Compliance Verification Activity Report: CV1718-157 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2463
• Inspector 2538

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada Pipelines Limited

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Environmental Protection
• Safety Management

Rationale and scope:

Following a public hearing (GH-002-2015) on NOVA Gas Transmission Ltd. (NGTL) a fully owned and operated subsidiary of TransCanada Pipelines Inc. (TransCanada) application for the 2017 NGTL System Expansion Project (NGTL 2017 or Project), on 26 May 2016 the National Enery Board (Board) issued Certificate GC-126 (Certificate) approving the application subject to conditions. The Boundary Lake Section of the NGTL 2017 expansion (Pipeline) is to transport natural gas from the Alces River Compressor Station located at NW 13-85-13 W6M to the existing Owl Lake South Meter Station located at NE 20-94-12 W6M and have a maximum operating pressure of 8,450 kPa. The Project loops the existing Northwest Mainline Boundary Lake pipeline, and is located approximately 6 km east of the AB/BC border in Clear Hills County, AB. The purpose of these inspections is to verify compliance to the National Energy Board Act (NEB Act.), the National Energy Board Onshore Pipeline Regulations (OPR) including referenced standards such as the Canadian Standards Association Standard for Oil and Gas Pipelines (CSA Z662-11)., as well as relevant Certificate GC-126 (Certificate) and its conditions, including relevant documentation on file with the Board and company documents applicable to the Pipeline. This inspection primarily verifies compliance to environmental requierments and commitments. Construction of the Pipelie was started in 2016-17 but continues in a second winter (2017-2018) in caribou habitat.

Compliance tool(s) used:

• None

Facility details

Facilities:

• NORTHWEST M/L (BOUNDARY LAKE SECTION) - NPS 36

Facility Types

• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Act (NEBA) 2016-06-19
• Plans And Procedures
• Project-specific Environmental Protection Plan (EPP)
• NGTL 2017 Boundary Lake Final EPP
• Project-specific plan or procedure
• Emergency Response Plan - Northwest Mainline Boundary Lake Season 2
• Project-specific plan or procedure
• TransCanada Northwest Mainline Loop Boundary Lake Season 2 - Doig River HDD Execution Plan
• Project-specific plan or procedure
• Site Specific Safety Plan, RFP No. 10128518 Northwest Mainline Loop - Boundary Lake Section
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• GC-126
• XG-N081-013-2016

Observations (no outstanding follow-up required)

Observation 1 - General Environment

Date & time of visit: 2018-02-13 07:00

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Soil Handling
• Biosecurity
• Soil Integrity
• Crowns/Subsidence
• Chemical Spills/Releases
• Restoration
• Surface Water Management
• Containment and Drainage Structures
• Water Bodies - Fish-bearing
• Sedimentation/Turbidity
• Use/Overuse/Flow
• Disturbance
• Reclamation
• Erosion
• Wildlife
• Access Control/Lines of Sight
• Disturbance
• Species of Concern
• Vegetation
• Vegetation Control
• Invasive Plant Management
• Destruction of Vegetation
• Species of Concern
• Access Control
• Training and Documentation
• Inspections

Facility:

• NORTHWEST M/L (BOUNDARY LAKE SECTION) - NPS 36 (Pipeline)

Observations:

• Take water permits and research fishing licenses were reviewed and available at construction field office.
• Confirmed clear span bridge, snow fills, and / or ice bridges were in place at watercourse crossings visited.
• Observed Temporary Work Space (TWS) along Right of Way (RoW), with no instances of trespass noted.
•  Observed the presence of salvaged timber stored in log decks. TransCanada representatives confirmed they were retained and are planned to be utilized as rollback for access control  and wildlife habitat management
• Observed sufficient soil / snow separation in areas of soil stockpiling.
• Noted breaks in roaches for surface water management. 
• Observed appropriate breaks in windrows, soil piles, and strung pipe. 
• Observed appropriate signage for watercourses, wetlands, environmental features, and wildlife.
• Noted appropriate breaks in welded pipe in key areas to allow for wildlife passage.
• Noted appropriate breaks in roach over buried pipeline in key areas to allow for wildlife passes and surface drainage.
• Observed that TWS for access roads and shooflies were appropriately flagged and identified with adequate signage.
• Observed spill kits present on all heavy equipment and mobile light/generator plants.
• One light/generator plant, near the entrance of the construction site yard, was observed to have unusually smoky exhaust. TransCanada confirmed that the particular unit had recently receive maintenance for that reason. The unit was taken out of service and replaced the same day. Officers are satisfied the issue is being appropriately managed in accordance with requirements of the Environmental Protection Plan. 
• No instances of food debris or other garbage on the RoW were identified.
• Officers note that Pipeline construction will extend into the Cariboo Restricted Activity Period (RAP). Officers confirmed that mainline construction is to be completed within the first few days of the RAP and that the company has been and is in communication with Alberta Environment, as required.

Compliance tool used: No compliance tool used

Observation 2 - General Safety

Date & time of visit: 2018-02-12 07:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Occupational Medical Surveillance
• Fire Protection
• Flammable and Combustible Liquids
• Hazard Assessment
• Materials Handling
• Overhead Cranes
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Temporary Structures
• Scaffolding and Temporary Ladders
• Temporary Stairs, Ramps and Platforms
• Lighting
• Task Lighting

Facility:

• NORTHWEST M/L (BOUNDARY LAKE SECTION) - NPS 36 (Pipeline)

Observations:

• Activities observed included, but were not limited to, Horizontal Directional Drill (HDD) section lift, HDD pullback, hydro-vac, installation of water course isolation, jeeping & coating repair, trenching (tracked excavator & ditch wheel), lowering-in, and backfill. 
• Open excavations, bell holes, and open trench areas were marked with appropriate signage, flagging, snow fencing, t-posts with end caps, to limit access and allow easy identification. Appropriate access and egress was available when workers present. 
• Field Level Hazard Assessments (FLHA) were available, appropriate, and explained to Officers upon arrival at various work crew at locations/activities visited.  
• Generally, appropriate Personal Protective Equipment (PPE) was worn and in use for tasks undertaken by workers throughout the right of way (RoW) and work crews visited.
• Observed that workers positioned themselves appropriately when working near heavy equipment, or in and around suspended loads.
• Requested Material Safety Data Sheets (MSDS) or Safety Data Sheets (SDS) were available and valid for products requested.
• Observed hazardous material storage along RoW and in laydown yards or temporary work space (TWS) had appropriate manufacture or workplace labels.
• Housekeeping found to be appropriate throughout work sites and along RoW.
• Communication and contractor oversight between TransCanada’s Inspectors (on behalf of NGTL) and Formans / crews was observed to have open dialogue and be appropriate.
• Hotline crossings observed to be clearly identified by signage / fencing as appropriate, and with snow fill / ice ramps in place.
• Observed equipment had up to date, well documented and completed log books, had adequately stocked spill kits, and appropriately sized fire extinguishers.
• Verified fire extinguishers were charged, had valid monthly inspection and annual certification.
• Observed and verified select slings on equipment, no concerns noted.
• Crane inspection certificates were available for verified equipment (mobile cranes) and provided upon request.
• Confirmed relevant safety materials, legislation, and plans, as well as NEB approvals and regulatory instruments were available at construction field offices.
• Noted portable toilets available in acceptable locations throughout the RoW and in proximity to ongoing pipeline construction   crews and activities.
• Noted radio controls in place in key areas and observed to be utilized appropriately.
• Observed portable light plants / generator in use along RoW, appropriately grounded.

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: