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:
Enbridge Line 3 Replacement Project. Inspection of Spread 9 construction. This inspection focused on topsoil handling and verification of Enbridge's mitigation measures to prevent spread of soil pathogens as identified in the Environmental Protection Plan.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - General Observations
Date & time of visit: 2018-08-14 15:45
Discipline: Environmental Protection
Categories:
Facility:
Observations:
NEB inspectors noted the following observations: Biosecurity - Cleaning and Disinfectant ProceduresMud-Eeze Car Wash (Morden, MB)Manitou Cleaning Station / SA’s Laydown Yard (off site)
Compliance tool used: No compliance tool used
Observation 2 - Document Review
Date & time of visit: 2018-08-16 14:20
The following documents were reviewed for compliance:Cleaning Logs
Observation 3 - IR# 2 Biosecurity Management - Disinfectant Mist
Date & time of visit: 2018-08-14 15:00
The NEB-IAMC Inspection Team and Enbridge representatives traveled to the car wash at Morden to clean their vehicles prior to travel on the RoW. After pressure washing vehicles, tires were sprayed with the disinfectant mist in use as of that date on Spread 9 (AG Services Storage Disinfectant). Boots were also sprayed. NEB IOs/IAMC IM and Enbridge staff then travelled to the RoW, approximately 30 minutes away. The contact time for these vehicles occurred while in motion, and therefore although greater than 15-20 minutes elapsed prior to travel on the RoW (suboil), it is expected that the disinfectant would have dried on the vehicles prior to 15-20 minutes. Manitou Cleaning StationThe NEB-IAMC Inspection Team observed fine cleaning and disinfectant mist application at the Contractor’s cleaning station site near Manitou. Much of the equipment observed at the site was equipment arriving to the construction spread.
Compliance tool used: Information Request (IR)
Regulatory requirement:
Relevant section(s):
Company action required:
Noting that in many environmental conditions, the disinfectant applied to vehicles, equipment, tools, boots etc. could dry prior to the contact time specified in Table 4 of the EPP being elapsed. A) Discussed verbally in the field and at the NEB Closing Meeting 16 August 2018: NEB Inspectors requested that Enbridge provide information from the manufacturer of the disinfectant about the product’s effectiveness as a disinfectant (spores, weeds, other crop diseases) in cases where it is applied but dries before the 20 minute hold time is up – e.g. does it need to be saturated/wet for 20 minutes to be effective, and if it dries should it be re-applied? Also, for what Enbridge is using it for (tracked or rubber tired equipment, vehicles, boots and possibly other tools) is the hold/contact time 10 or 20 minutes (non-porous vs porous)? [Enbridge provided a response 22 August 2018 indicating that, based on a request from CAEPLA, bleach would be the disinfectant used on the majority of spread 9, with the AG services disinfectant being used specifically on lands where the landowners/occupants had requested its use.] B) Sent 24 August 2018:Regarding the use of bleach as the main disinfectant, can you confirm whether, in accordance with the EPP, Enbridge will require contact with the bleach solution for 15-20 minutes? Because the EPP states “solution”, I interpret the requirement to be that the effective contact time is with a moist/wet bleach mixture for 15-20 minutes, which could therefore require additional applications through the 15-20 minute contact time, depending on environmental conditions.If Enbridge does not intend to keep the equipment moist/wet for the 15-20 minute hold time (for example, a single application is made that dries prior to 15-20 minutes), does Enbridge have any data or test information to demonstrate whether the bleach solution is effective at killing clubroot spores, weeds or other pests if it dries prior to 15-20 minute contact time?Additional clarification was sought:C) Sent 24 August 2018:For cleaning equipment that is arriving to site from other locations (e.g. at the Manitou cleaning station) will the procedure be the same?D) Sent 27 August 2018:The Biosecurity Management Plan requires “When Enbridge mobilizes for a pipeline construction spread, Earth Moving and Non-Earth Moving Equipment will arrive clean, free of soil and plant debris, and misted with a 1-2% active ingredient bleach solution or equivalent.” (Page 13). Noting that equipment coming to site could be from areas with weed or crop disease concerns (e.g. other Enbridge Line 3 spreads, including high risk sites or rental equipment where the previous work areas are unknown and could be high risk), could you confirm whether Enbridge would apply the bleach solution in the manner described in the Disinfectant Mist section of Table 4 of the Biosecurity Management Plan (i.e. attempt to allow contact with the bleach solution [interpreted as moist/wet] for 15-20 minutes), as it does for the high risk or moderate risk-1 sites? For equipment mobilized to the spread, if Enbridge does not apply the bleach solution in accordance with the Disinfectant Mist section of Table 4 of the Biosecurity Management Plan (moist/wet for 15-20 minutes), can Enbridge provide data or information to demonstrate whether and how the risk of transporting weeds or crop pests on equipment mobilized to site is mitigated (e.g. is there data or test information to demonstrate whether the bleach solution is effective at killing clubroot spores, weeds or other pests if it is not moist/wet for the 15-20 minute contact time)?
Due date: 2018-09-27
Date closed: 2018-09-27 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
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
