Compliance verification activity type: Field Inspection
Team:
Regulated company: Enbridge Pipelines Inc.
Operating company: Enbridge Pipelines Inc.
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Environmental construction inspection of Enbridge Pipelines Inc.'s (Enbridge) Line 3 Pipeline Replacement Project, Spread 8 near Brandon, MB. This inspection was conducted with monitors from the Indigenous Advisory Monitoring Committee (IAMC). The scope of the inspection included, but was not limited to, soil handling, erosion and sediment control, biosecurity, equipment cleaning, secondary containment, waste management, water body crossings, wildlife mitigation measures, and remediation of a historical contamination site. Construction activities observed during the inspection included topsoil stripping and bending and stringing operations. Wetland and watercourse crossings as well as a biosecurity cleaning station were also inspected.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - KP 913+160, Unnamed Drainage to Spring Brook (MB-WC37)
Date & time of visit: 2018-08-28 11:15
Discipline: Environmental Protection
Categories:
Facility:
Observations:
- Access across the drainage has been constructed using subsoil approach ramps and bridge.- Wingwalls made of geotextile define the edges of the approaches.- The bridge is lined with geotextile covering the bridge deck and the bridge railings.- Topsoil has been salvaged and subsoil graded to the edge of the watercourse buffer.- Watercourse crossing identification and fueling requirement signage has been established, and spill kits have been placed on both sides of the crossing.- Access ramp at Road 3 (KP 913+300) has been constructed with geotextile and flume.- Salvaged surface material has been stockpiled along the edge of the right-of-way (RoW) with adequate space between transition soils and subsoil where the footprint has been graded.
Compliance tool used: No compliance tool used
Observation 2 - KP 921+600, Road 8
Date & time of visit: 2018-08-28 11:45
- Observed the condition of grade and clearing.- Access ramp from the road to the RoW has been partially underlain with a thick geotextile material, as requested by the Canadian Association of Energy and Pipeline Landowner Associations on private land, with geotextile used through the bar ditch and constructed of subsoil.- Clearing through the tree belt located upstream of the road crossing has been narrowed to limit disturbance to the stand.
Observation 3 - KP 921+260, Oak Creek Crossing #1 (MB-WC42)
Date & time of visit: 2018-08-28 11:55
- Typical watercourse crossing mitigation has been implemented, including bridge construction, wingwalls, erosion and sediment control (ESC) mitigation, buffer zones and narrowed clearing.- Navigation warning signage was observed on the north side of the crossing, however due to a large bend in the creek the sign on the south side was not visible from the bridge. A company representative provided the NEB Inspection Officer (IO) with a photo of the south-facing sign later during the inspection.- This location has been identified as Northern Leopard Frog wintering habitat. Environmental Protection Plan (EPP) mitigation has been implemented including a biologist sweep and relocation of frogs found during construction and the establishment of exclusion fencing from the watercourse up the approach slope.- A topsoil pile to the east of the MB-WC42 crossing was missing an identification stake, which a company representative arranged to be replaced immediately. This was the only occurrence of a missing soil pile identification stake noted throughout the inspection.
Observation 4 - KP 959+120, Class III Wetland Crossing (MB-159)
Date & time of visit: 2018-08-28 14:50
- Wetland ramp constructed using subsoil material underlain by geotextile.- Vegetation over ditch line has been walked down using a snowcat but not removed; no evidence of rutting or water ponding over ditch line.- No flume has been installed as wetland was dry at the time of construction; company representative stated that access ramp will be pulled in the fall after pipe installation to prevent any water flow issues.
Observation 5 - KP 959+670, Rare Plant Community
Date & time of visit: 2018-08-28 15:10
- Observed the mitigation implemented at rare plant site VG-90.- Workspace through the rare plant area has been narrowed to avoid the rare plant community location.- Rare plant location has been fenced and demarcated.- Buffers between stockpiled soil on east and west side of the location established.
Observation 6 - MP 707.9, Historical Contamination Site
Date & time of visit: 2018-08-28 15:55
Observed ongoing clean-up of the historical contamination site located at MP 707.9. Company representatives provided the following information:- Enbridge Operations is implementing the NEB-approved Remedial Action Plan for the site.- Sampling has confirmed that the impact has been delineated and is stable. No additional contamination has been found to date outside of the delineated area.- Representatives on site were not aware of the source of the impact.- Excavated contaminated material stockpiled in six lined cells located on site; contaminated material is hauled to a disposal facility.- Samples are analyzed for BTEX and F1 to F4 periodically to confirm presence of contamination, and when there is a transition to non-contaminated soils. Dual sampling is being conducted in conjunction with the Swan Lake First Nation.- Accumulated water from precipitation events is pumped into a surge tank located on site; liquids are hauled to a disposal facility.- Backfill material is sourced from the same landowner a few kilometers away, and is tested prior to use.- Where soil cannot be excavated due to existing infrastructure, calcium peroxide will be applied to the contaminated material with activated carbon included as first part of backfill lift forming the in-situ treatment of contaminated material.- Site is delineated with groundwater monitoring wells.- Excavation averages six to seven metres in depth; approximately 12,000 m3 of material has been excavated and removed to facility for disposal since work began in July.
Observation 7 - KP 975+000, Old Homestead Location
Date & time of visit: 2018-08-29 11:10
- Homestead structure has been removed with concrete slab remaining; slab to be broken up and removed for disposal.- Tree stand has been cut and the area grubbed. Company representatives were unsure of the landowner’s plans for the piled timber.- Lots of debris and garbage observed, company representatives indicated that the site will be managed according to the Waste Management Plan.- Field west of the homestead has been staked but no soil handling has occurred.
Observation 8 - KP 966+377, Topsoil Stripping
Date & time of visit: 2018-08-29 11:55
- Observed topsoil salvage operations on the RoW through the use of a power dozer. The technique is effective at stripping topsoil and windrowing to the side.- Company representatives indicated that the final salvage will be conducted by dozers and graders.- A tiger salamander was observed on the RoW at KP 966+370 after a power dozer pass; the dozer was prevented from coming within 100 m of the site until a biologist could relocate the salamander to a low spot off-RoW.
Observation 9 - KP 968+800, Class V Wetland Crossing (MB-168)
Date & time of visit: 2018-08-29 13:30
- Observed access development adjacent to wetland MB-168.- Surface soils were salvaged from a pasture area immediately north of the wetland.- Biologists were on-site monitoring for Northern Leopard Frog presence; the frogs were not previously identified at this location during the ESA process and a contingency plan was being implemented. Three frogs and some garter snakes have so far been relocated and exclusion fencing has been erected around the wetland buffer.- Geotextile installed along north edge of the wetland to facilitate ramp install within the wetland boundary.
Observation 10 - KP 967+780, Cypress River Crossing #2 (MB-WC49)
Date & time of visit: 2018-08-29 14:00
- Observed the development of access on the west approach slope to Cypress Creek crossing #2 (MB-WC49) from a distance. The contractor was completing preparation work for bridge installation over the watercourse.- A 10 m setback buffer was demarcated with green stakes.- Company representatives pointed out a rare plant topsoil piled that was stripped and stored separately from the other topsoil piles.
Observation 11 - KP 954+200, Biosecurity Cleaning Station
Date & time of visit: 2018-08-29 15:00
- Observed the fine cleaning station set up on the east side of road 27, which marks the transition between rural municipalities. All boots were bleached prior to being allowed on site.- Observed fluid and mud from cleaning operations being removed from the cleaning station via vac truck.- Process involves mechanical cleaning followed by pressure wash, then bleach solution application for 15 minute soak time.- Company representative stated that ramps are washed between pieces of equipment.- A Biosecurity Auditor was on-site to verify the cleanliness of the equipment and complete record management.- All equipment that is cleaned is recorded and records are maintained throughout construction. NEB IO reviewed examples of the cleaning records.
Observation 12 - KP 944+533, Class IV Wetland Crossing (MB-157)
Date & time of visit: 2018-08-29 15:45
- Observed access constructed through the wetland (MB-157) between road 22B and Oak Creek crossing #2 (MB-WC44).- Surface material has been salvaged and stockpiled along the south edge of RoW.- Exclusion fencing has been installed along north and south edges of the RoW from the road crossing to Oak Creek as part of Northern Leopard Frog mitigation.
Observation 13 - KP 944+740, Oak Creek Crossing #2 (MB-WC44)
- Bridge crossing installed using fabricated bridge, piles and swamp mats abutments.- Subsoil ramping material installed over geotextile to form access ramps to the bridge.- Wingwalls and exclusion fencing were erected on both sides of the crossing.- Navigable signage installed on the north and south sides of the watercourse crossing.
Observation 14 - KP 910+050, Bending Operations
Date & time of visit: 2018-08-30 08:55
- Observed bending operations downstream of Road 1.- Contractor is utilizing a brand new bending machine.- No evidence of leaks or spills on or around the equipment.- Bottled hydraulic fluid is contained within spill trays on the machine.- No evidence of damage to topsoil or subsoil piles as a result of side boom movement.- RoW ramp built through a Class III wetland at this location.
Observation 15 - KP 920+000 and East, Stringing Operations
Date & time of visit: 2018-08-30 09:40
- Observed stringing operations downstream of KP 920+000.- Stringing trucks have adequate room to drive on the RoW.- Breaks are being left in strung pipe to accommodate the breaks left in soil stockpiles for wildlife and landowner access.- Observed deer tracks on the RoW.- RoW kept very clean and tidy; dunnage was being collected by labourers and disposed of.
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