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:
Inspection of Enbridge Line 3 Replacement Project Spread 5 - Construction. This inspection focused on topsoil handling and verification of Enbridge's mitigation measures to prevent spread of soil pathogens. The inspection verified the implementation of Enbridge's Environmental Protection Plan during construction.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Coating clean-up
Date & time of visit: 2018-09-11 10:45
Discipline: Environmental Protection
Categories:
Facility:
Observations:
The Inspection Team visited the location where crews were applying coating on welds on the drag-section of the pipe for the Chapleau Lake HDD on Tuesday 11 September. At the time of coating activity, the weather was windy. Crews were observed to be using a square of plywood or cardboard which was covered in black plastic as a drip-catcher. Spills and drips of coating material were observed on the ground in the area of coating activities. Inspectors were told that the spilled material and other garbage from the coating crew would be cleaned up later that day as part of the normal series of coating activities. When inspectors visited the site again on Thursday 13 September, the garbage was no longer present, but drips of coating material were still visible on the ground. Enbridge staff indicated that it would be unreasonable to expect that every drip would be picked up, and that as the material was inert once dried, they had few concerns. However, Enbridge staff indicated that they would nevertheless impart to the coating crew and others that proper cleanup is required, and that more effort would be put into raking up drips and overspray. An email from the contractor to Enbridge was provided that noted spot checks would be performed by contractor Management and QC personnel.
Compliance tool used: No compliance tool used
Observation 2 - Soil Pile Trespass
Date & time of visit: 2018-09-12 14:20
At the Kronau Creek crossing (approx. 576+600) and at the 3-lift saline soils area at KP578+750, the Inspection Team noted areas where the spoil piles were slightly outside the RoW boundaries marked by stakes.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
The company is to ensure that soil stockpiles are removed from the area outside the staked RoW, and provide photographic evidence of the completed work.
Due date: 2018-09-13
Date closed: 2018-09-19 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 3 - Soil handling, General
Date & time of visit: 2018-09-11 15:00
The Inspection Team went to the edges of the RoW to observe if spoil piles were within the boundaries of the RoW. In most areas, the company has left a gap between the edge of the spoil pile and the RoW to allow for a person to walk behind them. At the Kronau Creek area, topsoil from the native prairie portion of the RoW was stored separate from the remainder of the topsoil, and labelled. Tackifier was seen on or in the process of being applied to soil piles to reduce wind and water erosion. Enbridge representatives confirmed that soil would be tackified along the entire Spread, depending on weather and construction progress, and was not limited to the areas identified on the Alignment Sheets as prone to wind erosion. NEB IOs acknowledge that additional tackification is additional mitigation that goes beyond what was required in the EPP. In most areas of the RoW, topsoil and seconds had been salvaged and stockpiled separately. Soil piles were labelled, and there appeared to be good separation between the labelled stockpiles. The depth of topsoil salvage appeared to appropriately reflect the salvage depths cited on the Alignment Sheets, and topsoil depths observed in the field.The Inspection Team visited three-lift soil sites at KP 578 and 594. At KP 578, the configuration of stripped soils differed from the detail drawing in the EPP (the third lift soils were stripped, and piled alongside the trench area then packed down, rather than piled alongside the first and second lifts as shown in the typical drawings), however, the goal of segregating problem lower subsoils from upper subsoils during trenching would be met. The EPP/drawings allows for flexibility in stockpile configuration based on the site. At KP 594, the configuration of three-lift soils was as per the typical drawings. The Inspection Team was also able to speak with a soil specialist (EI) who was supervising, and observe the activities during the stripping of topsoil at KP 612. The Inspection Team had no concerns regarding soil handling.
Observation 4 - Speeding on Right of Way
Date & time of visit: 2018-09-11 09:00
Discipline: Safety Management
The Project is parallel to Highway 48 for some distance. As the Inspection Team was travelling along Highway 48, members could see the RoW and work being conducted. Inspectors noted a truck on the RoW that was travelling at a high rate of speed, that was a little slower than the Inspection Team’s vehicle, which was going 100km/hr on the highway. Although an exact rate of speed was not determined, the Inspection Team found that the vehicle travelling on the RoW was certainly travelling much faster than the 30 km per hour RoW speed limit.
The company is to ensure that all staff and contractors adhere to the speed limits established for the RoW.
Due date: 2018-09-11
Date closed: 2018-09-11 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.
Observation 5 - Wetlands and Waterbodies
Date & time of visit: 2018-09-13 11:00
The Inspection Team visited several watercourse and wetland crossings.
Observation 6 - Heritage and Traditional Land Use sites
Date & time of visit: 2018-09-11 10:00
The Inspection Team visited several sites indicated as heritage sites and traditional land use areas in the EPP. Notably, in the Chapleau Lake area (KP624), the area was being prepared for a Horizontal Directional Drill. This allowed the trenching to avoid most of the indicated Heritage sites indicated in the EPP in that area. During the course of the inspection, the signs, flagging, fencing staking of Heritage sites was noted. Company representatives provided more information on the actual heritage finds at each of the noted locations, and the specific mitigation measures beyond the information in the EPP documents. The Inspection Team also reviewed team-selected reports from Enbridge’s Aboriginal Monitors, and spoke with the Monitors about their work and their findings. The Inspection Team had no concerns regarding the mitigation measures in place at the heritage sites, or the company’s implementation of those measures.
Observation 7 - Biosecurity
Date & time of visit: 2018-09-13 16:30
During the course of the inspection, the Inspection Team visited the locations of several cleaning stations along the RoW. Due to the progress of work, the cleaning stations were not in use at the time of the site visits, other than the White City Construction Yard cleaning station. The Inspection Team also gathered reference numbers of equipment and vehicles seen on the RoW and reviewed the cleaning records for them, as well as cleaning records for the cleaning station at KP648+800. The Inspection Team’s vehicle also underwent the appropriate pre-cleaning to be permitted onto the RoW. The vehicle was washed, with particular attention to the undercarriage, wheels and wheel wells. The tires were then sprayed with a bleach solution, which was maintained in a damp state for 15 minutes after application. Team members’ boots and the tires were also re-sprayed prior to entry onto sites where the topsoil had not been stripped. The Inspection Team was able to view cleaning records as requested. During the review, the Inspection Team noted that the cleaning record for unit 0503 on 29 Aug 2018, had photographs showing quite a lot of soil/dirt on the mats of the cleaning station. A Wash Station Inspection had been conducted on 30-Aug-2018 by a project EI, which noted improvements required were to maintain cleaner station floors. Records and photographs reviewed from after 30-Aug-2018 (e.g. 31-August-2018 unit R291-D008) showed improvement to cleaning station floor cleanliness, indicating implementation of improvements required by the EI. No concerns regarding the cleaning of equipment and vehicles on the RoW for biosecurity purposes were identified. The Inspection Team observed cleaning of a pickup truck at the White City yard cleaning station. During discussions with the employee whose truck was being cleaned, the employee demonstrated he had a good understanding of the biosecurity cleaning requirements for the project, and described the cleanings he had undertaken over the course of his day (he was travelling on topsoil). Some soil material was observed in the wheel well following cleaning, which, upon identification to Enbridge and the cleaning crew was immediately removed by power wash.
Observation 8 - Missing Spill Kit
The Inspection Team looked for spill kits in different vehicles and pieces of equipment. A side-boom near the planned HDD (equipment ID SB 19) was inspected, and there was no spill kit on the unit . Although there is no specific requirement in the EPP for each piece of equipment on the RoW to have a spill kit, Company representatives stated that all equipment would be checked by the foremen for all crews prior to starting work on the next day to ensure that each had a spill kit. An email from the contractor to Enbridge personnel confirming that the equipment checks would be conducted was provided.The company also provided photographs showing that side-boom SB 19 had been equipped with a spill kit.
Observation 9 - Missing Fire Extinguisher
The Inspection Team looked for fire extinguishers in different vehicles and pieces of equipment. A side-boom near the planned HDD (equipment ID SB 19) was inspected, and there was no fire extinguisher.
The company is to ensure that all equipment on the RoW have fire extinguishers, as required.
Date closed: 2018-09-13 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.
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
