Compliance Verification Activity Report: CV2021-068 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-068
Start date: 2020-09-14
End date: 2020-09-18

Team:

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Environmental inspection of Enbridge Line 3, replacement and decommissioning. The focus of this CVA was operations and maintenance activities following final clean-up of the project, and reclamation efforts post construction. This field activity was completed in participation with Indigenous Monitors representing the Line 3 Indigenous Advisory and Monitoring Committee (IAMC). The scope of the inspection was limited to spreads 2 - 5, within the Province of Saskatchewan, where the Inspection Team evaluated several features on the Project Right-of-Way. The purpose of the inspection was to verify compliance to the Projects Environmental Protection Plan (EPP), notable deficiencies on the ROW according to Enbridge's Environmental Deficiency List, and areas with sensitive features (e.g., HER sites, TLU studies, wildlife and wildlife habitat, watercourses and wetlands), and mitigation measures to Traditional Land Use (TLU) and Heritage Resource (HER) sites.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2020-09-14 15:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

The following observations, based on category, were made during the week of September 14 - 18, 2020, on spreads 2 to 5 in Saskatchewan:
 
Right-of-Way (ROW) Conditions
The conditions at this time of year were evidently dry, creating challenges to clean-up and reclamation, as stated by the company. Much of the agricultural land exhibited dry soils and road conditions were very dusty. Much of the agriculture industry was combining at this time of year, and created challenges to travelling the ROW. However, the general consensus of the Inspection Team, was that the ROW was on the right trajectory to recovery.

General Comments

Erosion and Sediment Controls (ESC)
Much of the ROW was well vegetated. ESC measures required maintenance in areas of changing elevation and where topography is associated with watercourse crossings. ESC used on the terrestrial landscape consisted of the following:Weeds
The majority of the weed issues observed were nuisance weeds, with some areas of noxious weeds. The Company stated they have been implementing ongoing treatments at areas identified on their deficiency list. More treatments are scheduled for early October. 
Wetlands
Due to the dry climate at the time of the inspection, many of the wetland features were observed with no water or seasonally dried. The following observations were made:Watercourses
Nine watercourse crossings were observed during the inspection. Multiple watercourses were observed as seasonally dry, and others with low levels of flowing or stagnant water. The following observations were recorded:

Eagle Creek (Rosetown section)McDonald CreekSouth Saskatchewan RiverSSKP 341+340 – Drainage to S.SK.RiverIskwao CreekQu’appelle River  High Hill CreekCottonwood CreekManybone CreekWascana Creek    
Biosecurity
Heritage Resources (HER) and Traditional Land Use (TLU) 

Compliance tool used: No compliance tool used

Observation 2 - CNC 1: Missing Sign at Eagle Creek

Date & time of visit: 2020-09-15 07:55

Discipline: Damage Prevention

Categories:

Facility:

Observations:

While inspecting Eagle Creek (Rosetown section), the east bank of the creek had a notification sign, whereas the west side did not. The company representative stated that the signs were erected at the discretion of the engineering team. 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The company will erect a sign on the west side of Eagle Creek to ensure adequate identification of the pipeline through the corridor.

Due date: 2020-09-18

Date closed: 2020-10-02
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 - CNC 2: South Saskatchewan River HDD - Exit Pad

Date & time of visit: 2020-09-15 13:19

Discipline: Environmental Protection

Categories:

Facility:

Observations:

While inspecting the South Saskatchewan River, HDD exit pad site, the inspection team observed sediments migrating off the temporary work space (TWS) that was being reclaimed post construction.

At the southwest section of the pad, sediments (i.e., Sand) were observed as accumulated within a natural gully for water run-off. The sediments were approximately 2 – 3 centimeters deep and were accumulated over natural vegetation. Erosion and sediment controls were present in the greater area of the TWS, but not in the specific area in question were sediments had migrated off site.  
 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The company must remove the migrated sediment from the vegetation, and ensure that the sediments and erosion are controlled from migrating off the temporary work space and Project ROW. Photographic evidence is to be supplied to the Inspecting Officer to confirm corrective actions.

