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

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2864

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• Saskatchewan

Discipline(s):

• Environmental Protection
• Indigenous Monitoring

Related events:

• CV2021-069
• CV2021-510
• CV2122-029

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:

• Corrected Non-compliance (CNC) (5)
• Notice of Non-compliance (NNC) (4)
• Information Request (IR) (3)

Facility details

Facilities:

• Line 3
• ODESSA [Line 1 Connectivity]
• BETHUNE [ALBERTA CLIPPER]
• LOREBURN [Line 1 Connectivity]

Facility Types

• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Operations
• Post-Construction (Reclamation)

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Pipeline Damage Prevention Regulations – Obligations for Pipeline Companies
• Plans And Procedures
• Project-specific Environmental Protection Plan (EPP)
• Environmental Protection Plan for the Enbridge Line 3 Replacement Program. Rev 3. February 2018.
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• OC-063

Observations (no outstanding follow-up required)

Observation 1 - General Observations

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

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Biosecurity
• Water Bodies - Non-Fish-bearing
• Reclamation
• Water Bodies - Fish-bearing
• Sedimentation/Turbidity
• Destruction/Loss of Habitat
• Reclamation
• Erosion
• Wildlife
• Destruction/Loss of Habitat
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation
• Crop Productivity
• Housekeeping
• Waste Management
• Socio-economic
• Traditional Land and Resource Use
• Heritage Resources
• Training and Documentation
• Documentation Available/Up to Date

Facility:

• Line 3 (Pipeline)

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

• The IO estimates that ROW cover ranges anywhere from 65 – 100% throughout the majority of the areas observed
• The ROW is not evident in many locations, and less evident in agricultural lands.
• Sparse patches of bare soil were observed, however no erosion concerns were noted.
• There is an over abundant presence of field insects noted at several locations visited (e.g., beetles, grasshoppers, crickets, spiders).
• A diverse community of vegetation has re-established in many locations, and grasses were abundant in pastures and fields.
• Cattle grazing evident at several locations, likely hindering plant reestablishment. No subsidence observed.
• At SSKP 154+600, the ground had been disturbed to conduct ovality testing. Reclamation efforts have been reestablished.
• The ROW has been re-contoured adequately.
• Top soil reclamation occurring in Spread 5. Grading has occurred to evenly level the ground surface, and straw has been applied over a cover crop to mitigate potential erosion concerns.

• Diversion berms observed along steep slopes; constructed to mitigate high surface flow during run off (i.e., rain) events.
• Coir wrap observed on diversion berms to mitigate erosion. Damage evident, appears to be caused by cattle grazing. Locations visited were marked as deficiencies by the company EI.
• Straw wattles, sediment fence, erosion blankets, and check dams were observed to be functional in many of the locations visited. Some areas requiring maintenance due to cattle presence and movement through sediemnt and erosion controlled areas.

• Some areas of nuisance weeds are present, but no infestations observed.
• Where concerns existed, the company has been applying spray treatments; patches of dead weeds were observed in several locations.
• Weeds observed on ROW are comparable to off-ROW conditions.

• Where practical, the ROW has been narrowed through to avoid the sensitive habitat and the riparian area.
• Emergent vegetation, such as cattails were noted in several wetlands.
• Sedges and rushes are also prevalent in many wetlands, as well as deciduous trees in several of the class 3 wetlands.
• Contouring has been reestablished, and is comparable to surrounding landscape.
• Presence of weeds is minimal, and comparable to Off-ROW conditions.
• In some cases, a wetland was no longer present. Company EI stated that in some years, land owners have wetlands, and other years they are dry for cultivation.
• Where wildlife habitat is present, there are signs that habitat quality is functional and promoting use; tracks observed, and sounds (i.e., frog calls) heard in the area.

• Approximately 60% grass cover observed.
• Vegetation is comparable to Off-ROW conditions.
• ESC in place, consisting of diversion berms on approach slopes, with coconut matting, rock check-dams, and hydro-seed mulch.
• ESC in place within riparian zone (e.g., revetment posts and coir netting). Observed as functional with establishment of grasses and vegetation.
• Signage is present on east bank, but not on west bank – refer to CNC 1

• Land owner has erected fencing on both sides of the creek.
• ESC in the riparian area consists of revetment posts, coir netting, and straw wattles. Observed as functional with good establishment of vegetation, and extending into the watercourse.
• Minor presence of weeds, but comparable to Off-ROW conditions.
• Required signage in place on both sides of the creek.
• No evidence of cattle grazing.
• No issues.

• The crossing method used was trenchless (i.e., Horizontal Directional Drill). No disturbance within the riparian area, or the watercourse.
• Refer to CNC 2

• The drainage has been subject to cattle grazing, with rutting and compaction observed in the stream path, though erosion concerns are minimal.
• Stagnant water is present in the ditch area.
• Toad and frog habitat is intact and suitable for overwintering habitat.
• ROW is not evident and land use is similar to adjacent topography.

• Banks of the creek are well vegetated, extending into the riparian area.
• Wetland is in close proximity to the creek with cattails and sedges abundant.
• The creek was observed as completely dry, with no water flowing or water present.
• ESC consists of straw wattles and coir netting. No erosion concerns observed.
• Cattle have crossed the dry channel, creating challenges to reclamation by disturbing the channel substrate. Company EI stated this will be added to the deficiency list and will be mitigated before water re-inundates the creek crossing.
• Signage present on both banks.

• Trenchless crossing method used (i.e., HDD – Micro tunneling). No disturbance to the watercourse.
• Where temporary access structures (i.e., clear span bridge) were used, there is limited vegetation growth, however the company EI explained that it was left that way at the land owners request and cattle gates have been erected around the area. Confirmed by land owner that this was requested. Refer to IR for further details.
• HDD pads are not evident and have been reclaimed with grasses and vegetation. No weeds observed.
• Required signage is present on both banks.
• No issues.

• Vegetation cover is near 100%.
• Some presence of noxious weeds, though patches have been treated with spraying and mowing.
• Creek was observed partially dry, with stagnant water. Cattle grazing is evident.
• Habitat is suitable for amphibians, and signs of wildlife were present.
• ROW avoided adjacent wetland feature – riparian area left intact.
• Some ESC materials have been noted for removal, and identified on the deficiency list.
• No issues.

• Approximately 90% vegetation cover on the banks of the watercourse. Aquatic vegetation is abundant.
• Riparian area is stable and providing cover for fish and wildlife.
• Flock of ducks observed in stream.
• No issues.

• ESC is scheduled for removal next spring. The riparian area is well vegetated, with no evidence of erosion.
• Required signs present on both banks.
• No issues.

• Observed as completely dry with no flowing water. Channel is fully exposed.
• Revetment posts are in place to stabilize the banks.
• Coir netting and erosion mats are present in the riparian area
• Vegetation cover is limited (~50%), but no erosion observed.
• Stream bed is armored with cobble and rocks.
• No issues

• Carwash was required prior to conducting field inspection, plus 1-2% bleach solution applied to boots.
• Before inspecting each point of interest, all persons on the Inspection Team were subject to a 1-2% bleach solution applied to the boots.

• For the HER sites visited, mitigations during reclamation have ensured the areas have come back to equivalent land use capability were agricultural lands are owned. Some locations were observed on the ROW, whereas others have been avoided during construction. No issues were noted. 
• TLU sites are kept confidential, however the Company provided the Inspection Team with a table identifying the mitigations implemented and descriptions of cultural sites along, or cultural land uses on the ROW. No concerns were noted by the CER Officer or the IAMC Monitors. 

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:

• Pipeline Identification
• Signs

Facility:

• Line 3 (Pipeline)

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:

• National Energy Board Pipeline Damage Prevention Regulations – Obligations for Pipeline Companies

Relevant section(s):

• • 16 The damage prevention program that a pipeline company is required to develop, implement and maintain under section 47.2 of the National Energy Board Onshore Pipeline Regulations must include
    • (e) standards for locating a pipeline; and

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:

• Soils and Soil Productivity
• Erosion
• Soil Integrity

Facility:

• Line 3 (Pipeline)

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:

• Project-specific Environmental Protection Plan (EPP)
• Environmental Protection Plan for the Enbridge Line 3 Replacement Program. Rev 3. February 2018.

