Compliance verification activity type: Field Inspection
Team:
Regulated company: Enbridge Pipelines Inc.
Operating company: Enbridge Pipelines Inc. (Enbridge)
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Spread 5 - Line 3 Construction Inspection (Enbridge Line 3 Replacement Program). This field inspection focused on verification of Enbridge's implementation of environmental mitigation measures, protection of heritage and traditional land use sites, as well as occupational health and safety of observed activities.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - CNC#1 ~SSKP 624+100 Lack of Sanitary Facilities
Date & time of visit: 2018-10-24 09:37
Discipline: Safety Management
Categories:
Facility:
Observations:
Workers / employees / contractors / subcontractor / visitors in this area where construction activities were occurring did not have access to toilets.Portable toilets were present, but the units were on their sides, and not available for use. The nearest portable toilets were up the hill, approximately 2 km away.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
As soon as reasonably practicable, Enbridge will ensure that in this area of Construction Activities where workers / employees / contractors / subcontractor / visitors are in the workplace have access to toilets in accordance with applicable requirements.
Due date: 2018-10-25
Date closed: 2018-10-25 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 2 - Rare plants and protected areas
Date & time of visit: 2018-10-24 14:20
Discipline: Environmental Protection
The Inspection Team visited several sites indicated as having rare plants or native prairie landscape. During the course of the inspection, the signs, flagging, fencing, and avoidance of rare plants was noted. Locations with rare plants were noted to have photographs posted to show workers the plant to be avoided. In native prairie areas (Kronau Creek, Manybone Creek, Chapleau Lake area) the Inspection Team noted that signs indicating the presence of native prairie areas were in place, and salvaged soils were labelled and segregated. At locations where rare plants had been identified, the Inspection Team noted that the mitigation measures listed in the EPP were being applied – alternative travel surfaces, fenced off and flagged areas. Signs showing photographs of the rare plant for identification were also present. In the Chapleau Lake area, the Inspection Team noted that the ramp to protect a rare plant was in use, but that at one spot the wing-wall had fallen. Upon it being brought to the attention of Enbridge representatives, someone was dispatched to fix it within an hour. As no subsoil had been moved onto topsoil or vegetated areas, the fallen wing-wall was not considered a non-compliance.
Compliance tool used: No compliance tool used
Observation 3 - Construction and Storage Yards
Date & time of visit: 2018-10-25 12:50
The Inspection Team visited the Construction Yard in White City and observed the following:
Observation 4 - NNC#1 ~KP 600 +660 Unsafe Act - 14:46 Thursday 25 October
Date & time of visit: 2018-10-25 14:46
NEB Officer observed an unsafe act adjacent to a tie-in crew. Side-booms were holding sections of pipe inside the excavated trench while it was being welded (tie-in weld). Cribbing was in place either side of the ongoing weld. On the downstream (eastern side) from the easternmost side-boom (tractor), a worker was seen walking on the pipe within the trench over a distance of several meters. The worker took a reading and/or measurement of the pipe. NEB Officer and Enbridge Representative walked around the side booms and lowering crew to reach the area the worker had been observed, but the worker had already exited the trench, and left the site before the NEB Officer reached him. NEB Officer notes that the photo taken shows another worker was near the top of the ditch in the area the worker was walking the pipe and that there were a dozen or so workers in the area that could have seen this unsafe act occurring, and that to the knowledge of the NEB Officer, no one stopped this unsafe act.Further to reviews of documentation completed on 26 October 2018, the applicable hazard assessment and controls for risks associated with the activity of "Tie-In As-Builting" and identified hazards such as, pipe, unsafe ditch, and entering a ditch, were not adhered to. The applicable hazard assessment for the task of "Tie-In As-Builting" identified controls for risk such as: “never walk on pipe” and “never enter unsafe ditch”. This worker was observed showing unsafe practices/behaviors of walking the pipe in an unsafe ditch.In a Safety Stand-Down Meeting held at 7:00 in the Survey trailer at the White City yard on Friday 26 October 2018, it was identified that the worker involved in the unsafe act had tools normally utilized to conduct as-built surveys safely, but the tools were in disrepair when the event occurred.
Compliance tool used: Notice of Non-compliance (NNC)
Due date: 2018-11-02
Date closed: 2018-11-19 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 5 - CNC#2- Light Plant
Date & time of visit: 2018-10-26 08:02
Light Plant located in the southwestern corner of the White City Yard is not grounded.
Banister personnel to ensure appropriate grounding of equipment.
Due date: 2018-10-26
Date closed: 2018-10-26 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 - CNC#3 Compressed Gas Cylinders
Date & time of visit: 2018-10-26 08:08
Located in the northern corner if the White City Yard, Compressed Gas Cylinders observed to be stored without being secured.
Ensure cylinders are stored in a secure manaer.
Observation 7 - CNC#4 Hazardous Product Containment
Date & time of visit: 2018-10-26 09:11
Located in the White City Yard, a SeaCan with hazardous materials storage has free product on the floor of the container from a leaking barrel. Officer notes that this product release is contained within the SeaCan but still presents a potential for worker exposure to Hazardous Materials as there is free product.
The company is required to clean up all free product in order to mitigate potential health and safety hazards.
Observation 8 - Safety - General
Date & time of visit: 2018-10-26 09:30
Observation 9 - Heritage sites
Date & time of visit: 2018-10-24 08:30
The Inspection Team notes that signs indicating numbered heritage sites and areas with heritage sites were in place, and that the buffers around the sites continue to be maintained. Trenching was taking place during the inspection, and an archeologist was present in the area indicated in the EPP as requiring one during ground disturbance activities. The Inspection Team spoke with the archeologist, who explained the process for inspecting the excavation and excavated materials for artifacts. The Inspection Team has no concerns regarding the maintenance of heritage sites during the activities noted.
Observation 10 - Contaminated site activity
Date & time of visit: 2018-10-24 11:55
The Inspection Team visited a site that had been noted as having contaminated soil at KP642+300, stated by Enbridge to be registered with the NEB as contaminated site REM-0383. The area to be trenched was being excavated during the site visit, for the purpose of removing the contaminated material ahead of trenching. A third-party environmental consultant was on site, ensuring that the boundaries of the excavation were tested for petroleum hydrocarbons in the field using field-screening (Photo Ionization Detector) and selecting samples for further laboratory analysis. Additionally, benzene levels in the air were being monitored. The consultant explained and provided the FLHA that indicated the procedure for evacuation in the case of elevated levels of benzene. The consultant indicated that contaminated soil was being sent to a Class II landfill for disposal.
Observation 11 - CNC - spoil pile trespass
Date & time of visit: 2018-10-24 11:25
The Inspection Team reviewed the daily Deficiency List for the project, and noted two areas where there had been trespass reported – topsoil piles off the RoW. The Inspection Team visited the two locations and confirmed that topsoil onto cropped land (trespass) was still on-going. Enbridge staff indicated that they were in the process of negotiating with the landowners for the rights to retain the additional land space.
The company is to ensure that soil stockpiles are removed from the area outside the staked RoW, and provide photographic evidence of the completed work, or provide evidence that the additional land space has been agreed to by the landowner, and that the material is no longer trespassing.
Due date: 2018-11-09
Date closed: 2018-11-05 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.
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