Compliance Verification Activity Report: CV2021-414 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2021-414
Start date: 2020-05-01
End date: 2020-05-02

Team:

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Field response (on-demand field inspection) to INC2020-045 - Enbridge Crude Oil Release (150m3) at Hershel Station.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Overall observations - Emergency Management and Safety

Date & time of visit: 2020-05-01 15:00

Discipline: Emergency Management

Categories:

Facility:

Observations:

Enbridge set up an incident command post trailer at the Herschel Station equipped with Wi-Fi, desks, plugs, chairs, washroom and two separate meeting areas. The Incident Command System (ICS) positions filled by Enbridge personnel at the ICP were the Incident Commander, Public Information Officer, Liaison Officer, Indigenous Liaison Officer and the Safety Officer. The ICS positions that were virtually filled by Enbridge personnel were Environmental Unit Leader, Planning Section Chief, Situation Unit Leader, Logistics Section Chief, Finance Section Chief, Staging Area Manager, Documentation Unit Leader, Legal Officer and the Incident Command Advisor.

Control zones were identified and cold, warm and hot zones were delineated with signs. A decontamination trailer was set up in the warm zone for decontamination operations of contractors and Enbridge personnel.
 
The Safety Officer, Enbridge personnel and Contractors working in the hot zone all had gas detection personal monitors taking readings for O2, H2S, CO, and LELs. Enbridge personnel also had a PID (photoionization detector) to measure VOC and benzene levels which were low/normal. VOC readings at east and west boundaries of the Herschel Station were taken as well and readings for vapors were zero. As a result, Enbridge decided not to implement community air monitoring. Safe work permits and ground disturbance permits were prepared for all tasks being undertaken at Herschel Station.
 
Meetings were run efficiently, written agendas were used and roll call was taken. Ongoing status updates and next day assignments were clearly communicated during the briefing meetings.  The main ICS forms were used as needed, such as the ICS 201 (Incident Briefing form), ICS 214 (Individual Log form) and ICS 232 (Resources at Risk). Enbridge also developed a Traffic Control Plan and a Site Safety Plan.
                                                           
External notifications to the CER and Transportation Safety Board (TSB) were completed as per incident reporting requirements under the OPR. The incident was reported through the CER's Online Event Reporting System and discussions were held between Enbridge and the CER On-call Responder (OCR). Updates to the CER OCR were received in a timely manner. The level of emergency was determined to be a Level 1 in accordance with the company's Incident Classification Matrix. 

Compliance tool used: No compliance tool used

Observation 2 - Environment, Day 1 (May 1)

Date & time of visit: 2020-05-01 16:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

  1. PPE: There was appropriate adherence by Enbridge personnel to donning of pandemic specific PPE including latex gloves and N95 masks. Antibacterial wipes and hand sanitizers were available to all personnel. A distance of 6 feet was maintained for the most part.
  2. Residences: Three residences were identified near the Enbridge Herschel Station. One residence was approximately 1.5 km north of the station; another residence was approximately 2.5 km west of the station and another residence approximately 3 km east of the station. Enbridge said its land person contacted all the residences by telephone and no concerns were expressed from them.
  3. Discovery of release: The release was discovered by an Enbridge employee on 30 April 2020 and it occurred on the ¾ inch Swagelok flex hose auxiliary piping for injection of drag reducing agent – the flex hose goes into the pipeline (Line 3) access culvert. No oil was observed within the access culvert on May 1st. The ¾ inch Swagelok flex hose was removed by Enbridge’s investigation team. Enbridge indicated that it does not suspect overpressure was the cause of the release. The investigation will determine the cause.
     
  4. Environment work/sampling: All contaminated soil in the highway ditch was excavated and hauled to Tervita waste facility 14 kilometers north of Kindersley. Remediation for the highway ditch will be done in consultation with the Saskatchewan Department of Highways. An inverted weir was installed on the west side of the culvert in the highway ditch in order to prevent any residual oil from traveling to the west side of the culvert which was not impacted. Stantec was retained to complete the environmental work.
     
    • Inspection officer walked the entire length of the ditch to the west of the culvert and noted no sheen in standing water and no hydrocarbon odor in soil (approximately 130 meters of impacted ditch from the station entrance to the culvert and 235 meters of ditch not impacted west of the culvert). Stantec took a confirmatory water sample as well as a confirmatory soil sample at the inverted weir and 40 meters west of the inverted weir. NOTE: The soil sample indicated that hydrocarbons did not exit the culvert so analysis was not completed on the water sample.
    • Stantec took confirmatory samples in the highway ditch east of the culvert to confirm no residual contamination remains in the excavated area.
    • No impacted wildlife was observed and propane bangers were used to deter wildlife during the night.
    • Stantec took VOC readings at east and west boundaries of the station and readings for vapors were zero. As a result, Enbridge decided not to conduct community air monitoring.
    • Site sensitivity analysis was conducted at nearby wetlands/low lying areas and no impacts were observed.
    • Groundwater samples will be taken at the station on May 2 as well.
       
  5. Historical resources and Indigenous information: Enbridge said it looked at Traditional Land Use information collected during the Line 3 replacement program within a 1 km proximity to incident and found no known sensitive locations. Enbridge also identified that there was no First Nation Reserve within 10km of the Herschel Pump Station. Enbridge notified the Indigenous Advisory Monitoring Committee (IAMC). As a result, The Sweetgrass FN Chief (who is a member of IAMC) and a representative from the Red Pheasant FN and from the Saskatchewan FN Natural Resource Center of Excellence visited the Enbridge Herschel Station and did not express any concerns related to the hydrocarbon release and ongoing cleanup activities. One concern the Chief and Red Pheasant FN representative had was the need for better communication between Enbridge and with Indigenous Nations. They both indicated that the “Indigenous Advisory Monitoring Committee (IAMC) is good but sometimes the work that needs to be accomplished is not within its mandate”.
     
  6. Removal of free product and contaminated soil: Approximately 72 cubic meters of hydrovac material (free product/water/soil) has been recovered and hauled to Tervita (14 km north of Kindersley). Approximately 32 cubic meters was collected from within the station boundary and the majority of the free product from on site has been collected but there remains some free product on site adjacent to the containment berm on the south side.
     
    Approximately 70 yards of impacted soil was removed from the site on May 1st and approximately 80 yards of contaminated soil is stock piled on a liner within the facility. Note: The May 1st disposal records show that 89 m3 of impacted soil and 47m3 of hydrovac material was removed from site.
     
  7. Offsite migration: The sluice gate (manual gate that allows run-off to be discharged off site) was open at the time of the release and was the reason product migrated offsite. Enbridge said it will address why the sluiced gate was open at the time of release in its investigation and incident review.
     
  8. Ongoing clean-up activities: Ongoing clean up (i.e., contamination soil scraping, hauling, environmental sampling etc.) will continue on May 2. Enbridge anticipates that the incident will be in the project phase (i.e., remediation) starting on May 3.

Compliance tool used: No compliance tool used

Observation 3 - Environment, Day 2 (May 2)

Date & time of visit: 2020-05-02 08:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

  1. Ongoing clean-up activities: Clean-up activities continued and included scraping of contaminated soil by layers and hydro-vaccing of congested areas. The station yard is approximately 75 percent cleaned up with hydro-vaccing and manual removal of contaminated soil in congested areas to continue until complete.
     
  2. Air monitoring: Enbridge personnel continued taking VOC readings and they were low/normal. LELs, oxygen, CO and H2S levels were also continually measured and were normal as well.
     
  3. Delineation of soil contamination: Work to delineate extent of soil contamination within the boundary of the station was carried out on May 2nd. Stantec took confirmatory samples in the highway ditch and GPS points were assigned to the samples in order to be plotted. Hot spots were noted and marked for removal.
     
    Delineation of the extent of contamination within the station yard started and GPS points were assigned in order to be plotted. This work will continue until it is completed.
     
    Oil seeped into access culvert beside the area of release (there was no oil in access culvert on May 1). Product and water combination will be vacuumed and contaminated soil removed during remediation activities.
     
  4. Removal of contaminated soil: Removal of all stockpiled contaminated soil (approximately 150 yards total) was completed and hauled away by the end of May 2nd. Approximately 72 cubic meters of hydrovac material was  recovered and hauled to Tervita (14 km north of Kindersley) Note: The May 2nd disposal records show that 180 m3 of impacted soil and 44m3 of hydrovac material was removed from site.
     
  5. Groundwater: Enbridge said that the station yard (and the area in general) has a high water table. The station yard contains a number of deep water wells that pump water into a nearby field to keep the high water table down. Enbridge said the water pumps were turned off shortly after the release was discovered. The Inspection Officer walked the entire length of the hose containing the pumped water and noted no sheen, odor or signs of contamination along the hose and at hose end. Enbridge said the Groundwater sampling locations will be taken from wells nearest to release site using the existing deep water wells in the Station yard. The extent of groundwater sampling is being discussed and will be included and decided on during remediation activities.
     
  6. Hot wash and after incident report: Enbridge said that it would conduct a hot wash meeting to collect feedback on what worked well and areas for improvement. Enbridge also indicated that it would prepare an after incident report.
  7. Transition to project phase and CER Remediation Process Guide: Enbridge has transitioned the incident to the project phase and is expected to follow CER Remediation Process Guide. The Remediation Process Guide provides guidance on how to facilitate successful remediation in the event of a hydrocarbon or other type of contaminant release. The Remediation Process Guide describes the most common approaches by which a company can demonstrate that the contamination associated with CER-regulated infrastructure has been appropriately remediated.

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