Compliance Verification Activity Report: CV2122-379 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2194
• Inspector 2738

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Environmental Protection

Related events:

• INC2022-029

Rationale and scope:

Field inspection of the response to INC2022-029 release of crude oil within the Edmonton Terminal.

Compliance tool(s) used:

• None

Facility details

Facilities:

• EDMONTON TERMINAL
• Line 4

Facility Types

• Pipeline
• Terminal

Life-cycle Phases

• Operations

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)

Observations (no outstanding follow-up required)

Observation 1 - General Observation - Spill Response

Date & time of visit: 2022-02-15 13:00

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Chemical Spills/Releases

Facility:

• EDMONTON TERMINAL (Facility)

Observations:

Environmental Protection Inspection Officers (IOs) inspected Enbridge's response to the crude oil release which occurred on the evening of 12 February 2022 at the Edmonton Terminal. IOs assessed Enbridge's general response to the clean-up, with focus on management and monitoring of the hazard that the crude oil poses to environmental and human health. Specific observations noted during the inspection are as follows:

Clean-up Approach

• Enbridge representatives stated that the Incident Command System was initiated for emergency response and personnel is working 24 hours per day on clean-up efforts. An internal investigation is currently ongoing, and details of the event were not provided to the IOs.
• Upon arrival at the release location, no active clean-up work was observed at the off-site location due to the rotation of the waste disposal units to the landfill, however, throughout the course of the inspection three hydrovaccuum trucks were observed to be removing the pooled crude oil for transport to the landfill. Enbridge representatives reported that the rate of clean-up is limited by equipment availability and the distance to the landfill (45 minutes). They indicated volume estimates were being determined by sampling each truck load and additional equipment was to arrive on site the following day.
• IOs spot checked bins which Enbridge has temporarily installed for disposal of oily rags and other waste related to the response, no issues noted.
• The down-stream culvert which liquid from the terminal drains into via the drainage/culvert system had been effectively isolated to limit the spread of the crude. Absorbent socks and pads were observed along the drainage ditches and culverts.
• Enbridge representatives stated the general clean-up approach being employed is to 1) clean-up the liquid crude, 2) address the off-site impacts in the ditch, and 3) investigate the below-ground impacts of the release. No estimated timelines for the stages of the response were provided by Enbridge.
• Enbridge representatives indicated the environmental consultant hired to assist with the response was reported to have been present onsite to provide a more accurate estimate of the volume of the release. They also took GPS coordinates to delineate the release. The CER has been notified of the updated volume estimate via the incident reporting process. At the time of the inspection, Enbridge estimated that 88 m³ had been recovered, and that approximately 166 m³ of crude oil had been released.

Air Quality Monitoring

• Enbridge representatives indicated they have employed a three pronged approach to air quality monitoring during the response, given that crude oil is pooled at the surface in a few locations proximal to the release location. IOs observed 1) Enbridge staff wearing personal monitors, 2) a fixed air monitoring apparatus stationed proximal to the largest pool of standing crude, and 3) a consultant on site who Enbridge staff reported were conducting community based air quality testing which takes place at six locations (proximal to the pooled crude) hourly.
• Field staff were unable to comment on details of the fixed air quality results proximal to the pooled crude, nor were they aware of how staff would be alerted if air quality reached an unsafe level. 
• Enbridge representatives reported that the consultant was measuring volatile organic compounds (VOCs) as part of the community based air quality program. Staff were aware that on the day before the IOs inspected the site, VOCs were detected but were below the actionable concentration.

Signage

• IOs observed that the various areas with crude oil pooled were flagged and signage in place to alert workers to the potential hazard. Spray paint and staking was observed around the perimeter of the release. Staff also reported to IOs that all staff working within the terminal were already aware of this release location. IOs note that the pooled crude is primarily located within Enbridge's fenced and secure premises, with the exception of the off-site ditch, which is taped off and labeled appropriately. Enbridge representatives stated they were in communication and discussed clean up efforts with the adjacent property landowner and they did not have any concerns.

Personal Protective Equipment

• The workers observed at the time of this inspection were not standing in product but were working within the vicinity of the crude. No additional PPE outside the general requirements for work at the terminal was observed at the time of the inspection. Enbridge representatives stated atmospheric monitoring was below actionable levels and employees were wearing appropriate PPE for the work being completed. They also indicated if the scope of work changed, or atmospheric monitoring demonstrated a need, workers would have stopped to reassess, and donned appropriate and necessary PPE as required. Potential PPE based on difference scopes of work could include Tyvek or hand protection to ensure adequate chemical protection. CER IO’s note that Enbridge representatives stated Tyvek suits were donned later in cleanup efforts when conditions indicated it was appropriate and necessary.
• A safety data sheet (SDS) for the released product was provided to the IOs upon arrival at the site. IOs note that on page 10 of 22 of the SDS individual PPE is listed. Though not all of the listed PPE was observed in use by workers (nitrile gloves, face shield, respirators), the IOs inquired about tyvek suits. Enbridge reported that staff have additional PPE including tyvek suits available to them but that it is their choice whether to utilize it or not.

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: