Compliance Verification Activity Report: CV1920-045 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2619

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• Alberta
• Saskatchewan

Discipline(s):

• Environmental Protection

Rationale and scope:

Final Clean Up Inspection of Spread 2 of the Enbridge Line 3 Replacement Program. Construction was completed in 2018 with only final clean up remaining. Inspection focused on soil handling practices and watercourse crossing. This inspection was co-conducted with Indigenous Monitors (IMs) from the Indigenous Monitoring and Advisory Committee (IAMC).

Compliance tool(s) used:

• None

Facility details

Facilities:

• Line 3

Facility Types

• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Construction
• Post-Construction (Reclamation)

Regulatory requirements

Regulatory requirements that apply to this activity:

• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Act (NEBA) 2016-06-19
• Plans And Procedures
• Project-specific Environmental Protection Plan (EPP)
• Pipeline Environmental Protection Plan for the Enbridge Pipelines Inc. Line 3 Replacement Program (Rev 3 - February 2018)

Regulatory instrument number(s):

• OC-063

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2019-07-18 12:00

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Soil Handling
• Biosecurity
• Restoration
• Surface Water Management
• Containment and Drainage Structures
• Water Bodies - Non-Fish-bearing
• Reclamation
• Erosion
• Water Bodies - Fish-bearing
• Reclamation
• Erosion
• Vegetation
• Vegetation Control
• Invasive Plant Management
• Vegetation Reclamation
• Training and Documentation
• Documentation Available/Up to Date
• Permits/Approvals
• Training
• Inspections

Facility:

• Line 3 (Pipeline)

Observations:

 General Observations

• The inspection team met with the Company’s Aboriginal Construction Monitors, who indicated that they key in on soil moving activities in heritage areas. No concerns were expressed to the inspection team.
• The inspection team reviewed cleaning records for six randomly selected pieces of topsoil handling equipment.
• The inspection team visited a reclaimed wetland (SK-64) at which pipe was installed in winter 2017. Wetland vegetation appeared healthy and contours appeared consistent with surrounding landscape.
• A water withdrawal site (“lake 1”) was visited. Several intake hoses were present; Company representatives indicated that there are multiple withdrawal licenses. Enbridge’s hoses were not present. The IO reviewed the permit for the lake, which is valid until March 2020. The Company representatives indicated that the water could be used for construction purposes, but not for hydrostatic testing.
• A cleaning station was observed in use at road 102 between municipal boundaries. A grader was in the process of being cleaned (fine clean) when the inspection team arrived on site and cleaning of that unit continued for over an hour while the inspection was underway.
• Several pieces of equipment, including a tractor, bobcat and trackhoe were inspected on the right-of-way. All three units had spill kits, cleaning stickers, fire extinguishers with current inspection tags, and no visible leaks.
• Weeds were observed along the RoW and on spoil piles. Crews were observed mechanically removing weeds (mowing) in an organic field and spraying weeds with a herbicide on a non-organic field. No noxious weeds were observed. Company representatives indicated that the weed management was occurring up and down the right-of-way.
• Crews were preparing equipment for use when the inspection team arrived west of road 102. The crews dispersed upon their arrival. Two small grease spills (approximately 10mL each) were observed on clay within approximately 5 meters of one another. Company representatives provided documentation later that day indicating that the spills were cleaned up. The Inspection Officer is utilizing their discretion and has decided not to issue a non-compliance given that: the spills had likely occurred that morning (work had been shut down for 3 days due to rain) and the crews work had been disrupted by the inspection, thereby denying the crew an opportunity to observe and address the spill on their own.
• Dewatering activities were observed at KP 199+600. Water was being pumped from the RoW into an adjacent canola field. Company representatives indicated that they consulted with the landowner prior to water dispersal. The water was dispersed into a sediment bag in a well-vegetated area. The pump was within secondary containment and a spill kit was on site.

• Fuel storage area was lined with a fuel resistant liner and gravel berms around the perimeter. Drip pans were available next to all fueling nozzles.
• Spill kits were present at both ends of the fueling area.
• Waste segregation appeared appropriate, no waste was observed in incorrect locations.
• The perimeter of the yard was well organized and tidy.
• Secondary containment was in use where required.
• A piece of damaged equipment was tarped, locked out, and had a drip pan beneath it.
• All fire extinguishers checked had up to date inspection tags.

• Fish-bearing creek
• Company representatives indicated that no temporary access/bridge was used at this location and that the crossing was constructed using an open cut method.
• The inspection occurred from the west bank; an erosion control blanket was evident on this bank. Company representatives indicated that one was in use on the opposite bank as well.
• Company representatives indicated that a 10 m riparian zone and the creek banks were reclaimed in 2018 and that riparian seeding occurred in spring 2018.
• Banks appeared stable, vegetation growth approximately 60-80% cover on both banks.

• Nest surveys are conducted on foot, observations made for both audio and visual cues;
• Nests are recorded and tracked with a spreadsheet indicating species-specific buffers and the level of activity permitted; and
• “Bird buffers” are roped off to prevent access and marked with lathes indicating the species, date detected, and buffer distance.

• Company representatives indicated that reclamation was completed in approximately October 2018 and seeding occurred in the first week of November.
• The area was generally well vegetated. Grasses were observed in rows (i.e., from seeding) as were weeds. Some weeds reached approximately 1m in height. Company representatives indicated that weed management activities (mowing or spraying) had not yet occurred due to a bird buffer that was removed the previous day but would occur as soon as method of removal was confirmed with the Land Use Grazing Manager.
• No erosion was observed.
• The right of way through the pasture was to be fenced off for a year to keep cattle out and allow the vegetation to reestablish.

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: