Compliance Verification Activity Report: CV2223-165 - Westcoast Energy Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2194
• Inspector In Training T

Regulated company: Westcoast Energy Inc.

Operating company: Enbridge Inc.

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Environmental Protection

Related events:

• CV2223-266

Rationale and scope:

Field inspection of the flood response reclamation work. The November 2021 flood resulted in numerous sites filed for O&M work. This inspection focused on reclamation of work completed over the winter months as well as any work still occurring.

Compliance tool(s) used:

• None

Facility details

Facilities:

• SPECTRA - 30" MAINLINE
• SPECTRA - 36" LOOP

Facility Types

• Pipeline
• Pipeline right of way (ROW)

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Plans And Procedures
• Project-specific Environmental Protection Plan (EPP)
• Enbridge Environmental Protection Plan Gas Transmission and Liquids Pipelines Engineering Projects (Canada) Nov 2020
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2022-06-14 15:00

Discipline: Environmental Protection

Categories:

• Water Bodies - Fish-bearing
• Direct Mortality of Fish
• Sedimentation/Turbidity
• Destruction/Loss of Habitat
• Disturbance
• Reclamation
• Erosion

Facility:

• SPECTRA - 30" MAINLINE (Pipeline)

Observations:

Company representative sent CER IO copies of the following documents for review:

• BCOGC Emergency Interim Approvals (for instream work),
• Map of flood site locations, 
• Coquihalla #9 Indigenous Engagement and Interest Report,
• Enbridge Environmental Protection Plan November 2020,
• Enbridge Environmental Clearances, and
• DFO and MFLNRORD fish salvage permits.

Compliance tool used: No compliance tool used

Observation 2 - Coldwater 1 (INC2021-212/OM2022-061)

Date & time of visit: 2022-06-14 10:22

Discipline: Environmental Protection

Categories:

• Water Bodies - Fish-bearing
• Direct Mortality of Fish
• Sedimentation/Turbidity
• Destruction/Loss of Habitat
• Disturbance
• Reclamation
• Erosion

Facility:

• SPECTRA - 30" MAINLINE (Pipeline)

Observations:

• A river weight on the pipe was exposed during the flood.
• Company representatives stated that a spur was installed 6 years ago by operations which helped to protect the pipe during the floods. A new spur was installed this year, and rip rap was placed along the east bank for Phase 1 to stabilize the area for freshet.
• Temporary large sandbags are currently on top of the pipe for protection.
• Company representatives stated Phase 2 including revetment plans and environmental permitting are currently being developed and obtained. Tentative schedule to be in place in August or September 2022.
• Company representatives indicated the pipe will be excavated and inspected and a water management plan would be developed and implemented during instream works.  A fish salvage is planned to be completed but if not possible methods to scare the fish away from the worksite would be applied.

Compliance tool used: No compliance tool used

Observation 3 - Coldwater 2 (INC2021-179, INC2021-189, INC2021-221/OM2021-014)

Date & time of visit: 2022-06-14 12:30

Discipline: Environmental Protection

Categories:

• Water Bodies - Fish-bearing
• Direct Mortality of Fish
• Sedimentation/Turbidity
• Destruction/Loss of Habitat
• Disturbance
• Reclamation
• Erosion

Facility:

• SPECTRA - 30" MAINLINE (Pipeline)

Observations:

• This floodplain site has 3 exposure areas: #1 a sleeve was explored for exposure #1, but a cut out was completed, #2 was inspected and backfilled and #3 remains exposed and will require a cut out.
• Root wads were left at the bend in the river for fish habitat.   
• River was diverted to the original channel and banks were reestablished, contoured and armoured with riprap.
• Company representatives stated approximately 1500 fish were salvaged with only 5 mortalities documented.
• The area has an extremely high-water table and the Environmental Inspector onsite indicated dewatering was challenging but after trying a few different methods they found filtering the water through the rocks and allowing the water to settle out ended up being the most successful way to keep turbidity levels low.
• Open excavations were fenced off with appropriate signage and fire extinguishers, life preservers and spill kits were available if required.

Compliance tool used: No compliance tool used

Observation 4 - Juliette Creek (INC2021-188, INC2021-176/OM2022-015)

Date & time of visit: 2022-06-14 14:00

Discipline: Environmental Protection

Categories:

• Water Bodies - Fish-bearing
• Direct Mortality of Fish
• Sedimentation/Turbidity
• Destruction/Loss of Habitat
• Disturbance
• Reclamation
• Erosion

Facility:

• SPECTRA - 30" MAINLINE (Pipeline)

Observations:

• Pipe was exposed at the surface from scour during the flood events.  
• To prevent additional erosion and minimize the risk of exposure the creek was widened, the channel was re-contoured and a rock revetment structure was constructed. Rock and gravel fill was placed in the creek channel to build up the creek bottom creating a riffle to slow down the flow of water to prevent future erosion and scouring.
• Ministry of Transportation and Infrastructure (MOTI) narrowed the creek width downstream of the pipeline crossing under the bridge.
• Rip rap was tied into MOTI’s banks and a spur was installed on the north bank.

Compliance tool used: No compliance tool used

Observation 5 - Coquihalla 2 Othello Road and Highway 5 (INC2021-171, INC2021-200, OM2021-478)

Date & time of visit: 2022-06-14 15:40

Discipline: Environmental Protection

Categories:

• Water Bodies - Fish-bearing
• Direct Mortality of Fish
• Sedimentation/Turbidity
• Destruction/Loss of Habitat
• Disturbance
• Reclamation
• Erosion

Facility:

• SPECTRA - 30" MAINLINE (Pipeline)

Observations:

• Company representatives indicated they worked closely with MOTI to coordinate the pipeline replacement and the reconstruction of Highway 5 and Othello Road. Two sections of pipe were replaced at this site totaling 370m of pipe. The trench was backfilled and the river banks were reestablished with a spur upstream to divert the water away from the pipeline.
• Company representatives stated MOTI brought in 3 meters of fill to put the area back to grade at Highway 5. They also indicated dewatering and water quality monitoring was conducted and a fish salvage was completed prior to construction.
• Company representatives stated after they cut out the pipe MOTI completed the backfill and the trench was excavated, and saddle weights were placed on top of the pipe. MOTI has not made their final decision on where exactly the highway will be put back. After the highway is replaced, reclamation will be completed.

Compliance tool used: No compliance tool used

Observation 6 - Coquihalla 9 (INC2021-220, OM2022-052)

Date & time of visit: 2022-06-15 09:39

Discipline: Environmental Protection

Categories:

• Water Bodies - Fish-bearing
• Direct Mortality of Fish
• Sedimentation/Turbidity
• Destruction/Loss of Habitat
• Disturbance
• Reclamation
• Erosion

Facility:

• SPECTRA - 30" MAINLINE (Pipeline)

Observations:

• Work has not been completed at this location at the time of the inspection and company representatives stated the following:
  • Breeding birds have delayed the start of this work. A Qualified Environmental Professional (QEP) has been conducting surveys to confirm the area is clear of active nesting activity prior to clearing. This area is in Northern Spotted Owl critical habitat and requires additional bird surveys prior to construction.
  • An archaeological monitor will be present for all ground disturbing work and an Indigenous monitor will be onsite during construction activities (see Indigenous Community Observations for additional information).
  • Associated project approvals and permitting is complete for work at this site except for instream approvals from BC OGC.
  • Instream work is scheduled to be completed within the least risk window August 1 to August 31.
  • Approximately 8 ft of material was deposited, and the river has shifted so it will require an isolation to complete the 200m pipe replacement.
  • Dewatering will consist of a sump and pump in a vegetated area.
  • Enbridge applied to clear 4 ha of trees but will only require 1 ha for site access and temporary workspace.
  • Unlike many of the other sites in the area, this site is vegetated and will require additional reclamation including planting on the southside which will likely occur next year. Course woody debris will be retained for reclamation and distributed throughout the cleared temporary workspaces.
  • A temporary 100 ft bridge will be installed across the river in order to install the concreate coated pipe.

Compliance tool used: No compliance tool used

Observation 7 - Coquihalla 16 (INC2021-175)

Date & time of visit: 2022-06-15 10:53

Discipline: Environmental Protection

Categories:

• Water Bodies - Fish-bearing
• Direct Mortality of Fish
• Sedimentation/Turbidity
• Destruction/Loss of Habitat
• Disturbance
• Reclamation
• Erosion

Facility:

• SPECTRA - 30" MAINLINE (Pipeline)

Observations:

• During the 2021 flood events two decommissioned sections of pipeline were exposed and require removal. Company representatives stated the following:
  • Instream work is scheduled to be completed within the least risk window August 1 to August 31.
  • A temporary bridge will be installed requiring the river to be forded, but overall, there will be limited activity within the channel.
  • A Qualified Environmental Professional will be onsite for water quality monitoring and fish surveys for spawning fish and redds up and downstream. The river will not be isolated so a fish salvage will not be required.
  • A sump will need to be excavated to dewater during the cutout.
  • After the two sections of pipe are removed the banks will be armored with rip rap using a site-specific engineered drawing.
  • A tentative construction and reclamation plan was discussed with the Department of fisheries and Oceans.
  • No additional workspace is required.
• CER IO discussed with company representatives the lack of navigable water signage and indicated they should be installed. Westcoast agreed and said signs would be put up prior to construction and the bridge installation.

Compliance tool used: No compliance tool used

Observation 8 - Indigenous Community Observations

Date & time of visit: 2022-06-15 08:00

Discipline: Socio-Economic

Categories:

• Lands and landowner concerns
• General
• Effects on Indigenous interests
• General
• Consultation with Indigenous communities
• General

Facility:

• SPECTRA - 30" MAINLINE (Pipeline)

Observations:

• The company opened the meeting with their own land acknowledgement.
• Coldwater Reserve is located on the east side of the Coldwater River 1 crossing. Company representatives stated the reserve was notified of the work and access will be restricted to the west side.
• Company representatives provided the following information:

• The Indigenous relations team provides direct engagement with the Indigenous communities including the Coldwater Indian Band, Lower Nicola Indian Band and Nooaitch Indian Band. Communications were completed prior to construction. Most nations were interested but due to limited positions available nations agreed to have selected nations involved to represent them.
• Indigenous Groups Engagement Log as of June 22, 2022 for Coquihalla 9 was reviewed and the amount of communication between the company and nations appear to be satisfactory.

• The updated consultation letter with the scope of work and mapping was sent to 22 Indigenous groups with interests registered in the BC Consultative Area Database on January 10, 2022. To date no outstanding concerns have been identified.
• Indicated Indigenous Monitors (IMs) are organized through a consulting company and are on rotating shifts during construction as required. IMs were not present at the time of inspection, but they would be present on crown land locations during construction.
• Coquihalla 9 will require IMs to be present during construction. Shovel testing at this location was completed but no archaeological finds or protected cultural features were identified. Heritage Conservation Act (HCA) Heritage Inspection Permit (2021-0465) and Sto:lo Heritage Inspection Permit (2022-015) have been obtained. A tree at this location was originally thought to be a CMT but was later confirmed to have obtained markings from the flood event. Nations are being asked to do an assessment for the reclamation plans and to have input on what to plant in the 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: