Compliance Verification Activity Report: CV2122-154 - TransCanada Keystone Pipeline GP Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2122-154
Start date: 2021-07-05
End date: 2021-07-09

Team:

Regulated company: TransCanada Keystone Pipeline GP Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Environment inspection of clean up and reclamation activities related to the 2020 construction activities and previously completed HDD sites.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - Pre-Inspection IR No. 1

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Information is required to assist with scoping and planning for the upcoming inspection.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Provide the following information:

  1. A table breaking down the following:
    • The KP ranges and locations where any Project work has taken place to date;
    • What has been done in each range (clearing, ground disturbance, pipe installed, final clean-up, etc.);
    • Any areas where activities are either ongoing, outstanding or planned for the coming months;
  2. A copy of the current Landowner Consultation Tracking Table (maintenance of such is required by Condition 18).
  3. A copy of the most up-to-date COVID protocol for this project.

Due date: 2021-06-22

Date closed: 2021-06-22
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 - General Observations

Date & time of visit: 2021-07-06 09:30

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Right-of-Way Observations 

  • Where the ROW was stripped and graded, soil piles segregated and labelled. Wetland soils were observed to be segregated and stored separately from top and subsoil piles. Company stated that topsoil piles were tackified with a lignon-based product in 2020.  

  • Multiple erosion and sediment control (ESC) measures were observed to be not functioning properly at the time of inspection (see NNC No. 1 – Erosion and Sediment Control Measures). In some instances, sediment had trespassed off ROW (see NNC No. 2 – Trespass). 

  • Observed topsoil pile trespassing onto road allowance at Monitor KP 43+600 (see NNC No. 2 – Trespass). 

  • Non-listed weeds were present in varying quantities across the project. TCK stated they do weed control (either spraying, or manual removal in organic lands) prior to replacing the topsoil.  

  • Observed the South Saskatchewan River HDD entry pad. Final clean up had taken place approx. 2 weeks prior to the inspection. Area seeded and covered with a combination of straw crimping and hydro-mulching. ESC measures were installed (geotech fencing, waddles and diversion berms).  

  • Observed instances of litter on the ROW at the majority of sites visited, including: cigarette butt  at approx. Monitor KP 11+915;  two empty diesel exhaust fluid containers under access road matting at approx. Monitor KP 16+950; string and various pieces of construction debris at multiple places along the ROW including Bindloss KP 0+200, Oyen South KP 60+500). See NNC No. 3.   

  • Upon arriving at parking area near Oyen South 56+500, 2 Michels trucks were observed idling (units BC-324 and BC-406) with no workers in sight. TCK representative turned the vehicles off when questioned by the IAMC IM. EPP states that idling is permitted for up to one hour in extreme temperatures. Given the temperature at the time of observation was ~30C, this considered to be in compliance. However, TCK representative stated at the closing meeting that staff were reminded to not idle at the 7 July 2021 morning meeting.  

  • TCK provided records of wildlife mortalities that have happened on the project to date. Records indicate 13 non-listed species and 8 instances of SARA listed species mortalities have occurred on the Project (all Prairie Rattlesnakes). TCK was asked to provide wildlife observation forms completed for each of these instances, however only one form was provided.  See IR No. 1.  
  • While talking on the public road, near Access Road 51, Officer observed a bird’s egg on the side of the road, within the staked project boundaries. When Officer asked one TCK representative who was in their vehicle if they planned on doing anything, they made a joke and proceeded to turn their vehicle around.  After consulting the requirements outlined in the Nesting Bird Management Plan, Officer reminded the TCK representatives that they are required to assess the egg given that a nest is likely nearby. Pylons were put on the road to deter users from disturbing the egg. Wildlife Resource Specialists (AJM Environmental) arrived on site ~1.5hours later to assess the egg. They determined it was a sparrow egg, and based on their assessment (egg was cracked and sun-bleached indicating it had been there for some time), they determined it was a non-reportable observation.  


Bindloss Pump Station (PS) 

  • Bindloss PS construction is essentially complete at the time of inspection. Fully fenced substation is also constructed adjacent to the Bindloss PS on the north side, but TCK does not have access/control over that site – the utility provider controls that site. Graveled laydown yard is adjacent to the PS, which is underlaid by heavy duty geotextile to make gravel removal easier.  Power is not yet running to the Bindloss PS, power is provided by an on-site generator. TCK representative stated that workers are on site at least once per week for security purposes and to inspect and refill the generator. 

  • ESC measures still installed, final clean up not yet completed at the site. Litter observed within the Bindloss PS fence line and outside of it. TCK representative stated that there are a few things on the deficiency list for the site that require correction. Observed areas of erosion and observed geotech fencing required maintenance or correction at a couple locations around the PS (see NNC 1 for additional details on ESC at the site).  

  • Inspected a portion of the ROW adjacent to Bindloss PS. Final cleanup was complete on that section of the ROW – soil respread, seeded and straw crimped. TCK representative stated that straw is sourced from the landowners of the land, where possible. Unused straw is returned to owner or permission obtained to use in other parcels.  

 
Ness Property  

  • Visited a site, north of Access Road 51 at Monitor KP 11+915, where landowner concerns were identified in the Condition 18 (c.18) tracker. C.18 tracker indicated the concerns related to ESC measures and indicated most of the issues were referred for future monitoring.  

  • Observed the slough referred to in the c.18 tracker, where concerns with water levels were identified. Wetland and no-refueling signage present. No sitting water was observed in the slough at the time of inspection. Officer noted other comparably sized wetlands in the area also appeared to be low or dry.  

  • Observed downed geotech fencing across the slough on the north side, but were unable to assess up close given the proximity of heavy equipment working. In one area of down fencing appeared to be completely disconnected and another area appeared to be falling down. 

  • Observed an area ~40m x 10m outside of some semi-permanent fencing on the south side of the slough. A length of geotech fencing was down on the outside of the fencing and mostly underneath what appeared to be disturbed soil (see NNC No. 1). TCK representative stated that there used to be mats around the slough when they were constructing and the water levels were high. Company provided a photo of what the set up looked like and a copy of the updated landowner agreement showing the agreed upon additional TWS.   

  • Visited another area of the Ness Property, at approx. Monitor KP 16+950. Additional issues with ESC measures were observed (erosion, down geotech fencing) and some litter was observed in wetland WL-580 (see NNC No. 1 – ESC, and NNC No. 2 – litter).  

  • Discussed how TCK's land rep follows up with landowners following these types of events/inspections. Land representative said he will reach out to the landowner and provide an update. TCK is to provide an updated copy of the c.18 tracker to reflect any additional concerns.  

 

Compliance tool used: No compliance tool used

Observation 3 - IR - Traditional Knowledge (TK) and Heritage Sites

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

Background:

TK-047:TK-001 to TK-005:POI-001:TK-011

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Explain what measures TCK implemented at the access road near TK-047 to prevent public access while the ROW was not actively being worked on.  TCK's Condition 16 submission dated 25 May 2011 states "Keystone plans to employ a total of four Aboriginal Resource Technicians (ART or Aboriginal construction monitors), two per pipeline construction spread, whose specific duties will be to monitor mitigation activities for heritage and TK sites during construction." (emphasis added). 

TCK's Project EPP dated April 2020, outlines mitigations relating to Clean-up and Reclamation, including Topsoil/Strippings Replacement, in Section 8: Project Construction. 

During the inspection, CER and TCK discussed the feasibility of accomodating one of the Company IM's request to be present during Topsoil/Strippings Replacement at POI-001, which is culturally significant to their Nation. TCK stated that they needed to consult with additional stakeholders (e.g., land agent, crews, etc.) before it could state whether it would be able accomodate the request. 

Provide an update on what TCK has determined relating to the Company IM's request to be present duing soil replacement activities at POI-001. 

Due date: 2021-08-13

Date closed: 2021-09-08
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 - IR - Species at Risk

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Condition 7 Appendix C, in Table C-1: Wildlife Project-Specific Mitigation Measures outlined in the January 2019 Condition 7 filing (PDF pg. 135 of 136, A97058-3) outlines the following mitigations for Prairie Rattlesnake: 

The Officer was unable to find mitigations outlined in Appendix C of Condition 7, in the 2019 EPP (A97058). Condition 13 requires that "The EPP shall be a comprehensive compilation of all environmental protection procedures, mitigation measures, and monitoring commitments, as set out in Keystone’s application for the Project, subsequent filings or as otherwise agreed to during questioning in the OH-1-2009 proceeding or in its related submissions."

During the CV2122-154 Opening Meeting, CER and TCK discussed whether there were any mortalities of species listed on the Species at Risk Act (SARA). The Officer requested copies of each of the Wildlife Observation documentation for each of the SARA species mortalities that had occured on the project. On 14 July 2021, TCK provided a table outlining the list of SARA species mortalities on the Project within the last year. The table listed details of mortalities of 8 Prairie Rattlesnakes that have occured on the Project. Upon request, TCK provided one Wildlife Observation form for the 11 August 2020 mortality. 

All eight of the mortalities outlined in the table occured in the months between June to August.  Three mortalities also occured in the locations specifically referenced in the Condition 7 mitigation listed above (Oyen KP 49+600, Oyen KP 49+900 and Bindloss KP 12+500). 

 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

  1. Explain where in the EPP the mitigations outlined in Condition 7 are located in the most recently approved EPP.
  2. Provide a copy of the orientation training provided to workers.
  3. Provide copies of each of the remaining 7 Wildlife Observation documents previously requested.
  4. Confirm whether any additional SARA mortalities have occurred since the 14 July 2021 update.
  5. Provide the following information for each of the SARA-species mortalities that have occurred on the Project in the last year:
    1. The activities being conducted at the time of the mortality;
    2. Whether ‘appropriately trained personnel’ were on site (i.e., within the work area of the applicable crew) to monitor construction;
    3. A copy of the daily tailgate meeting documentingn who caused/discovered the deceased rattlesnakes (i.e., tailgate documentation from 17 Jun 2021, 12 June 2021, up to and including 11 Aug 2020, along with any more recent incidents);
    4. Location of the rattlesnake signage nearest the deceased snake;
  6. Explain why work was being done between May 1-Sept 30 within the locations that Alberta Environment and Parks recommended TCK avoid during those periods.  
  7. Explain whether TCK has adjusted or changed its mitigations to prevent further occurrences of SARA species mortalities. If changes have been made, provide details. If no changes have been made, explain why not.

Due date: 2021-08-13

Date closed: 2021-10-01
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 - PCEM Reporting

Discipline: Environmental Protection

Categories:

Facility:

Observations:

In the Opening Meeting, TCK stated that it plans to conduct post-construction environmental monitoring (PCEM) at all pump station and pipeline areas that had works completed, regardless of the level of construction completed. They will submit the PCEM reports, required by Condition 19, to the CER. First year PCEM is planned to be done next year, and the first report anticipated to be filed in 2023.  TCK stated that if they can’t complete all of the final clean up in 2021, the PCEM in the delayed areas will start in 2022.  

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Confirm that TCK's plan for PCEM reporting is accurately reflected and provide any additional details that may be relevant to the CER. If it is inaccurate, describe TCK's plan for PCEM reporting. 

Due date: 2021-08-20

Date closed: 2021-09-14
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 6 - NNC No. 1 - Erosion and Sediment Control Measures

Date & time of visit: 2021-07-08 17:30

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Monitor Section

Lakesend Section
Bindloss Pump Station
Based on the numerous identified issues observed relating to ESC measures, the Officer has issued NNC No. 1. 

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

Regulatory requirement:

Relevant section(s):

Company action required:

1. On or before 23 July 2021, TransCanada Keystone (TCK) must file an ESC Corrective Action Plan, outlining / including:
a) Confirmation that TCK has had a qualified person inspect and assess all ESC measures across the Project, where any ground disturbance has taken place since Project approval;
b) A prioritization system for the correction of any inadequate or ineffective ESC measures, or areas that require but do not yet have ESC measures, identified during the inspection required in part a);
c) Section-specific tables that outline breakdown the number of sites for each prioritization within the respective sections; and
d) A description as to how, and at what frequency, TCK will be carrying out ongoing monitoring of ESC measures going forward.
 
2. Ensure corrections of any inadequate or ineffective ESC measures are implemented, under the supervision of a qualified person, as follows:
a) At a minimum, high priority sites shall be corrected on/before 6 August 2021. Provide confirmation, on/before 6 August 2021, that this has been completed as well as photos and the KP locations of each corrected high priority site.
b) Low (+/- moderate) priority sites shall be corrected on/before 20 August 2021. Provide confirmation, on/before 20 August 2021, that this has been completed.

Due date: 2021-08-20

Date closed: 2021-09-23
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 7 - NNC No. 2 – Trespass

Date & time of visit: 2021-07-06 10:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

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

Regulatory requirement:

Relevant section(s):

Company action required:

At the closing meeting, TCK representatives confirmed that the areas of trespass identified during the inspection will be added to the list of sites to monitor during PCM.

Due date: 2021-07-09

Date closed: 2021-07-30
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 8 - NNC No. 3 – Litter and housekeeping

Date & time of visit: 2021-07-06 16:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

At closing meeting, company stated that they issued a reminder at the 8 July 2021 Inspectors meeting that cigarette butts are to be disposed of properly and not litter them.
 

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

Regulatory requirement:

Relevant section(s):

Company action required:

Explain how TCK has communicated the requirements and expectations regarding litter and construction waste along the construction footprint. 

Due date: 2021-08-13

Date closed: 2021-09-23
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 9 - NNC No. 4 - Working within timing restrictions for Species at Risk

Date & time of visit: 2021-09-27 10:11

Discipline: Environmental Protection

Categories:

Facility:

Observations:

The EPP states "Mainline construction activities from Oyen South KP 49+108 to 51+000 and Bindloss South KP 12+469 to 13+960 and 16+630 to 17+393 shall be conducted between October 1 and April 30, depending on conditions."

Following the closing meeting, TCK provided a list of any mortalities of species listed under SARA that had occured since the start of project construction. TCK provided details of eight mortalities of Prarie Rattlesnakes (listed on Schedule 1 as a species of Special Concern), four of which occurred in June 2021 within the areas subject to timing restrictions. 

TCK provided the following additional information in response to IR - Species at Risk:

TCK stated that AEP is notified of mortalities via presentations with the SAR bilogist in an annual presentation, and via Fish and Wildlife Information Management System data uploads at the end of the calendar year. TCK further stated that "regular consultation and communication occurs between the project and the AEP SAR biologist regarding general wildlife observations and mitigations applied during construction" and that AEP did not suggest any additional mitigations in response to the mortalities. 

Given four of the snake mortalities occured wtihin the locations on which timing restrictions apply, the Officer has determined that TCK was in non-compliance with the abovementioned mitigation. 

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

Regulatory requirement:

Relevant section(s):

Company action required:

Provide documentation to demonstrate that AEP has been notified of the mortalities that occured within the restricted timing windows. 

Due date: 2021-10-08

Date closed: 2021-11-09
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 10 - IAMC Observation - Metis Nation Region 3

Date & time of visit: 2021-07-08 17:00

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:



1.0          INTRODUCTION
The environmental reclamation inspection took place near the town of Oyen, and included visits to Bindloss, Oyen, Monitor and Lakesend Section of the KXL Pipeline Project between July 5-9, 2021.  Overall, the Indigenous Monitors were pleased with the pipeline operations and the company representatives in explaining the operation as well as answering questions.
 
