Compliance Verification Activity Report: CV1718-112 - TransCanada PipeLines Limited

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1718-112
Start date: 2017-05-04
End date: 2017-05-04

Team:

Regulated company: TransCanada PipeLines Limited

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

TransCanada submitted a Grout Abandonment Plan (A5K6H0) for abandonment of the Humber River Horizontal Directional Drill (HDD) on the Vaughan Mainline Expansion Project. The inspection focused on abandonment (grouting) activities.

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 - Humber River Horizontal Directional Drill (HDD) Exit Side

Date & time of visit: 2017-05-04 09:45

Discipline: Environmental Protection

Categories:

Facility:

Observations:

At the time of the inspection, grouting activities had begun at the exit side of the HDD.  According to company representatives, the plan for this activity is to pour approximately 1350 m3 of grout material into the HDD hole in order to abandon it, as per scenario 1 (section 6.1.1) of the Grouting Abandonment Plan.  The grout was being poured from the HDD exit side site, as this side of the drill path is at higher elevation than the entry side.  This operation was anticipated to  take less than 36 hours, although this estimate would be altered if the pumping rate changes. 

Cement trucks with pre-mixed grout product were observed on site.  A grout pump truck was used to deposit the grout material into the HDD hole using a custom attachment.  A spare pumping truck was observed on site, which company representatives explained was a precaution in the event of mechanical failure of the primary truck. 

A shack for QA/QC testing of the grouting product was observed.  Company representatives indicated that staff take samples in order to test the grout material in established intervals for quality control purposes.

Inspection staff requested Material Safety Data Sheets (MSDSs) for the grout material as part of this inspection.  Staff reviewed, and note no evidence of toxic materials in the MSDSs provided.  During the inspection, company representatives confirmed the grout material is non-toxic.

With respect to preparedness for the containment of potential releases, the following was observed:

Inspection staff discussed the monitoring of the Humber River during the grouting activities with a representative of the environmental consulting company on site.  Regular turbidity monitoring of the river has been conducted  throughout the HDD activities, with monitoring continuing through grouting activities.  In addition, personnel are visually monitoring the river for signs of release.  According to the representative, a total of six personnel (“frac walkers”) are on this site monitoring the river and sinkhole areas. No issues were noted by company representatives to date during the grouting activities. 

General observations at the site include the following:Inspection staff observed the large sinkhole area between the site and the Humber River.  The area was fenced to prevent unauthorized access. 

Two contractor personal (“frac walkers”) were observed to be watching the sinkhole area for signs of returns, as the sinkhole could present a preferential pathway for material.  Staff indicated that no signs of material had been observed in this area at the time of the inspection.  Company representatives indicated that the “frac walkers”were looking for signs of water, grout material or drilling mud.  Drilling mud was not used during grouting operations, but residual amounts could be in the hole following the HDD drilling activities.  NEB inspection staff requested MSDS sheets for the drilling mud additives used during activities.  Inspection staff review of the MSDSs did not identify toxic additives.  On site, company representatives confirmed that the drilling fluid used in the HDD was non-toxic.

In addition to the “frac walkers”, an additional preventative measure was a pump in place in the sink hole area with an attached hardline.  In the event of release into the sink hole area, the pump could be used to transport fluid up the hill to the drilling area.  Company representatives indicates that in the event of cement returns in the sink hole area, an addition response measure would be manually containing and retrieving  the grout material with labourers, noting the material hardens more slowly than conventional cement.  

While on site, inspection staff and company representatives discussed the plans to reclaim the sinkhole area.  The proposed Sinkhole Remedial Plan (filed with the Board) was discussed, and company representatives verbally confirmed that the landowner is being consulted throughout the process.  Staff understands that the grouting activities must be completed prior to the completion of any work to reclaim the sinkholes.   

Compliance tool used: No compliance tool used

Observation 2 - Humber River HDD Entry Side

Date & time of visit: 2017-05-04 11:46

Discipline: Environmental Protection

Categories:

Facility:

Observations:

At the entry side, two hydrovac trucks were on site as a cautionary measure.  Large orange storage bins were on site and available as a precautionary measure in the case of flush backs.  Extensive rig matting was in place.

Two sinkholes were present in a bermed area (which were constructed from sandbags, sediment fencing and plywood).  Three pit pumps were on site.  One pump was set up in each sink hole, with a spare pump located near the drill rig.  The drill rig was not in operation, however company representatives indicated that the rig would remain on site until it could be confirmed that it was not needed.  The rig would be used is the case of scenario 2 as per the Grout Abandonment Plan.

Company representatives confirmed “frac walkers” were to be viewing the river, which was not observed due to heavy tree cover and slope.  At the area of the sink holes, company representatives were observing the area steadily to visually confirm returns.  Circulation was reported to be good, with small amounts of water and bentonite clay reaching the hole.

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