Compliance Verification Activity Report: CV1718-394 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1718-394
Start date: 2018-02-05
End date: 2018-02-06

Team:

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Enbridge Line 3 Inspection of spreads 3 and 4 to assess right of way condition at close of construction and company preparedness for spring melt. The focus of the inspection will be verify implementation of the Environmental Protection Plan and other relevant commitments. Issues of interest include topsoil storage and erosion and sediment control.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Additional Project-specific requirements or conditions:

OC-063

Observations (no outstanding follow-up required)

Observation 1 - General RoW Observations

Date & time of visit: 2018-02-05 13:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Over the course of two days, NEB Inspection Officers (IOs) assessed sites from KP 418 to KP 499 on Spread 4. During the course of this inspection, NEB Inspectors assessed erosion and sediment control measures implemented in consideration of spring readiness.  A summary of observations of general RoW conditions is provided below: 
 

 

Compliance tool used: No compliance tool used

Observation 2 - Wetland observations

Date & time of visit: 2018-02-05 13:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

NEB IOs inspected the following wetlands which were traversed by the project. Related observations included for each site:
 

Wetland 333
 (KP 469)
  • Observed completed spring preparation of wetland crossing
    • NW access ramp has been removed; break in roach left to facilitate water movement across ditchline
  • Observed hotline ramping over in-service Enbridge lines
    • Used a coloured, more resilient woven geotextile to underlay ramping material over topsoil
    • Should facilitate easier removal of ramping material and decrease geotextile tearing and loss during clean-up
  • Topsoil stockpiles have been tackified to mitigate wind erosion; where topsoil was not stripped it has been treated with hydroseed base to mitigate wind erosion
  • NEB IOs observed ruts located on both sides of the work side of this crossing (Please refer to CNC #1)
Wetland 231A (KP 444)
  • Access ramp has been pulled from the crossing
    • Small amount of geotextile found in ramping material; removed for disposal (see CNC #2)
    • Enbridge personnel noted that they will keep an eye out for additional geotextile material and dispose of as clean-up continues
  • Wetland has been adequately recontoured.
  • Adequate soil separation in work areas adjacent to the wetland
Wetland 300 (KP 455)
  • NEB IOs observed the silt fence bordering the ramp installed through the wetland has been installed backwards. Enbridge personnel indicated this deficiency had been previously identified within their deficiencies list and has been flagged for monitoring for sedimentation up until ramp removal. Enbridge personnel indicated monitoring would continue through spring break up in accordance with the Spring Readiness Plan.
  • Access ramp has been slotted to allow for water flow across the right-of-way
  • Enbridge personnel indicated rare plant community at the east end of the ramp had been matted with access mats prior to ramp installation preserving topsoil and root material in place. Ramping material and access mats have been removed for spring to allow early growing season revegetation.
 

Compliance tool used: No compliance tool used

Observation 3 - Watercourse crossing observations

Date & time of visit: 2018-02-05 14:57

Discipline: Environmental Protection

Categories:

Facility:

Observations:


KP 418 Iskwao Creek Crossing
  • Workspace is tidy and free of debris
  • Observed significant grade cuts on east and west valley slopes; adequate separation between subsoil and topsoil stockpiles
  • Temporary berms have been installed on east and west slopes of the valley
  • Multiple environmental features (heritage resources, rare plants, traditional resources) present in the valley that are well marked with mitigation implemented for protection
  • Deficiencies noted that Enbridge personnel committed to follow-up and address:
    • T-bar found imbedded in one of the berms on the west slope and construction debris (box) found frozen in to abutment on east side of crossing (see CNC#2).
    • Wattles installed on the discharge end of the lowest berm on the west side of the crossing are installed off right-of-way – Enbridge to follow-up to confirm that there is landowner permission.

KP 485 Qu’Appelle Valley (west slope)
  • Observed significant grade cuts through multiple side slopes on the west slope of the valley
    • Area disturbed by construction activity has been minimized as per request from Pasqua FN
    • Enbridge personnel indicated filled areas will require Erosion and Sediment Control (ESC) mitigation to avoid erosion/sedimentation into the draw to the south of the right-of-way, which will be completed prior to spring break-up.
  • Enbridge construction personnel indicated monitoring of this area will occur via the Spring Readiness Program which is a monitoring program to monitor ESC mitigation (silt fencing, berms, etc.) to identify and address deficiencies during and after spring break-up.
  • Adequate separation between grade fill/subsoil stockpiles and topsoil noted
  • Ditch drain installed to prevent the migration of water down ditchline; this will remain as part of final clean-up to mitigate potential slope stability issues.

KP 488+700 Qu'Appelle River Crossing
  • Pipeline was installed using Direct Pipe technology
    • Enbridge personnel noted no issues during construction of the crossing; no evidence of frac outs or bank issues noted
  • The construction bridge has been installed over an existing, old concrete bridge to avoid damage.
  • NEB IOs observed geotextile wrap in place on bridge and adequate silt fencing in place on and around crossing ramps.

KP 489+400 Qu'Appelle Valley (east slope)
  • Observed large grade cuts through minimal work space
    • Salvaged topsoil separated from subsoil by physical barrier (geotextile)
  • Berms and drains installed on the slope to mitigate run-off and water migration down the ditchline
  • East slope of the valley is a controlled clubroot area
    • Wash area located at the base of the slope shows no evidence of erosion or sedimentation

KP 499 Highhill Creek
  • Pipe installation complete and ramp removal / clean-up ongoing at time of inspection
    • Coir wrap reclamation complete on the west bank; topsoil respreads, seeded and coconut matting installed
    • Channel to be re-established at toe of west slope; secondary channel re-established on east side of crossing
    • Additional ESC to be installed as clean-up progresses
  • Additional slope stability work planned for west slope on south side of right-of-way to address potential slope stability issues

Compliance tool used: No compliance tool used

Observation 4 - Corrected Non-Compliance (CNC) #1 - Ruts located in wetland crossing KP 469 - Wetland Crossing - Wetland SK-333

Date & time of visit: 2018-02-05 13:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

NEB IOs observed ruts located on both sides of the work side of this crossing.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company was given until COB Friday 9 February, 2018 to confirm repair has been completed. 

Due date: 2018-02-09

Date closed: 2018-02-09
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 5 - Corrected Non-Compliance (CNC) #2 - Construction Waste KP 418 - Iskwao Creek Crossing - Wetland SK-231-A

Date & time of visit: 2018-02-06 09:30

Discipline: Environmental Protection

Categories:

Facility:

Observations:

NEB IOs observed the following deficiencies:

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company was given until COB Friday 9 February, 2018 to provide evidence that the construction debris identified by IOs had been removed.

Due date: 2018-02-09

Date closed: 2018-02-09
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 6 - Information Request #1 KP 418 - Iskwao Creek Crossing - Wetland SK-231-A

Date & time of visit: 2018-02-06 09:30

Discipline: Environmental Protection

Categories:

Facility:

Observations:

NEB IOs observed:

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Due date: 2018-02-09

Date closed: 2018-02-27
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 7 - Information Request #2 KP 455 - Wetland Crossing - Wetland 300

Date & time of visit: 2018-02-06 12:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

NEB IOs observed:

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Due date: 2018-02-09

Date closed: 2018-02-09
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