Compliance verification activity type: Field Inspection
Team:
Regulated company: Spectra Energy Midstream Canada Partner Corporation
Operating company: Spectra Energy Midstream Canada Partner Corporation
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Operations environmental inspection of the West Doe Pipeline Right-of-Way (RoW) and West Doe Laterals RoW. The Pipeline was constructed in 1999 and the Laterals were constructed in 2007. The RoWs are located primarily across private, cultivated, agricultural land. The West Doe Pipeline was constructed using Horizontal Directional Drilling (HDD) to cross Doe Creek and Coleman Creek to mitigate impacts to the creeks, banks, and associated habitat. An NEB environmental inspection has not been conducted in recent years.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Additional Project-specific requirements or conditions:
Observation 1 - Range Road 133 Crossing
Date & time of visit: 2016-07-05 09:50
Discipline: Environmental Protection
Categories:
Facility:
Observations:
- Vegetation (crops and along road) consistent on and off Right-of-Way (RoW); RoW not distinguishable from surrounding land other than by signage.- Crop damage from recent flooding visible in low areas, but no erosion of RoW visible.- Spectra Energy Midstream Canada Partner Corporation (Spectra) representatives stated that weed management approach depends on each landowner. If a weed issue is identified, Spectra looks at it with the landowner and agrees on appropriate measures (e.g. spraying, hand picking, etc.) and then either Spectra implements measures or subsidizes landowner to do it. Similarly works co-operatively with county road inspectors and local invasive plant councils to address weed issues along roads.
Compliance tool used: No compliance tool used
Observation 2 - Township Road 804 Crossing
Date & time of visit: 2016-07-05 10:20
- Vegetation (crops and along road) consistent on and off RoW; RoW not distinguishable from surrounding land other than by signage.- Canola crops south of road crossing: hummocky terrain, sparse vegetation (Spectra representatives stated that seeds washed/rolled off by recent heavy rains) but consistent on and off RoW.- No erosion of RoW visible.
Observation 3 - Coleman Creek Crossing
Date & time of visit: 2016-07-05 10:45
- Vegetation (crop to east; shrubs, grasses and wildflowers at top of bank, and mature trees in creek valley) consistent on and off RoW; RoW indistinguishable from surrounding land other than by sign-post (refer to "Missing Signage" observation).- Creek is in deep v-shaped valley; east creek valley side-slope has slumped (approximately 7 m wide by 25 m long) at south edge of RoW, but is well-vegetated with sweet clover, with no apparent evidence of recent erosion or slide activity; 30 Sept 2015 Pipeline Right-of-Way Inspection Report shows that company is aware of and monitoring potential slope instability.
Observation 4 - Coleman Creek Crossing - Missing Signage
Date & time of visit: 2016-07-05 10:47
Discipline: Damage Prevention
- Pipeline identification sign missing from post at top of east slope of Coleman Creek valley.- Could not access top of west slope during inspection to verify if signage was present there.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
In the field, Spectra representatives committed to:
Due date: 2016-07-08
Date closed: 2016-07-20 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 - Arc Resources 8-25 Lease Road Crossing (SE 25-8-14 W6M, north of Road 222)
Date & time of visit: 2016-07-05 11:40
- Vegetation (crops and along lease road) and erosion consistent on and off RoW; RoW not distinguishable from surrounding land other than by signage.- Some weed issues noted (stinkweed, foxtail, thistle, etc.) between lease road and adjacent crops to east and west, but consistent on and off RoW; company representatives stated that they would note thistle concern to the lease road owner (provincially regulated).- Some erosion in drainage ditch between lease road and canola crop to the east, and rill erosion on east edge of the lease road near a culvert; 30 Sept 2015 Pipeline Right-of-Way Inspection Report shows that company is aware of and monitoring this erosion; company representatives stated that if erosion becomes worse, they will alert the lease road owner of the need to prepare a plan to mitigate the erosion (in consultation with Spectra where the lease road crosses Spectra's RoW).
Observation 6 - 1-27 ESD Riser Site / 207 Road Crossing
Date & time of visit: 2016-07-05 12:10
- Refer to "1-27 ESD Riser Site / 207 Road Crossing - Invasive Plant Management" for detailed observations and notes regarding site inspections, weeds, and weed management.- Observed small leak of hydraulic oil from gauge on ESD, with adsorbant pads placed on ground below leak; company representatives stated that leak was discovered that morning, leak was stopped and spill pads laid down to contain drips; an instrument technician will come later in the day to check gauge and complete clean-up, and contaminated material will go to West Doe Plant hazardous waste bins; event will be reported in Spectra's system (personnel arrived to complete this as NEB and company representatives were leaving the site).- Observed appropriate signage on both sides of Road 207, as well as at riser site (and piping labelled with NEB Order number)- Posts located at four corners of riser site for damage prevention.- Maps show natural drainage east of and approximately parallel to Road 207; drainage not obvious, well vegetated with grasses and shrubs, consistent on and off RoW.- Vegetation (crop to east, field to west, along road and through drainage) consistent on and off RoW; RoW not distinguishable from surrounding land other than by signage and presence of riser; no erosion visible.
