Compliance verification activity type: Field Inspection
Team:
Regulated company: NOVA Gas Transmission Ltd.
Operating company: NOVA Gas Transmission Ltd.
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Follow up inspection for spread 1 of the North Montney Project. Focus on environmental mitigation measures at watercourse crossings and the Peace Moberley Tract. Also follow-up to Inspection Officer Orders MMO-001-2018 and AML-002-2018.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - General Observations
Date & time of visit: 2019-01-23 12:00
Discipline: Environmental Protection
Categories:
Facility:
Observations:
Compliance tool used: No compliance tool used
Observation 2 - IR #1 - Peace Moberly Tract Orientation Records
Date & time of visit: 2019-01-24 14:10
The entrance to the Peace Moberly Tract (PMT) was clearly identifiable in the field, with signage and a mandatory cleaning station at approximately KP 38 + 550. NEB Inspectors note that this location in the field is approximately 2.5 km prior to the start of the PMT (which extends from approx. KP 41 to 51), however, signage at the entrance to this area stated “Must have PMT Orientation Past This Point”.
While within the PMT area (i.e., past the signage), NEB inspectors selected random workers for confirmation of PMT orientation. This confirmation was done by the presence of the PMT orientation hard hat sticker and/or verbal confirmation with the worker. One member of the utility crew did not have a sticker and when asked, was unsure if he had completed the PMT orientation.
Inspectors asked for confirmation of this worker's training. Company representatives provided an email indicating that he completed general orientation on Jan 12 and that PMT orientation had also been provided at the yard. The email further stated that he was trained again the day following the inspection to remove all uncertainty.Additional information is required to verify compliance.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
1. Explain how PMT orientation is recorded and tracked.2. Explain how PMT orientation is verified for workers entering the PMT area.
Due date: 2019-03-08
Date closed: 2019-03-14 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
Observation 3 - IR #2 - Designated Smoking Areas
The Project Environmental Protection Plan (EPP) states that smoking is to occur only in designated areas. This message was also provided during the general orientation that all workers are required to attend.
On the east side of the Pine River, several designated smoking areas were observed. On the west side, designated smoking areas were only observed in the Jackfish Yard. Company Representatives indicated that the entire RoW is considered a designated smoking area, except in areas where people congregate (e.g., the yard and camp).NEB Inspectors observed smoking and vaping along the RoW and require additional information to verify compliance.
Observation 4 - CNC #1 - Trespass
Date & time of visit: 2019-01-23 10:36
At approximately KP 5 + 300, NEB Inspectors observed spoil piles that were encroaching on the flagged RoW boundaries, including leaning against staked trees. Some clumps of frozen soil were observed off RoW.
Compliance tool used: Corrected Non-compliance (CNC)
1. Remove soil from off RoW.
Due date: 2019-01-23
Date closed: 2019-01-23 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.
Observation 5 - CNC #2 - Staining on Soil
Date & time of visit: 2019-01-24 11:22
At the north side of the Moberly River, NEB Inspectors observed an area of stained soil in a windrow immediately behind a light tower. The light tower was contained within secondary containment and there was no evidence of drips or leaks observed. Company representatives indicated that the staining may be a result of exhaust from the light tower.
At the Jackfish Yard, NEB Inspectors observed an area of stained soil near a large vehicle fuel tank under the re-fueling hose. Spill kit was observed adjacent to the fueling station and was half empty at that time (unlike the kits adjacent to the other hoses). No workers or activity was observed in the immediately vicinity.While in the field, Company Representatives provided photographs and spill reports to Inspectors showing that both stains were cleaned up. No further corrective action is required.
1. Clean up stained soil and provide spill reports.
Due date: 2019-01-25
Date closed: 2019-02-11 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.
Observation 6 - NNC #1 - Workplace Conduct
Discipline: Management System
Along the RoW NEB Inspectors observed a member of a work crew, who identified themselves as the crew foreman, with an inappropriate (i.e., sexually suggestive) hardhat sticker. Foreman stated to the NEB Inspectors that the sticker was a contractor’s company logo, and they were not aware of a policy specifically regarding stickers. When NEB Inspectors raised concerns regarding the sticker with Company Representatives, one appeared unconcerned, while another covered the inappropriate sticker with another company logo sticker.At the Moberly River crossing, NEB Inspectors entered a welding shack that was not in use. Several inappropriate (i.e., sexually explicit) images were taped to the interior walls of the welding shack. One image was largely burned and the tape that had been holding it up was melted. The same Company Representative who had covered the inappropriate sticker ensured the images were immediately removed and disposed of.NEB Inspectors discussed the images with Company Reprentatives at the closing meeting. Company Representatives indicated that a RoW memo would be provided to all workers the following day. This memo was also provided to NEB Inspectors. The memo outlined The Respectful Workplace Standard, and requested that workers refrain from the posting of hard hat stickers or posters depicting profanity or inappropriate content. While in the field, NEB Inspectors asked for a copy of NGTL’s policy on harassment. Following the inspection, a Company Representative provided the NEB Inspectors with a copy of TransCanada’s Harassment-Free Workplace Policy (Policy). NEB Inspectors note that the images and sticker and non-compliant with the Policy.
Compliance tool used: Notice of Non-compliance (NNC)
1. Remove the offensive material observed by NEB Inspectors.This was done while Inpsector's were in the field.2. Develop and implement a plan to:a) remove any similar materials from the workplace;b) inform workers that materials such as those observed are should not be displayed in the workplace; andc) ensure future compliance to the Policy, including a reporting mechanism.3. Explain how the plan in part 2) is consistent with TransCanada's Harassment Free-Workplace Policy.
Date closed: 2019-03-15 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.
Observation 7 - NNC #2 - Voiding Along the RoW
Date & time of visit: 2019-01-24 12:00
Discipline: Safety Management
At the North Side of the Moberly River, portable toilets were not available at the base of the slope. The nearest facilities were a few hundred meters away up a steep slope. During inspection activities at the base of the slope, NEB Inspectors observed a large area behind windrows on the west side of the RoW that appeared to have been used for repeated instances of urination.NEB Inspectors also observed urine on the snow-covered soil pile in the PMT, approximately 20 m away from the site's portable toilets.
1. Outline how NGTL will prevent reoccurrance and/or remove contaminated material.
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
