Compliance Verification Activity Report: CV1617-096 - Foothills Pipe Lines Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2507

Regulated company: Foothills Pipe Lines Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

• Alberta
• British Columbia

Discipline(s):

• Environmental Protection

Rationale and scope:

Operations environmental inspection of the South BC - Zone 8 pipeline right-of-way (RoW) between Fernie and Moyie BC areas.

Compliance tool(s) used:

• Information Request (IR) (6)
• Corrected Non-compliance (CNC) (6)
• Notice of Non-compliance (NNC) (1)

Facility details

Facilities:

• South BC - Zone 8
• ANG Mainline
• ELK RIVER SECURITY LOOP

Facility Types

• Pipeline
• Pipeline right of way (ROW)
• Valve site

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• 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)
• Invasive Vegetation Weed Control Management Canada; Brush Control Procedure; Heritage Resources Protection Procedure Canada; Wetlands, Watercourses and Waterbody Protection Procedure Canada; Aerial Pipeline Patrol Procedure; Soils Management Procedure; Pipeline Right of Way Procedure; TransCanada Signage Procedure
• Project-specific Environmental Protection Plan (EPP)
• Environmental Protection Plan for the Pipeline Maintenance Program - NGTL &FPL Systems, 2014 Alberta & British Columbia Summer Integrity Dig Programs
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Information Request #1

Date & time of visit: 2016-08-02 12:25

Discipline: Environmental Protection

Categories:

• Vegetation
• Invasive Plant Management
• Training and Documentation
• Documentation Available/Up to Date

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

Inspection Officers submitted the following Information Request (IR) via email following the opening meeting.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• National Energy Board Act (NEBA) until 1 April 2020, Canada Energy Regulatory Act (CERA) after 1 April 2020

Relevant section(s):

• National Energy Board Act (NEBA)
  • 49. Inspection Officers
    • (2) For the purpose described in subsection (1), an inspection officer may at any reasonable time
      • (c) examine and make copies of any information contained in any books, records or documents, or in any computer systems, that the inspector believes on reasonable grounds contain any information relating to the design, construction, operation, maintenance or abandonment of a pipeline.

Company action required:

Please provide the following information:

• The latest revisions of:
  • Invasive Vegetation Weed Control Management Canada;
  • Brush Control Procedure;
  • Wetlands, Watercourses and Waterbody Protection Procedure Canada;
  • Aerial Pipeline Patrol Procedure;
  • Soils Management Procedure; and
  • Environmental Complaint Investigation Procedure.
• A copy of the Environmental Protection Plan for TransCanada’s 2016 O&M program.
• A copy of the Notice of Intent to Treat for the section of RoW covered in today’s inspection.

Due date: 2016-08-08

Date closed: 2016-08-25
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 - KP 0+3 XR-001 AB/BC Border - Crossover Valve

Date & time of visit: 2016-08-02 12:27

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Chemical Spills/Releases
• Air Quality
• Emissions Control/Monitoring

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• No oil staining observed under facility equipment.
• Company representative stated that a fugitive emmissions test was conducted in 2016.
• Valves cycled in 2016.
• Site drawings attached to perimeter fence near facility gate.

Compliance tool used: No compliance tool used

Observation 3 - CNC #1: KP 0+3 XR-001 AB/BC Border - Crossover Valve

Date & time of visit: 2016-08-02 14:27

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Control

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

Site is a few hundred meters within AB border, discussed that weed control is responsibility of AB operator. Some mullein, oxeye daisy within facility fenceline, vegetation not managed within facility or outside of the perimeter fence. 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Standard Operating Procedure or Plan (SOP)
• Invasive Vegetation Weed Control Management Canada; Brush Control Procedure; Heritage Resources Protection Procedure Canada; Wetlands, Watercourses and Waterbody Protection Procedure Canada; Aerial Pipeline Patrol Procedure; Soils Management Procedure; Pipeline Right of Way Procedure; TransCanada Signage Procedure

Relevant section(s):

• Invasive Vegetation Weed Control Management Canada, Revision 07 4.3.2.1 Vegetation Management Plan Development 6. Identifying the objectives of the vegetation management program a. Conduct total vegetation control on all gravelled areas within the fence line of facility sites (compressor stations, meter stations, pump stations, block valve sites, gas storage facilities, and energy facilities), excluding landscaped office areas. Refer to the Physical Security and Incident Procedure to ensure vegetation management extends the appropriate distance beyond the facility fence to ensure clear sight lines. If the site is gravelled beyond the fence line, consideration can be given to extending total control to the edge of the gravel. Targeted vegetation control should extend beyond the facility fence line to the property boundary unless an agreement is in place with a landowner for land use.

Company action required:

TransCanada shall ensure that weed management is conducted at the KP 0+3 crossover valve site and send photo(s) upon completion.

Due date: 2016-08-05

Date closed: 2016-08-05
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 - CNC #2: KP 0+3 XR-001 AB/BC Border - Crossover Valve

Date & time of visit: 2016-08-02 14:27

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

Personal protective equipment (PPE) requirements are missing from facility signage.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Standard Operating Procedure or Plan (SOP)
• Invasive Vegetation Weed Control Management Canada; Brush Control Procedure; Heritage Resources Protection Procedure Canada; Wetlands, Watercourses and Waterbody Protection Procedure Canada; Aerial Pipeline Patrol Procedure; Soils Management Procedure; Pipeline Right of Way Procedure; TransCanada Signage Procedure

Relevant section(s):

• TransCanada Signage Procedure, Revision 08 Appendix A: Signage List 01 Public Messaging 01 Facility ID: Signs in this section have a public audience and are required by regulation to identify facilities, including meter stations, valves and well sites. Type of Sign (Layout Number(s)): General Facility ID 01-01-01-X-X Description: - Common Requirements: Mount at the main gate of each Facility. For unfenced facilities, mount where visible upon approach. - Additional Requirements: Personal Protective Equipment: PPE which may be required for the site to be displayed on the main gate of the Facility. Federally Regulated Oil and Gas Pipeline facilities must also include: • Hazard Identification. This can be either text “Warning High Pressure (Natural Gas/Petroleum)” or the appropriate TDG Icon (Flammable Gas Class 2/Flammable Liquid Class 3). • For NEB regulated facilities, ensure hearing protection icon is included at the main gate of all facilities where a pipeline blow down can occur. Message Requirements: - Common Requirements • Operating Company name and logo • Facility name • Emergency phone number • “Personal Protective Equipment on site as required.” and icons showing equipment required on site, but not necessarily required in yard, or equivalent messaging. Typical icons to include are as follows: o Hard Hat Icon o Safety Boots Icon o Safety Glasses Icon o Gloves Icon o Hearing Protection Icon o Fire Resistant Clothing Icon o Respirator Icon

Company action required:

TransCanada shall install PPE requirements signage on the facility fencing and submit photo(s) upon completion.

Due date: 2016-08-05

Date closed: 2016-08-05
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 - KP 3+73 Summit Creek Crossing

Date & time of visit: 2016-08-02 15:06

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Control
• Invasive Plant Management
• Water Bodies - Fish-bearing
• Erosion

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• Creek banks were stable and well vegetated.
• Width of riparian buffer is approximately 10 m on the south side of the creek.
• Weeds present within riparian buffer; mainly oxeye daisy and Canada thistle, which are prevalent in the area. Company representative stated that herbicides are not used within 10 m of the high water mark.
• A railroad ran along the side of the creek; company representative stated that a train derailment had occurred in the area approximately 10 years ago.

Compliance tool used: No compliance tool used

Observation 6 - Information Request #2

Date & time of visit: 2016-08-02 15:06

Discipline: Environmental Protection

Categories:

• Water Bodies - Fish-bearing
• Disturbance

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

A rusted steel grate possibly from a historic train derailment was resting on the creek banks. A company representative stated that they would consult with a biologist on possible disturbance caused by removal of the grate. 

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 submit a copy of the email response from the biologist regarding possible disturbance cause by removal of the grate from the creek.

Due date: 2016-10-14

Date closed: 2016-10-05
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 - CNC #3: Power Plant Road Crossing

Date & time of visit: 2016-08-02 15:42

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

A Foothills Mainline sign was down on the SW side of the road crossing, the TransCanada sign was on both sides of the crossing. A company representative stated that there is a work order to conduct RoW maintenance, including signage repairs/replacements.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Standard Operating Procedure or Plan (SOP)
• Invasive Vegetation Weed Control Management Canada; Brush Control Procedure; Heritage Resources Protection Procedure Canada; Wetlands, Watercourses and Waterbody Protection Procedure Canada; Aerial Pipeline Patrol Procedure; Soils Management Procedure; Pipeline Right of Way Procedure; TransCanada Signage Procedure

Relevant section(s):

• Pipeline Right Of Way Procedure 4.1.1 Location of Marker Signs 1. Warning Signs shall be installed on both sides of all: a. public roads; b. rivers, creeks and other bodies of water.

Company action required:

TransCanada shall repair the Foothills Mainline signage and submit a photo to NEB staff upon completion.

Due date: 2016-08-05

Date closed: 2016-08-05
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 8+0 Other Side of Hill from Sparwood Tap

Date & time of visit: 2016-08-02 16:20

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Control
• Invasive Plant Management

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• Abundance of weeds observed on the RoW including oxeye daisy, Canada thistle, and knapweed. It was confirmed through Information Request #1 that this site is on the list for weed control this year.
• Brushing at this location was conducted 2-3 years ago, brush was piled to the side of the RoW.
• Did not brush trees and bush by seasonal drainage/low lying area (left approximately 10 m buffer).

Compliance tool used: No compliance tool used

Observation 9 - Information Request #3

Date & time of visit: 2016-08-03 08:50

Discipline: Environmental Protection

Categories:

• Vegetation
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

Following an overview of the 2016 B.C. Summer Dig Program, company representative stated that sites were reseeded using a low elevation or a high elevation seed mix.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Project-specific Environmental Protection Plan (EPP)
• Environmental Protection Plan for the Pipeline Maintenance Program - NGTL &FPL Systems, 2014 Alberta & British Columbia Summer Integrity Dig Programs

Relevant section(s):

• Environmental Protection Plan for the Pipeline Maintenance Program - NGTL & FPL Systems 2014 Alberta & British Columbia Summer Integrity Dig Programs 8.8 Clean-up and Reclamation Seeding and Revegetation 40. Acquire Certificates of Analysis for all seed mixes.

Company action required:

Please submit the Certificate of Analysis for the low elevation seed mix.

Due date: 2016-09-02

Date closed: 2016-08-05
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 10 - KP 15+3 MLV Site 1-0a

Date & time of visit: 2016-08-03 09:59

Discipline: Environmental Protection

Categories:

• Wildlife
• Disturbance
• Vegetation
• Invasive Plant Management

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• This site marks the beginning of the 2015 decommissioning project involving the 36" Leach Creek section of the Foothills Mainline.
• Lay down area/turnaround on the east side and temporary workspace on the west side of the valve site were stripped and recently reseeded.
• A company representative stated that the Environmental Inspector (EI) will conduct a post-construction inspection of the site (evaluation includes vegetation reclamation success).
• There was a robin’s nest inside the valve site, company installed snow fence around the nest area to prevent disturbance.
• Valve site is graveled, no weeds observed within the fenceline with the exception of scentless chamomile in the SE corner which could not be sprayed due to proximity to robin’s nest.
• Fenceline was mowed (approximately 0.5 m strip width).
• A small creek crossed the RoW to the north of the valve site.
• Canada thistle and toadflax observed along the north side of the fenceline, which wasn’t sprayed due to proximity to robin’s nest and 10 m buffer to nearby creek.
• A section of the 36” Leach Creek pipeline that was removed from a launcher during decommissioning activities was lying on the ground in a separate grassy area; there was a labeled stake next to it and one wooden board placed directly beneath the pipe.
• A company representative stated that the pipe from the launcher had been tested for hydrocarbons and NORMs prior to placing it on the ground, and that it will be picked up by the landowners for their personal use.

Compliance tool used: No compliance tool used

Observation 11 - KP 18+2 Inlet to Byron Creek Meter Station

Date & time of visit: 2016-08-03 11:06

Discipline: Environmental Protection

Categories:

• Vegetation
• Invasive Plant Management

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• This site was part of the 2015 decommissioning project, work at this site was completed a week prior.
• Geotextile and gravel had been laid down to prevent weed growth.
• Cattle were grazing to the south of the yard on the RoW.

Compliance tool used: No compliance tool used

Observation 12 - KP 17+3 Carbon Creek Crossing

Date & time of visit: 2016-08-03 11:25

Discipline: Environmental Protection

Categories:

• Water Bodies - Fish-bearing
• Reclamation
• Erosion
• Vegetation
• Invasive Plant Management

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• Creek was the site of a pipeline exposure in 1995 according to the company representative.
• Observed bank armouring with geotextile and boulders; a section of boulders on a steep part of the bank had fallen into the creek, exposing some geotextile but doesn’t appear to be impeding flow.
• Mullein, oxeye daisy, and other weeds observed along the river bank, are prevalent in the area.
• Observed pipeline identification signage for three pipelines on the NW side of the creek; signage on SE side had been knocked down. Please refer to NNC #1 for follow-up information.

Compliance tool used: No compliance tool used

Observation 13 - KP 19+2 Leach Creek Crossing

Date & time of visit: 2016-08-03 12:15

Discipline: Environmental Protection

Categories:

• Water Bodies - Fish-bearing
• Reclamation
• Erosion
• Vegetation
• Invasive Plant Management
• Wildlife
• Habitat Restoration/Offsets

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• Observed long stretch of bank armouring that was completed in 2003 due to erosion concerns.
• Observed signage for three pipelines on both sides of the creek crossing.
• Observed wildlife trees near the crossing that had been installed by company in 2002 for benefit of woodpeckers; trees had signs of use.
• Cathodic protection leads observed on sign posts along RoW.
• Majority of RoW was covered in oxeye daisies, a company representative stated that this area is included on a list to be sprayed (please refer to Information Request #5 for more information).

Compliance tool used: No compliance tool used

Observation 14 - GWD 24710 Integrity Dig Site

Date & time of visit: 2016-08-03 12:24

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Integrity
• Water Bodies - Non-Fish-bearing
• Reclamation
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• Reclamation has been completed at this site, company representatives confirmed that the site was reseeded on 23 June 2016.
• Company hasn’t yet replaced pipeline identification signage that was taken down for construction, currently only the north side of the crossing has two signs (see Information Request #6).
• Tire tracks from recreational vehicles were observed on the water bars of a drainage ditch over the RoW.
• Partial disturbance of wetland area at the east end of the drainage was extremely wet and muddy, although vegetation is starting to come in. This area was separated from the undisturbed wetland area by a sediment fence (keyed in properly and in good working condition).

Compliance tool used: No compliance tool used

Observation 15 - Information Request #4

Date & time of visit: 2016-08-03 12:24

Discipline: Environmental Protection

Categories:

• Training and Documentation
• Documentation Available/Up to Date

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

Inspection Officers noted water bars approximately 1 m width and 0.3 m high along the bank of the drainage ditch at the GWD 24710 integrity dig site.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• National Energy Board Act (NEBA) until 1 April 2020, Canada Energy Regulatory Act (CERA) after 1 April 2020

Relevant section(s):

• National Energy Board Act (NEBA)
  • 49. Inspection Officers
    • (2) For the purpose described in subsection (1), an inspection officer may at any reasonable time
      • (c) examine and make copies of any information contained in any books, records or documents, or in any computer systems, that the inspector believes on reasonable grounds contain any information relating to the design, construction, operation, maintenance or abandonment of a pipeline.

Company action required:

Please submit a copy of the pre-activity report (including photos taken prior to ground disturbance) to Inspection Officers for the GWD 24710 dig site.

Due date: 2016-08-08

Date closed: 2016-08-08
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 16 - KP 24+4 Valve Station

Date & time of visit: 2016-08-03 12:53

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Control
• Invasive Plant Management
• Housekeeping
• Temporary Structures

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• This location marks the end of the 2015 decommissioning project.
• Valve station was clean and graveled.
• A temporary work space constructed from gravel was located to the south of the station; a company representative stated that it will be removed once work has been completed.

Compliance tool used: No compliance tool used

Observation 17 - KP 32+0

Date & time of visit: 2016-08-03 15:48

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Control
• Invasive Plant Management

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• Site located at high elevation with steep, variable terrain.
• Inspection Officers were informed that the RoW between KP 15+3 to KP 35+0 is to be brushed after a nesting period ends as part of the company's 2016 vegetation management plan.
• A company representative stated that herbicide will be applied at this site in 2-3 years.

Compliance tool used: No compliance tool used

Observation 18 - GWD 20600 Integrity Dig Site

Date & time of visit: 2016-08-03 16:08

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Integrity

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• Cause of dig was to investigate stress corrosion cracking (SCC) on the 1980 36" section of the Foothills Mainline.
• Company representative stated that several digs have been conducted along this section to investigate SCC the past 10-15 years.
• A small creek crosses the RoW more than 30 m distance away.
• Snow fence and signage was placed around the excavation perimeter.
• Reportedly a wet area, however no water was visible at this time.

Compliance tool used: No compliance tool used

Observation 19 - CNC #4: GWD 20600 Integrity Dig Site

Date & time of visit: 2016-08-03 14:08

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Handling

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

No separation observed between topsoil and subsoil piles on the east side of the excavation due to narrow area/lack of space for excavator, and no sediment fence or other barrier separated the soil piles.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Standard Operating Procedure or Plan (SOP)
• Invasive Vegetation Weed Control Management Canada; Brush Control Procedure; Heritage Resources Protection Procedure Canada; Wetlands, Watercourses and Waterbody Protection Procedure Canada; Aerial Pipeline Patrol Procedure; Soils Management Procedure; Pipeline Right of Way Procedure; TransCanada Signage Procedure

Relevant section(s):

• Soils Management Procedure, Revision 07 4.4 Topsoil Stripping Best practice is maintaining a 1 m or 3 ft. separation between topsoil and subsoil storage piles, workspace permitting. Alternatively, silt fence or another appropriate physical barrier can be used to avoid mixing of soils and the loss of topsoil.

Company action required:

TransCanada shall install a sediment fence or other appropriate barrier between the topsoil and subsoil piles.

Due date: 2016-08-04

Date closed: 2016-08-04
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 - KP 40+2 Morrissey Creek Crossing

Date & time of visit: 2016-08-03 16:47

Discipline: Environmental Protection

Categories:

• Water Bodies - Fish-bearing
• Sedimentation/Turbidity
• Housekeeping
• Temporary Structures

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• Temporary access bridge across Morrissey Creek was installed approximately one month ago for access to the GWD 31120 integrity dig site.
• A pipeline identification sign was down on the north side of the creek and a sign on the south side was tilted; a company representative stated that the sign will be replaced once work has been completed (see Information Request #6).
• Sediment fence barriers installed along the access bridge corners to the creek were keyed in and functioning properly.

Compliance tool used: No compliance tool used

Observation 21 - GWD 31120 Integrity Dig Site

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

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Handling

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• Both ends of the 36" 1980 Foothills Mainline cutout were capped; cut out was result of suspected SCC, and was taken to a valve yard for testing.
• Snow fence and signage was placed around the excavation perimeter.
• Groundwater was observed in the bottom of the excavation.
• There was adequate separation between soil piles on the SE side of the excavation.
• A second smaller excavation was adjacent to the dig site.
• Observed secondary containment for pumps, however the pumps were not onsite at the time.
• Sediment fences installed around the bottom of the soil piles downslope of the excavation were in good working condition.
• An area to the west of the excavation looks to have been disturbed fairly recently due to lack of vegetation; a company representative estimated that a dig occurred there 2-3 years ago.
• Pipeline identification signage for two pipelines was missing from the SE side of an unnamed tributary to the Flathead River at the base of the hill (next to the temporary access bridge). A company representative stated that the signage will be replaced once work has been completed (see Information Request #6).

Compliance tool used: No compliance tool used

Observation 22 - CNC #5: GWD 31120 Integrity Dig Site

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

Discipline: Environmental Protection

Categories:

• Water Bodies - Non-Fish-bearing
• Sedimentation/Turbidity
• Housekeeping
• Temporary Structures

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

At the base of the hill where the excavation took place was a temporary access bridge (constructed from rig mats) over an unnamed tributary to the Flathead River. The sediment fence barriers at the corners of the bridge had failed, allowing sediment from the road to flow into the creek from all sides.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Project-specific Environmental Protection Plan (EPP)
• Environmental Protection Plan for the Pipeline Maintenance Program - NGTL &FPL Systems, 2014 Alberta & British Columbia Summer Integrity Dig Programs

Relevant section(s):

• Environmental Protection Plan for the Pipeline Maintenance Program - NGTL &FPL Systems 2014 Alberta & British Columbia Summer Integrity Dig Programs 8.4 Watercourse Crossings Erosion Control Install erosion and sediment control at all watercourses and/or waterbodies as directed by the Environmental lnspector(s) (Appendix A, Dwgs. STDS-03-ML-05-00 1 , STDS-03-ML -05-131 and STDS-03-M L -05-132)

Company action required:

TransCanada will repair the sediment fence barriers and remove as much sediment as practicable from the creek.

Due date: 2016-08-05

Date closed: 2016-08-05
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 23 - KP 53+7 Fernie Sales Meter Station

Date & time of visit: 2016-08-04 08:42

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Control
• Invasive Plant Management

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• New facility signage had recently been installed.
• Site was graveled inside the fenceline, and there was a 1 m mowed and graveled strip around the station.
• Oxeye daisy, scentless chamomile, mullein, Canada thistle, large patch of common tansy were observed on the RoW adjacent to the fenceline (refer to Information Request #5).
• Observed area where company representative marked off blueweed rosettes for the sprayers as rosettes are difficult to see (also recorded GPS coordinates for a map for the sprayers).

Compliance tool used: No compliance tool used

Observation 24 - KP 49+5

Date & time of visit: 2016-08-04 10:01

Discipline: Environmental Protection

Categories:

• Vegetation
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• From road, observed RoW for 1961 ANG Mainline and 1970s Elk River Security Loop on steep mountain face.
• Observed from a distance a portion of access road for a historic (2006) O&M dig on the Elk River Security Loop; part of road had been washed out.
• Company representative stated that the dig site was seeded with a high elevation seed mix.
• Company representative stated that there have been many past digs in the area for dents.
• Site was on border between Nature Conservation Canada (NCC) and crown land owned by a Native reserve.
• Very steep incline, blends in well with surroundings (lots of native vegetation).
• Some small patches of bull thistle observed.

Compliance tool used: No compliance tool used

Observation 25 - KP 48+0 Valve Site

Date & time of visit: 2016-08-04 10:34

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Control
• Invasive Plant Management

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• A gate around the high point vent was down; company representative stated that it would be replaced within 2 weeks. After the inspection was completed, Inspection Officers received confirmation from the company that the damaged compounds had been removed and four new heavy duty compound fences were installed around yards in areas of high volume snow pack with 8' markers providing good visibility for the yards.
• Company representative stated that in the winter, the area typically receives around 20 ft of snow pack; snowmobiles often hit and bend parts of the valves and signage (e.g. wheel on valve was slightly bent).
• Company representative stated that brushing in the area is scheduled for 2017.
• Abundant oxeye daisy observed on the RoW; company representative stated that a crew would come in before September to spray (see Information Request #5).
• Observed a pump standard and air compressor placed in lined secondary containment.
• Additional signage (no smoking, PPE, etc.) inside valve site fence line waiting to be installed.
• Large boulders were placed around the valve site for additional protection.

Compliance tool used: No compliance tool used

Observation 26 - KP 46+5

Date & time of visit: 2016-08-04 11:04

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Control
• Invasive Plant Management

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• Company representative estimated that this area of the RoW has not been brushed for around 7-8 years, however RoW was still well-defined.
• RoW went into very steep incline at this point, could not access further (other side of hill is where GWD 31120 dig site is located).
• Signage for both lines observed at small creek crossing on RoW.

Compliance tool used: No compliance tool used

Observation 27 - KP 51+0

Date & time of visit: 2016-08-04 11:56

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Control
• Invasive Plant Management

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• RoW at this location on property owned by NCC.
• RoW had been mechanically brushed fairly recently (estimated to be within 3 years).
• Abundance of oxeye daisy, Canada thistle, mullein along the RoW; company representative stated that this site is on the list for upcoming spraying (see Information Request #5).
• Various pipeline signage was missing at miscellaneous small creek/ditch crossings between KP 46+7 to KP 49+0. This area experiences heavy snow pack and high volume traffic in winter from recreational vehicles that knock the signs over. As the likelihood of third party construction activity at these crossings is very low, they are not considered to be high consequence or strategic crossings and therefore there are no concerns with the signage.

Compliance tool used: No compliance tool used

Observation 28 - Mount Broadwood Erosion Repair

Date & time of visit: 2016-08-04 13:13

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Vegetation
• Vegetation Control
• Vegetation Reclamation

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• Repairs of pipe exposure from mudslide were completed last fall (4-5 m long exposure, portion of 42” line exposed all the way around and top of 36” line exposed).
• Company representative stated that there have been multiple exposures of pipe at this location due to annual occurances of slides in unstable terrain.
• Company representative stated that they plan to remove fines from till material displaced by the slide and build taller berms.
• Boulders were imported from a nearby quarry, and also brought in material from another localized slide (~2 km away) to build a berm around material displaced by mudslide (received approval from the NCC).
• Area has so far re-vegetated well, however company is monitoring for potential knapweed issues.
• Coconut matting erosion control blankets were keyed in along slopes and rolled into waddles for additional protection.
• Company representative stated that a low elevation seed mix was used to reseed the site.

Compliance tool used: No compliance tool used

Observation 29 - KP 59+0 (Approximate)

Date & time of visit: 2016-08-04 14:08

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Control
• Invasive Plant Management

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• Site was difficult to access due to steep topography.
• Observed large knapweed infestation along the RoW at this location that continues up the hill for several meters.
• St. John’s wort and mullein also observed on RoW.
• Company representative stated that the area was last sprayed for weeds two years ago, involving two applications of Lontrel. A contractor is scheduled to spray the area again this year (see Information Request #5).
• RoW on very rocky terrain which is otherwise well-vegetated.

Compliance tool used: No compliance tool used

Observation 30 - Upstream Plot Plan

Date & time of visit: 2016-08-04 14:51

Discipline: Environmental Protection

Categories:

• Vegetation
• Vegetation Control
• Invasive Plant Management

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• Section of RoW between KP 55+0 and KP 69+4 (Elk River crossing) where company had co-implemented a 10-year volunteer spraying program to eliminate knapweed infestation.
• Company representative stated that bio-control methods were tested at higher elevations at this site, and spraying was implemented at lower elevations.
• Very few knapweed specimens were observed at this location.
• Fully grown blueweed plant was observed, as well as abundant St. John’s wort. Observed the company representative recording GPS coordinate of blueweed for weed control application.

Compliance tool used: No compliance tool used

Observation 31 - KP 69+4 Elk River Crossing

Date & time of visit: 2016-08-04 15:34

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Integrity
• Vegetation
• Vegetation Control
• Invasive Plant Management
• Water Bodies - Fish-bearing
• Erosion

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

• Abundant knapweed in riparian area, company representative stated that during the 10 year volunteer program this area was handpicked but the knapweed grew back quickly.
• Observed three pipeline identification signs on the SE side of the crossing (two signs had bullet holes).
• There are three pipeline markers at the top of the cliff on the NW side, signs are not visible from the river however it is not possible to place them any closer due to cliff steepness and erodible material (some rill erosion observed).
• Company representative stated that the cliff is monitored via aerial patrols.

Compliance tool used: No compliance tool used

Observation 32 - KP 131+0 GWD 30080 Integrity Dig Site

Date & time of visit: 2016-08-05 09:15

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Water Bodies - Non-Fish-bearing
• Reclamation
• Vegetation
• Vegetation Control
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• ANG Mainline (Pipeline)

Observations:

• Cause of dig was to investigate corrosion on the 1961 ANG mainline.
• Work was completed approximately 1.5 months ago according to company representatives.
• Large felled branches were spread across the dig site as a deterrent for ATV traffic.
• Confirmed that site was re-seeded on June 24, can see vegetation beginning to establish despite lack of topsoil (very stony).
• There is a seasonal drainage that crosses the NE end of the dig site, currently dry.
• Stone Creek crosses the RoW approximately 30 m from the dig site to the SW.
• Reviewed the Environmental Design Basis for the dig site.

Compliance tool used: No compliance tool used

Observation 33 - CNC #6: KP 131+0 GWD 30080 Integrity Dig Site

Date & time of visit: 2016-08-05 09:15

Discipline: Environmental Protection

Categories:

• Water Bodies - Fish-bearing
• Reclamation
• Erosion

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

Observed approximately 10 m of an old sediment fence within the riparian area of Stone Creek that had been left in the ground from previous work (likely from the 1991 dug-out).

Compliance tool used: Corrected Non-compliance (CNC)

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:

TransCanada will remove the sediment fence and dispose of it appropriately. 

Due date: 2016-08-05

Date closed: 2016-08-05
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 34 - NNC #1: Missing/Damaged Pipeline Identification Signage

Date & time of visit: 2016-08-05 10:45

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

KP 17+3 Carbon Creek Crossing and KP 18+9:

• There were signs for three pipelines on the NW side of the creek, and the sign posts for the SE side were downed.
• While traveling to next site, crossed a creek at approximately KP 18+9 that had a downed sign on one side of the creek.

• There were signs for both pipelines on the SW side of Stone Creek, however signs were missing from the NW side.

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

Regulatory requirement:

• Standard Operating Procedure or Plan (SOP)
• Invasive Vegetation Weed Control Management Canada; Brush Control Procedure; Heritage Resources Protection Procedure Canada; Wetlands, Watercourses and Waterbody Protection Procedure Canada; Aerial Pipeline Patrol Procedure; Soils Management Procedure; Pipeline Right of Way Procedure; TransCanada Signage Procedure

Relevant section(s):

• Pipeline Right Of Way Procedure 4.1.1 Location of Marker Signs 1. Warning Signs shall be installed on both sides of all: a. public roads; b. rivers, creeks and other bodies of water. 2. Consideration shall be given to the installation of warning signs on both sides of private roads, trails and undeveloped road allowances.

Company action required:

Replace all missing or damaged signage at identified locations as per TransCanada's Pipeline Right Of Way Procedure, and provide photos of each location to NEB staff upon completion.

Due date: 2016-09-30

Date closed: 2016-10-05
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 35 - Information Request #5

Date & time of visit: 2016-08-05 10:45

Discipline: Environmental Protection

Categories:

• Vegetation
• Invasive Plant Management

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

Several areas along the RoW were observed to have noxious weed infestations. The company representatives stated that these sites were scheduled to undergo weed spraying in the fall of 2016. Most of the impacted areas were confirmed through Information Request #1 to have been included in the 2016 Notice of Intent to Treat, however Inspection Officers would like to confirm that the following locations have been included for treatment as well: KP 53+7 Fernie Sales Meter Station surrounding RoW (oxeye daisy, scentless chamomile, mullein, Canada thistle, common tansy), KP 48+0 Valve Site surrounding RoW (primarily oxeye daisy), and KP 51+0 (primarily oxeye daisy, Canada thistle, and mullein observed). 

Compliance tool used: Information Request (IR)

Regulatory requirement:

• National Energy Board Act (NEBA) until 1 April 2020, Canada Energy Regulatory Act (CERA) after 1 April 2020

Relevant section(s):

• National Energy Board Act (NEBA)
  • 49. Inspection Officers
    • (2) For the purpose described in subsection (1), an inspection officer may at any reasonable time
      • (c) examine and make copies of any information contained in any books, records or documents, or in any computer systems, that the inspector believes on reasonable grounds contain any information relating to the design, construction, operation, maintenance or abandonment of a pipeline.

Company action required:

Please submit the Herbicide Use Sheets for the above-noted locations after weed spraying has been completed.

Due date: 2016-09-30

Date closed: 2016-10-13
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 36 - Information Request #6

Date & time of visit: 2016-08-05 10:45

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs

Facility:

• South BC - Zone 8 (Pipeline)

Observations:

At the following locations signage was observed to be missing or in disrepair (possibly due to ongoing construction), a company representative stated that the signage will be replaced once work has been completed:

GWD 24710 Integrity Dig Site:

• Company hasn’t yet replaced pipeline identification signage that was taken down for construction, currently only the north side of the crossing has two signs.

• A pipeline identification sign was down on the north side of the creek and a sign on the south side was tilted.

• Pipeline identification signage for two pipelines was missing from the SE side of an unnamed tributary to the Flathead River at the base of the hill (next to the temporary access bridge).

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Standard Operating Procedure or Plan (SOP)
• Invasive Vegetation Weed Control Management Canada; Brush Control Procedure; Heritage Resources Protection Procedure Canada; Wetlands, Watercourses and Waterbody Protection Procedure Canada; Aerial Pipeline Patrol Procedure; Soils Management Procedure; Pipeline Right of Way Procedure; TransCanada Signage Procedure

Relevant section(s):

• Pipeline Right Of Way Procedure 4.1.1 Location of Marker Signs 1. Warning Signs shall be installed on both sides of all: a. public roads; b. rivers, creeks and other bodies of water.

Company action required:

Please submit photos of replaced signage at the above-identified locations to NEB staff upon completion.

Due date: 2016-09-30

Date closed: 2016-10-14
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: