Compliance verification activity type: Field Inspection
Team:
Regulated company: NOVA Gas Transmission Ltd.
Operating company: TransCanada Pipelines Limited
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Environmental abandonment inspection of NOVA Gas Transmission Ltd. (NGTL)'s Daysland Receipt Meter Station and associated Lateral, as part of the NGTL 2015 Meter Stations and Laterals Abandonment Program. Work includes the removal of above and below ground facilities at the meter station, and the lateral segment will be purged clean and removed. The purpose of the inspection was to confirm compliance with Order ZO-N081-001-2016, the National Energy Board ("NEB or Board") Act, NEB Onshore Pipeline Regulations, CSA Z662-15, and any relevant company plans, manuals, procedures, and commitments. The scope of the inspection included clubroot and noxious weeds mitigation, soil handling, waste management, and wildlife mitigation.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - Meter Station
Date & time of visit: 2017-08-16 10:10
Discipline: Environmental Protection
Categories:
Facility:
Observations:
- Company representative stated that a contractor will conduct soil sampling to identify potential contamination by taking full-depth presence/absence samples during the preliminary Phase II sampling, which will be conducted once the meter station buildings have been removed and before the site is reclaimed.- Company representative stated that sampling locations will include the areas under the buildings, as well as at the historical contamination site in the southeast corner of the facility. If contamination is confirmed from these samples, a full investigation will be conducted next year and a remedial action plan will be developed in accordance with the Remediation Process Guide.- Company representative indicated that once the gravel is stockpiled for waste characterization, if it is determined to be clean it may be used at other company facilities, otherwise it will be disposed of.- There were two large recycling containers outside of the fence line, and a covered waste bin was observed inside one of the recycling containers. All containers were empty at the time of inspection.- NEB Inspectors did not have access to the communications building because of the biohazard risk (highly contaminated with mouse droppings), access was restricted by the company until it could be cleaned out.- Instrumentation inside the meter run building had been removed, the building was orderly and no tripping hazards were observed.- In a storage area in the southwest corner of the facility, observed a generator and fuel stored in secondary containment as well as garbage being temporarily stored under a tarp.- Observed weed infestations surrounding the fence line that included Canada thistle, perennial sow-thistle, and foxtail barley. There was evidence of spraying approximately 1 m around the fence line. A company representative stated that spraying had been conducted annually at the facility, and the 1 m spray distance was to avoid damaging the landowner’s crops. It was also stated that weed control at this site would be included as criteria needed to meet reclamation goals.- The storage trailer was orderly, and included tools, hoses, shovels, a spill kit, back-up generator, and fire extinguishers. Please refer to Observation 2 for a corrected non-compliance regarding an outdated fire extinguisher inspection tag.
Compliance tool used: No compliance tool used
Observation 2 - Corrected Non-Compliance - Fire Extinguisher
Date & time of visit: 2017-08-16 11:30
Discipline: Safety Management
A fire extinguisher inspection tag in the storage trailer at the meter station was out of date.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
The company will inspect the fire extinguisher to ensure that it is in proper operating condition and update the inspection tags.
Due date: 2017-08-17
Date closed: 2017-08-17 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 3 - Lateral and Side Valve
Date & time of visit: 2017-08-16 11:45
- One of the agricultural fields in the immediate area was identified as impacted by clubroot disease. A company representative indicated that the company is awaiting clubroot testing for the Project’s two fields. To minimize risk of transferring soil between quarter sections, the company indicated that heavy equipment will complete work on the east field of the lateral, before moving onto the west field of the lateral.- The equipment, vehicle and boot cleaning station was located next to a rig mat at the lateral access road, and contained a spill tray with disinfectant solution and brush. Buckets of water, a bottle of bleach and spill pads were also observed. A company representative stated that the tray water was stored in liquid disposal containers until it could be transferred for disposal in a disposal well at the station. It was also stated that a steam truck came and power washed the backhoe before it was disinfected and permitted to enter the east field. The company representative stated that the steam truck would come and power wash the backhoe again before it is disinfected and allowed in the west field.- A ‘clubroot/noxious weeds’ sign was posted at the cleaning station and had handwritten directions for cleaning equipment and boots.- Company representatives stated that they were not using an equipment cleaning log, however created one while the NEB Inspectors were on site and posted the log on the sign at the cleaning station during the course of the inspection.- A signed smoke pit and muster point were located on the road at the access gate to the meter station. A fire extinguisher with an up-to-date inspection tag was observed at this location.- Noxious weed infestations were observed along the road access and fence line, and included Canada thistle, perennial sow-thistle and white cockle. Weed densities were comparable to off-RoW conditions.- Observed an inspection marker for equipment cleaning that noted the excavator had been inspected and bleached, and included the date and inspector initials.- No sharp-tailed grouse had been identified in the area. Two abandoned birds’ nests were identified in trees adjacent to the RoW.- The RoW runs through an agricultural field with a wetter low-lying area where vehicles and equipment were diverted around. Company representatives stated that there will be bell holes on either side of the wet area through which they will pull the pipe out.- Observed the side valve being dismantled and expelling residual gas (the pipeline had been purged the day prior). There was very little water in the site hole.- Also observed topsoil stripping in the agricultural field to clear an area to store the side valve gravel pile on subsoil. A worker was rock-picking during breaks between stripping. A company representative indicated the large rocks will be removed from site with the gravel from the side valve fenced area.- Company representatives stated that the topsoil piles from the field will be separated from soil from the fence line and valve site (which contain noxious weeds).- ‘Caution’ signage and a spill kit were observed next to a rig mat at the side valve location. A company representative stated that mats were bleached prior to coming on site. Other spare items including snow fencing, a spill tray, hose, ladders, shovels, and tools were neatly stored in this area.
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