Compliance Verification Activity Report 1516-446 – NOVA Gas Transmission Ltd.

Type of Compliance Verification Activity: Field Inspection

Activity #: 1516-446
Activity start: 12/7/2015
Activity End: 12/9/2015

Related Activity Numbers: 1516-455, 1516-440

Inspection Officer Number(s): 2365

Incident #:
Landowner Complaint File #:

Company: NOVA Gas Transmission Ltd.

Facility Name(s): Cutbank River Lateral Loop No. 2 (Pinto Creek Section)

Province(s): Alberta

Theme(s): Environmental Protection

Compliance Tools Used:

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

Order XG-N081-007-2015; AO-001-XG-N081-007-2015

Observations & Discussion

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 General - Watercourse crossings Environmental Protection Yes

Observations

The following observations concern construction activities at the 10 trenched watercourse crossings
- small unnamed watercourses with no evidence of flowing water during inspection
- required watercourse identification and 100 m re-fuelling restriction signage in place
- right-of-way (RoW) appropriately narrowed down at trenched crossings
- trench and pipe installation not completed; to occur at a later date
- watercourse buffer area over ditchline fenced off to restrict access
- no grading or soil disturbance observed on ditchline within watercourse and buffer area
- temporary bridge installation for vehicle passage complete at all of the crossings
- bridge construction included geotextile barrier between structure and soil surface, plywood side boards and geotextile barrier on deck, and sediment and erosion control at bridge approach

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 Kilometer Post (KP) 29+358 Environmental Protection Yes

Observations

Observed construction RoW (new cut) through dry, ephemeral drainage
- minimal disturbance with snow fill though the drainage
- dewatering discharge location signage observed on edge of RoW
- trench backfilled with approximately 1.5 m high roach over trench
- during clean-up, roach and clay ramp across drainage to be removed
- observed large slash pile on a timber deck; the slash to be used for access control in new cut area

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 27+430 Environmental Protection Yes

Observations

Observed mitigation measures through low-lying area with western toad breeding pond
- environmental signage included 100 m refuelling restriction and western toad habitat
- minimal disturbance techniques used with clay ramp over biodegradable geotextile
- geotextile barrier installation at east (travel side) RoW boundary along entire length of western toad area
- RoW boundaries clearly marked
- observed ditch wheel excavating trench; spill kit present on machine

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 27+140 Environmental Protection Yes

Observations

Observed mitigation measures through wetland area: wetland (WL) 6 with western toad breeding pond
- environmental signage included wetland start/end, 100 m refuelling restriction and western toad habitat
- minimal disturbance techniques used through wetland with clay ramp over biodegradable geotextile
- geotextile barrier installation at east (travel side) RoW boundary along entire length of wetland

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 26+980 Environmental Protection Yes

Observations

Observed mitigation measures through wetland area: WL 5
- environmental signage included wetland start/end, 100 m refuelling restriction
- minimal disturbance techniques used through wetland with clay ramp over biodegradable geotextile
- geotextile barrier installation at east (travel side) RoW boundary along entire length of wetland

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 26+840 Environmental Protection Yes

Observations

Observed mitigation measures through wetland area: WL 4
- environmental signage included wetland start/end, 100 m refuelling restriction
- minimal disturbance techniques used through wetland with clay ramp over biodegradable geotextile
- geotextile barrier installation at east (travel side) RoW boundary along entire length of wetland
- soil stockpile adequate distance from wetland
- soil stockpiles had identification signage (i.e. clay or topsoil) to ensure proper replacement

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 26+250 Environmental Protection Yes

Observations

Observed inactive bending machine parked on edge of RoW
- visual evidence of fluid leak on the machine
- absorbent pad on soil surface to catch drips and leaking hoses crimped off
- informed that construction crew aware of equipment issue and will attend to minor surface spill

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 ~KP 24+200 Environmental Protection Yes

Observations

Observed coating crew applying coating to pipe
- drop cloths in use and effectively catching overspray
- used drop cloths in bags and awaiting removal from RoW

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 23+423 Environmental Protection Yes

Observations

Observed construction activities at watercourse crossing (WC) 12
- see Observation 1 (General - Watercourse crossings)
- small pile of cut brush and two construction skids near watercourse, to be removed
- exposed subsoil within 5 m of watercourse, channnel bends and runs sub-parallel to RoW boundary and adjacent to clay ramp approaching bridge
- noted clay ramp to be removed and sediment fencing to be installed during rough clean-up

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 22+966 Environmental Protection Yes

Observations

Observed construction activities at WC 11
- see Observation 1 (General - Watercourse crossings)
- two rare plant populations near watercourse, identified with signage and flagging/fence
- RoW narrowed down and area fenced off appropriately

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 21+930 Environmental Protection Yes

Observations

Observed construction activities at WC 10
- see Observation 1 (General - Watercourse crossings)
- approx. 25 m north of crossing, evidence of water/ice flow across RoW
- source of water was a flowing spring located off-RoW, the culvert which was channelling flow across RoW had frozen off
- mitigation plan includes construction of a collection sump and new culvert installation

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 P 16+205 (WC 9) and 16+170 (WC 8) Environmental Protection Yes

Observations

bserved construction activities at WC 8 and 9
- see Observation 1 (General - Watercourse crossings)
- two crossings in close proximity, very uneven ground and past beaver activity evident
- geotextile containing sides of clay ramp between crossings observed to be at reduced height, but at adequate distance from watercourse channels

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 14+339 Environmental Protection Yes

Observations

Observed construction activities at WC 7
- see Observation 1 (General - Watercourse crossings)

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 P 12+200 Environmental Protection Yes

Observations

Observed rare lichen transplant location
- tree supporting the lichen was cut down and log moved off-RoW
- informed that botanist supervised the log removal and placement procedure
- the placement area was appropriately marked to restrict access

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 12+090 Environmental Protection Yes

Observations

Observed construction activities at WC 6
- see Observation 1 (General - Watercourse crossings)
- significant cut down at south side of crossing, bank reconstruction and erosion/sediment control to be installed during rough clean-up
- soil stockpiles had identification signage to ensure proper replacement

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 11+840 Environmental Protection Yes

Observations

Observed rare lichen transplant location
- decaying log supporting the lichen was moved off-RoW
- informed that botanist supervised the log removal and placement procedure
- the placement area was appropriately marked to restrict access

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 10+019 Environmental Protection Yes

Observations

Observed construction activities at WC 5
- see Observation 1 (General - Watercourse crossings)

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 8+782 Environmental Protection Yes

Observations

Observed construction activities at WC 4
- see Observation 1 (General - Watercourse crossings)

Observations & Discussion
Date visited Location Theme Compliance Confirmed
08-Dec-15 KP 8+246 Environmental Protection Yes

Observations

Observed construction activities at WC 3
- see Observation 1 (General - Watercourse crossings)
- a beaver dam observed adjacent to crossing, dam was not disturbed
- bare soil adjacent to bridge aproach, but appropriate distance from watercourse
- was informed that duff layer removed and geotextile overlaid for bridge construction; duff layer to be replaced when bridge dismantled
- observed hydrovac slurry pits at at approximately 300 m north of WC 3 and at KP 3+150
- pits appeared to be well constructed and adequately containing slurry material

Observations & Discussion
Date visited Location Theme Compliance Confirmed
09-Dec-15 KP 28+730 Environmental Protection Yes

Observations

Observed road bore and trench dewatering activities
- spill kits and fire extinguishers present on equipment
- RoW tidy and adequate housekeeping
- trench dewatering using gasoline pump
- adequate secondary containment for pump unit
- water discharge off-RoW into approved well-vegetated area and through filter sock
- informed that all off-RoW water discharge areas approved by province

Observations & Discussion
Date visited Location Theme Compliance Confirmed
09-Dec-15 ~KP 16+500 Environmental Protection Yes

Observations

Observed mainline welding
- minimal welding waste related to pipe preparation
- tidy work site and no garbage issues

Observations & Discussion
Date visited Location Theme Compliance Confirmed
09-Dec-15 ~KP 5+100 Environmental Protection Yes

Observations

Observed horizontal directional drilling (HDD) rig at WC 1 (Bald Mountain Creek)
- informed that drilling mud release occurred on 8 Dec 2015, release site approximately 100 m from the watercourse; sixth release event to occur to land during the drill
- reviewed emergency response procedures for drilling mud release (CCI Inc. and rig) and Water Quality Monitoring Plan (CCI Inc.)
- confirmed use of non-toxic drilling mud additives, reviewed material safety data sheets and ecotoxicology reports
- overall, the rig and work area was tidy and had adequate housekeeping in place
- fuel containers and other fluids stored in secondary containment on rig floor
- small container storage on metal shelves in sea-can, secondary containment absent but storage acceptable based on size/volume of containers and distance from watercourse
- large spill kits observed on rig floor
- mud release containment materials supply at rig depleted, informed that materials on-site at creek and resupplied as needed by contractor

Observations & Discussion
Date visited Location Theme Compliance Confirmed
09-Dec-15 KP 4+500 Environmental Protection Yes

Observations

Observed drilling mud release sites and response procedures at WC 1 (Bald Mountain Creek)
- one release site on south side of crossing
   - spill reports show release occurred 22 Nov 2015, approximately 110 m from creek, and mud ran approximately 30 m downhill under snow
   - containment with sand bags, plastic sheeting and sediment fence
   - site was snow-covered therefore difficult to discern release path and mud material remaining
- electronic monitor and data logger present on creek ice, downstream of pipeline crossing (second monitoring station located upstream but not observed during inspection)
- physical water sampling sites present upstream and downstream of crossing
- CCI Inc. consultant described monitoring and sampling procedures; consistent with EPP commitments
- observed clean-up activities at 4 Dec and 8 Dec 2015 mud release sites on north side of crossing (two small 3 Dec 2015 release sites not visible under snow)
   - releases occurred high on north side of creek valley, ran downhill and contained approximately 90 m from the creek, did not enter creek or adjacent wetland (WL 2)
   - mud release containment with sand bags and sediment fence
   - some material removed using vacuum truck; clean-up plan will include use of pressurized water and removal by vacuum

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

Observations

- new Trans Canada environmental orientation video (non site-specific) and site-specific environmental orientation slideshow presented during overall site orientation
- bear safety information included in site-specific environmental orientation, as required by EPP, and “Wildlife Sighting Cards” distributed
- confirmed required environmental documentation available in construction offices (Environmental and Socio-Economic Assessment, EPP, NEB Order and Amending Order, provincial permits, etc)
- spill records review completed
   - included HDD mud releases and five other small spills (hydraulic fluid, diesel, lube and antifreeze, all 5 L or less)
   - documentation shows appropriate clean-up and storage and handling of spilled material
- overall housekeeping is good
- soil stockpiles had identification signage to ensure proper replacement
- slash/non-merchantable timber stockpiled for future rollback use on new cuts (i.e. where cleared RoW non parallel to existing access/cuts)
- RoW and temporary workspace boundaries clearly marked


Compliance Summary

 

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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