Compliance verification activity type: Field Inspection
Team:
Regulated company: Enbridge Pipelines Inc.
Operating company: Enbridge Pipelines Inc.
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Environmental inspection of Enbridge Line 3 Replacement Project construction on spreads 3 and 4 in Saskatchewan. Focus of inspection included soils handling, watercourse crossings, biosecurity, hazardous waste and hazardous product storage.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - General Observations
Date & time of visit: 2017-09-27 12:35
Discipline: Environmental Protection
Categories:
Facility:
Observations:
Over the course of four days, NEB Inspectors assessed sites from KP 289 to KP 414 on Spread 3, and from KP 438 to KP 481 on Spread 4. NEB Inspectors also inspected the construction yard in Outlook, SK. During the course of this inspection, NEB Inspectors observed activities including hydrovacing, grading, ditching, stringing, lowering-in, and backfilling. A summary of observations is provided below: HDD Sites:NEB Inspectors visited the HDD sites of in-progress work at Canal WM1 and the setup for the HDD at the South Saskatchewan River, and observed the following:
Compliance tool used: No compliance tool used
Observation 2 - Information Request (IR) #1 - Hazardous materials storage in yard
Date & time of visit: 2017-09-28 09:30
NEB Inspectors observed general waste segregation and handling practices in the yard to be appropriate upon spot checks of waste containers. NEB Inspectors observed bins for recycling, contaminated soil, general garbage and empty aerosol cans. The contents of the bins matched their labels, and there was no apparent mixing of the different waste streams. NEB inspectors also observed following areas of concern outside of secondary containment and weather protection adjacent to the maintenance building:
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
NEB Inspectors require additional information to verify compliance. Enbridge will provide NEB Inspectors with a response indicating the provincial requirements for hazardous waste and hazardous materials storage in Saskatchewan and its assessment of how its current practices comply with these requirements.Enbridge will provide a response indicating the location of waste battery storage at the Outlook construction yard and rationale for their observed location during the inspection.
Due date: 2017-09-28
Date closed: 2017-09-28 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 3 - Information Request (IR) #2 - Contaminated Site REM-096 traversed by project
Date & time of visit: 2017-09-27 08:50
NEB Inspectors visited location KP288+157 where a known contaminated site (NEB file REM-096) is traversed by project construction. NEB Inspectors reviewed and signed onto the FLHA for the site. During the time of the inspection, contaminated material was being excavated and loaded into a truck for disposal offsite (no on-site storage).
NEB Inspectors observed and met with a representative of a consulting firm who was supervising the dig. The representative indicated his role was to ensure that all contaminated material in the construction RoW was removed. This individual was the only personnel equipped with a gas monitor at the site.NEB Inspectors observed a truck driver with no PPE being told to remain in his vehicle.NEB Inspectors note that site representatives were unable to demonstrate a clear understanding of the potential hazards of the contaminant being excavated and why the precautions observed were selected, or other precautions (such as having assigned gas monitors) were not being followed.
Compliance tool used: Information Request (IR)
NEB Inspectors require additional information to verify compliance. Enbridge will provide NEB Inspectors with the following:
Due date: 2017-11-23
Date closed: 2017-12-04 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.
Observation 4 - Corrected Non-Compliance (CNC) #1 - Dewatering location inappropriate
Date & time of visit: 2017-09-27 10:30
NEB Inspectors observed that the trench was being dewatered in preparation for lowering-in on spread 3, KP310+700. The trench water was being discharged through a filter bag onto the RoW at the time of the inspection. NEB Inspectors noted that the released water was flowing between the topsoil and subsoil/seconds piles, and was eroding the bases of both piles.
Enbridge will choose an appropriate dewatering location and move the filter bag to this location.
Due date: 2017-09-27
Date closed: 2017-09-27 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.
Observation 5 - Corrected Non-Compliance (CNC) #2 - Hazardous materials storage in yard
NEB Inspectors observed 5 vehicle batteries on a wooden pallet on the loading dock in front of the mechanics quonset. NEB Inspectors issued IR #1 to gather additional information on Enbridge compliance with provincial requirements and conformance with its own waste management procedures.Response to IR #1 indicated the battery storage observed during the inspection did not meet the requirements of the Enbridge Waste Management Plan.
Enbridge will store the waste batteries such that they meet the requirements of its Waste Management Plan.
Observation 6 - Notice of Non-Compliance (NNC) #1 - Fuel leaks and spills at Spread 3 construction yard
Date & time of visit: 2017-09-28 08:30
NEB inspectors observed the following at the aboveground fuel storage tanks at the Spread 3 construction yard:
Compliance tool used: Notice of Non-compliance (NNC)
Enbridge will:
Due date: 2017-11-16
Date closed: 2017-12-13 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.
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