Compliance Verification Activity Report 1516-458 – NOVA Gas Transmission Ltd.

Compliance Verification Activity Report - NOVA Gas Transmission Ltd. [PDF 421 KB]

Type of Compliance Verification Activity: Field Inspection

Activity #: 1516-458
Activity start: 26/11/2015
Activity End: 26/11/2015

Related Activity Numbers:

Inspection Officer Number(s): 2654, 2275

Incident #: 2015-120, -125, -128, -129 and -130
Landowner Complaint File #:

Company: NOVA Gas Transmission Ltd. (NGTL)

Facility Name(s): Athabasca River Horizontal Directional Drill (HDD) - McDermott Extension Project

Province(s): Alberta

Theme(s): Environmental Protection

Compliance Tools Used: Corrected in field (Corrected Non-Compliance) (4)

Purpose

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

 X  NEB Act

 X  Onshore Pipeline Regulations

    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-N081-013-2015

Observations & Discussion

Observations & Discussion
Date visited Location Theme Compliance Confirmed
26-Nov-15 HDD Entry Site - West Side of the Athabasca River Environmental Protection Yes

Observations

NGTL staff provided an update on the current status of the HDD at the time of the inspection. Work was being conducted to intersect exit and entry pilot holes on the HDD.

NEB IOs observed pallets with bags of drilling mud additives on the site (bentonite, calcium carbonate, hyperdrill, soda ash, kwik-seal and limestone ground).

Secondary containment was observed beneath a light generator trailer. NGTL staff indicated all mobile equipment is inspected for leaks in the staging area before it arrives on site.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
26-Nov-15 HDD Entry Site - West Side of the Athabasca River Environmental Protection No

Observations

NEB IOs observed a chemical storage area with inadequate secondary containment. Secondary containment was present, but too small for the number and volume of products present. Some containers were observed to be outside of the secondary containment due to lack of capacity. This is considered Corrected Non-Compliance #1 (CNC #1).

Observations & Discussion
Date visited Location Theme Compliance Confirmed
26-Nov-15 HDD Entry Site - West Side of the Athabasca River Environmental Protection No

Observations

NEB IOs observed a gap in rig mats that presented a tripping hazard. This observation is considered Corrected Non-Compliance #2 (CNC #2).

Observations & Discussion
Date visited Location Theme Compliance Confirmed
26-Nov-15 HDD Entry Site - West Side of the Athabasca River Environmental Protection No

Observations

NEB IOs observed a waste pipeline pig stored on the ground a on the west side of the site. NGTL staff confirmed that the pig was clean, however the pig was not stored in an appropriate area, and therefore is considered waste on the right-of-way. This observation is considered CNC #3.

Observations & Discussion
Date visited Location Theme Compliance Confirmed
26-Nov-15 HDD Exit Site - East Side of the Athabasca River Environmental Protection Yes

Observations

NEB IOs were joined by Alberta Environment and Parks (AEP) representatives (an Environmental Protection Officer and a Municipal Approvals Engineer), who accompanied them for the remainder of the inspection.

The drilling rig at this site was not operating at the time of the inspection.

NEB IOs observed approximately four pallets of bentonite in bags. A tarp and flagging tape were observed to be covering a pallet, which NGTL staff indicated contained drilling mud additives which were in the process of removal from the job. NGTL staff confirmed that the flagging was in place so that these drill mud additives would not be used, until it could be removed from the site.

NEB IOs visited the site of Incident 2015-130, where a chunk of frozen sloughed off the treed slope during implementation of the Instream Drilling Mud Release Contingency Plan (Section 7.0 of the EPP). The Incident occurred on a slope, in a treed setting. NEB IOs, AEP representatives and NGTL staff discussed the circumstances of the Incident. The AEP indicated they had requested submission of an Environmental Impact Assessment by 7 December 2015, and a Remediation Plan by 14 December 2015. Inspectors discussed the planned, coordinated regulatory approach with the AEP regarding this area going forward. NEB IOs note no immediate hazards associated with this incident, and will coordinate regulatory approaches with the AEP to determine if additional corrective action is required.

Near the area of INC2015-130, NEB IOs observed data logging equipment in Pelican cases. Company staff indicated that the equipment is for turbidity monitoring. NGTL indicated that data is collected every 15 minutes, with personnel downloading the data hourly on a 24 hour basis. The Environmental Monitor indicated that three turbidity monitors were installed via helicopter on the day of the inspection. Four monitors are in place at the time of the inspection, located as follows:

  1. 50 meters upstream of the HDD.
  2. 25 m downstream.
  3. 100 m downstream.
  4. 300 m downstream.
Observations & Discussion
Date visited Location Theme Compliance Confirmed
26-Nov-15 HDD Exit Site - East Side of the Athabasca River Safety Management No

Observations

A missing fire extinguisher was noted on a piece of motorized equipment near the rig. This is considered CNC #4.


Compliance Summary

Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Environmental Protection Corrected in field (Corrected Non-Compliance) 27/11/2015
Date/Time visited Location
26/11/2015 12:47:00 PM HDD Entry Site - West Side of the Athabasca River

Observations

NEB IOs observed a chemical storage area with inadequate secondary containment. Secondary containment was present, but too small for the number and volume of products present. Some containers were observed to be outside of the secondary containment due to lack of capacity. This is considered Corrected Non-Compliance #1 (CNC #1).

Regulatory Requirements

The Waste and Chemical Handling section (1.3.3) of the EPP states that, "secondary containment may be required depending on location, type, volume, and duration of the waste or chemical being stored. Secondary containment will be in accordance with applicable federal, provincial and municipal requirements."

and

Section #1.3 (Guiding Principles) of the Chemical and Waste Management Plan in the EPP states that, "reasonable preventative measures will be taken to avoid the release of wastes and hazardous materials into the environment".

and

Section #48 of the OPR states that:

"A company shall develop, implement and maintain an environmental protection program that anticipates, prevents, manages and mitigates conditions that could adversely affect the environment".

Corrective Action or Request Required

NEB IOs indicated that the corrective action for CNC #1 was for the company to reassess the secondary containment in this area and implement corrective actions to mitigate potential hazards.

Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Safety Management Corrected in field (Corrected Non-Compliance) 27/11/2015
Date/Time visited Location
26/11/2015 1:01:00 PM HDD Entry Site - West Side of the Athabasca River

Observations

NEB IOs observed a gap in rig mats that presented a tripping hazard. This observation is considered Corrected Non-Compliance #2 (CNC #2).

Regulatory Requirements

Section 47 of the OPR states that, "a company shall develop, implement and maintain a safety management program that anticipates, prevents, manages and mitigates potentially dangerous conditions and exposure to those conditions during all activities relating to construction, operations, maintenance, abandonment and emergency situations."

Corrective Action or Request Required

Corrective action for CNC # 2 required the company to reassess this area and take corrective actions to mitigate the tripping hazard.

Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Environmental Protection Corrected in field (Corrected Non-Compliance) 27/11/2015
Date/Time visited Location
26/11/2015 1:30:00 PM HDD Entry Site - West Side of the Athabasca River

Observations

NEB IOs observed a waste pipeline pig stored on the ground a on the west side of the site. NGTL staff confirmed that the pig was clean, however the pig was not stored in an appropriate area, and therefore is considered waste on the right-of-way. This observation is considered CNC #3.

Regulatory Requirements

Section 1.3 (Guiding Principles) of the Chemical and Waste Management Plan in the EPP states that, "reasonable preventative measures will be taken to avoid the release of wastes and hazardous materials into the environment", and "waste and hazardous materials will, to the extent feasible, be recycled, disposed of or moved to an approved area as required."

Corrective Action or Request Required

Required corrective action for CNC # 3 for the company to dispose of or move this material to an appropriate, approved area.

Compliance Summary
Theme Compliance Tools Used Corrective Action Due Date
Safety Management Corrected in field (Corrected Non-Compliance) 27/11/2015
Date/Time visited Location
26/11/2015 3:37:00 PM HDD Exit Site - East Side of the Athabasca River

Observations

A missing fire extinguisher was noted on a piece of motorized equipment near the rig. This is considered CNC #4.

Regulatory Requirements

Section 5.0 of the EPP, the Fire Suppression Contingency Plan states that, "all motorized equipment must carry a fully charged fire extinguisher".

Corrective Action or Request Required

Required corrective action for CNC # 4 is for NGTL to replace the missing fire extinguisher.

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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