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:
Inspection of Line 3 construction of spreads 3 and 4. This inspection should focus on environmental mitigation measures for all activities including topsoil handling and pathogen mitigation during clean up.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - Macdonald Creek KP 297.5
Date & time of visit: 2017-10-17 10:25
Discipline: Environmental Protection
Categories:
Facility:
Observations:
At the time of the inspection, the McDonald Creek watercourse was isolated and the pipe installed. Company representatives indicated that coating and welding work were remaining steps prior to backfilling the adjacent trenches. A trench box was in use where crews were active. A discussion was had on site with company representatives regarding environmental protection measures used for the crossing, including turbidity monitoring and fish salvage. Dewatering filter bags were observed in an adjacent agricultural field. At the time of the inspection, the dewatering appeared in compliance with Section 9 of the EPP, point 83 (EPP Part 1 of 2, page 60 of 203).A protected area for rare plants was observed at this site, with signage and fencing as mitigation. The area was appropriately 20 m x 20 m (using visual approximation). Heritage resource signage was also in place at the site.
Compliance tool used: No compliance tool used
Observation 2 - WM1 Canal Horizontal Directional Drill (HDD)
Date & time of visit: 2017-10-17 12:06
The NEB Inspection Officer observed the site of the previously completed WM1 Canal HDD. Rig matting and sediment fencing were each in use in the area. Company representatives and the Inspection Officer discussed future plans to cross the wetland in this area. A road access was recently constructed. A piece of tracked equipment was spot checked for biosecurity records at the site. No compliance issues were identified at the WM1 Canal site.
Observation 3 - South Saskatchewan River HDD - KP 335
Date & time of visit: 2017-10-17 13:16
The NEB Inspection Officer and accompanying company representatives were signed onto the tailgate safety document upon arrive to site, following a brief discussion of anticipated hazards to be aware of. The NEB Inspection Officer requested to view the Material Safety Data Sheets (MSDS) for all products at the site, and no issues were noted. At the time of the inspection, the HDD was approximately 980 m into the pilot hole, with a total distance of 1375 m anticipated remaining. Circulation was good to date, according to company representatives. Adequate use of secondary containment and spills kits were observed on the site. The NEB Inspection Officer discussed the ongoing turbidity monitoring with staff of an environmental consulting company responsible for the monitoring. No compliance issues were identified at the site.
Observation 4 - Backfill Crew - KP 348
Date & time of visit: 2017-10-17 15:02
The backfill crew was observed working in this area of KP 348. Two pieces of the equipment working were spot checked with respect to biosecurity. Signage in this area identified a riparian buffer setback area, a wetland and a wildlife feature in this area of the right-of-way (RoW). The NEB Inspection Officer observed an area of narrowed RoW to avoid a wetland. A discussion was had on site regarding erosion and sediment control at this location.
Observation 5 - Backfill Crew - KP 348 Corrected Non-Compliance #1 (CNC #1) - Equipment Use Without Spotter
Date & time of visit: 2017-10-17 15:03
Discipline: Safety Management
The NEB Inspection Officer observed that a piece of equipment that part of the backfill crew was working in a restricted space without a spotter in place, which is non-compliant with Enbridge's LP/MP Safety Manual. This is considered Corrected Non-Compliance #1 (CNC #1).
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Company representatives immediately corrected the issue in the field. The machine proceeded with the work only once the spotter was in place. At the inspectors meeting the following morning, company representatives reminded attendees about the importance of the use of spotters.
Due date: 2017-10-17
Date closed: 2017-10-17 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 - Three Lift Soils Area - KP 371.5
Date & time of visit: 2017-10-18 09:55
Soils were stripped using a three-lift technique in this area, which appears to correspond with the environmental alignment sheets. Stockpiles were clearly marked using labeled stakes, with adequate separation observed between each pile. A windrow break for wildlife was observed in this area (which appeared compliant with the EPP part 1 of 2 - Section 6, point 29 on page 27 of 203).
Observation 7 - Coating Crew
Date & time of visit: 2017-10-18 10:14
Upon arriving at the site, the NEB Inspection Officer and company representatives met with the site foreman and were signed on to the safety tailgate document. The coating crew was observed working in this area. A moveable shack with poly sheeting was used to prevent potential drips of the coating material from reaching the ground. The NEB Inspection Officer viewed the MSDS's for this site, as well as the Environmental Hazard Assessment document that had been completed by the crews. A piece of tracked equipment was spot checked for biosecurity records at this location.
Observation 8 - KP 391 - Area of Narrowed Right of Way
Date & time of visit: 2017-10-18 11:50
In this area, it was observed that the RoW was narrowed in order to avoid a mature stand of deciduous trees. Nearby, a crew was working to apply tackifier to the edge of the RoW as an erosion and sediment control prevention measure.
Observation 9 - Wildlife Feature 46 (WF-46) - KP 398 +600
Date & time of visit: 2017-10-18 12:36
The area of RoW of Wildlife Feature 46 (WF-46) was observed, and the mitigations implemented during clearing discussed on site with company representatives.
Observation 10 - Qu'Apple River - KP 488.51
Date & time of visit: 2017-10-18 14:50
Soil was stripped at this entry pad site, with good soil storage practices observed. Signage was displayed at the site demarking environmental features including a wetland, heritage resources and wildlife features. Erosion and sediment control measures were observed on site. At the time of the inspection, preparations were underway to for the trenchless crossing. Company representatives indicated that this crossing will be completed using micro-tunneling technology. Equipment for that purpose was not yet mobilized to site. At the time of the inspection, crews were preparing to install a large metal clear span bridge over the river. The existing bridge at this location was observed to be dated. The Inspection Officer returned to this location a second time on October 19, 2017. The new metal bridge was observed to have been installed across the river at this time. Company representatives indicated that next steps in the completion of the bridge work includes construction of ramps to access the bridge. No compliance issues were identified at this location on either inspection date that this site was visited.
Observation 11 - Topsoil Crew - KP 521
Date & time of visit: 2017-10-19 08:54
At KP 521, active topsoil crews were observed on Spread 4. Two powerdozer machines, as well as tracked equipment were observed conducting stripped activities. All work observed was within the limits of the RoW, which was identified using stakes. Temporary Work Space (TWS) was also flagged with stakes, and was undisturbed in all areas observed at this site. Signage identifying a wetland area and prohibiting fueling within 100 m was observed. At the time of the inspection, the wetland appeared to be dry. A spot check for biosecurity was conducted on one of the two powerdozer machines working in the area. No non-compliances were identified at with respect to the topsoil crew.
Observation 12 - Fine Cleaning Station 1
Date & time of visit: 2017-10-19 10:12
A fine cleaning station was located the divide between two Saskatchewan Rural Municipalities (RMs), which is consistent with the EPP (Part 2 of 2, point 11 on page 54 of 155). The cleaning station included three wash bays. Air compressors were in place at each station for the purpose of an initial clean. Each air compressor was observed to have a fire extinguisher, secondary containment and hose whips. A discussion was had on site regarding the procedure for the removal of the wash effluent once the collection bays were full. Company representatives indicated the wash effluent is removed using a hydrovaccum truck on an as-needed basis. The Inspection Officer discussed the fine cleaning station as well as project biosecurity in general with the company’s Biosecurity Specialist at this location. A spot check for biosecurity records was completed at this location on a pickup truck. Soil separation and storage were observed to be sufficient at this location during the inspection.
Observation 13 - Fine Cleaning Station 2
Date & time of visit: 2017-10-19 11:19
Biosecurity measures were observed by the Inspection Officer at a second location, including a secure/locked fence, signage and fine cleaning station. The cleaning station was designed such that in order to access the work area, the fence would require unlocking and entry into the cleaning station would be mandatory. Company representative indicated that the Biosecurity Specialist maintains possession of the keys to the locked gate. At the time of the inspection, this location was observed to be in compliance with the EPP (part 2 - point 12 of page 54 of 155).
Observation 14 - Other - Inspectors Meetings, Indigenous Construction Liaison, Documentation, Bending Crew Shut Down
Date & time of visit: 2017-10-19 11:20
Inspection MeetingsOn Wednesday October 18 and Thursday October 19, the Inspection Officer attended the 6:15 AM inspector's meeting at the yard in Outlook and Moose Jaw respectively. Each meeting included a safety moment, as well as general discussions about the progress of the project and work locations.Indigenous Construction Liaison Following the Wednesday morning inspectors meeting, the Inspection Officer met with Indigenous Construction Liaison for Spread 3 at the Outlook yard to discuss his role, the project to date and the day to day activities of Indigenous monitors on the project. Documentation ReviewBeginning at 8:36 AM on October 17, 2017, the NEB Inspection Officer reviewed the environmental permits for Spread 3 at the Outlook yard. All reviewed permits appeared to be up-to-date. No issues were identified with the environmental permits at the time of the inspection. Bending Crew – Shut DownOn October 18, 2017, the NEB Inspection Officer planned to visit the site that bending crew was working. Prior to reaching the site, the NEB Inspection Officer was informed the bending crew had been shut down due to high winds.
Observation 15 - General Observations
Date & time of visit: 2017-10-19 11:23
SchedulingStaff referenced the Environmental Alignment sheets for Spreads 3 and Spreads 4, as well as Table 5 SK (for the same spreads) with respect to scheduling, for example Restricted Access Periods. No issues were identified with the company’s actions during the inspection, with respect to scheduling.WorkspaceTemporary workspace (TWS) was observed to be cleared demarked during the inspection. At all locations observed, the company was working with the limits of the TWS. In the area of the WM1 Canal, the TWS was marked but undisturbed. Company representatives indicated that the TWS was applied for, but not needed to date, and therefore undisturbed. SignageThroughout the inspection, signage was observed to be adequate (as per the EPP part 1 of 2 - Section 6, point 11 on page 25 of 203). This included signage demarking rate plants, wildlife features, watercourse crossings (no refueling signage), and historical resource areas.BiosecurityPrior to travel the RoW on the first morning of the inspection, the vehicles (trucks) participating in the inspection were cleaned in Outlook, SK. Disinfectant spray was used on the tires of each vehicle, and the cleaning was logged using a smart phone application. Throughout the inspection, compliance to the Enbridge’s Biosecurity Management Plan (Appendix G of the EPP) was evaluated. This included spot checking the records of cleaning of pieces of various pieces of equipment of the RoW. The smartphone application allows the creation and reference of cleaning records, referenced by vehicle number. The records included photographs of the equipment being cleaned. All requested biosecurity records requested in the field were promptly accessed, with no issues identified. PDF copies of each of the records were requested by and provided to the Inspection Officer. In addition to spot checking records, the inspection included the locations of two fine cleaning stations on the RoW. No non-compliances were identified related to biosecurity.GapsGaps in strung pipe and soil windrows (“wildlife breaks”) were observed during the inspection. It appeared that gaps were located in appropriate areas and with sufficient frequency.
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