Observation 7 - 1-27 ESD Riser Site - Invasive Plant Management
- Weed issue noted at ESD riser site and throughout surrounding field (thistles, etc. in field west of 207 Road); weed issue in field is migrating onto riser site.- Company representatives stated that they write up a vegetation management plan for each riser site every year, plan vegetation management in consultation with the landowner, and have spraying (if applicable) conducted by a contractor.- Company representatives stated that they perform three documented inspections of ESD riser site annually (including vegetation management observations): riser inspection, "line break valve" (i.e. ESD) inspection and aerial lands/geotechnical RoW patrol.- Company representatives stated that contractor would be spraying and cutting site next week, weather permitting, then will return 2 weeks later to confirm effectiveness of weed control.
Compliance tool used: Information Request (IR)
Please provide copies of the following, with respect to vegetation management at Spectra's 1-27 and 16-25 riser sites, by 5 August 2016:
Due date: 2016-08-05
Date closed: 2017-01-11 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 8 - Rolla Road Crossing
Date & time of visit: 2016-07-05 13:30
- Vegetation (chemical fallow to east, crop to west, and along road) consistent on and off RoW; RoW not distinguishable from surrounding land other than by signage.- Maps show natural drainage crossing in field west of Rolla Road; drainage visible as low lying area in canola field, but cultivated through; no erosion or subsidence visible.
Observation 9 - 213 Road Crossing
Date & time of visit: 2016-07-05 13:50
- Vegetation (crops and along road) consistent on and off RoW; RoW not distinguishable from surrounding land other than by signage; no erosion or subsidence visible.
Observation 10 - 16-25 Riser Site / 215 Road Crossing
Date & time of visit: 2016-07-05 14:15
- Company representative stated that riser site belongs to provincially regulated company (Kelt Exploration); Spectra subleases a small part for their riser, which is located at the junction of Spectra's West Doe Pipeline and West Doe Lateral 1.- Overgrown weeds primarily inside fenced enclosure include scentless chamomile, quack grass and thistle.- Company representative stated that they would notify Kelt Exploration of weed issues and handpick and bag noxious weeds.- Company indicated contractor weed management (spraying) was to have been performed in May but was delayed, and is currently scheduled to occur next week (weather permitting).- See observation titled "1-27 ESD Riser - Invasive Plant Management" with respect to requested plans showing the scheduled spraying, etc.- Other than riser site, vegetation (crops and along road) consistent on and off RoW; RoW not distinguishable from surrounding land other than by signage.- Crop damage from recent flooding visible in low areas of canola field east of road crossing, but consistent on and off RoW and no erosion or subsidence of RoW visible.- Follow-up: company representative emailed a photo of riser site after weeds had been picked to NEB staff on 12 July 2016.
Observation 11 - West Doe Laterals RoW between 16-25 Riser and West Doe Gas Plant
Date & time of visit: 2016-07-05 14:30
- RoW runs south from riser site through bearded wheat field, then canola field, then turns west through canola field to plant; RoW observed across field from adjacent road.- No evidence of RoW through canola field (visible parallel lineations occur in sets on and off RoW, appear to have been caused by agricultural equipment).- Bearded wheat appears slightly lower in a line following approximate course of RoW, but cause is not evident (under crop cover).- Company representative stated that previous subsidence issues in this area were corrected a couple of years ago; the landowner is proactive about letting Spectra know about any issues but they haven't heard any concerns from the landowner recently, so unlikely there is currently any issue; however, will confirm in fall when crop removed and ground is visible/accessible.- No signage on RoW; company representative stated that this is because the RoW is fully within cultivated fields and there are no road crossings.- Thistles observed in road ditch parallel to but off of RoW; no weed issues visible on RoW.
Observation 12 - Access Road to CNRL 11-1 Dehydrator Site (NW 1-81-15 W6M)
Date & time of visit: 2016-07-05 15:00
- Vegetation (crop to north, sloping meadow with nearby trees to south, and along access road) consistent on and off RoW (with exception of mature trees off RoW to south); RoW not distinguishable from surrounding land other than by signage and by mature trees off RoW to south.- Crop damage from recent flooding visible in low muddy areas, but no erosion of RoW visible.- Signage present on both sides of road; sign on north side of road shows Alberta One-Call phone number; company representative stated that this sign was posted in response to an NNC from a recent NEB Damage Prevention inspection, and the only sign available in the warehouse was one with the AB number; will be replaced with BC sign as soon as it is available. It was also noted that the sign is posted lower than is typical to avoid being hit by agricultural equipment.
Observation 13 - Spectra Sender and Injection Site at CNRL 11-1 Dehydrator Site (11-1-81-15 W6M)
Date & time of visit: 2016-07-05 15:15
- Spectra facilities at this location include valves, pig sender with secondary containment, and corrosion inhibitor tank and injection pump with secondary containment; located at edge of larger provincially regulated CNRL site.- Tank contains "Bremtag 8050 Corrosion Inhibitor Continuous" per WHMIS labeling on tank and MSDS contained in plastic tube adjacent to tank.- Pump is located over secondary containment for tank, in case of pump failure; some water in secondary containment due to recent rain, company representative stated that it had been pumped out in the spring and will be pumped out again shortly.- Secondary containment under pig sender is grounded; company representative stated that this was in response to an incident a few years ago.- Signage posted next to Spectra facilities where the pipeline enters the ground.- No weeds or other vegetation inside lease area (site is "blackened"); off lease to south, vegetation (crop) consistent on and off RoW as noted in previous observation; RoW not distinguishable from surrounding land other than by signage.- Minor erosion observed at outfall of small culvert installed by CNRL due to recent rain; company representatives stated that they would notify CNRL.
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