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:
Compliance oversight for INC2022-026. The incident was the release of oil sprayed upward and blown southward. The incident resulted in mist impacting approximately 84,293 square meters, with 7,105 square meters within the facility and 77,188 square meters off site. Off-site, the oil mist impacted the Gretna Cemetery, an agricultural field, Pieper Avenue and ditches, and a small portion of Manitoba Hydro site. Follow up meetings to discuss the site and remediation were held with the company on 15 Feb 2022, 23 Mar 2022, 30 Mar 2022, and 5 May 2022.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Documentation requested during Field Inspection
Date & time of visit: 2022-02-11 11:00
Discipline: Environmental Protection
Categories:
Facility:
Observations:
The following documents (attached) were requested as part of the Field Inspection:
The documents were provided as requested and were reviewed. Follow-up IRs were issued as indicated above.
Compliance tool used: No compliance tool used
Observation 2 - General onsite observations
Date & time of visit: 2022-02-10 17:35
The CER was notified of this release (INC2022-026) 9 Feb 2022. The incident resulted in the release of an estimated 2m3 of oil that was sprayed/misted on and south/southeast of the Gretna Terminal, given the characteristics of the release and high winds. The oil sprayed/misted an area on the south side of the terminal and areas south/southeast of the Terminal which include Pieper Avenue, the Gretna Cemetery, an agricultural field, and a small portion of Manitoba Hydro infrastructure. CER Inspection Officer and two IAMC Indigenous Monitors deployed to release site, arriving near dusk 10 Feb 2022.
On 10 Feb 2022, the Inspection Team conducted a brief site orientation and check-in and an expedited opening meeting prior to observing work which was occurring at the Gretna Cemetery. Observed that although a relatively small estimated total release volume, a large area was impacted. Requested and received mapping showing the visibly impacted area. CER staff understand this entire area will be cleaned via snow removal
At the time of the inspection start, cleanup work was focused on the cemetery, to be followed by the agricultural area. Cleanup completion was estimated by Enbridge as follows:
1) On Terminal site – Cleanup ~ 60% complete
2) Pieper Avenue roadway and ditches south of the Terminal – Cleanup~ 60% complete.
3) Cemetery immediately south of Terminal - ~20% complete. This was the main area of concern and work at the time of inspection. Impacted snow removal in this area is primarily being done by hand shoveling.
4) Agricultural area to the southeast of Terminal 0 % complete. Enbridge noted cleanup in this area would be conducted by machine.
Enbridge reps indicated that it had observed only the upper layer of snow (the wind crust layer) was affected by the release. In some cases the depth might be up to 6” but that impacts hadn’t permeated the depth of snow down to the soil (based visual observations). This was consistent with observations made by the IO during the field inspection.
Work observed at the time of inspection included removing snow from the cemetery area using hand shovels, moving the removed snow by sleds/toboggans or a small loader, stockpiling the impacted snow, and transporting the snow to an offsite disposal location (Miller Environmental Services). Transport of snow occurred on 10 Feb 2022, but did not occur 11 Feb 2022 due to poor road conditions in the area.
IO shared feedback to Enbridge regarding the importance of body positioning for workers, i.e. for workers not standing down wind of shoveling to minimize exposure to blowing snow. Enbridge noted they had adjusted work plans due to wind speed and direction that day.
Discussed decontamination of PPE and tools, noting that for this particular release there is no defined decontamination area/process. Enbridge rep confirmed that in the Pre-Job meeting, the topic of leaving contaminated snow on site, and brushing off PPE, boots etc. was communicated. Given the conditions (generally lightly contaminated, dry snow) the IO agrees this is appropriate in this case.
Observed the initial site of release on Line 2. Sprayed oil was visible on snow and on downwind infrastructure. Enbridge reps confirmed that the investigation into the release is ongoing. CER will oversee the incident investigation per its Incident Review process.
Product released was a high temp gear oil – SDS provided as requested.
Enbridge Rep confirmed no evidence of vapour concerns based on monitoring that is being done (hourly monitoring is being conducted and personal monitors are worn by workers). No hits have occurred. The product released has low volatility as confirmed by SDS.
Discussed potential and likelihood of unauthorized or unintended public access. At this time, site security consists of road blocks on the public road (set up by the MD monitored by Enbridge staff). Road blocks were to be removed once the snow removal work at the cemetery and agricultural field is complete. Following onsite discussions, Enbridge sourced and installed signage indicating contaminated site as mitigation to deter unauthorized or inadvertent public access. Given the location, and current winter (blizzard) conditions, the risk of public access to the site is low.
Discussed the plans to clean the headstones and monuments at the Cemetery. Enbridge Reps confirmed that the plan had been circulated to the MD for review. At the time of inspection, a test of the method(s) to clean the monuments was planned for the next days.
Met virtually with the Incident's Environment Unit Lead to discuss environmental work and planning. Discussed that soil sampling was planned to occur following impacted snow removal (soil sampling plan requested). Results of soil sampling will inform the need for groundwater monitoring. Enbridge Rep confirmed that a stormwater management plan is being developed. Discussed plans for tree cleaning, which is expected to be difficult. Currently Enbridge is considering a low pressure wash with containment (e.g. absorbent materials). A plan is being developed for tree cleaning (Tree Cleaning plan requested, see IR 2 Wildlife Deterrence and Tree Cleaning). Discussed wildlife on and near the site. Enbridge rep noted that preliminary findings were that no sensitive species were identified, and that a plan was being developed, which would also include non-sensitive species (requested a copy of the wildlife plan, see IR 2 Wildlife Deterrence and Tree Cleaning).
Observation 3 - Engagement
Date & time of visit: 2022-02-11 13:00
Discipline: Socio-Economic
Over the course of the inspection, the Inspection Team and Enbridge discussed engagement, particularly with the MD of Rhineland, who is the cemetery owner. The MD's Public Works department conducts the maintenance at the cemetery. CER staff understood that Enbridge had engaged with the MD on various occasions regarding the release and cleanup, and that notification of the release was shared via public source media.
Onsite discussions centered on the potential need for engagement with the larger community or cemetery users. Based on onsite discussions, and feedback from the Inspection Team, Enbridge held additional discussion with the MD focused on identifying any additional engagement that might be required, notably with cemetery users or the community. A follow-up virtual meeting was held with Enbridge Reps, the IO and CER Technical Leader, Engagement on 14 Feb 2022 to discuss the results of the conversations with the MD that occurred following the field inspection. Enbridge reps confirmed that the MD does not require additional engagement and that the level of engagement has been satisfactory thus far, and additional public notice is not required at this time. Enbridge confirmed that the engagement strategy is flexible, and if additional engagement is needed, Enbridge is prepared to do so. Based on the conversations held in the field and in follow-up meeting, the IO found that the level of engagement regarding this release and the cleanup is currently adequate, noting that this may change, and additional public engagement may become required, depending on public interest, concerns or feedback from the Cemetery owner the MD of Rhineland. IO requested and Enbridge provided a summary of the additional conversations held with the MD of Rhineland.
Observation 4 - IR 1) Site Specific Work Plan - Soil Sampling Gretna Line 2 Release, dated 12 Feb 2022
Preamble
As part of the inspection of the site, Enbridge provided the soil sampling plan as requested by the IO.
The plan includes the following: 10 m x 10 m grid sampling of the on-site area. Figure 1 shows an approximately 125 m x 25-50 m area impacted on site, suggesting approximately 20-50 samples are planned for the on-site area. For the cemetery, two samples are planned for the treed area on the north side, and two samples are planned for the cemetery, four samples total. An estimated number of samples for the agricultural area is not provided. In general, for off-site areas, the IO understands that soil samples will be obtained from areas “considered to represent high levels of impact where hydrocarbon penetrated through snow cover during cleanup activities.”
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
Request
Due date: 2022-02-23
Date closed: 2022-02-25 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 5 - IR 2) Wildlife Deterrence and Tree Cleaning
The CER IO has reviewed the plans provided as part of the field inspection to the Gretna release (INC2022-026). Gaps have been identified in the plans, and the IO highlights the following:
Site-Specific Work Plan Wildlife Deterrence – Gretna Line 2 Release
The wildlife deterrent plan states “The wildlife deterrents described in this plan will be maintained until the snow with visible impacts observed on the surface has been removed.” The IO notes that although snow with visible impacts has been removed, impacts remain on the trees and branches. These areas are accessible to wildlife, notably birds (e.g. upcoming nesting or migrating birds, wintering birds), and other resident species (e.g., squirrels), and ungulates who browse trees and shrubs. It is the IOs view that until the oil is cleaned from the trees, the potential hazard to wildlife of exposure to oil remains.
To protect both birds and ungulates, the plan indicates the following mitigation “Work lights will be used during night time work to deter wildlife from the work area. Work lights will be placed surrounding the Gretna Cemetery”.
The IO notes that work was not and presumably is not currently at night at the site (work was ending at dusk at the time of inspection and snow removal is understood to be complete). This suggests this mitigation measure is not currently being applied. Given impacted snow cleanup is complete, and work is not occurring at night, the IO interprets that no wildlife deterrents are currently in place for the trees and cemetery. The IO notes that tree cleaning is not yet complete, which presents a potential hazard for wildlife which may be accessing the trees (undeterred).
Site-Specific Work Plan Impact Prevention Plan – Gretna Line 2 Release (i.e. Tree cleaning plan)
The IO notes that based on the nature of the release, it is expected that, with variability, oil would have impacted the entire height of the trees. Cleaning the lowest two meters of the trees is not expected to result in complete removal of the oil in the trees, leaving the potential for continued exposure to and spreading of oil from the cemetery trees.
As indicated above, there is potential for harm to environmental receptors including wildlife (e.g. birds, ungulates, squirrels), soil, surface water and groundwater due to the release and remaining impacts at the cemetery due to a) lack of wildlife deterrents and b) contamination remaining in the trees. The CER IO is of the view that the plans provided do not adequately protect these environmental receptors such that there is potential hazard that has not been mitigated via the current plans. Updates to plans are required.
Submit updated plans or a response to address the potential hazards identified above.
Due date: 2022-03-14
Date closed: 2022-03-31 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 6 - Virtual Meeting held 23 Mar 2022 to Discuss spill mitigation: impacts remaining on trees and associated potential impacts to wildlife and insects.
Date & time of visit: 2022-03-23 15:00
The CER IO reviewed the response to IR 2) Wildlife Deterrence and Tree Cleaning. Following review of the updated plans, the IO had concerns regarding potential impacts to environmental receptors (notably wildlife, insects) given that oil remains on the trees at a height above 2 m, and had questions regarding whether the current tree cleaning plan was/is adequate. IMs had also raised questions and concerns regarding the tree cleaning. A meeting with the company was requested and was held on 23 Mar 2022 to discuss the concerns, the status of the site, and plans for ongoing assessment contributing to the understanding of risks to environmental receptors. See attached Meeting Agenda (which documents the IO's concerns) and Meeting Minutes.
Observation 7 - Virtual meeting held 30 Mar 2022 to review Enbridge Transferability Assessment Plan
Date & time of visit: 2022-03-30 13:30
Enbridge reps presented their plan for assessing the transferability of oil remaining on the trees at the cemetery site. Reps confirmed that transferability was being assessed by their environmental consultants at the cemetery site as of 30 Mar 2022. Any questions raised by CER staff were addressed, and minor updates to the plan were to be made in response (clarify number of samples planned, clarify photographs will include the swabbing material, clarify shrubs will be included in the assessments). CER Officers confirmed they had no concerns with the planned approach, and per IR 3) an update will be provided following the field portion of the assessment, with the final documented results of the transferability assessment due 13 Apr 2022. See Meeting Minutes attached.
Observation 8 - Virtual meeting held 5 May 2022 to discuss current site conditions and review response to IR 3.
Date & time of visit: 2022-05-05 13:00
Enbridge Representatives and CER IOs met to discuss the current status of the site, and to review the results of the Ecological Risk Assessment prepared in response to IR 3) on 5 May 2022. Overall, Enbridge has investigated and demonstrated that the risk associated with the released oil have been mitigated where possible and that the oil remaining on the trees is relatively low. This was determined and demonstrated via sampling soil, sampling captured/ponded water from the tarps under the impacted trees at the cemetery, sampling precipitation runoff (drippings) from impacted trees at the cemetery, sampling surface water/runoff contained/held in the drainage ditches along Pieper Avenue, and through an Ecological Risk Evaluation focused on the oil remaining on trees within the cemetery. See attached Meeting Agenda, Meeting Minutes, and Power Point presentation prepared by Enbridge. Continued oversight of this site will occur via the CER's remediation process (REM2022-011), as well as via the CER's Incident Review process, (INC2022-026).
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
