of visit: 2021-03-17 10:45
Observation 3 - Brewster - General Observations
Date & time of visit: 2021-03-18 09:30
The Brewster segment was further along in the construction phase and the ROW was traversable in some locations. General observations were made under the following categories:Clearing
Observation 4 - IR - Deficiency List (Robb, Dismal, Brewster)
Ground crews were observed to be actively addressing concerns in preparation for seasonal shut down and spring breakup. The Officers made observations at the following locations:Robb spread
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
The Company will provide an updated Deficiency List that indicates the concerns noted by the Inspection Team have been documented.
Due date: 2021-04-16
Date closed: 2021-04-01 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 - IR 2 - Spring Mitigations and Erosion Controls
Near shoe-fly access road at KP 38+450, the ROW leads down a steep coulee to a water course crossing. The area has been stripped and graded with soils and spoil piles at the edge of the ROW. Erosion and sediment controls were in place for the water course, though the Inspection Officer observed minimal controls in place for the sediments piled along the edge of the ROW.
The Company will respond to the following information request:
Date closed: 2021-04-26 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 - CNC - Housekeeping on Dismal ROW
Date & time of visit: 2021-03-17 15:14
On the ~400m walk between the access road and WC35 Officers and Company reps removed ~30 pieces of litter (broken flagging tape and stakes). A few broken stakes and pieces of litter were frozen in the ground and unable to remove by hand. Company indicated this area is on the deficiency list but it has been prioritizing preparing for spring break up. Company indicated they would have crews come and pick up the remaining pieces of litter.
Compliance tool used: Corrected Non-compliance (CNC)
Company removed waste and disposed of it appropriately, providing photos to demonstrate completion.
Due date: 2021-03-21
Observation 7 - CNC 2 - Failure To Abide By COVID 19 Safety Protocols
Date & time of visit: 2021-03-16 11:00
Discipline: Safety Management
Over the course of the three day inspection, a total of 19 workers not wearing masks correctly while working within 6 feet of others were observed by the Officer. These individuals were either not wear masks at all, or not wearing them properly (having either their nose, mouth or both uncovered). On all observed instances, either the Officer or the Company rep spoke to the individuals. In all but one of the instances observed, the individuals donned masks properly upon request.The one individual who failed to comply, on 16 March 2020, was the driver in a pickup truck with two other workers (sitting in the driver, passenger and rear passenger seats, therefore social distancing was not practicable) on the Robb Section. The pickup truck had no physical barrier protections installed in the vehicle. When asked by the Officer to don the mask properly, the driver explained that he can't cover his nose with the mask because it would fog his glasses which would pose a safety hazard for driving. Since Company reps were not present at the time, Officer relayed to the driver that they would communicate his rationale to the Company reps who may follow up with him themselves. Company reps were informed and relayed to the Officer later that day that because the individual was willfully breaching Company rules they were suspended from the worksite and discharged from the Company. A memo was issued at the following morning meeting for the Robb Section to remind all workers of the COVID protocol requirements, including the requirement to wear masks properly while working within 6 feet of another individual.
Company implemented the Project discipline ladder in this instance and discharged the individual who was willfully breaching the Company rules. The Company also issued a memo, to be discussed at the morning meetings on 17 March 2021, reminding all workers of the COVID protocol requirements.
Due date: 2021-03-17
Observation 8 - Indigenous Monitor Observations
Date & time of visit: 2021-03-16 09:00
Discipline: Indigenous Monitoring
Additional observations recorded by IAMC Indigenous Monitors participating in the CER inspection. Any compliance-related observations that require specific regulatory follow-up have been recorded above.Archeological Inspected old archeological site between KP 3 and KP 4. This site has an Alberta Culture, Multiculturalism and Status of Women (ACMSW)-approved avoidance plan. There was an opportunity to speak with the Participants in NGTL's Aboriginal Construction Participation Program (ACPP). Part of their job is to look for indigenous heritage sites and record any findings. There were three out on Robb Section, one participant on the Dismal Creek Section, and two on the Brewster Section.Site Orientations There were several site orientations on these inspections over the four-day period. The discussions at these site orientations was safety: some of the topics covered were the Emergency Response Plan (ERM), radio channels, road conditions and life saving rules. At another site inspection KP 48+800, reviewed safety orientation, site clean-up, safe driving conditions on muddy roads, and when to use a spotter when backing-up. At site orientation at KP 38 +500 inspected medivac helicopter pad. At each site orientation, there was a review of the Covid19 protocols and sign-off.Cleaning Practices There was discussion on the cleaning of equipment, where the solution is 2% industrial bleach compound to kill any contamination that might be on the equipment before it arrives on location. Inspected that equipment had the proper cleaning stickers.Watercourse There were several watercourse crossings during this inspection. Robb Creek Section, watercourse at KP 0+56 inspected, all mitigations were in place. Continued to inspect watercourse KP 3+740 and KP 4+240, all mitigations were in place. Inspected a newly constructed clear span bridge at KP 2+23, and all mitigations were in place. Inspected bridge at KP 38+621 for erosion.Dismal Creek Section watercourse #77 was inspected. Silt cloth mitigation was in place. There was not any rutting or soil compaction at this site. On this day an HDD at KP 21+500 was visited, for a site orientation and sign off on Covid19 safety policy and review a hazard assessment. Fire extinguishers were all up to date. Brewster Section watercourse at KP 9 +146 and Chamber Creek KP 57+130, all signage in place and mitigation measures in place. Inspected under river boring, all safety and mitigation measures in place.Wetlands Inspected wetlands on the Robb Section at KP 0+500 and all mitigations were in place. At wetland KP 10+817 up to KP10 +630 matting in place. On the Brewster Section, at KP 48 +720 inspected wetland berm, procedures in use were back filling and pipe jeeping.Other Observations There were two site orientations and inspections on the Brewster Section, one was inspecting pipe stringing at KP 44+250 where pipe was being installed in a ditch. The other was at KP 43+940 where the inspection was an open ditch. Ditch mitigation in place. Rope and flag barriers in place. At this last site, the Job Safe Analysis (JSA) was reviewed. There were two opportunities to inspect contractor burning slash piles. At these sites non-merchantable wood was being burnt. There was a fire truck on stand-by.Inspected power supply unit for oil and diesel leaks. All units had drip pans. Refueling signs in place. Refuelling mitigation inn place.At KP 35 on the Robb Section, inspection of noxious weed mitigation for control was discussed.
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