2.0          OBSERVATIONS
2.1          Archeological
Visited TK 047, company IM elder wanted to show the site, and share their concerns.  TC had debriefed us at our first meeting when we had arrived on July 5th. Many elders shared that these sites are important markers either as guides or warnings of what is ahead. There are not any records or documentation from the original assessment about the stones. TransCanada Keystone is undergoing internal research to find the original documents.  The elder said there were photos taken in the original report, she has requested that report from her community. The area had been identified as an area of avoidance. There was signage in place as well as the area was roped off.
Next site visited was TK 005 The company IM elder again concerned about the missing stones They could be buried under the topsoil piles next to the site There was conversation about being present when the construction crew is reclaiming those soils.
2.2          Vegetation
Met with TC Energy personnel, at the Bindloss Pump Station(PS), and went through a JSA. Talked about the area around the substation, and the berm clean-up. Erosion Control fencing needed maintenance. Could see the ROW seeded area outside of the fenced PS. We asked about the seed mix being used, TC Environment person said it was a “agroeconomics” mix which is Canada Blue grass, and sheep fescue. Compatible to dry areas. The PS station site will be cleaned up in August, there was lots of debris around. North side of the PS the Erosion Control fencing was breached. We walked the seeded ROW, the straw is sourced locally, and the unused straw will be returned to the owner or used elsewhere.
Stopped at a SARA listed species site – Tiny Cryptanthe. Fencing and signage in place. The seed mix in this area is #5, but not rare plants seeds. The TC Environment person talked about the rare plant seed mix, and that it would be applied in the fall.
The next stop was to review another SARA species – Slender mouse ear cress. At the site there were two vehicles left idling, and no one around. The TC Environment person turned off the vehicles. We were told that in the EPP vehicles were allowed to idle for one hour in extreme temperatures. The temperature on that day was 30 degrees.
2.3          Wildlife
CER lead found small egg on the side of the road as we were walking back to vehicles. Called in wildlife specialists, AJM Environmental. This was a sparrow egg, a non-reportable observation.
At the Bindloss PS inspection, near the porta potties, the TC Regulatory person spotted a rattlesnake just laying on the gravel.
2.4          Soils
Drove along the ROW and stopped to review topsoil sites. Discussed the weed control measures for these sites.
2.5          Wetlands
Visit one of the Landowners and their concern about his slough listed in the Condition table is the slough is not maintaining water, at Access Road 42 – Monitor Segment. There were several places the silt fencing was down and needed to be fixed. A cigarette butt was found where the workers were having their morning meeting. The slough is located approximately Monitor KP 11+600, open cut. Several silt fencing down. The landowner had a fence up where there was a TWS, used to go around the slough. The question was raised about how that TWS now that it is fenced will be reclaimed. The area needs a final clean-up.
Stopped at WL 764.The erosion barrier had been compromised. The silt was going into the TWS.  The erosion silt fencing needs maintenance.
2.6          Other Observations
Loyalist Creek Access Road 51, the “No Vehicle” access ropes and signage down. Could see tire tracks on the ROW. This area was stripped and graded in Aug/Sept of 2020, no pipeline here.
 
3.0          NON-COMPLIANCES/COMPANY FOLLOW-UP REQUIRED
At every site visit, the erosion fencing needed repair, or there was debris on the ROW. TC was very open to conversation and resolution for the “missing” stones at the TK sites we visited. They are researching internally for the archived documents from the previous surveys and are committed to finding a solution.
 
4.0          SUMMARY
It was a very intriguing experience it be part of the field inspection group and working along with the CER, Michel’s KXL, and the IMs.  I gained a lot of knowledge at every inspection and every stop along the ROW.  At the end of day we would have a close out meeting and discuss highlights.  Any questions that were asked some one would have a answer.  The mitigative measures the prime contractor and the proponent put in place are working as intended and the companies are following the EPP.
The company IMs were knowledgeable about the heritage sites, and shared their history of the area. The Proponent and the Prime Contractor went to great lengths to address questions and concerns, and we very open to “fix” any issues that the team pointed out.
I was impressed how the Proponent and the Prime Contractor went to great lengths to ensure that the inspection team was able to visit as many sites as we did.
Covid19 safety and Personnel safety were Number One.

Compliance tool used: No compliance tool used

Observation 11 - IAMC Observation - Thunderchild First Nation

Date & time of visit: 2021-07-08 16:00

Discipline: Indigenous Monitoring

Categories:

Facility:

Observations:

1.0 INTRODUCTION 
The Canada Energy Regulator (CER) CV2122-154 Environmental inspection on the KXL Expansion Pipeline (project) took place in Oyen AB, from July 6th-9th, 2021. The day we travelled to Oyen the inspection team met and discussed the scope of the project prior to meeting with the company. Opening meeting with TransCanada Keystone (TCK ) and Michels (KXL prime contractor ) took place in the Oyen Yard where the inspection activities were planned for the following week. Closing meeting took place July 08, 2021, after having a day in the field. The company participants along with CER and IAMC Indigenous Monitors (IMs ) discussed the inspection that took place. There were no official complaints with traditional knowledge (TK) or IM related observations and any IRs, NNCs or CNCs were made by the CER officers.
2.0 OBSERVATIONS
2.1 Archaeological
  • Company stated that an Archaeologist will assess features  along the right of way and determine if the site falls under Heritage Resources Act (HRA) to be protected under the HRA. This does not include TK sites as some sites do overlap the TK sites are marked off by the Indigenous and Metis communities.
2.2 Wildlife
  • Monitor KP 44+715 observed an antelope
  • Monitor KP 45+100 observed an grouse lek
  • Pump station by road 10 – rattlesnake encounter
  • Monitor KP+500 observed a Lone sparrow egg
  • Crows and ground squirrels were spotted throughout the ROW.
2.3 Wetlands
  • Wetland WL-752:  Observed a straw waddle for erosion control that needed repair, subsoil and topsoil mixing and seeping into wetland. Company stated that is being monitored.
  • Wetland WL-764: observed a silt fence deficiency , west silt fenced had already been fixed prior.
  • Silt fence deficiency was a common reoccurrence throughout the project.
2.4 Soil
  • Soil piles were staked and marked throughout the project,
  • Monitor KP 43+700: Topsoil was trespassing 1-2’ outside of the project boundaries .
  • Company stated that soil piles are sprayed for weeds before they are spread across ROW.
2.5 Other observations
  • Silt fence deficiency (falling down, full or not keyed in to the edge of disturbance, etc.)  and housekeeping were two main reoccurring issues throughout the inspection.
  • Monitor KP 11+915 a landowner has soil erosion concerns as a silt fence on a slough that was pushed down by soil.
3.0 TRADTITIONAL KNOWLEDGE
  • TK-47 rocks that completed a constellation were not marked down on the original survey therefore were moved and not kept aside. Discussed whether one of the Company IMs be present during the time the soil is to be moved back incase they see the rocks that belong to the constellation so long as all safety and land access measures are met. 
  • TK 1-5 There was missing rocks that were not documented, more signage will be put up to warn others that is a sensitive feature. Upon arrival to this site an elder had made a prayer in Cree as we were approaching the Neutral Hills and a TK site that meant something to the nations.
  • TK 11 All mitigations are being met.
  • Overall, the Company IMs wishes seemed to be  being met, and they seem  to enjoy being a part of the project, learning from each other and sharing their knowledge. 
4.0 NON-COMPLIANCES/COMPANY FOLLOW UPS:
  • All IR, NNC and CNC were done by the Environmental Inspection Officers.
5.0 INSPECTION SUMMARY:
  • This inspection was great to be a part of, I learnt a lot about the reclamation phases of the construction process. Meeting with the Company IMs, listening to their stories and being able to take part of their knowledge sharing is a great experience. The inspection overall went well it has been great seeing this project through from the start. Working with the company and TCK was great they were open and transparent with the information shared.

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