Relevant section(s):

• Section 14.0. Interim Clean-up and Final Reclamation – Contractor Measures. Place erosion control matting, wood chips, wood mulch, tackifier, staked logs or rollback on steep slopes or exposed sites that will be difficult to stabilize as advised by Enbridge Environmental Inspection (see Details 21, 22 and 23 in Appendix E, and Appendix D17). Ensure that adequate anchoring of the erosion control matting is in place.

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:

• Groundwater
• Monitoring and Testing

Facility:

• Line 3 (Pipeline)

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:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 48. A company shall develop, implement and maintain an environmental protection program that anticipates, prevents, manages and mitigates conditions that could adversely affect the environment.

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:

• Soils and Soil Productivity
• Chemical Spills/Releases

Facility:

• ODESSA [Line 1 Connectivity] (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:

• An emerging pipe with a valve control, labelled: 2-SSV-1, was dripping hyrdocarbons, and was accumulating a >1m in diameter stain on the ground surface.
• A pipe, labelled 13-SDV-1, had some residual staining of Hydrocarbon’s on the ground surface directly beneath a pipe join. The pipe itself, nor the gasket where the pipe was joined was exhibiting any staining.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 48. A company shall develop, implement and maintain an environmental protection program that anticipates, prevents, manages and mitigates conditions that could adversely affect the environment.

Company action required:

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

• 2-SSV-1 (valve control)
• 13-SDV-1 (pipe)

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:

• Housekeeping
• Waste Management

Facility:

• ODESSA [Line 1 Connectivity] (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:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 48. A company shall develop, implement and maintain an environmental protection program that anticipates, prevents, manages and mitigates conditions that could adversely affect the environment.

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:

• Vegetation
• Vegetation Control
• Invasive Plant Management

Facility:

• BETHUNE [ALBERTA CLIPPER] (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

• Nuisance weeds were observed at several locations around and inside the facility grounds, but mainly on the North, South, and East perimeter fence.
• Nuisance weeds were observed around and within the berm of an inactive, horizontal flair pit, near the northeast part of the perimeter fence, but outside the facility grounds. 

• Noxious weeds (Canada thistle) were observed on the south and west sides of the perimeter fence. Nuisance weeds were observed on the east side of the fence.
• Some small clusters of weeds, or single stems were observed within the facility.

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

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 48. A company shall develop, implement and maintain an environmental protection program that anticipates, prevents, manages and mitigates conditions that could adversely affect the environment.

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.

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:

• Housekeeping
• Waste Management

Facility:

• BETHUNE [ALBERTA CLIPPER] (Facility)

Observations:

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

Specifically for Loreburn Pump Station

• Waste was noted at several locations, with items such as Styrofoam, wood stakes, tarp fragments, plastic pipe, cardboard, metal posts, and other miscellaneous refuse items.
• A windsock was observed on the ground, near the fence at the south end of the facility.
• A sign has fallen off the perimeter fence and was observed approximately 3 - 4 meters from the fence.

• Multiple signs were observed on the ground around the perimeter fence.
• Waste and miscellaneous refuse items were observed along all sides of the fence and within the facility grounds.

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

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 48. A company shall develop, implement and maintain an environmental protection program that anticipates, prevents, manages and mitigates conditions that could adversely affect the environment.

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,

• Collect and dispose of any and all waste/refuse items found along the perimeter fence and within the facility grounds, including the windsock, Styrofoam, wood stakes, tarp fragments, plastic pipe, cardboard, and metal posts.
• Provide photogrqaphic, and/or documented evidence that the facilities have been cleaned up an disposed of as per Enbridge procedures. 

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:

• Soils and Soil Productivity
• Erosion

Facility:

• BETHUNE [ALBERTA CLIPPER] (Facility)

Observations:

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

Loreburn Pump Station

• Erosion and sediment controls (silt fence) within the facility and near the southern perimeter fence were not functioning and in disarray.

• Erosion and sediments controls (silt fence) were observed as non-functional and in disarray at multiple locations within the facility grounds; northeast, south, and western sides primarily.

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

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 48. A company shall develop, implement and maintain an environmental protection program that anticipates, prevents, manages and mitigates conditions that could adversely affect the environment.

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:
 

• Erosion and sediment control structures must be maintained, and/or be removed according to operational requirements.
• Upon completion, documentation which may include photographic evidence, must be submitted to the Inspecting Officer.
   

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:

• Vegetation
• Vegetation Control

Facility:

• BETHUNE [ALBERTA CLIPPER] (Facility)

Observations:

The following issues were observed:

• A cattail colony has established on the Northeast corner of the perimeter fence, and a seasonal wetland feature has resulted. There was no inundation of water at the time of the inspection, but it was evident that no outer perimeter maintenance had occurred in the past year.
• On the west side of the inner facility, what appears to be a wetland feature, lush with vegetation has formed within the facility grounds.

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

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 48. A company shall develop, implement and maintain an environmental protection program that anticipates, prevents, manages and mitigates conditions that could adversely affect the environment.
  • 53. General Compliance
    • (1) A company shall conduct inspections on a regular basis and audits, with a maximum interval of three years, to ensure that its pipeline is designed, constructed, operated and abandoned in compliance with
      • (c) these Regulations; and
      • (d) the terms and conditions of any certificate or order issued by the Board, as they relate to the protection of property and the environment and the safety of the public and of the company’s employees.

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:

• Training and Documentation
• Inspections

Facility:

• Line 3 (Pipeline)

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):

• SSKP 156+100: Cattle fence down. Company will confirm land owner use
• SSKP 331+300: Drainage site requires some erosion and sediment control (ESC) maintenance; landowner use of heavy equipment in the area has disturbed the west bank (tracks observed).
• S. Sask. River: ESC measures require maintenance. Rills forming within reclaimed temporary works space (TWS) area. Vegetation cover is minimal, though area exhibits sandy/silty soils.
• SSKP 418+350: ROW leading down to Iskwao Creek has evidence of cattle grazing. Vegetation cover is approximately 70%. ESC in the area requires maintenance.
• Iskwao Creek: Cattle crossing the channel over the ROW has created disturbance to the substrate; no water present - channel is dry.
• Qu’appelle River: TWS for clear-span bridge are not reclaimed (left as is at land owners request, and enclosed with cattle panels). Spoil piles on edge of ROW. Gravel pile left onsite near pre-existing bridge. Pipe has been left onsite.
• High hill Creek: ESC (straw wattles) can be removed; vegetation cover is near 100%.
• Cottonwood Creek: ESC (straw wattles) are scheduled for removal; vegetation cover is approx. 90%.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 39. A company shall develop a surveillance and monitoring program for the protection of the pipeline, the public and the environment.

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:

• Confirmation that the cattle fence at SSKP156+100 is the land owners.
• A technical drawing describing the works to be completed at the S. Sask. River.
• Photographic evidence of the work completed in the substrate at Iskwao Creek.
• Confirmation from the land-owner that the materials left at the Qu’appelle River HDD crossing were left at the land-owners request.

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:

• Training and Documentation
• Inspections

Facility:

• BETHUNE [ALBERTA CLIPPER] (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:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 6.5 Management System Processes
    • (1) A company shall, as part of its management system and the programs referred to in section 55,
      • (u) establish and implement a process for inspecting and monitoring the company’s activities and facilities to evaluate the adequacy and effectiveness of the programs referred to in section 55 and for taking corrective and preventive actions if deficiencies are identified;

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:

• Permanent Structures
• Signage

Facility:

• BETHUNE [ALBERTA CLIPPER] (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.

• At Loreburn Station, a sign reading, “Danger – Hydrogen Sulfide Gas and Explosive Gases”, was observed outside the perimeter fence at the Southeast section.
• At Bethune Pump Station, multiple signs reading, “Danger – High Voltage”, were observed along the South perimeter fence, and a sign reading, “Primary Evacuation Site #2”, was observed on the ground, inside the perimeter fence at the North end (near the entrance).
   

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 47. A company shall develop, implement and maintain a safety management program that anticipates, prevents, manages and mitigates potentially dangerous conditions and exposure to those conditions during all activities relating to construction, operation, maintenance, abandonment and emergency situations.

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:

• Danger – Hydrogen Sulfide Gas and Explosive Gases.  

• Primary Evacuation Site #2
• Multiple – Danger high voltage

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: