Compliance Verification Activity Report: CV1718-136 - Westcoast Energy Inc., carrying on business as Spectra Energy Transmission

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2507

Regulated company: Westcoast Energy Inc., carrying on business as Spectra Energy Transmission

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Environmental Protection

Related events:

• CV1617-239
• CV1617-438

Rationale and scope:

Environmental operations inspection intended to verify that Westcoast Energy Inc., carrying on business as Spectra Energy Transmission (Westcoast) has reclaimed the Project right-of-ways (RoWs) as specified in its post-construction environmental monitoring reports. The Projects visited during this inspection include the North and South Maxhamish Loops, and the Transmission North Expansion (Fort Nelson Mainline N4 Loop, Stewart Lake Pipeline, and Sunset Creek Compressor Station). The North Maxhamish Loop (NML) consists of approximately 37 km of NPS 24 O.D. pipeline. Clearing and pipeline construction activities began in November 2009, with RoW clean-up and reclamation completed in November 2010. An updated issues table filed in December 2016 (file number A81049-1) indicated that several unresolved issues remain and require ongoing monitoring. The South Maxhamish Loop (SML) consists of approximately 30 km of NPS 24 O.D. pipeline. Clean-up and reclamation of the RoW following construction was completed in October 2011. The fifth and final post-construction environmental monitoring report was filed in January 2017 (file number A81528-2), and indicated that there are still unresolved issues in many areas (primarily invasive species). The Fort Nelson Mainline N4 Loop (FNML) consists of approximately 24.4 km of NPS 36 O.D. pipeline that transports raw natural gas. The FNML parallels Westcoast’s Fort Nelson Mainline, and adds transmission capacity to the Fort Nelson Mainline to transport sweet gas processed at the Fort Nelson Processing Plant. The FNML traverses several wetland or muskeg areas and 23 watercourses, including ten tributaries to Kobes Creek, eight tributaries to Groundbirch Creek, two tributaries to Farrell Creek, Kobes Creek, Groundbirch Creek and Farrell Creek. The Stewart Lake Pipeline (SLP) consists of approximately 19.8 km of NPS 36 O.D. pipeline that transports sweet natural gas from Westcoast’s Fort St. John Mainline to NOVA Gas Transmission Ltd. (NGTL)’s Groundbirch Pipeline. This component of the Project also involved the construction of the Sunset Creek Compressor Station (CS) at the southern end of the SLP. The SLP crosses several wetland or muskeg areas and 13 watercourses, including Sunset Creek and 12 tributaries to Sunset Creek. All but approximately the first two km of the SLP are located in designated Agricultural Land Reserve (ALR) areas in both private and Crown land. Final RoW clean-up and reclamation following construction of the Transmission North Expansion Project was completed in the summer of 2013.

Compliance tool(s) used:

• Information Request (IR) (1)
• Corrected Non-compliance (CNC) (1)

Facility details

Facilities:

• North Maxhamish Loop
• South Maxhamish Loop
• Stewart Lake Pipeline
• SUNSET CREEK [Stewart Lake Pipeline]
• N4 LOOP

Facility Types

• Pipeline
• Compressor station
• Pipeline right of way (ROW)

Life-cycle Phases

• Post-Construction (Reclamation)

Regulatory requirements

Regulatory requirements that apply to this activity:

• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Act (NEBA) 2016-06-19
• Plans And Procedures
• Project-specific Environmental Protection Plan (EPP)
• Environmental Manual for Construction Projects in Canada (3rd Edition)
• Standard Operating Procedure or Plan (SOP)
• Vegetation Management SOP
• Standard Operating Procedure or Plan (SOP)
• Right-of-Way Maintenance SOP
• Standard Operating Procedure or Plan (SOP)
• Lands Pipeline Right-of-Way Patrol SOP
• Standard Operating Procedure or Plan (SOP)
• Environmental Management Program - Manage Vegetation Process
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• XG-W102-005-2011
• AO-1-XG-W102-04-2009

Observations (no outstanding follow-up required)

Observation 1 - North Maxhamish Loop

Date & time of visit: 2017-06-27 08:44

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Crowns/Subsidence
• Restoration
• Surface Water Management
• Containment and Drainage Structures
• Water Bodies - Non-Fish-bearing
• Reclamation
• Erosion
• Water Bodies - Fish-bearing
• Reclamation
• Erosion
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation
• Species of Concern
• Housekeeping
• Temporary Structures
• Training and Documentation
• Inspections

Facility:

• North Maxhamish Loop (Pipeline)

Observations:

• Good vegetation establishment and growth along the majority of the right-of-way (RoW). Vegetation observed included grasses, flowers (including a blue-listed species), shrubs and trees (approximately 2-3 m tall).
• ATV tracks were observed along the length of the RoW.
• A trench crown that reached approximately 0.5 to 1 m in height was observed along the length of the RoW. The trench crown was mostly vegetated, consistent with the rest of the RoW. However, two segments approximately 30 m in length each were unvegetated (approximately KP 0.71 and KP 2.0). Company representatives indicated that maintenance work may have been undertaken to repair subsidence at these locations and committed to providing additional information, please refer to the Information Request (IR).
• Berms were observed across the RoW in several locations, including slopes.
• Four watercourse crossings were observed. Overall the banks and slopes were well-vegetated and stable, with minor erosion observed at the Deszen Creek crossing (WC 6) and diversion berms were observed on the slopes of the watercourse crossing near KP 4.0. A company representative noted that erosion is one of the issues identified during annual aerial patrols, and impacted areas are either fixed or flagged for future monitoring depending on the severity. 
• Near the watercourse crossing at approximately KP 4.0 and at other locations along the RoW, swathes or piles of large boulders were observed at the edges of the RoW and in a storage area. Company representatives stated that these boulders were likely left over from previous construction work.
• High density of weeds (primarily perennial sow-thistle) was observed at approximately KP 15.0 along a gravel access road perpendicular to the pipeline. Perennial sow-thistle appeared to be contained to the access road and was not observed elsewhere along the RoW. Company representatives stated that weed treatment has not yet been applied to the RoW this year. It was also stated that the company is working with the Northern Rockies Invasive Plants Council to monitor invasive species where RoWs parallel highways.
• Gully erosion was observed in the following two locations:
  • Approximately KP 19.9, two channels were observed running parallel to the trenchline. These channels were approximately 10 m long x 0.5 m wide x 0.3 m deep. Additional information was requested regarding monitoring of erosion, please refer to the IR.
  • Approximately KP 23.0, one channel was observed running parallel to the trench line. This channel was observed only from the air and was estimated to be approximately 50-100 m in length and approximately 0.5 - 1 m in width. Additional information was requested regarding monitoring of erosion, please refer to the IR.
• Several wetlands were observed on and adjacent to the RoW. Wet conditions has led to large areas of ponding along the RoW. No issues with vegetation growth were observed at the wetlands.

Compliance tool used: No compliance tool used

Observation 2 - South Maxhamish Loop

Date & time of visit: 2017-06-27 13:30

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Crowns/Subsidence
• Restoration
• Surface Water Management
• Containment and Drainage Structures
• Water Bodies - Non-Fish-bearing
• Reclamation
• Erosion
• Water Bodies - Fish-bearing
• Reclamation
• Erosion
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation
• Training and Documentation
• Inspections

Facility:

• South Maxhamish Loop (Pipeline)

Observations:

• The RoW generally appeared to be very well vegetated with grasses, flowers, shrubs and trees (approximately 2-3 m in height) and few small areas with slightly lower vegetation establishment. One area (approximately 40 m x 6 m) of poor vegetation establishment was observed at KP 7.3. This area was likely the location of a log deck site and is possibly indicative of admixing during construction. Company representatives indicated that they will continue to monitor it for vegetation establishment.
• The trench crown was well-vegetated and less than 0.5 m in height along the majority of the route. In some locations the trench crown was indiscernible from the surrounding area on the RoW.
• High density perennial sow-thistle and scentless chamomile was observed in some locations along the RoW (including at approximate KPs 4.7, 7.5, 11.0, 16.0, and 25.86). Company representatives stated that herbicide application had not yet occurred in 2017, and provided additional information indicating that regular weed maintenance activities occur along this line. The pipeline closely parallels the Liard Highway for the majority of the route, and high densities of weeds were also observed immediately adjacent to the highway. A company representative indicated that they work with an organization to monitor the spread of invasive species along the highway. NEB Inspectors are satisfied that appropriate measures are being taken to manage weeds along the RoW.
• Four watercourse crossings were observed, along with several small drainages and several wetlands. Sloughing was observed on the SW bank of an unnamed stream crossing (designated by company as WC 4) at KP 14.5. Company representatives stated that this location had been previously identified and was being monitored by geotechnical experts during annual aerial patrols. NEB Inspectors note that this location was included in post-construction monitoring reports for this project. No other erosion issues were observed at the watercourse crossings and riparian vegetation appeared to be well established.
• Ponding was observed throughout the RoW, as the route runs through marshy low-lying areas. Several water diversion berms were observed along the RoW. Possible rill erosion was observed at approximately KP 25.0 and KP 28.0, however these sites were only observed from the air as there were no safe landing locations due to the wet conditions. Company representatives indicated that erosion issues are monitored during annual aerial patrols.

Compliance tool used: No compliance tool used

Observation 3 - Stewart Lake Pipeline

Date & time of visit: 2017-06-29 09:03

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Handling
• Surface Water Management
• Containment and Drainage Structures
• Surface Water Management Plan
• Water Bodies - Non-Fish-bearing
• Reclamation
• Erosion
• Water Bodies - Fish-bearing
• Reclamation
• Erosion
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation
• Socio-economic
• Human Occupancy and Resource Use
• Wildlife
• Species of Concern

Facility:

• Stewart Lake Pipeline (Pipeline)

Observations:

• The pipeline is located within an agricultural/settlement resource management zone, as well as Agricultural Land Reserve. Part of the RoW runs through Crown land which has been leased as a community grazing pasture, which was evident by cattle trails and large areas of erosion and poor vegetation growth. Tracks from recreational vehicles were also observed in several areas along the RoW.
• The RoW not impacted by grazing was generally well-vegetated with primarily clover and grasses, as well as some smaller bushes and trees; there is still a noticeable difference in vegetation from off-RoW conditions. Small weed infestations including perennial sow-thistle and Canada thistle were observed at a few locations along the RoW, as well as some areas with woody debris. A company representative indicated that the company re-visits new pipeline RoWs approximately every four to five years to observe the RoW condition, including invasive species. Issues are also noted during company aerial patrols or through third party reports.
• The pipeline RoW traverses several wetland and watercourse crossings, including Sunset Creek and tributaries to Sunset Creek. Inspectors observed evidence of cattle trampling on banks at multiple watercourses on the RoW where there were cattle crossings, specifically noted at tributaries to Stewart Creek (SL 1, SL 2) which were located within leased grazing areas. It was observed that vegetation clearing had been narrowed at watercourse crossings, and banks were stable and well-vegetated with grasses, trees and willows in areas not impacted by cattle crossings.
• Observed areas noted as western toad habitat. The majority of these sites looked to be in good condition, with the exception of the tributaries that had evidence of cattle trampling.
• Minor ponding was observed at multiple locations, and several water diversion berms were observed on slopes throughout the RoW. A large ponding area was observed on private property adjacent to Wrangler Creek and approximately 30 m from the Sunset Creek crossing from KP 11.23 - 11.53. Company representatives identified this location as having erosion and ponding issues that were repaired prior to 2016, and they are currently discussing future repair work with the landowner. NEB Inspectors noted that the area had experienced high levels of rain and flooding events throughout May that likely contributed to the high water level.
• Appropriate company pipeline identification signage was observed at watercourse and foreign pipeline/transmission line crossings, as well as at fences.

Compliance tool used: No compliance tool used

Observation 4 - Sunset Creek Compressor Station

Date & time of visit: 2017-06-29 10:50

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Handling
• Surface Water Management
• Containment and Drainage Structures
• Vegetation
• Vegetation Control
• Invasive Plant Management
• Housekeeping
• Waste Management
• Temporary Structures

Facility:

• SUNSET CREEK [Stewart Lake Pipeline] (Facility)

Observations:

Sunset Creek Compressor Station

• Observed rill and gully erosion throughout the graveled pad that extended downslope outside the fence line on all sides of the facility. A large, well-vegetated gully approximately 0.8 m deep was observed next to a culvert on the east side of the facility boundary. Large areas of ponding water were also observed within the facility boundary, with snow fencing encircling the larger ponds. A company representative stated that there are no sensitive receptors nearby, and it was observed that the run-off from the slopes was directed into bermed ditches or a well-vegetated field owned by the company and leased for farming. NEB Inspectors requested further information on the surface water management at this facility, please refer to the IR.
• There was good vegetative growth on the surrounding berms outside of the facility fencing, and abundant weedy species were observed. Some noxious weeds were observed on the berms and in the graveled pad, including Canada thistle and perennial sow-thistle. There was evidence of spraying inside the fence line. NEB Inspectors requested further information on weed spraying at this facility, please refer to the IR.
• NEB Inspectors observed good vegetative growth on the south side of the access road, which had been repaired and re-seeded in 2015.
• Observed an provincial environmental protection notice at the main entrance for work done in late 2016 - early 2017 to expand the compressor station as part of the High Pine Expansion project (approved by the Board under Order XG-W102-024-2016).
• A soil pile mixed with woody debris was located to the southeast of the facility outside the fence line. It was not clear to NEB Inspectors if the pile consisted of topsoil or subsoil. The pile was not placed on a barrier from the soil/vegetation below, nor were any erosion and sediment control measures installed around the soil. However, the pile was downslope and surrounded by tall  grasses and weedy species, and NEB Inspectors had no concerns with potential sediment run-off into the adjacent pasture.
• A culvert on the south slope was observed to have a low sediment load, and drained through boulders placed at the bottom into a well-vegetated field owned by the company. Another culvert on the north slope was also observed to drain through large boulders at the bottom of the slope into a treed area, and an erosion control blanket was installed on the hill at the top of the culvert.

Compliance tool used: No compliance tool used

Observation 5 - Fort Nelson Mainline N4 Loop

Date & time of visit: 2017-06-29 13:11

Discipline: Environmental Protection

Categories:

• Surface Water Management
• Containment and Drainage Structures
• Soils and Soil Productivity
• Crowns/Subsidence
• Water Bodies - Non-Fish-bearing
• Reclamation
• Erosion
• Water Bodies - Fish-bearing
• Reclamation
• Erosion
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation
• Socio-economic
• Human Occupancy and Resource Use
• Wildlife
• Species of Concern

Facility:

• N4 LOOP (Pipeline)

Observations:

• The RoW runs through several marshy areas, and for the most part is well-vegetated with the exception of a few areas with poor growth and woody debris (specifically noted at approximately KPs 4.0, 9.0, and 15.5). It was noted that these areas are not confined to this pipeline RoW, but the entire shared RoW.
• No trench crown was visible, the RoW blended in well with surroundings.
• Small water diversion berms were strategically placed along slopes.
• Vehicle tracks were observed throughout the length of the RoW.
• Numerous watercourse crossings were observed, all of them appeared to be stable and well-vegetated with the exception of rutting from third-party recreational vehicles.
• Man-made dugouts from the project's construction were observed at KPs 7.02 and 7.08. These dugouts were built to replace western toad habitat impacted by construction, the water was clear and the banks were well-vegetated with tall grasses and trees.

Compliance tool used: No compliance tool used

Observation 6 - Information Request (IR)

Date & time of visit: 2017-06-30 11:13

Discipline: Environmental Protection

Categories:

• Surface Water Management
• Surface Water Management Plan
• Vegetation
• Invasive Plant Management
• Training and Documentation
• Documentation Available/Up to Date
• Inspections

Facility:

• North Maxhamish Loop (Pipeline)

Observations:

 North Maxhamish Loop

• A trench crown that reached approximately 0.5 to 1 m in height was observed along the length of the RoW. The trench crown was mostly vegetated, consistent with the RoW. However, two segments approximately 30 m in length each were unvegetated (approximately KP 0.71 and KP 2.0). Company representatives indicated that maintenance work had been undertaken to repair subsidence at these locations and committed to providing additional information.
• Gully erosion was observed in the following two locations:
  • Approximately KP 19.9, two channels were observed running parallel to the trenchline. These channels were approximately 10 m long x 0.5 m wide x 0.3 m deep.
  • Approximately KP 23.0, one channel was observed running parallel to the trench line. This channel was observed only from the air and was estimated to be approximately 50-100 m in length and approximately 0.5 - 1 m in width.

• Observed rill and gully erosion throughout the graveled pad that extended downslope outside the fence line on all sides of the facility. A large, well-vegetated gully approximately 0.8 m deep was observed next to a culvert on the east side of the facility boundary.
• Some noxious weeds were observed on the berms and in the graveled pad, including Canada thistle and perennial sow-thistle.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Standard Operating Procedure or Plan (SOP)
• Lands Pipeline Right-of-Way Patrol SOP

Relevant section(s):

• All findings will be recorded on a “Pipeline ROW Inspection Report” (7.1 Appendix 1 – Pipeline Right-of-Way Inspection Report). Alternative formats are acceptable provided they capture the following minimum information: i. General: Pipeline, Patrol area, Patroller, Date, Method ii. Site Specific: Location (km or mile post), UTM, description of issue/observation/remarks

Company action required:

 North Maxhamish Loop

1. Provide documents, including photos, outlining any maintenance work that may have been conducted to repair subsidence at approximately KP 0.8 and 2.0.
2. Regarding gully erosion observed at approximately KP 20 and 23, please provide reports from aerial monitoring and any other monitoring at these locations in 2015 and 2016.

1. Provide dates of any scheduled weed spraying at the CS in 2017.
2. Provide the standard operating procedure (SOP) for environmental management at facilities. If surface water management is not included in this SOP, please provide applicable documentation for surface water management at the CS.

Due date: 2017-07-07

Date closed: 2017-07-17
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 7 - Corrected Non-Compliance

Date & time of visit: 2017-06-29 12:00

Discipline: Environmental Protection

Categories:

• Housekeeping
• Waste Management

Facility:

• SUNSET CREEK [Stewart Lake Pipeline] (Facility)

Observations:

NEB IOs observed a company representative pick up downed facility signage on the NE slope boundary. As this signage was left over from some recent construction activities, it was considered garbage.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 48. A company shall develop, implement and maintain an environmental protection program that anticipates, prevents, manages and mitigates conditions that could adversely affect the environment.

Company action required:

The company will ensure that the signage is properly stored or disposed of.

Due date: 2017-06-29

Date closed: 2017-06-29
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

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: