Compliance Verification Activity Report: CV1617-433 - Pouce Coupé Pipe Line Ltd. as agent and general partner of the Pembina North Limited Partnership

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1617-433
Start date: 2017-01-17
End date: 2017-01-20

Team:

Regulated company: Pouce Coupé Pipe Line Ltd. as agent and general partner of the Pembina North Limited Partnership

Operating company: Pouce Coupé Pipe Line Ltd. as agent and general partner of the Pembina North Limited Partnership

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

The Board granted an application from Pouce Coupé to construct and operate the Pouce Coupé Lateral (Project). The Project entails the construction of approximately 27 km of 12-inch nominal pipeline flowing east from north of Dawson Creek, B.C. to the Bay Tree area in Alberta. The Project will be designed to transport natural gas liquids (NGLs), condensate and crude oil and will parallel the existing 8-inch NEB-regulated Pouce Coupé System from the Dawson Meter Station in BC to the Pouce Coupé Riser Station block valve site in AB. Pouce Coupe initially proposed a construction start date of 1 September 2016. Due to weather conditions, construction start was delayed to late November, 2016. Rationale: The Project is being constructed in frozen and non-frozen conditions, partly in agricultural land and forested crown land. Environmental protection mitigation measures have been designed for the Project and will be implemented by the construction contractor. Scope: The scope of the NEB inspection is to verify compliance to the environmental protection requirements found in the National Energy Board Act, the National Energy Board Onshore Pipeline Regulations and to the requirements of National Energy Board Order XO-P123-013-2016.

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 - KP 2+100

Date & time of visit: 2017-01-18 11:48

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Debris on RoW - broken skids, T bar, pump hose

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Clean up waste materials on RoW, ensure waste containers are available for each working unit, as required. 
 

Due date: 2017-01-20

Date closed: 2017-01-20
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 - Road 201 Mechanic's Truck

Date & time of visit: 2017-01-18 12:03

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Mechanic truck did not have a shovel for spill response. 

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

Regulatory requirement:

Relevant section(s):

Company action required:

Company representative stated at closing meeting that mechanic’s truck now had a shovel, as required. 
Provide written assurance that this was done, and that other vehicles have been similarly checked and equipped. 

 

Due date: 2017-01-20

Date closed: 2017-01-24
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 3 - KP 19+100, KP 19+500 & KP 20+500 Wildlife Trails

Date & time of visit: 2017-01-19 11:51

Discipline: Environmental Protection

Categories:

Facility:

Observations:

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

Regulatory requirement:

Relevant section(s):

Company action required:

Create gaps in windrowed snow and provide photographic evidence of this to NEB. 
Provide evidence (photographic or otherwise) that the logs blocking access to the trail have been removed. 

Due date: 2017-02-20

Date closed: 2017-02-24
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 - Sediment Guarding at Watercourses 9, 15, 16, 17, 18, 19, 20, Road 10 Bar Ditch

Date & time of visit: 2017-01-19 13:03

Discipline: Environmental Protection

Categories:

Facility:

Observations:

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

Regulatory requirement:

Relevant section(s):

Company action required:

 

 

Due date: 2017-02-20

Date closed: 2017-02-24
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 - Vegetative Buffers at Watercourses # 9, 15, 16, 17, 18, 19, and 20

Date & time of visit: 2017-01-18 13:07

Discipline: Environmental Protection

Categories:

Facility:

Observations:

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

Regulatory requirement:

Relevant section(s):

Company action required:

Due date: 2017-02-20

Date closed: 2017-02-24
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 - Designated Smoking Areas

Date & time of visit: 2017-01-19 15:30

Discipline: Environmental Protection

Categories:

Facility:

Observations:

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

Regulatory requirement:

Relevant section(s):

Company action required:

Please provide confirmation that the orientation has been updated to be consistent with the Environmental Protection Plan, and specify where the designated smoking locations are for the Project. 

Due date: 2017-02-20

Date closed: 2017-02-24
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 - WC#15 KP 17+205 and WC#17 KP 20+654 Water Management

Date & time of visit: 2017-01-19 11:15

Discipline: Environmental Protection

Categories:

Facility:

Observations:

At both locations, water accumulation on south (upstream) side of RoW may cause erosion during thawing. 
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Please provide the following additional information needed to assess compliance:

Due date: 2017-02-20

Date closed: 2017-03-03
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 - KP 17+300 Ditch-only Stripping

Date & time of visit: 2017-01-19 11:12

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Please provide the following additional information needed to assess compliance:



 

Due date: 2017-02-20

Date closed: 2017-02-23
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 - KP 8+400 Pouce Coupé HDD

Date & time of visit: 2017-01-17 15:53

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 10 - KP 2+000 WC#0 - Wetland

Date & time of visit: 2017-01-18 11:39

Discipline: Environmental Protection

Categories:

Facility:

Observations:

175m bore was conducted under wetland. 
During closing meeting, company committed to putting up a sign restricting unecessary travel in the area. 
 

Compliance tool used: No compliance tool used

Observation 11 - KP 25+921 WC#25

Date & time of visit: 2017-01-18 15:01

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 12 - General Waste Management

Date & time of visit: 2017-01-19 09:45

Discipline: Environmental Protection

Categories:

Facility:

Observations:

 

(6.21 of EPP - Remove and dispose of all waste substances (hazardous and non-hazardous) to the nearest approved disposal facility. Provide separate collection and storage procedures and equipment to separate hazardous and non-hazardous waste.)
 
 

Compliance tool used: No compliance tool used

Observation 13 - Weed Control

Date & time of visit: 2017-01-18 11:16

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Construction equipment steam-cleaned prior to being sent on RoW. 

 (15.2.2, subsection 8, and 15.3.3 of EPP – use of weed clean-off stations at locations identified by the EI, for cleaning with steam or high-pressure water during non-frozen conditions)
 

Compliance tool used: No compliance tool used

Observation 14 - Wildlife Mitigation Measures

Date & time of visit: 2017-01-19 11:40

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Wildlife mitigation measures implemented. 

(15.4.5 of EPP:  In the Green Area of Alberta, Pouce Coupé has undertaken to ensure ungulate movement around a mineral lick on an adjacent right-of-way and has also committed to the placement of roll-back to minimize access in this section of the right-of-way. The area will be flagged and signed during construction to restrict access and ensure gaps are left in spoil piles, strung pipe, and the trench so as not to block animal movement. Some areas of old growth forest were identified in the same area. Pouce Coupé has undertaken to adjust the right-of-way where practicable to preserve old growth trees and associated habitat. A final assessment of the right-of-way before construction will identify the need for additional flagging and fencing.)
 

Compliance tool used: No compliance tool used

Observation 15 - Stripping and Soil Management

Date & time of visit: 2017-01-17 12:47

Discipline: Environmental Protection

Categories:

Facility:

Observations:

 
 

(8.44 of EPP:  Maintain a minimum separation distance of 1 m between topsoil and spoil piles when stored on the same side of the trench.)
 

Compliance tool used: No compliance tool used

Observation 16 - No Trespassing

Date & time of visit: 2017-01-17 14:47

Discipline: Environmental Protection

Categories:

Facility:

Observations:

7.4 of EPP:  Ensure construction vehicles and personnel do not trespass off the right-of-way.
7.17 of EPP:  Do not allow clearing or grading beyond the staked/flagged boundaries of right-of-way
and TWS, and within buffers.
 

Compliance tool used: No compliance tool used

Observation 17 - Orientation and Training

Date & time of visit: 2017-01-17 09:45

Discipline: Safety Management

Categories:

Facility:

Observations:

4.15 of EPP:  Provide training and orientation to all Project-related personnel, including all visitors
to the construction site and rights-of-way prior to site entry.
 

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