Compliance Verification Activity Report: CV2223-260 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2541
• Inspector 2738

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• Manitoba

Discipline(s):

• Environmental Protection
• Indigenous Monitoring

Related events:

• CV2223-231

Rationale and scope:

Field inspection in support of the Management System Audit of contaminated sites management. Locations across the Enbridge right of way and facilities in western/central Manitoba were inspected, with a contaminated sites management focus in the general theme of Environmental Protection.

Compliance tool(s) used:

• None

Facility details

Facilities:

• Cromer
• WEST SOURIS
• MANITOU
• ST.LEON

Facility Types

• Pipeline
• Pipeline right of way (ROW)
• Pump station
• Terminal
• Valve site

Life-cycle Phases

• Decommissioning & Abandonment
• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16

Observations (no outstanding follow-up required)

Observation 1 - General Observation

Date & time of visit: 2022-07-19 10:15

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Soil Handling
• Biosecurity
• Crowns/Subsidence
• Chemical Spills/Releases
• Restoration
• Surface Water Management
• Containment and Drainage Structures
• Groundwater
• Monitoring and Testing
• Chemical Spills/Releases

Facility:

• Cromer (Facility)

Observations:

The Inspection Team verified compliance at various locations in Manitoba as desribed below:

Cromer Terminal

• Two Line 3 Decommissioning Project excavations taking place within Cromer Terminal were inspected, which are located proximal to existing contaminated sites (REM-0398 and REM2020-009). The Environmental Inspection demonstrated awareness of soil stockpiling, de-watering and soil testing procedures from the Enbridge Environmental Protection Plan for the decommissioning work. Presumed-contaminated groundwater was observed to be stored separately in a floc-tank destined for off-site disposal as contaminated water.
• The Inspection Team spot checked an Environmental Clearance Form for Line 3 excavation MB-1S-3040-1 and verified that it meets Enbridge’s process requirements.
• Facility monitoring-status sites REM2020-007, -008 & -009 and associated groundwater wells in the vicinity were viewed, no concerns noted.
• The Inspection Team inspected surface water drainage at the Cromer Terminal. At the outflow location where surface water is released to the surrounding wetland ecosystem and drains into Pipestone Creek, vegetation was observed to be healthy and well established. The drainage area was reinforced with riprap as needed. The water flowing towards Pipestone Creek was clear to the eye; no sediment loading or erosion issues noted. Enbridge staff indicated that there are no provincial permits or other requirements in place that need to be met prior to discharge.
• The closed contaminated site at the former ‘lagoon’ (REM-0116b) was observed to be reclaimed with grasses. No slumping or grading issues noted.
• The former Bio Remediation Facility (BRF) area was inspected. The former ‘stockpile’ site (REM-0116d) area was observed in its reclaimed state, with a healthy grass population and no slumping, grading or erosional issues observed. The next step for REM-0116d is an eventual Closure Report. The former bio-cells for the BRF were observed with healthy vegetation and signage in place. Monitoring wells were observed to be present, capped and locked in the BRF region.
• In the north-west corner of the Terminal, in close proximity to the BRF, is an area set-up to accept contaminated soils from project work at the Terminal. Three separate small lined ‘pools’ are able to accept contaminated or suspect soil.
• The Inspection Team requested the ‘Pathway to closure’ document for REM2021-045 within the Cromer Terminal. Enbridge provided the report, which was reviewed and noted to be aligned with Enbridge Process. No concerns noted.
• The ‘bone yard’ was inspected and found to be well organized and tidy. No issues noted.

• The Souris River crossing of the Enbridge RoW, including the Line 3 Replacement RoW was inspected. The slopes rising from both sides of the Souris River valley were observed to be well established with grasses. No instances of bare soil or erosion was observed. The riverbank was observed to be stable with existing riprap and silt fences.
• Enbridge staff reported that the bank stability is monitored as part of Enbridge’s Geohazard program and is assessed annually (each fall). No signs of sloughing or bank instability were observed, despite the heavy rainfall in the area this spring. No concerns noted.

• Enbridge staff summarized the contaminated site at this location (REM-0243) and demonstrated awareness of the hazards and controls in place.
• The inspection Team observed healthy vegetation at the RoW, and no noxious weeds were observed. No indication of erosion or sediment control issues were identified.
• The valve site was signed and fenced.
• Monitoring wells were observed at the site, with cattle guards, casings and locks.
• Environmental Site Assessment work has been completed on both sides of the roadway that bisects this site.
• This site represents a ‘low risk’ example with respect to the hazard posed by the remaining contamination and will be further delineated/reassessed in the Line 93 RoW in the near future.
• The Inspection Team asked if there were any landowner concerns with the site and Enbridge staff indicated that no concerns to date had been raised.
• No concerns noted.

• Hazardous material storage was spot checked opportunistically. In all instances inspected, labels and secondary containment were observed. No concerns noted.
• General housekeeping at the Stations was observed to be very tidy. Signage was verified at entries, fencing was in good condition, waste materials were stored/organized well.
• Surface water management was observed at all three Stations. Site drainage structures and stormwater retention were well maintained. Valves were observed to be closed. Enbridge staff demonstrated awareness and implementation of the Surface Water Monitoring Plan. No concerns noted.
• Monitoring wells were spot checked for metal casings, locks and general condition. All wells viewed were in good condition, capped and locked except for one instance at Manitou Station which was missing a lock. Enbridge confirmed it will ensure the lock is replaced.
• Enbridge staff summarized the contaminated sites being managed at each Station, demonstrating awareness of the hazard and controls in place as well as the longer-term management planning (facility monitoring).
• Groundwater monitoring well networks were observed in each Station. The Inspection Team notes that groundwater wells were placed downgradient along the Station fence line in all instances observed. At the St. Leon Station, Enbridge reported that three wells had been installed between 2020 and 2022 in response to the expansion of the Station to include two new pump stations. The Inspection Team spot checked the groundwater monitoring results from 2021 at the West Souris Station. The report identified instances where Stations has a groundwater exceedance measured, and instances where a groundwater well needed maintenance. Compliance with Enbridge’s Facility Groundwater Monitoring Program was observed at these three locations.
• At West Souris Station the Inspection Team asked about the status of the old Line 3 sump tanks and Enbridge staff were able to demonstrate that the tanks were empty.
• At the Souris Station the Inspection Team conducted a walkthrough of the Line 93 pump building, no issues noted at the time of the inspection.

• The Inspection Team verified that Enbridge is conducting the biosecurity protocol for clubroot during the group’s travels between agricultural fields (bleaching and washing boots).
• The riparian ecosystem at Black Creek was observed to be thriving.
• Enbridge staff indicated that the contamination at this location extends both on and off the Right-of-Way.
• Monitoring wells were observed with cattle guards (in agricultural field), casing and locks.
• Enbridge staff demonstrated a thorough understanding of the hazards and risks remaining at Black Creek, as well as the risk management plan being implemented.
• Enbridge is not planning active remediation at the site as part of its Remedial Action Plan, rather they have proposed a Risk Assessment /Risk Management approach to a complex site. Three years of studies have gone into the development of the Risk Management plan for the site.
• No compliance issues were noted.

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: