Compliance Verification Activity Report: CV2324-205 - LBX Pipeline Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2324-205
Start date: 2023-09-26
End date: 2023-09-27

Team:

Regulated company: LBX Pipeline Ltd.

Operating company: Husky Midstream

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Operations inspection including sites of INC2021-199 and INC2021-206 horizontal directional drilling inadvertent fluid releases on the Onion Lake Reserve.

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 - General Observation, LBX

Date & time of visit: 2023-09-26 08:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Onion Lake System RoW (Right of Way)

8ETIL and 20LLO Systems Shared RoW
  • East Till Junction Site:
    • Inspected mixed waste bin and contaminated soils bin. No concerns noted.
    • Staining beneath pig trap was noted by IO’s. LBX Operator cleaned up stained gravel while IO’s were still onsite. No further concerns.
    • Chemical and electrical buildings inspected. Secondary containment was present in chemical building and appropriate containment below a noted drip was present. Discussed procedures of disposal of waste fluids associated with drip with LBX Operator. Monitoring checklist was available for review. No concerns noted.
    • Secondary containment was observed to be built into generator.
    • No issues noted with respect to the drainage or vegetation management at the East Till facility.
    • IOs noted that there is no hazardous chemical storage onsite.
    • Facility signage in place with emergency contact number, which was confirmed to be operational.
  • Inspected creek crossing within the RoW. Creek crossing was completed by directional drilling in 2016. Vegetation and watercourse on RoW were indiscernible from surrounding areas not associated with the RoW.  Though the creek banks are of a fairly steep slope on one side, the slope is well vegetated and no erosion was visible. Appropriate signage was present.
  •  Inspected largest wetland along the RoW. Installation of the pipeline in 2016 was conducted using directional drilling which did not disturb the wetland. The wetland was observed to be densely vegetated around the edges, geese and ducks were present, and the RoW and was indiscernible from surrounding areas.
Onion Lake Facility
  • IO’s verified various waste types (contaminated soil, oily rags, mixed, waste, household waste, etc) to be stored and labelled appropriately.
  • Viewed Lease Automated Custody Transfer (LACT), electrical and chemical storage buildings, and noted absorbent pads and drip catchers where needed, waste properly stored, signage in place. No concerns noted.
  • Spot checked fire extinguishers and eyewash stations to be present and maintained.
  • IO’s noted that no hazardous chemicals are stored onsite.
Document Review and Spot Checking Management System Elements
  • LBX staff shared the environmental risk registry on request by the IO’s. Staff shared that LBX and Husky Midstream is preparing a new version of their Environmental Management Program, to expand on the current version and gain alignment with Cenovus’s management system.
  • IOs spot checked documentation of a LBX non-reportable (to the CER) spill which occurred at Onion Lake. No concerns noted.
  • IO’s provided feedback to LBX that the updated Environmental Management Program should include contaminated site management (identification through to remediation).

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:

- 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