Compliance Verification Activity Report 1516-432 – NOVA Gas Transmission Ltd.

Type of Compliance Verification Activity: Field Inspection

Activity #: 1516-432
Activity start: 07/12/2015
Activity End: 11/12/2015

Related Activity Numbers: 1516-434 and 1516-442

Inspection Officer Number(s): 1680

Incident #:
Landowner Complaint File #:

Company: NOVA Gas Transmission Ltd.

Facility Name(s): Liege Lateral Loop 2 (Thornbury Section)

Province(s): Alberta

Theme(s): Environmental Protection

Compliance Tools Used: Corrected in field (Corrected Non-Compliance) (2)
Information Request (2)
Notice of Non-Compliance (NNC) (3)

Purpose

This activity was undertaken to verify compliance with the following regulatory requirements.

 X  NEB Act

 X  Onshore Pipeline Regulations

 X  CSA Standard Z662 Oil and Gas Pipeline Systems

    Other:

    Electricity Regulations

    Processing Plant Regulations

    Pipeline Crossing Regulations Part I

    Pipeline Crossing Regulations Part II

Regulatory Instrument

XG-N081-003-2015

Observations & Discussion

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 3 + 100 Environmental Protection Yes

Observations

- Minimal surface disturbance procedure (MSD Procedure) has been used for preparing the Right-of-Way (RoW) for the pipeline project including vegetation clearing and bridging over watercourses.

- RoW vegetation was cut, mowed and broken up using a light mulcher.

- Line-of-sight feature has been designed for this location as per the Caribou Habitat Restoration Plan.

- Willow stakes will be planted across the width of the RoW (~30 m) in a 10 m wide section. The exact location of willow planting will be selected based on site conditions.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 3 + 400 Environmental Protection No

Observations

- Site selected for installation of an access control feature.

- Earth mounds (mounding) will be constructed across the width of the RoW, for a 50 m long section. Mounds will be planted with coniferous trees, e.g. spruce and pine species. The exact location of mounds will be selected based on site conditions.

- Construction waste on RoW - broken skid and plastic crate.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 4 + 697 Environmental Protection Yes

Observations

- Epoxy applied to small chips in the pipe coating, with adequate protection in place to catch drips on the ground underneath.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 6 + 230 Environmental Protection Yes

Observations

- Rare plant species (Goldthread) identified with signage. Plant is surrounded by fencing, and will be left undisturbed throughout construction.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 7 + 300 Environmental Protection Yes

Observations

- Watercourse crossing #2 identification signage in place as a protection measure.

- Vegetation has been hand cleared within 10 m of watercourse in order to protect the riparian root system and the organic layer from disturbance.

- Vehicle access over this small watercourse will be constructed using machine made, and natural snow.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 7 + 300 Environmental Protection No

Observations

- Truck idling on the RoW. The NGTL Environmental Inspector stated that there has been on going awareness training for this EPP requirement.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 7 + 900 Environmental Protection Yes

Observations

- RoW has been graded, and the organic layer has been stockpiled separately from the mineral soil.

- RoW graded away from wetlands as per the EPP.

- EPP requires the company to salvage timber, and for this Project NGTL has been given authorization from AB Government to use the merchantable timber as rollback for caribou mitigation.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 8 + 800 Environmental Protection Yes

Observations

- Woody debris left over from clearing is being burned on the ditch-line using a metal sloop with walls to contain the fire, as specified in the MSD Procedure.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 9 + 500 Environmental Protection Yes

Observations

- Wildlife trail has been identified, and then marked. Access will be maintained across the RoW during every phase of construction.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 7 + 500 to 10 + 000 Environmental Protection Yes

Observations

- Trucks spraying water along the RoW to induce frost formation prior to frost packing by heavy equipment. Freezing in the mulched layer provides protection of underlying vegetation from compaction by traffic.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
09-Dec-15 Pipe Yard Environmental Protection Yes

Observations

- Historic infestation of Scentless Chamomile at the location where the pipe yard has been established. Hand pulling and chemical treatment applied prior to use, then the entire yard was covered with wood matts to prevent vehicles and equipment from picking up weed seeds in the soil and transporting to other locations on the pipeline RoW or access roads.

- NGTL will monitor, conduct treatments, and report in the Post Construction Environmental Monitoring Report the effectiveness of scentless chamomile control in future growing seasons

Observations & Discussion
Date visited Location Theme Compliance Confirmed
09-Dec-15 KP 2 + 200 Safety Management No

Observations

- An unsecured ladder was located in the excavated pipeline ditch. This is a safety non-compliance.

- Upon a return inspection to the site later in the day, NGTL had secured this ladder.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
09-Dec-15 KP 2 + 200 Environmental Protection No

Observations

- Smoking observed outside of a designated smoking area on the RoW.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
09-Dec-15 KP 0 + 100 Environmental Protection Yes

Observations

- Sub-surface water in the pipeline trench being pumped into a well vegetated area, and adequate erosion protection in place.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
09-Dec-15 KP 0 + 400 Environmental Protection Yes

Observations

- Land spreading of Highway 63 Horizontal Directional Drill (HDD) slurry at this location. NGTL confirmed a Technical Field Authorization was obtained from the Provincial Regulator to conduct this activity.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
09-Dec-15 KP 0 + 900 Environmental Protection Yes

Observations

- Pipeline has been installed at this location. The backfill material is approximately 1 m high, and will settle as the frozen material melts over time.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
09-Dec-15 KP 1 + 400 Environmental Protection No

Observations

- Discarded food waste observed on the side of the RoW and was being eaten by a raven. NGTL representative immediately picked up discarded food waste and disposed appropriately. The food waste was not adequately contained, and this is a non-compliance to the EPP.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
09-Dec-15 KP 1 + 500 Safety Management No

Observations

- Two workers in an excavated ditch operating “Tiger Torches” without fire resistant clothing, plus with a container of Acetone (MSDS 300-010) nearby. In addition, a fire extinguisher did not appear to be in the ditch during the work activity.

- The MSDS 300-010 Acetone contains the statement "Extremely flammable liquid and vapor, and vapor may cause flash fire".

Observations & Discussion
Date visited Location Theme Compliance Confirmed
10-Dec-15 Equipment Yard Environmental Protection Yes

Observations

- Equipment cleaned, then inspected to ensure weed contaminated soil is not transported to the RoW. A project specific sticker is applied to each machine once it passes inspection, and the date of each equipment inspection is recorded in a log book that is kept in the onsite Environmental Inspector Office.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
10-Dec-15 Wash Station in Equipment Yard Environmental Protection Yes

Observations

- Equipment wash station was lined with geo-tech fabric, and a ditch was present for soil and water collection. The ditch is pumped out, as needed, and liquid is disposed of at a Hazardous Waste station.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
11-Dec-15 Closing Meeting Environmental Protection No

Observations

Appendix 1E in the EPP does not contain the 'Instream Drilling Mud Release Contingency Plan'.


Compliance Summary

Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Environmental Protection Corrected in field (Corrected Non-Compliance)  
Date/Time visited Location
08/12/2015 2:30:00 PM KP 3 + 400

Observations

- Site selected for installation of an access control feature.

- Earth mounds (mounding) will be constructed across the width of the RoW, for a 50 m long section. Mounds will be planted with coniferous trees, e.g. spruce and pine species. The exact location of mounds will be selected based on site conditions.

- Construction waste on RoW - broken skid and plastic crate.

Regulatory Requirements

Order XG-N081-003-2015 , Condition 3 states "NGTL shall implement or cause to be implemented all of the policies, practices, programs, mitigation measures, recommendations, procedures, and its commitments for the protection of the environment included in, or referred to in its application or in its related submissions".

The Environmental Protection Plan (EPP), Page 21 states "The Contractor will collect all construction debris and other waste material, and dispose of daily at an approved facility and in accordance with the Waste Management Plan as well as the Spill Contingency Plan unless otherwise authorized by the Environmental Inspector(s)".

Corrective Action or Request Required

NGTL representatives confirmed that construction waste was picked up immediately, and that it is being picked up daily as per the Environmental Protection Plan (EPP).

Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Environmental Protection Corrected in field (Corrected Non-Compliance)  
Date/Time visited Location
08/12/2015 4:00:00 PM KP 7 + 300

Observations

- Truck idling on the RoW. The NGTL Environmental Inspector stated that there has been on going awareness training for this EPP requirement.

Regulatory Requirements

ORDER XG-NO81-003-2015, Condition 3 states " NGTL shall implement or cause to be implemented all of the policies, practices, programs, mitigation measures, recommendations, procedures, and its commitments for the protection of the environment included in, or referred to in its application or in its related submissions".

The EPP, Page 22, Mitigation Measures for Air Quality/Emissions states "Reduce idling of equipment, where possible".

Corrective Action or Request Required

NGTL Inspectors were reminded in the morning meeting to only idle trucks when necessary.

Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Safety Management Notice of Non-Compliance (NNC) 14/01/2016
Date/Time visited Location
09/12/2015 2:00:00 PM KP 2 + 200

Observations

- An unsecured ladder was located in the excavated pipeline ditch. This is a safety non-compliance.

- Upon a return inspection to the site later in the day, NGTL had secured this ladder.

Regulatory Requirements

ORDER XG-NO81-003-2015, Condition 2 states " NGTL shall cause the approved Project to be designed, located, constructed, installed, and operated in accordance with the specifications, standards, commitments made and other information referred to in its application or in its related submissions".

TRANSCANADA PIPELINES PRELIMINARY SITE SPECIFIC SAFETY AND SECURITY PLAN, dated August 2015 (TCPL Safety Plan)

Section 14. Ladders
3. Supervisors are responsible to ensure instruction for workers and that they are competent in ladder usage.
f. Surface for ladder must be level and firm, and then held, tied or otherwise secured to prevent slipping.
g. Ladder will be anchored and set at an angle so that the distance from the base to the vertical plane is approximately 25% of ladder length.
i. Ladder should extend a minimum of 1 m above the ground level when placed in an excavation or trench, or 1 m above a platform or landing.
q. ensure a “Field Level Hazard Assessment” (FLHA) is performed prior to beginning the task.

Corrective Action or Request Required

GTL will provide to the Inspection Officer via email the following information:

a) The FLHA for KP 2 + 200 on 9 December 2015;
b) Provide a documented Supervisor Review as described in TCPL Safety Plan, Section 7.4, for the use and placement of a ladder in an excavated ditch.
c) Provide confirmation that the findings have been reviewed in a formal safety meeting attended by all employees who are potentially exposed to this risk/hazard, and include the sign-in sheet for those in attendance.

Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Environmental Protection Notice of Non-Compliance (NNC) 14/01/2016
Date/Time visited Location
09/12/2015 2:00:00 PM KP 2 + 200

Observations

- Smoking observed outside of a designated smoking area on the RoW

Regulatory Requirements

ORDER XG-NO81-003-2015, Condition 2 states " NGTL shall cause the approved Project to be designed, located, constructed, installed, and operated in accordance with the specifications, standards, commitments made and other information referred to in its application or in its related submissions.

TRANSCANADA PIPELINES PRELIMINARY SITE SPECIFIC SAFETY AND SECURITY PLAN, dated August 2015 (TCPL Safety Plan).

Section 3.2, Key Policy Requirements - Company Rules
20. Smoking will be permitted in designated areas only.

Corrective Action or Request Required

NGTL will provide to the Inspection Officer via email the following information:

a) Provide the FLHA for KP 2 + 200 for 9 December 2015.
b) What is the criterion for selecting designated smoking areas as a control measure to the hazards on the RoW?
c) How is the designated smoking area communicated to the workers?
d) Where is the waste generated by cigarettes disposed of?
e) How will the communication of the Company Rules for smoking be improved for this Project?

Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Environmental Protection Notice of Non-Compliance (NNC) 14/01/2016
Date/Time visited Location
09/12/2015 3:00:00 PM KP 1 + 400

Observations

- Discarded food waste observed on the side of the RoW and was being eaten by a raven. NGTL representative immediately picked up discarded food waste and disposed appropriately. The food waste was not adequately contained, and this is a non-compliance to the EPP.

Regulatory Requirements

ORDER XG-NO81-003-2015, Condition 3 states " NGTL shall implement or cause to be implemented all of the policies, practices, programs, mitigation measures, recommendations, procedures, and its commitments for the protection of the environment included in, or referred to in its application or in its related submissions".

The EPP, Page 21 states "The Contractor will collect all construction debris and other waste material, and dispose of daily at an approved facility and in accordance with the Waste Management Plan as well as the Spill Contingency Plan unless otherwise authorized by the Environmental Inspector(s)".

EPP, Chemical and Waste Management Plan, Waste Disposal, 2. States ‘each construction site will be equipped with adequate garbage receptacles for solid, nonhazardous wastes and debris. Food wastes will be stored in animal proof (bear-proof) containers and transported to an appropriate land fill site.

Corrective Action or Request Required

GTL will provide documentation to the IO via email of what measures will be implemented to ensure the workforce is aware of the reasons for not allowing wildlife to eat discarded food waste. The measures will include, and not be limited to:

a) Description of improved training messages in the Michels and TCPL orientations;
b) Confirmation that the FLHA will be utilized as a tool to remind the workforce of the hazard and mitigation for food waste;
c) Confirmation that all transient waste containers on the project will be outfitted with a lid; and
d) Confirmation that the relationship between habituation to human food and wildlife fatalities (collisions and human safety incidents) has been explained by the NGTL onsite Environmental Inspectors.

Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Safety Management Information Request 14/01/2016
Date/Time visited Location
09/12/2015 2:15:00 PM KP 1 + 500

Observations

- Two workers in an excavated ditch operating “Tiger Torches” without fire resistant clothing, plus with a container of Acetone (MSDS 300-010) nearby. In addition, a fire extinguisher did not appear to be in the ditch during the work activity.

- The MSDS 300-010 Acetone contains the statement "Extremely flammable liquid and vapor, and vapor may cause flash fire".

Regulatory Requirements

ORDER XG-NO81-003-2015, Condition 2 states "NGTL shall cause the approved Project to be designed, located, constructed, installed, and operated in accordance with the specifications, standards, commitments made and other information referred to in its application or in its related submissions".

TRANSCANADA PIPELINES PRELIMINARY SITE SPECIFIC SAFETY AND SECURITY PLAN, dated August 2015 (TCPL Safety Plan).

Section 10.8 Fire Resistant Clothing
5. Fire resistant clothing must be worn:
d) where determined by hazard assessment

Fire Protection Code of Practice - Michels (Fire Code)
1. Purpose - The Fire Code is to control and reduce the possibility of fire, and to specify the type of equipment to use in the case of fire.
3. Workplace Fire Hazards
8. Ensure flammable substances stored or used in the work area:
e) are stored separately from other sources of ignition are eliminated or adequately controlled.
7. Fire Prevention Equipment Training - The purpose is to train employees in fire hazard recognition, safe work procedures and use of the equipment.
4. Fire Protection Equipment
1) Fire protection equipment shall be readily available at the worksite and suitable for the risk.

Corrective Action or Request Required

NGTL please provide to the Inspection Officer via email the following information:

a) the FLHA for the Coating Crew at KP 1 + 500 on 9 December 2015;
b) a documented Supervisor Review as described in the TCPL Safety Plan, Section 7.4 Review to evaluate the effectiveness of the controls for eliminating or reducing hazards identified when workers are operating “Tiger Torches” in an excavated ditch.

Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Environmental Protection Information Request 06/01/2016
Date/Time visited Location
11/12/2015 8:30:00 AM Closing Meeting

Observations

Appendix 1E in the EPP does not contain the 'Instream Drilling Mud Release Contingency Plan'.

Regulatory Requirements

ORDER XG-NO81-003-2015, Condition 3 states " NGTL shall implement or cause to be implemented all of the policies, practices, programs, mitigation measures, recommendations, procedures, and its commitments for the protection of the environment included in, or referred to in its application or in its related submissions".

The EPP, Page 31 states "In the event of sediment releases or spills of deleterious substances during the construction of the trenchless crossings, implement the Directional Drilling Procedures and Instream Drilling Mud Release Contigency Plan (Appendix 1E).

Corrective Action or Request Required

NGTL provide to the Inspection Officer via email the Instream Drilling Mud Release Contingency Plan that is referred to on Page 31 of the EPP.

This notice reflects the observations of non-compliance with regulatory requirements or company commitments, made by the inspection officer during the compliance verification activity. If the corrective actions identified are implemented by the completion date, the matter is considered resolved. Any unresolved compliance matters will be addressed by the inspection officer and may be referred to NEB enforcement staff.

517 Tenth Avenue SW Calgary, Alberta  T2R 0A8
Telephone: 403-292-4800   Toll Free: 1-800-899-1265

 

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