Compliance Verification Activity Report: CV2223-038 - Enbridge Pipelines Inc.


Compliance verification activity type: Field Inspection

Activity #: CV2223-038
Start date: 2022-08-23
End date: 2022-08-25


Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):


Related events:

Rationale and scope:

<span style="font-size:11.0pt"><span style="font-family:&quot;Calibri&quot;,sans-serif">Field inspection of decommissioning activities for the Line 3 Decommissioning. Focus on Segment 1 Segmentation/Isolation/Railway Fill scheduled for mid-June to September. Segment 1 is 176.31 km in length from Hardisty Terminal KP 175.445 to Kerrobert Terminal KP 351.291. Specific locations and activities of interest to be provided by Line 3 subcommittee.</span></span>

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - Line 3 Decommissioning (L3D) sites

Date & time of visit: 2022-08-23 08:00

Discipline: Environmental Protection




KP 196+550  Rail fill crossing location.
Phase of construction is Survey. Company representatives indicated that plan for this site involves 4m of pipe to be excavated and exposed.
Rare plant location identified in this area. Company representatives stated that access road to site will be matted and that biologist had determined matting to be acceptable mitigation for rare plants identified on access road. 
Proposed dig location inspected. Site is adjacent to highway and railway line and 10m buffer from rail line staked and in place.
Company Environmental Inspector (EI) I noted Right-of-Way (RoW) Ops and maintenance plan will take over for lifecycle of pipeline remaining plan in place post decommissioning. 
CER IO notes that photomosaic drawings available for each site where interaction with soil occurs, which provide similar level of environmental information to Environmental Alignment Sheets. Rare plant sites in this area identified with polygons in this area on photomosaic drawing.

Traditional Land Use (TLU) site identified in this area. Company EI indicated that company Indigenous Monitors (IMs) are involved in process to ensure mitigation is appropriate for TLU sites.

KP is 32+700
Access road to site is matted with geotextile beneath wooden matting.
Excavation has occurred at site, with soil piles appropriately staked and segregated.
This site involved a valve demolition where pipeline valve was removed from pipeline at this location. Site excavated at time of inspection with plates observed welded to either end of exposed line. Company representative indicated that cathodic protection will be maintained beyond the scope of this project from construction to preserve line integrity. Company representative indicated that one of the potential risks that this practice aims to mitigate is potential transport of water through decommissioned pipeline, which had nevertheless been cleaned prior to decommissioning work.

At this location potentially contaminated soil was identified. The soil was observed wrapped with polyurethane tarp at site. Company representative indicated that additional soil samples were taken and sent to internal remediation group which has engaged additional specialists to conduct further sampling. At time of inspection the samples are still being analyzed and based on these results, a notice of contamination may be filed with the CER. Company representative indicated that if possible contamination will be removed and managed within the scope of L3D project and if not it will be managed longer-term via the company remediation group. CER IO is of the view this issue is being appropriately managed at the time of the inspection.
Housekeeping appropriate no garbage or construction waste observed.
Excavation observed to be appropriately flagged and roped off.
CER inspection team requested, received and reviewed information confirming archaeological and historical resource clearance for a heritage site in this area. Upon review of the documentation no issues were noted.

239+400 L3D / 64+500 L3R 
Multiple TLU sites identified in this area – Company EI indicated that company IMs were involved in the planning stage for mitigation for these sites.
Site access is matted. 
Topsoil being replaced at time of inspection. Company representative indicated that topsoil was imported for this work and that land agent had worked with landowner to coordinate these works. Company representative stated that if topsoil is from a different landowner it must be tested.  CER IO requested, received, and reviewed soil information for this site which revealed topsoil was provided by the landowner, and was nevertheless tested by the company. Testing records for this topsoil reviewed by CER IO. No concerns identified.

Company contractors hand grading topsoil at site, with topsoil screened and in good visible condition at time of inspection.
Company representative indicated landowner requested area be seeded with alfalfa. Company representative indicated that wind erosion will be mitigated with track packing following regrading works.
 CER IO requested, received, and reviewed cleaning record for SK115 skidsteer working at site. No issues noted.

KP73+100/ Site 7002 Rail fill location 

Phase of work is survey and site is staked at time of inspection.
Wetland feature identified in this area and wetland buffer staked at time of inspection.
Company EI indicated that heritage resource requirements altered slightly in Environmental Protection Plan (EPP) change log to accommodate scope of work for decommissioning.

TLU site identified by company at this location. Land use type is agricultural pasture land and cultivated canola.
CER inspection team requested additional information regarding section 5.4.1 EPP - notification of applicable indigenous groups of construction schedule with as much lead time as possible. The request applied to multiple sites visited including TLU 99,100,101,12 and 13.
CER Inspection team received and reviewed company response to this field level information request and did not identify any concerns with the information provided at the time of the inspection.
No issues noted.

L3R 96+450 site 4001 - Environmental segmentation location
Company representative indicated that decommissioning segmentation locations are chosen consciously to consider and mitigate risk of water movement, should decommissioned pipe deteriorate over time.
Biosecurity undertaken on site for all personnel boots with fine-level cleaning provided via application of diluted bleach solution.
Topsoil, seconds and subsoil appropriately staked and segregated.
Site is currently excavated with trench box in place, ladders for egress and fire extinguisher in place with excavation appropriately roped off. Hydro vac holes covered with plywood.
Matting not in place of the site. Company EI indicated that in terms of site access, mat use is determined on a risk-based process. 
Enbridge representatives indicated that mat biosecurity is conducted via a number of means including keeping mats separate from soil with geotextile, rough cleaning mats between sites if required and conducting level three cleaning of mats which are in any contact with soil to maintain biosecurity. Company representatives indicated that no mats have been moved ahead and required this management to date.
Aerial crossing sign in place to indicate to aerial surveillance that this is company approved work.

kP118+125/ Site 4002
Biosecurity completed for all personnel boots.
Company representative indicated that this site is fully matted to allow work on rainy days. Site is directly adjacent to roadway for ease of access. This allows work to progress on weather days where sites with longer access and no mats are avoided until dry to preserve topsoil integrity. 
Soil piles are staked and appropriately segregated.
Excavation roped off with signage in place. Hydro vac holes covered with plywood and identified with rope and flagging.

No issues noted.

KP122+550/ Sites 1206 and 4003
Soil piles appropriately staked and segregated.
Excavation is roped off and signed with Hydro vac holes covered.
Nearest environmental feature is wetland which is 10m beyond workspace boundary. Active workspace is well within the boundary and estimated to be 90 m from wetland.
Site is mattered with geotextile and mats to existing roadway. 
Land uses cultivated agricultural.
Biosecurity signage outside site entrance and biosecurity protocols completed prior to site access.
Aerial signage in place at site.

No issues noted.

KP146+040 / Site 4007
Active excavation underway at time of inspection.
Inspection team reviewed and signed onto FLHA. Biosecurity completed prior to accessing site. During FLHA contractor foreman mentioned importance of monitoring for spills and spill cleanup. Work crew is installing egress and ladders in trench at time of inspection.
Diesel slip tanks with handles appropriately installed in drip catchers observed in crew trucks.

Soil piles appropriately staked and segregated.
Land-use in this area is cultivated agricultural.
Fire extinguishers on site.

No issues noted.

Site 4010
Site is matted for access at time of inspection with rig mats installed over geotextile.
Multiple TLU sites identified by the company at this location.
Wetland identified at site boundary with buffer staked at time of inspection. Wetland at this location is outside of worksite and approximately 50m from proposed to dig location.
EPP mitigations for environmental features are identified on photo mosaic drawing for site.

No issues noted.


Compliance tool used: No compliance tool used

Observation 2 - Line 3 Replacement (L3R) reclamation sites

Date & time of visit: 2022-08-25 08:00

Discipline: Environmental Protection




KP 161+800 / Site 3009 / Mainline block valve MP 208.19 / L3RSSKP161+800
Biosecurity completed.
Company representative indicated valve deactivation to be completed within graveled area of this valve site.
Right of way health assessed in area of valve site for L3R reclamation. Right of way north of valve site is agricultural land and crop health on and off right of way appears equivalent.
Area of low regrowth identified (approximately 5m x 5m) in native prairie area traversed by RoW. CER IO requested, received and reviewed information confirming that this site had been pre-identified for follow up by the company,
which provided confirmation that this area will be seeded again in the fall and that it was previously seeded in 2020. Company representative indicated that this area is on the deficiency list for 2022 and will remain on the list until it is remedied. This whole land tract including this bare area is under specific monitoring by the company. Company representative indicated that drought last year had led to challenges with grass reestablishment in certain locations. CER IO considers this issue as being appropriately managed by the company.
Wetland in area at base of slope observed to be appropriately recontoured and revegetated with no erosion or sedimentation issues observed. Hydrophytic vegetation re-emerging on wetland boundary.

CER Inspection team notes that this area is within broader TLU location.
RoW grade and regrowth in this area otherwise on appropriate reclamation trajectory. 

KP 109+550 Tributary to Cactus lake 
Erosion control berms installed on valley wall approaching watercourse inspected. Berms are in good condition, but minimal vegetation regrowth noted on berms. CER IO notes this isn’t contributing to erosion, sedimentation or spread of weeds. Company representative indicated this location will be reseeded before winter.
Reclamation and regrowth of vegetation on/off RoW near equivalent at valley bottom near watercourse. 
Regrade and recontour appropriate with surrounding area.
Regrowth and RoW health in cultivated wheat field indistinguishable on and off RoW in area adjacent to watercourse feature. No subsidence or crown observed on centreline.
No issues noted.

KP 37+900
Reclaimed right of way area Ribstone Creek.
CER IO observed Canada Thistle individuals in this area, some with evidence of herbicide control. CER IO requested, received, and reviewed L3R spray list and confirmed that his location had been pre-identified for invasive plant management, and is currently in the process of receiving ongoing weed control. Enbridge indicated two rounds of spraying completed on RoW this year. Several dead thistle individuals noted on RoW from spraying. Company representative indicated that second round of spraying had occurred, and that re-evaluation of control next growing season will be done by Enbridge during project phase, as well as by third party consultant during PCMR program. CER IO considers this issue as being appropriately managed by the company.
Erosion control berms in place with appropriate revegetation.

Right of way observed from top
of the hill approximately 1 km from Ribstone Creek Crossing. Right of way vegetation composition and health appears similar on and off right away across multiple land use types including pasture land, cultivated, and riparian areas.

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