Due date: 2020-09-21

Date closed: 2020-10-05
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 4 - CNC 3: Ground Water Monitoring Post Unsecured

Date & time of visit: 2020-09-15 13:19

Discipline: Environmental Protection

Categories:

Facility:

Observations:

While on site at the South Saskatchewan River HDD exit pad, a ground water monitoring well, labelled BGC16-SSR-01, was observed with no lock on the cap, and was bound/closed with electrical tape. The company was unsure if this was an active well, but stated that confirmation will be provided by the end of the inspection week.
 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

In accordance with the OPR, the Company is required to ensure adequate protection of property and the environment. To achieve compliance, the company will appropriately mitigate the issues identified and properly secure and cap the monitoring well.

Photographic evidence will be provided to the Inspecting Officer upon completion of the maintenance.
 

Due date: 2020-09-18

Date closed: 2020-10-05
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 5 - CNC 4: Odessa Pump Station - Hydrocarbon Staining

Date & time of visit: 2020-09-17 13:52

Discipline: Environmental Protection

Categories:

Facility:

Observations:

The Inspection Team was able to gain access to Odessa Pump Station due to electrical maintenance coinciding with time of the visit to the facility. Maintenance crews gave the Enbridge regulatory advisor access to the employee trailer to review the Field Level Hazard Assessment, which all persons present for the station inspection signed. The Inspection Team was provided with a H2S gas monitor to use, however there was no need to enter the facility buildings on site. While touring the grounds within the facility, the following non-comliances were observed:

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The company is required to clean-up of the hydrocarbon stains observed at the two locations identified below:

Once clean up is complete, photographic evidence of the clean up will be submitted, as well as an explanation as to how the clean up was conducted.

Due date: 2020-09-21

Date closed: 2020-10-07
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 6 - CNC 5: Wildlife Refuse at Odessa Pump Station

Date & time of visit: 2020-09-17 14:11

Discipline: Environmental Protection

Categories:

Facility:

Observations:

While touring Odessa Pump Station, a birds nest was observed underneath a platform and on top of a pipe near 13-SDV-1. No bird activity was observed within the nest, and no fledglings were found in the area.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

The Company will remove and properly dispose of the inactive birds nest observed near operating components within the facility. Upon removal, confirmation will be provided  to the CER. 

Due date: 2020-09-18

Date closed: 2020-10-19
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 7 - NNC 1: Pump Station Grounds - Weeds and Vegetation

Date & time of visit: 2020-09-15 15:33

Discipline: Environmental Protection

Categories:

Facility:

Observations:

The Inspection Team visited two pump stations on the Enbridge Pipeline Corridor. Loreburn Station and Bethune Station. The team did not enter the grounds of the stations, however they walked the perimeter fence at each location noting the condition of the facility premises.
 
The following non-compliant issues regarding management of weeds and vegetation were observed:

Loreburn Pump Station

Bethune Pump Station

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Upon observations made at the facilities, and with regards to management of weeds, the company must implement the following corrective actions:

Specifically for Loreburn Station, the company must correct the following non-compliant issues:

  1. Implement a plan to remove the nuisance weeds along the perimeter fence, within the facility grounds, and around the berm of the inactive flair pit at the northeast end (outside the facility) ; and
  2. Implement a plan to conduct maintenance of vegetation and weeds where no vegetation-free buffer currently exists, primarily on the southeastern side of the perimeter fence.
Specifically for Bethune Station:
  1. Implement a plan to remove, or treat, nuisance and noxious weeds observed on the southern and western sides of the perimeter fence; and
  2. Remove weeds in areas requiring maintenance within the approved facility grounds.

Due date: 2020-11-18

Date closed: 2020-11-24
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 8 - NNC 2: Pump Station Grounds - Waste Management

Date & time of visit: 2020-09-16 13:16

Discipline: Environmental Protection

Categories:

Facility:

Observations:

The following non-compliant issues for House-keeping and Waste Management were observed:

Specifically for Loreburn Pump Station

Specifically for Bethune Station

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Upon observations made at the facilities in regards to management waste and general house-keeping, the company must implement the following corrective actions for the following issues:

For Loreburn Pump Station and Bethune Pump station,

Due date: 2020-11-06

Date closed: 2020-11-24
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 9 - NNC 3: Pump Station Grounds - Erosion and Sediment Controls

Date & time of visit: 2020-09-15 15:33

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Erosion and sediment controls were poorly maintained, and non-functional in many cases. The following observations were made:

Loreburn Pump Station

Bethune Pump Station

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Upon observations made at the facilities in regards to management of erosion and sediment controls, the company must implement the following corrective action for Loreburn Station, and Bethune Station:
 


 

Due date: 2021-02-10

Date closed: 2021-02-24
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 10 - NNC 4: Bethune Pump Station - Wetland Vegetation within Facility Grounds

Date & time of visit: 2020-09-16 13:32

Discipline: Environmental Protection

Categories:

Facility:

Observations:

The following issues were observed:




 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Upon observing the expanse of characteristic wetland vegetation at the northeast corner, and within the western portion of the facility, the company must develop and implement the following corrective actions:

  1. Remove vegetation around and within the perimeter fence buffer, where the cattail colony has emerged at the northeast corner. Provide photographic evidence.
  2. Develop a plan to remove the emergent wetland vegetation that has established within the western portion of the facility grounds; and
  3. Provide written documentation that details how the company will remove the wetland vegetation within Bethune Station, and the timeline to completing the task.

 

Due date: 2021-02-10

Date closed: 2021-02-24
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 11 - IR 1: Updated Deficiency List

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Throughout the inspection of spreads 2 – 5, several areas were noted to have deficiencies. To ensure adequate monitoring and maintenance of the ROW, and at select locations visited, the inspecting Officer made notes of deficient mitigation measures, informed the company of the deficiency, and requested to see an updated deficiency list (or email confirmations) at the end of the inspection to confirm that future works/maintenance have been planned at the locations. The following deficiencies were noted (KP’s are approximate):

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

The company will submit their environmental deficiency list, identifying the areas of deficiency observed during the inspection, and with applicable updates to confirm the areas will be monitored and scheduled for maintenance in the future. Also required with the information request, the Company will provide:

Due date: 2020-09-21

Date closed: 2020-10-05
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 12 - IR 2: Facility Inspections

Discipline: Environmental Protection

Categories:

Facility:

Observations:

While inspecting the perimeter of the facility grounds at Bethune Pump Station and Loreburn Pump Station, the inspecting officer observed multiple concerns of poor vegetation maintenance around the perimeter fences and within the facilities (i.e., through the fence).

Wetland vegetation (e.g., Cattails) has reached heights over 6 feet around the perimeter fence at the northeast corner, and emergent wetland vegetation has formed what appears to be a wetland feature inside the facility grounds on the west side of the facility.  At several points around the perimeter fence, there is evidence of water inundation, which in some cases has eroded sediments to a point of structural concern.

Among other concerns noted were waste and debris, weeds, erosion and sediment (controls), and missing signage. These other concerns have been addressed as Non-Compliances in this report.   
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Enbridge will provide the Inspecting Officer with the Company's environmental inspection reports for the past two (2) years at both Loreburn Pump station and Bethune Pump Station.

 

Due date: 2020-11-06

Date closed: 2020-11-10
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 13 - IR 3: Pump Stations - Missing Signage

Discipline: Safety Management

Categories:

Facility:

Observations:

During the inspections of both Loreburn and Bethune Pump Stations, the Inspection Team found several signs on the ground, becoming refuse and not performing the intended function.

 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

The Company will provide the Inspecting Officer with an explanation, and/or documentation, of the posting requirements for the signage identified below, including where within the grounds of the facility the signs must be posted, in accordance with enbridge operating procedures.

Sign observed at Loreburn Pump Station:

Signs observed ta Bethune Pump Station:
Also, please provide the Enbridge Operating Procedure (or similar) for signage requirements around and within facilities. 

Due date: 2020-11-06

Date closed: 2020-11-10
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

Observations (company follow-up required)

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