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Burnaby Mountain Tunnel Option CER File OF-Fac-Oil-T260-2013

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Burnaby Mountain Tunnel Option CER File OF-Fac-Oil-T260-2013 Trans Mountain Expansion Project Email: [email protected] | Phone: 1.866.514.6700 | Website: www.transmountain.com | @TransMtn VIA ELECTRONIC SUBMISSION March 9, 2020 Canada Energy Regulator Suite 210, 517 Tenth Avenue S.W. Calgary, Alberta T2R 0A8 To: Ms. Louise George, Secretary of the Commission Dear Ms. George: Re: Trans Mountain Pipeline ULC (“Trans Mountain”) Trans Mountain Expansion Project - Certificate OC-65 Condition 26: Burnaby Mountain Tunnel Option Revised Response to Information Request No. 20.2 (“IR No. 20.2”) CER File OF-Fac-Oil-T260-2013-03 61 In response to the CER’s IR No. 20 [C04160] with respect to its prior submissions concerning Condition 26 (Burnaby Mountain Tunnel Option), Trans Mountain filed a submission on February 7, 2020 [C04607]. Upon further review, Trans Mountain became aware that there were inconsistencies in Trans Mountain’s IR No. 20.2 response concerning a previously filed document, namely the Lower Mainland Project-Specific Safety Plan (PSSP) that was filed on June 23, 2017 [A84570]. Trans Mountain realized that its IR 20.2 response referenced a revised and updated version of the PSSP that had not been submitted to the CER. On March 6, 2020, Trans Mountain filed this revised PSSP [C05072]. Having made some minor revisions to its prior response to address the inconsistencies noted above, Trans Mountain resubmits its response to IR No. 20.2, with changes shown in blackline. Suite 2700, 300 – 5 Avenue SW Calgary, Alberta, T2P 5J2 CANADA Should you have any questions or wish to discuss this matter further, please contact the the undersigned at [email protected] or (403) 514-6400. Yours truly, Original signed by Scott Stoness Vice President, Regulatory and Compliance Trans Mountain Canada Inc. Enclosure 2 Trans Mountain Pipeline ULC (Trans Mountain) Trans Mountain Expansion Project – Condition Compliance Certificates OC-065 File: OF-Fac-Oil-T260-2013-03 61 Information Request No. 20.2 Condition 26: Burnaby Mountain Tunnel Option – Design, Construction, and Operation February 7, 2020 Revised March 9, 2020 20.2 Confined Space Reference: i) Trans Mountain Expansion Project Certificate OC-065, Condition 26(a)(ii), PDF page 13 of 70, C00061-3 ii) Trans Mountain’s filing dated 12 March 2018 for Condition 26: Burnaby Mountain Tunnel Option – Design, Construction and Operation (Condition 26), Response to NEB Information Request (IR) 72.1, PDF Pages 3 to 6 of 12, A6C0X0 iii) Trans Mountain’s filing dated 2 February 2018 for Condition 26, Response to NEB IR No. 59.1 Supplemental Submission, PDF Pages 2 to 4 of 4, A5Z9Y2 iv) Trans Mountain’s filing dated 12 March 2018 for Condition 26, NEB IR No. 72, Attachment 1 Condition 26, Trans Mountain’s Tunnel Entry Procedures, A6C0X1 v) Trans Mountain’s filing dated 1 March 2018 for Condition 26, Appendix A Part 1 of 7, Section 3.5 – A description of the methods to be used for pipe handling and welding, PDF page 14 of 16, A5J1X2 Preamble: Reference i) requires, among other things, Trans Mountain to file with the Commission, for approval, the Burnaby Mountain tunnel (Tunnel) confined space entry procedures. In Reference ii) Trans Mountain stated that although the Tunnel is not considered a confined space under the Canada Occupational Health and Safety Regulation (COHSR), Part XI regulations, the specific safety requirements of the COHSR regulations will be followed on the Project. The reference further stated that Trans Mountain considers the Tunnel to be an ‘underground working’, under Worksafe BC Underground Workings. Page 1 of 4 Trans Mountain Pipeline ULC (Trans Mountain) Information Request No. 20 – Condition 26 Burnaby Mountain Tunnel option – design, construction, and operation In References ii) and iii) Trans Mountain provided additional information to support Trans Mountain’s interpretation of these regulations. The Commission notes that the requirements of Condition 26 are not tied to any particular regulation and that Condition 26 stands independent of any regulations. The Commission further notes that Trans Mountain to date has not filed a Tunnel confined space entry procedure, as required by Condition 26. Instead, in Reference iv), Trans Mountain provided the Tunnel Entry Procedures which is not adequate to meet the requirements of the Condition. Reference v) indicates that once the boring and lining is completed, workers will enter the tunnel to carry out construction work such as installation of pipe supports, welding and coating activities. The Tunnel Entry procedure that Trans Mountain filed deals with a person’s initial entry into and exit from the tunnel and does not discuss entering the tunnel when these activities are undertaken, as some of these activities inside the Tunnel have the potential for the generation of harmful airborne contaminants that may need to be considered when entering the Tunnel. Nor does the procedure address potential complications in delivering first aid, evacuation, rescue or other emergency response services as a result of the internal configurations of the Tunnel. The Commission requires Trans Mountain to file a Tunnel confined space entry procedure, and expects the procedure to be a comprehensive and stand-alone document which includes the necessary information for a person to enter and conduct work safely in the Tunnel environment. Request: Provide a Tunnel confined space entry procedure which includes, but is not limited to, the following: • Roles and responsibilities of personnel (e.g., Owner, Prime Contractor, Sub Contractors, Emergency service workers, etc.); • Training requirements; • Hazard Assessment and Identification process(es); • Permit Requirements (e.g., confined space); • Safety requirements - operational procedures which describe the hazards and define the rules and conditions under which persons will be permitted to enter to confined spaces; and • References to Emergency and rescue procedures. Page 2 of 4 Trans Mountain Pipeline ULC (Trans Mountain) Information Request No. 20 – Condition 26 Burnaby Mountain Tunnel option – design, construction, and operation Response: Trans Mountain currently has filed with CER two documents with reference to the Burnaby Mountain Tunnel: • KLTP Lower Mainland Project Specific Safety Plan (A84570-3 C05072), filed on March 6, 2020June 23, 2017. • KLTP Site Specific Emergency Response Plan – Burnaby Mountain Tunnel (A84571-6), filed on June 23, 2017. With respect to the Burnaby Mountain Tunnel, the prime contractor is the Kiewit Ledcor Trans Mountain (KLTP). Given the specialized nature of tunnel construction, McNally Construction Inc.(McNally) was retained as a subcontractor. As part of the preparation for the Project, McNally prepared documentation specific to the proposed Burnaby Mountain Tunnel. These KLTP documents above are referenced by the additional documents discussed below. Trans Mountain attaches three additional documents: (1) McNally Tunnel Confined Space Entry Procedure (Attachment 2) (2) McNally (Tunnel Subcontractor) Project Specific Safety Plan (Attachment 3) (3) McNally (Tunnel Subcontractor) Site Specific Emergency Response Plan (Attachment 4) Table 20.2-1 summarizes the document references that address the specific issues raised in the Information Request. Table 20.2-1 – Document References Item Reference Roles and responsibilities of personnel (e.g., • McNally PSSP, PDF pages 11 to 19 Owner, Prime Contractor, Sub Contractors, Emergency service workers, etc.); Training requirements • McNally PSSP, PDF pages 19 to 22 Hazard Assessment and Identification • McNally PSSP, PDF pages 30 to 32 process(es) Permit Requirements (e.g., confined space) • McNally PSSP, PDF pages 9, 51 to 58 Safety requirements - operational procedures • Tunnel Confined Space Entry Procedure which describe the hazards and define the • McNally PSSP, PDF pages 103 to 120 Page 3 of 4 Trans Mountain Pipeline ULC (Trans Mountain) Information Request No. 20 – Condition 26 Burnaby Mountain Tunnel option – design, construction, and operation Item Reference rules and conditions under which persons will be permitted to enter to confined spaces References to emergency and rescue • McNally ERP, pages 1 to 64. procedures Page 4 of 4 Trans Mountain Pipeline ULC (Trans Mountain) Information Request No. 20 – Condition 26 Burnaby Mountain Tunnel option – design, construction, and operation Attachment 2 S. D Ayres Sr. H&S Manager March 3, 2020 Reviewed By; Trans Mountain Expansion Project Tunnel Entry Procedures Tunnel Entry Procedures 1. SCOPE 1.1 To ensure the safety of persons either working in or visiting the tunnel, strict procedures are to be implemented. These cover procedures for the initial entry into the tunnel, location of safety equipment, exit procedures and the actions to be taken in the event of an emergency evacuation. This procedure is not only intended for the regular workforce and visitors but is to be used for all persons who may at some stage enter the tunnel. Occasional visitors will only be allowed into the tunnel when accompanied by an experienced person, however the visitor will still need to be aware of all the hazards associated with the tunnel environment. This procedure is to form part of an orientation for all first-time visitors. 2. DEFINITIONS 2.1 Entry Procedure - Bullet point list to be posted at the tunnel entrance, indicating the steps to be taken on entry and exit into the works. 2.2 Notice board - Board located at the entrance of the tunnel, housing tag boards, mailbox for contraband, tunnel location plans and notice board for posting
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