Compliance Verification Activity Report: CV1617-221 - Trans-Northern Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2507

Regulated company: Trans-Northern Pipelines Inc.

Operating company: Trans-Northern Pipelines Inc.

Province(s) / Territory(s):

• Ontario

Discipline(s):

• Environmental Protection

Rationale and scope:

NEB inspectors conducted an environmental operations inspection of completed and ongoing integrity digs between Belleville and Cornwall, ON. The focus of this inspection was to verify compliance with TNPI's Construction Safety and Environmental Manual, as well as the NEB Act, OPR, and CSA Z662-15.

Compliance tool(s) used:

• Information Request (IR) (5)

Facility details

Facilities:

• Mainline
• MAITLAND STATION [Mainline]
• Ottawa Lateral

Facility Types

• Pipeline
• Pipeline right of way (ROW)
• Pump station

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Occupational Health and Safety Regulations (COHSR)
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Act (NEBA) until 1 April 2020, Canada Energy Regulatory Act (CERA) after 1 April 2020
• Plans And Procedures
• Standard Operating Procedure or Plan (SOP)
• Construction Safety & Environmental Manual (2016)
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Mile Post (MP) 184.4

Date & time of visit: 2016-08-16 09:35

Discipline: Environmental Protection

Categories:

• Socio-economic
• Human Occupancy and Resource Use
• Training and Documentation
• Permits/Approvals
• Inspections

Facility:

• Mainline (Pipeline)

Observations:

• Dig was a small excavation located in the centre island of a traffic circle surrounded by undeveloped land owned by the City of Kingston; the dig area was marked off by pylons.
• Permission was required from the City to conduct the work and arrange site traffic management. 
• Excavation was backfilled and concrete poured on sidewalk portion a few days prior.
• Company representative stated that contractors will be re-paving the road portion of the dig in a week (small area).
• Signage was observed on both sides of the road crossing, sign on the SW corner of the intersection was partially concealed by brush. Company representative stated that signage maintenance is conducted during company inspections of the right-of-way (RoW).

Compliance tool used: No compliance tool used

Observation 2 - MP 184.6

Date & time of visit: 2016-08-16 10:12

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Reclamation
• Socio-economic
• Human Occupancy and Resource Use

Facility:

• Mainline (Pipeline)

Observations:

• Dig was a small area located on a grassy verge bordering a parking lot.
• Replaced sod and small garden over the dig site upon completion, which looks comparable to or better than the surrounding area.
• Observed many pipeline markers delineating the RoW along the road looking east, as well as at the entrances to the parking lot.

Compliance tool used: No compliance tool used

Observation 3 - MP 202.2

Date & time of visit: 2016-08-16 11:05

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Crowns/Subsidence
• Vegetation
• Vegetation Reclamation
• Crop Productivity
• Training and Documentation
• Inspections

Facility:

• Mainline (Pipeline)

Observations:

• Dig site crossed boundary between two private properties (east property was in crop, however crops were not impacted by the dig).
• Company representative stated that the site was re-seeded two weeks prior with a landowner-approved pasture seed mix upon completion.
• The majority of work took place in a clearing surrounded by bush (primarily cedars, junipers, berry shrubs). No brushing was required prior to start of excavation.
• Excavation was approximately 10 m in length and 6 m width.
• Site was re-contoured properly, no crowning or subsidence observed.
• Contractors were able to use pre-existing access road to mobilize equipment to site.
• Company representative stated that it is standard practice to follow up with landowners one year following dig completion to see if there are any outstanding concerns (if not notified previously) and evaluate environmental factors including vegetation establishment and soil integrity.

Compliance tool used: No compliance tool used

Observation 4 - MP 222.1

Date & time of visit: 2016-08-16 13:47

Discipline: Environmental Protection

Categories:

• Surface Water Management
• Containment and Drainage Structures
• Vegetation
• Vegetation Reclamation
• Training and Documentation
• Permits/Approvals

Facility:

• Mainline (Pipeline)

Observations:

• Completed dig was located on private property adjacent to an access road on the north side in a grassy area.
• Company representative stated that an Ontario Conservation Authority permit was required at this location prior to conducting the dig.
• The surrounding vegetation is primarily cattails to the north of the road and trees on the south side.
• Integrity dig was completed in July 2016, the excavation area was approximately 15 m by 20 m.
• Heavy rain at the time of inspection, area was very wet with lots of ponding observed on and off RoW.
• Landowners are in the process of building a drainage ditch adjacent to the dig site that traverses the road crossing from north to south. The landowner is currently in the process of obtaining permission from the company to cross the pipeline. A small piece of pipe for the culvert is currently being stored on the RoW.
• Vegetation was establishing very well in the reclaimed area.

Compliance tool used: No compliance tool used

Observation 5 - MP 129.4

Date & time of visit: 2016-08-17 09:05

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Handling
• Surface Water Management
• Containment and Drainage Structures
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation
• Housekeeping
• Temporary Structures
• Socio-economic
• Human Occupancy and Resource Use
• Wildlife
• Habitat Restoration/Offsets
• Training and Documentation
• Permits/Approvals

Facility:

• Mainline (Pipeline)

Observations:

• Site was located at the edge of a rural residential neighbourhood.
• Company representative stated that the area's residents and landowner (Township of Augusta) were consulted prior to the dig, and reviewed the pre-construction report.
• While on site, Inspection Officers reviewed the ‘Approval of Clean-up’ and the ‘Post-Construction Report’ prepared for the dig, which was completed in the spring of 2016.
• Crossed a temporary access bridge over a drainage ditch on the way to the dig site, a company representative stated that the bridge will be removed in September.
• Company representative stated that the dig site was reseeded with a Ministry of Transportation (MTO)-approved seed mix; please refer to Information Request (IR) #1.
• Landowner planted select wildflowers to aid in bee habitat and monarch butterfly migration route along RoW where excavation occurred, and conducts public walking tours through the area. It was noted that there were some weedy species that were likely included in the seed mix (i.e. purple loosestrife).
• At landowner’s request, company installed a gravel path through the affected portion of RoW (underlain by geotextile) as part of the restoration measures (replacing what was previously a grassy path).  
• The RoW is used by recreational vehicles and cross-country skiers as well as for the garden walking tours.
• Vegetation had established very quickly, and was nearly as tall as surrounding vegetation. The dig site (approximately 10 m by 3 m) was indistinguishable from the surrounding area.
• Inspection Officer (IO) inquired about soil handling during construction activities. The company representative stated that a sediment fence was installed between the topsoil and subsoil piles.
• Can see outline of soil storage area where vegetation was depressed and some bare areas, however overall vegetative cover is good.
• Observed pipeline identification marker at private road crossing. Company representative stated that the company is in the process of updating pipeline identification signage throughout the entire RoW, observed new marker at this location.
• A small drainage runs north-south across the RoW through a culvert, located slightly less than 30 m west of the dig site. Company representative stated that residents had installed the culvert approximately 15 years ago to prevent flooding of the subdivision.

Compliance tool used: No compliance tool used

Observation 6 - MP 128.8

Date & time of visit: 2016-08-17 09:53

Discipline: Environmental Protection

Categories:

• Surface Water Management
• Containment and Drainage Structures
• Vegetation
• Vegetation Control
• Invasive Plant Management
• Groundwater
• Monitoring and Testing

Facility:

• MAITLAND STATION [Mainline] (Facility)

Observations:

• Dig was located in the TNPI Maitland Meter Station through a gravel berm surrounding the metering manifold to the riser (approximately 6 m by 4 m).
• A cement pad was located directly over the pipeline dig site on the berm (for truck access to conduct maintenance at the station).
• Company representative stated that the gravel used to construct the berm was sourced from a nearby quarry.
• Piezometers were installed throughout the station yard; looked inside one nearest to dig site, it was dry.
• Company representative stated that the facilities are sprayed for weeds by a certified contractor on an annual basis; yard was clean and weed-free.
• At least a 1 m strip was cleared around the fence line.
• Observed proper station identification and hazard signage on all quadrants of the fence.
• A railroad and third-party battery site are located to the southeast of the meter station, and the TNPI Maitland Pump Station is located across the road to the south of the meter station.

