Compliance Verification Activity Report: CV1819-074 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2275
• Inspector 2641

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• Alberta
• Saskatchewan

Discipline(s):

• Environmental Protection

Rationale and scope:

Inspection of the Enbridge Line 3 Replacement Program Project (L3RP). On Tuesday 8 May 2018, NEB Inspection Officers (IOs) conducted a helicopter overflight of spreads 1 to 4, which were constructed the previous fall and winter. During the course of this inspection, NEB Inspectors assessed erosion and sediment control measures implemented during spring break-up and verified compliance to the EPP and other environmental protection requirements and commitments applicable to the project such as the L3RP Spring Break Up Preparedness and Monitoring Plan. An observer from the Line 3 Indigenous Advisory and Monitoring Committee (IAMC) was also present during the inspection. Due to weather conditions, a short segment of the RoW south-east of Hardsity was flown on the way back from Regina, Enbridge Staff were not present for this portion of the inspection.

Compliance tool(s) used:

• None

Facility details

Facilities:

• Line 3

Facility Types

• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Construction

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 plan or procedure
• Pipeline EPP
• Project-specific plan or procedure
• L3RP Spring Break Up Preparedness and Monitoring Plan

Regulatory instrument number(s):

• OC-063
• XO-E101-004-2016

Observations (no outstanding follow-up required)

Observation 1 - NEB Environmental Inspection of the Line 3 Replacement Program, Helicopter flyover of Spreads 1 to 4

Date & time of visit: 2018-05-08 06:00

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Water Bodies - Non-Fish-bearing
• Sedimentation/Turbidity
• Reclamation
• Erosion
• Temporary Access Structures
• Water Bodies - Fish-bearing
• Sedimentation/Turbidity
• Reclamation
• Erosion
• Temporary Access Structures
• Housekeeping
• Waste Management
• Temporary Structures

Facility:

• Line 3 (Pipeline)

Observations:

Water levels were observed to be high in isolated areas, more so along spread 1. Water levels decreased and dryer conditions prevailed as the inspection advanced SE towards Regina.

Enbridge noted that they had conducted two overflights and additional site visits during the spring monitoring program and provided a list of maintenance items to NEB IOs. Enbridge stated that maintenance items are being corrected as ground conditions improve to allow equipment access to the RoW.

A summary of observations is provided below:

Spread 1

~KP 38.6 Ribstone Creek

Erosion and sediment control measures were in place. NEB IOs are satisfied with the mitigation and control measures implemented at this site.

~KP 97.5 AB‐WC‐16 – Eyehill Creek

NEB IOs assessed this site and requested additional follow-up information with respect to mitigation and erosion control measures implemented at Eyehill Creek. Enbridge provided the following response:

• All work within the watercourse and 10m buffer was completed and topsoil was replaced.
• The west side ramp was removed and all machine clean-up was completed back to the quarter section boundary. Topsoil was also replaced in this area.
• A berm was installed to the west of the quarter section boundary to divert any run off/sediment away from the reclaimed area.
• The east bank was re‐established and topsoil was replaced. No additional mitigation was required as the natural drainage pattern was to the west away from the watercourse.
• Some minor settling has been identified and will be addressed during final clean-up.

• Enbridge stated that a geotechnical assessment of the area would be completed in the weeks following the inspection once conditions in the area improved. Enbridge noted that additional planning is underway to complete stabilization of the crossing and approach slopes.

• In anticipation of the spring season the temporary vehicle crossing ramp was notched and the flume was removed.
• Geo‐textile silt curtains were established around the edges of the ramp to help prevent erosion of the ramp via water travelling down the access approach.
• Cross drainage berms were established on both slopes to assist in slowing run off while diverting it into the ramped area.
• The pipeline installation area was backfilled and topsoil was replaced within the 10 m buffer of the drainage.
• During machine clean-up, it was determined that silt fence was not required around the roach and adjacent topsoil pile as it was in a well vegetated flat area at the bottom of the coulee area, and the potential for water runoff and subsequent erosion of these piles was considered to be low (due to minimal channel definition at this location)
• Additional straw wattles were added earlier this spring to assist in preventing run off water from moving down the approach slopes.
• This site (much like the tributary to Cactus Lake) experienced higher than anticipated spring runoff levels. Enbridge has identified the characteristics of this type of site as requiring additional mitigation for spring breakup and will ensure that these measures are implemented during subsequent spring mitigation planning.
• This site is on the spring maintenance list as requiring additional efforts
• Silt fence has been installed around the soil roach and topsoil pile (May 10, 2018) after further review by Enbridge environment after the overflight of May 8 with the NEB. The silt fence has been installed as a protective measure should heavy rains cause erosion of these soil piles. The site will have full reclamation completed during final cleanup.

• The attempted installation of the aqua‐dams at wetland SK‐044 took place in late fall during the early work in Spread 2. The proposed isolation was abandoned as frozen conditions prohibited the completion of the installation. At this point the dams became too frozen in to be removed.
• The wetland has been monitored through the break up season and will continue to be checked until the dams are removed. This location is identified on the spring breakup monitoring plan and is being monitored for potential movement and interference with wetland function.
• The damaged aquadam will be removed at the same time as the new aquadam to replace it is installed to minimize potential disturbance to the wetland (conditions are wet in this area to access ahead of construction and there is potential for interaction with migratory birds). This will be scheduled early in the construction season (approximately August). The dam will be removed sooner if they are deemed to pose a significant risk to the wetland function or wildlife.

• SK‐137 (Class 3 dry wetland) was full width stripped due to lack of water, wet soils and wetland vegetation. It is located at KP 282+950 and was identified on the spring preparedness list as requiring silt fence to be removed prior to crews leaving in February, 2018. At the time of inspection in January (when the spring preparedness list was built) it was decided that the topsoil pile that was left in the wetland did not require a notch as there appeared to be minimal risk of water flowing across the wetland due to how flat the ground was.
• When Enbridge flew the ROW in April 2018, it did not appear to have any water ponding issues and was not identified as a follow up in our spring maintenance list. After the water ponding issues were identified during the NEB flight on 8 May 2018, two labourers were dispatched to the area to start notching the topsoil pile with hand shovels as it was too wet for equipment to gain access. Notching will allow for water movement across the topsoil pile if the water levels rise again. The site will continued to be monitored as part of the spring breakup monitoring program.

• A snow fence was installed through the wetland at KP386 during construction of the aquadam to keep wildlife (muskrats) from ripping the aquadam fabric. Crews were unable to remove the snow fence during machine clean‐up operations (due to frozen ground). Enbridge has removed the snow fence from the wetland to minimize disruption to the wetland.

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: