Compliance Verification Activity Report: CV2122-328 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2122-328
Start date: 2021-10-12
End date: 2021-10-15

Team:

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Inspection of decommissioning activities of Line 3 in Manitoba.

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 - Decommissioning sites

Date & time of visit: 2021-10-14 15:20

Discipline: Environmental Protection

Categories:

Facility:

Observations:

General observation for the following sites:

The Inspection Officer (IO) and accompanying IAMC Indigenous Monitors (IMs) visited the sites noted above. The decommissioning work at all the sites was completed and restoration was also completed. Sites were either seeded with seed mix requested by the landowner or left unseeded for spring farming activities. No concerns noted.

The IOs and IMs also visited the Gretna Terminal and inspected the Line 3 decommissioning activities at the Terminal. Three distinct sites were visited. Excavated areas were being actively pumped to keep water out. Filter bags were installed on the outlets and water was being tested (visually and field measurements of physical properties) prior to discharge into the terminal's surface water system. 

Compliance tool used: No compliance tool used

Observation 2 - Meeting with Slave Lake First Nation Chief and Council

Discipline: Socio-Economic

Categories:

Facility:

Observations:

The inspection team met with the new Chief and council members of the Swan Lake First Nation (SLFN). The Chief raised three main concerns.

The first concern was with nearby contaminated sites being managed by Enbridge and regulated by the CER. These sites are off reserve, but are upstream of the water supply of the Nation. SLFN leadership needs more information and assurance that the remediation sites are not affecting their water supply. Enbridge committed to meet with the SLFN to provide a status update on the remediation work.

The second concern was specific to the decommissioning site on the reserve. The company committed to have a SLFN monitor attend the sites and observe various activities. Unfortunately, due to some miss communication, Enbridge PipeLine Maintenance (PLM) crew cut the pipe and capped it without the presence of the SLFN monitor. The monitor was able to observe various other activities at the site, but not the actual cut and cap. (See IR #1)

The third concern was related to the long term relationship between the company and the Nation. Enbridge committed to meet with leadership. A meeting was already planned for the following week.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

1.1.  Provide relevant information related to the notification of Swan Lake First Nation with regards to the activities on site 4056, including but not limited to:

1.2.  Provide photos of the worksite including the actual cut out and capping activities.

Due date: 2021-11-05

Date closed: 2021-11-05
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

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