Compliance tool used: No compliance tool used

Observation 7 - MP 127.3

Date & time of visit: 2016-08-17 10:44

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Integrity
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• Mainline (Pipeline)

Observations:

• Dig was completed in spring/early summer 2016; the total disturbance area was approximately 20 m by 8 m.
• IO inquired about dig scheduling. Company representative stated that in integrity dig program, dig timing is based on several factors including the risk model, availability of crews and equipment, landowner approval, etc.
• Dig site is located behind a former fertilizer plant.
• RoW was overgrown with primarily goldenrod, purple loosestrife, thistle, and giant hogweed; this was similar to off-RoW conditions, no concerns.
• A Hydro Ontario powerline crosses the RoW a few meters from the dig site, observed pipeline marker at crossing.
• A third party pipeline crosses the pipeline RoW approximately 50 m from the dig site.
• Region has experienced a very dry summer; ground was cracked and dry, however vegetation (primarily goldenrod) have established fairly well. Company representative stated that the dig site was reseeded with an MTO-approved seed mix.  

Compliance tool used: No compliance tool used

Observation 8 - MP 127.2

Date & time of visit: 2016-08-17 11:03

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Integrity
• Crowns/Subsidence
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation
• Socio-economic
• Human Occupancy and Resource Use

Facility:

• Mainline (Pipeline)

Observations:

• Dig site was located a couple hundred meters away from MP 127.3, both digs shared an equipment lay-down area. The excavation dimensions was approximately 10 m by 10 m.
• Backfilled soil over the excavation was pitted and cracked due to lack of moisture, and slight subsidence was noted.
• Despite dry soil, vegetation has established fairly well so far at this site (primarily consisting of 50 cm tall grasses, approximately 80% coverage). There are few weeds growing on the dig site compared to off-site conditions.
• Site is located in a popular area for recreational vehicles as evidenced by tracks through field.
• RoW at this location is in an open field dominated by goldenrod and other tall weedy species; the RoW would be indistinguishable if not recently mowed where work was completed.

Compliance tool used: No compliance tool used

Observation 9 - MP 118.8

Date & time of visit: 2016-08-17 11:48

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Integrity
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation
• Destruction of Vegetation
• Socio-economic
• Human Occupancy and Resource Use

Facility:

• Mainline (Pipeline)

Observations:

• Dig site (10 m by 12 m) is located on private property in a backyard, work was completed in May. A residence is located approximately 20 m northeast of the dig site. The RoW continues into a treed area, however the dig site was located in a clearing and therefore required no brushing.
• Spoke with tenants living on the property, who stated that they have no concerns.
• The site was reseeded with grass seed, which hasn’t established well so far as tenants mowed the grass prior to seed establishment (erosion observed on the reclaimed area). Company’s landowner liaison stated that they had contacted the property owner, who indicated that they were aware of tenant’s activities impacting the grass and had no concerns. The company representative stated that the site will be reseeded at the landowner's request.
• Observed pipeline identification signage on either side of the nearby road crossing.

Compliance tool used: No compliance tool used

Observation 10 - Iroquois Pump Station

Date & time of visit: 2016-08-18 13:35

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Industrial Sanitation and Personnel Facilities

Facility:

• Mainline (Pipeline)

Observations:

• Pump station was not in the scope of the inspection. 
• Upon entering the station, one NEB employee developed a severe headache.
• The water in the washroom was coloured, and noted to have a strong sulfuric odour.
• There is no sour product in the lines. Odour seemed to originate from tap water in the washroom.
• Signs in washroom advise against drinking tap water. 
• A case of 250 ml bottles of drinking water was present in the work area. 
• Company representatives confirmed that workers regularly access the pump station for routine operation and maintenance activities.
• It is not known what water quality testing was undertaken prior to making the recommendation to put signs up discouraging drinking the tap water and the provision of bottled drinking water at the station. 
• To the best knowledge of the Inspection Officer, the company had not completed air quality testing or otherwise assessed possible hazards to the health and safety of its employees.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 6.5 Management System Processes
    • (1) A company shall, as part of its management system and the programs referred to in section 55,
      • (c) establish and implement a process for identifying and analyzing all hazards and potential hazards;

Company action required:

Please demonstrate how the Iroquois Pump Station meets the requirements of 6.5 (1) (c) of the Onshore Pipeline Regulations under the National Energy Board Act with respect to the tap water provided for worker use.  Specifically,

• Have potability tests been conducted on the water? If so, when were these tests last conducted and what is the testing frequency?
• Have seasonal changes been taken into consideration when determining the testing frequency? 
• If available, please provide the most recent potability test results, or justification if no such tests have been conducted. 

• Do staff wear personal monitors that can detect H2S when inside the building? 
• Has any air quality been monitoring conducted in the station building previous to the inspection? If so, was H2S detected? If no such testing has been conducted, please provide justification.
• What building ventilation or other measures are undertaken to ensure that the air quality in the building is appropriate? 

Due date: 2016-10-14

Date closed: 2016-10-17
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 11 - MP 111.6

Date & time of visit: 2016-08-17 14:21

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Integrity
• Crowns/Subsidence
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation
• Socio-economic
• Human Occupancy and Resource Use

Facility:

• Mainline (Pipeline)

Observations:

• At this location, RoW is located on private property in a treed area used by a local snowmobile club as well as other recreational vehicles.
• A large man-made pond (remnant of Highway 401 construction) is located less than 30 m from the dig site.
• Topography along the RoW is variable, the dig site was located in a low-lying area.
• This area is typically very wet, however due to unseasonably dry summer the soil was cracked with some bare patches. Despite this, vegetation is still coming in well (mostly weeds, primarily purple loosestrife).
• Company representative stated that an MTO-approved seed mix was used to reseed the site.
• RoW was overgrown by goldenrod, knapweed, purple loosestrife, wild caraway, and Joe-Pye weed. Company representative stated that the landowners have no concerns.
• Excavation was approximately 50 m by 10 m in area.
• Observed pipeline identification markers on either side of the dig site.
• Snow fencing was still in place around excavation area as soil was wet at the time of completion, company representative stated that contractors will be coming by to take it down soon.
• Company representative stated that work was completed in spring 2016.

Compliance tool used: No compliance tool used

Observation 12 - MP 118.2

Date & time of visit: 2016-08-18 09:40

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Handling
• Housekeeping
• Waste Management
• Temporary Structures
• Vegetation
• Access Control
• Training and Documentation
• Documentation Available/Up to Date
• Permits/Approvals
• Training
• Inspections

Facility:

• Mainline (Pipeline)

Observations:

• Went through tailgate meeting prior to entering the work space.
• Reviewed the site’s Safe Work Permit and signed the tool box and task card.
• On the access path to the site (a brushed and flattened path through a weedy field off of Highway 401), observed a gravel pile laid down on geotextile. Company representative stated that the gravel was sourced from a certified quarry.
• Site had been previously excavated approximately 10 years ago, so soil was already loose and prone to sloughing in. Company lined walls with gravel to provide extra support.
• Dig site was located approximately 1 km from a former Highway 401 borrow pit.
• Company is in the process of excavating the pipeline, which was exposed. Work began the previous afternoon.
• Company representative stated that the purpose of the dig was to look for corrosion.
• Excavation took place on land owned by Infrastructure Ontario and Hydro One.
• Observed a ladder and stairway in the excavation for egress.
• A wind sock was installed next to the excavation pit.
• Snow fencing and excavation signage were laid down next to the pit, ready for installation.
• Company representative stated that on-site staff have been trained to complete an initial assessment of the pipe, and then will send information to third-party contractor for assessment once the location of the anomaly has been confirmed.
• Topsoil and subsoil piles had approximately 1 m separation between them.
• Spoil banks had more than 1 m set back from the pit.
• A gas station is located near the site. A company representative stated that the excavator and other equipment are refueled in the paved parking lot next to the gas station.
• Pipeline identification signage was observed along the RoW.
• An on-site fire extinguisher inspection tag was up-to-date (August 2016).
• Observed a generator placed in secondary containment.
• Looked at contents of spill kit, which contained spill pads, geotextile, plastic sheeting, and spill socks (all in good working condition).
• Reviewed the daily equipment check for the excavator, which was up-to-date and complete. The excavator was also equipped with a fire extinguisher and spill kit.
• Observed hose pumping water out of excavation into filter bag in treed area. Gravel was placed around pump in the excavation to keep sand out.
• Plastic tarp had been laid down in excavation to capture and dispose of sand-blasting debris.

Compliance tool used: No compliance tool used

Observation 13 - MP 95.7

Date & time of visit: 2016-08-18 11:23

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Integrity
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• Mainline (Pipeline)

Observations:

• Dig was completed in late spring/early summer 2016 and was approximately 50 m by 8 m.
• Site was located on private property in a wetland area, which was dry at the time of the inspection. There was a man-made pond approximately 100 m from the site.
• Vegetation on the surrounding RoW in the wetland was primarily cattails and phragmites, with horsetails on the access pathway to the site. Vegetation off-RoW consisted of primarily aspen trees.
• Surface soil was stony and of poor quality, however there were no discernible differences when compared to off-RoW conditions (in the treed area).
• Excavation was re-contoured properly, topography was consistent with the surrounding area.
• Vegetation is establishing fairly well, with approximately 5% bare patches (area was very dry this summer).
• Vegetation on the dig site included clover, purple loosestrife, and wild caraway. Company representative stated that the site was reseeded with an MTO-approved mixture that establishes quickly despite the dry conditions. Please refer to Information Request (IR) #1.

Compliance tool used: No compliance tool used

Observation 14 - MP 76.9

Date & time of visit: 2016-08-18 13:16

Discipline: Environmental Protection

Categories:

• Vegetation
• Invasive Plant Management
• Vegetation Reclamation
• Socio-economic
• Human Occupancy and Resource Use

Facility:

• Mainline (Pipeline)

Observations:

• Excavation was completed in spring 2016, was one of the first digs to be conducted in the 2016 program.
• Site was located approximately 25 m west of a swale running through a cultivated field, which was dry at the time of the inspection.
• Dig site was indistinguishable from the surrounding area.
• There were many invasive species observed on and off RoW at this location, including goldenrod, burdock, knapweed, and wild caraway. Company representative stated that the site was reseeded with an MTO-approved seed mix (see IR #1).
• A pipeline identification marker was visible on the east side of the field, but was not visible on the west side which could not be accessed due to a cultivated field (see IR #3).

Compliance tool used: No compliance tool used

Observation 15 - MP 75.0

Date & time of visit: 2016-08-18 13:42

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Reclamation
• Socio-economic
• Human Occupancy and Resource Use

Facility:

Observations:

• Dig site was located on a grassy verge within a parking lot approximately 10 m away from the nearest building.
• The excavation was conducted in June 2016.
• Fresh sod was placed down over dig site, which was indistinguishable from the surrounding area.
• Observed pipeline identification signage near the entrance to the parking lot.

Compliance tool used: No compliance tool used

Observation 16 - MP 74.5

Date & time of visit: 2016-08-18 13:56

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Reclamation
• Soils and Soil Productivity
• Restoration
• Socio-economic
• Human Occupancy and Resource Use

Facility:

• Mainline (Pipeline)

Observations:

• Excavation was completed in June 2016, approximately 3 m by 1 m in area.
• Dig site was located in a residential neighborhood, extending from part of a city-owned verge to the street. Company representative stated that a trench box was used during construction, and traffic was re-routed from the street during the dig.
• Sod was replaced over the affected area of the lawn, which was growing relatively well despite dry weather. The excavated part of the road had been re-paved.
• Observed pipeline identification signage across the road next to the sidewalk (no sidewalk on other side of the road crossing).
• Spoke with landowner living across from the dig site who stated that they had been notified about the dig and have no concerns. Company representative stated that there were also no concerns from the affected landowner, and that the rest of the neighbors nearby had been notified.

Compliance tool used: No compliance tool used

Observation 17 - Ottawa Lateral (OL) 5.5

Date & time of visit: 2016-08-18 14:41

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Handling
• Soil Integrity
• Surface Water Management
• Containment and Drainage Structures
• Vegetation
• Vegetation Reclamation
• Housekeeping
• Temporary Structures

Facility:

• Ottawa Lateral (Pipeline)

Observations:

• The Ottawa Lateral is a 12” pipeline that was built in the 1970s. There is another 8” line in the RoW corridor that has been abandoned since the 1960s.
• Staff went through a safety orientation and tailgate meeting prior to entering the site.
• A contractor was conducting an analysis of the exposed pipeline at the time of the inspection. According to a company representative, they were investigating two indications of internal corrosion (approximately 8” apart).
• The dig is located on county property within peatland adjacent to a road. Off-RoW was treed area (primarily aspen), and undisturbed RoW vegetation was primarily cattails.
• The area is normally extremely wet; however, due to dry summer the peaty substrate was only slightly damp at the time of the inspection.
• Excavation was approximately 2.5 m deep, was shored with gravel and had two ladders and egress on each wall of the trench.
• Observed sump pumps leading out of the excavation into treed area. As there were poisonous plants identified in the treed area, NEB IO received verbal confirmation from company representative that there was a filter bag on the end of the hose.
• Observed that generator was placed in lined secondary containment.
• Snow fence and safety signage was erected around excavation and a wind sock was placed on the subsoil pile.
• Sediment fence was installed around soil piles along tree line, was keyed in and functioning properly.
• Tree stumps along the RoW had been sprayed with fluorescent paint as hazard identification.
• Company representative stated that the site and access would be reseeded with an MTO-approved seed mix (see IR #1).

Compliance tool used: No compliance tool used

Observation 18 - OL 5.7

Date & time of visit: 2016-08-18 15:14

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Handling
• Soil Integrity
• Surface Water Management
• Containment and Drainage Structures
• Vegetation
• Vegetation Reclamation
• Housekeeping
• Temporary Structures

Facility:

• Ottawa Lateral (Pipeline)

Observations:

• Excavation located approximately 350 m from OL 5.5.
• Contractor was in the process of conducting non-destructive testing on the pipeline.
• Swamp mats were placed at the edge of the excavation.
• Observed that the walls of the excavation had been shored with gravel.
• There were two ladders and egress on all sides of the trench, which was 2.5 m deep.
• Partial snow fencing had been erected along the tree line.
• First strippings consisted of peat, second strippings consisted of more clayey soil.
• There was a sediment fence around the topsoil pile near the tree line.
• Observed > 1 m separation between soil piles.
• Observed sump pumps leading out of the excavation into treed area. As there were poisonous plants identified in the treed area, NEB IO received verbal confirmation from company representative that there was a filter bag on the end of the hose.
• Generator was placed in lined secondary containment.
• Observed fire extinguisher and spill kit located at the muster point approximately 6 m from the excavation.
• Company representative stated that the site and access would be reseeded with an MTO-approved seed mix (see IR #1).

Compliance tool used: No compliance tool used

Observation 19 - Information Request (IR) #1

Date & time of visit: 2016-09-18 15:48

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Reclamation

Facility:

• Mainline (Pipeline)

Observations:

Company representatives stated that the following sites were reseeded with a Ministry of Transportation (MTO) approved seed mix: MP 129.4, MP 95.7, OL 5.5, and OL 5.7. It was observed that the MP 95.7, OL 5.5 and OL 5.7 dig sites were located in wetland areas.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Standard Operating Procedure or Plan (SOP)
• Construction Safety & Environmental Manual (2016)

Relevant section(s):

• Fertilizer formulations, seed (mix) selection and application rates will be as indicated in the site-specific requirements, or as requested by the landowner in the Line List.

Company action required:

Please provide the site-specific requirements and Certificates of Analysis for the MTO-approved seed mixes used to reseed each site.

Due date: 2016-10-14

Date closed: 2016-10-17
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 20 - IR #2

Date & time of visit: 2016-08-18 11:23

Discipline: Environmental Protection

Categories:

• Training and Documentation
• Documentation Available/Up to Date

Facility:

• Mainline (Pipeline)

Observations:

Company representative stated that a pre-construction Environmental Protection Plan was developed by a third-party contractor for MP 95.7. The NEB Inspection Officer would like to review the pre-construction conditions at the site.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

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

Company action required:

Please provide a copy of the site-specific Environmental Protection Plan developed for the MP 95.7 integrity dig. 

Due date: 2016-10-14

Date closed: 2016-10-17
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 21 - IR #3

Date & time of visit: 2016-08-18 13:16

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs

Facility:

• Mainline (Pipeline)

Observations:

At MP 76.9, a pipeline marker was visible on the east side of the field, but was not visible on the west side. A company representative stated that a marker should be located on the west side, and it is either concealed by brush or has been knocked down. The west side could not be accessed due to a cultivated field, and due to the agricultural use of the land the NEB IO would like confirmation that a pipeline marker is placed at the property boundary to reduce the possibility of damage and interference.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• CSA Z662-15 - Oil and Gas Pipeline Systems

Relevant section(s):

• CSA Z662 - Oil and Gas Pipeline Systems
  • 10. Operating, maintenance, and upgrading
    • 10.5 Operating and maintenance procedures
      • 10.5.3 Pipeline identification
        • 10.5.3.1 Signs shall be installed to identify the presence of pipelines to reduce the possibilities of damage and interference. Such signs shall be posted along pipeline rights-of-way, as applicable, as follows:
          a) at railway and road rights-of-way; and
          b) at strategic areas of
          i) utility corridors;
          ii) subdivision development;
          iii) construction activity;
          iv) drainage systems;
          v) irrigation systems; and
          vi) other anticipated third-party activity.

Company action required:

Please provide a photograph of the sign on the west side of the field at MP 76.9 once permission has been obtained by the landowner to access the field.

Due date: 2016-10-31

Date closed: 2016-10-24
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 22 - IR #4

Date & time of visit: 2016-10-20 18:38

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Reclamation

Facility:

• Mainline (Pipeline)

Observations:

Company representatives stated that the following sites were reseeded with a Ministry of Transportation (MTO) approved seed mix: MP 129.4, MP 95.7, OL 5.5, and OL 5.7. It was observed that the MP 95.7, OL 5.5 and OL 5.7 dig sites were located in wetland areas.

According to the Environmental Protection Plan (EPP) for the integrity dig at MP 95.7, the dig was located in a provincially significant wetland. It was also determined during the inspection that this site was seeded with an MTO-approved seed mix which has subsequently been identified as a standard roadside mix.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Standard Operating Procedure or Plan (SOP)
• Construction Safety & Environmental Manual (2016)

Relevant section(s):

• Section 3.10: Ontario's Wetlands Policy is to ensure that there will be no loss of provincially significant wetland functions or area in the Great Lakes-St. Lawrence Region. Provincially significant wetlands are identified by the Ministry of Natural Resources. The policy also encourages protection of all other wetlands. This policy in enforced through the Ontario Planning Act. [...] Trans-Northern is aware of these policies and has considered them in developing the mitigation and restoration measures listed below. Where a wetland has been identified as being of importance or worthy or preservation, construction or other activities should avoid or reduce disturbance to the extent possible. During pipeline maintenance activities, the following measures should be implemented. • A vegetative inventory along the construction area may be undertaken prior to construction. [...] Wetlands will normally be permitted to re-vegetate naturally as re-seeding and fertilizer application is usually not advised.

Company action required:

Please provide the following information via email by 3 November 2016:

1. A copy of the EPP for the OL 5.5 and OL 5.7 dig sites.
2. Vegetation inventories for MP 95.7, OL 5.5 and OL 5.7, or justification if no such inventories were taken.
3. Justification for applying the seed mix to the MP 95.7 dig site, which was identified in the EPP as being located in a provincially significant wetland.
4. The reclamation goals for each integrity dig completed in a wetland area, and how TNPI intends to achieve them.

Due date: 2017-10-01

Date closed: 2017-11-10
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

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: