Compliance Verification Activity Report: CV1718-318 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1718-318
Start date: 2017-09-25
End date: 2017-09-28

Team:

Regulated company: Enbridge Pipelines Inc.

Operating company: Enbridge Pipelines Inc.

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Environmental inspection of Enbridge Line 3 Replacement Project construction on spreads 3 and 4 in Saskatchewan. Focus of inspection included soils handling, watercourse crossings, biosecurity, hazardous waste and hazardous product storage.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2017-09-27 12:35

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Over the course of four days, NEB Inspectors assessed sites from KP 289 to KP 414 on Spread 3, and from KP 438 to KP 481 on Spread 4. NEB Inspectors also inspected the construction yard in Outlook, SK. During the course of this inspection, NEB Inspectors observed activities including hydrovacing, grading, ditching, stringing, lowering-in, and backfilling.  A summary of observations is provided below: 

HDD Sites:
NEB Inspectors visited the HDD sites of in-progress work at Canal WM1 and the setup for the HDD at the South Saskatchewan River, and observed the following: 

Biosecurity:
NEB Inspectors accompanied Enbridge personnel to a commercial car-wash where vehicles and work boots were washed and misted with a bleach solution prior to being taken onto the RoW. 
NEB Inspectors visited an equipment wash station on the RoW, which was not in use at the time of the inspection. There were no concerns with the set up or described operation of the wash station. 
NEB Inspectors spoke with several equipment operators during the course of the inspection.  The operators were aware of biosecurity requirements, and indicated repeated cleanings of equipment and vehicles were undertaken in accordance with requirements. 
NEB Inspectors also collected the reference numbers of several pieces of equipment, and reviewed their cleaning records.   Cleaning records were available for all equipment requested.  Notably, the records showed multiple cleaning events for equipment that was tasked to working in topsoil, such as hydrovac trucks (11 events for one truck) and a power dozer (25 events).   Cleaning records also included photographs, and the equipment in the photographs appeared thoroughly cleaned.  

Sediment Control:
NEB Inspectors examined sediment fencing at watercourse and road crossings.
Durable and extra thick yellow and black fencing, advocated by CAEPLA was used at crossings in cultivated areas.
In general, sediment fencing appeared to be in good repair, and effectively precluded the entry of sediment into watercourses and ditches.
 
Soils and soils handling:
NEB Inspectors noted that Enbridge was using several techniques to manage stripped material.
In many areas, topsoil and subsoil were observed to be sandy and silty.  In order to reduce wind-erosion of the spoil piles, Enbridge had initially begun using a tackifier on only the most erodible of materials, and then taken the decision to use it on all spoil piles.
NEB inspectors requested and reviewed information (SDS) about the tackifying material used. No issues were noted.
In areas where the L3 construction was alongside another Enbridge RoW, instead of stripping the area for storage of topsoil and subsoil, Enbridge had begun tamping down the soil surface to reduce microtopography, then used a tackifier/mulch as a base, and placed spoil material upon it. 
The mulch was a bright green, and formed a visual clue for the operator conducting backfill to see that the right depth had been reached.  Enbridge also stated that only the best and most experienced operators were being used in the pull-back of material that had been laid upon this mulch.
NEB inspectors observed that in some areas where pull-back had occurred, there was a fine skiff of subsoil (less than 2") on the surface of the vegetation.  Enbridge stated that in agricultural areas this material would be cultivated into the topsoil, and that overall it was a less invasive and more protective method of handling spoil than any they had used previously. NEB Inspectors indicated that although they have no issue with the technique being employed, the expectation would be that depth of residual subsoil on topsoil be such that it will not interfere with reclamation success, in both agricultural and sensitive areas such as native prairie.
 

Compliance tool used: No compliance tool used

Observation 2 - Information Request (IR) #1 - Hazardous materials storage in yard

Date & time of visit: 2017-09-28 09:30

Discipline: Environmental Protection

Categories:

Facility:

Observations:

NEB Inspectors observed general waste segregation and handling practices in the yard to be appropriate upon spot checks of waste containers.  NEB Inspectors observed bins for recycling, contaminated soil, general garbage and empty aerosol cans.  The contents of the bins matched their labels, and there was no apparent mixing of the different waste streams. 

NEB inspectors also observed following areas of concern outside of secondary containment and weather protection adjacent to the maintenance building: 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

NEB Inspectors require additional information to verify compliance. Enbridge will provide NEB Inspectors with a response indicating the provincial requirements for hazardous waste and hazardous materials storage in Saskatchewan and its assessment of how its current practices comply with these requirements.

Enbridge will provide a response indicating the location of waste battery storage at the Outlook construction yard and rationale for their observed location during the inspection.

 
 

Due date: 2017-09-28

Date closed: 2017-09-28
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 3 - Information Request (IR) #2 - Contaminated Site REM-096 traversed by project

Date & time of visit: 2017-09-27 08:50

Discipline: Environmental Protection

Categories:

Facility:

Observations:

NEB Inspectors visited location KP288+157 where a known contaminated site (NEB file REM-096) is traversed by project construction. NEB Inspectors reviewed and signed onto the FLHA for the site. During the time of the inspection, contaminated material was being excavated and loaded into a truck for disposal offsite (no on-site storage). 


NEB Inspectors observed and met with a representative of a consulting firm who was supervising the dig. The representative indicated his role was to ensure that all contaminated material in the construction RoW was removed.  This individual was the only personnel equipped with a gas monitor at the site.
NEB Inspectors observed a truck driver with no PPE being told to remain in his vehicle.
NEB Inspectors note that site representatives were unable to demonstrate a clear understanding of the potential hazards of the contaminant being excavated and why the precautions observed were selected, or other precautions (such as having assigned gas monitors) were not being followed.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

NEB Inspectors require additional information to verify compliance. Enbridge will provide NEB Inspectors with the following:


 

Due date: 2017-11-23

Date closed: 2017-12-04
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 4 - Corrected Non-Compliance (CNC) #1 - Dewatering location inappropriate

Date & time of visit: 2017-09-27 10:30

Discipline: Environmental Protection

Categories:

Facility:

Observations:

NEB Inspectors observed that the trench was being dewatered in preparation for lowering-in on spread 3, KP310+700.  The trench water was being discharged through a filter bag onto the RoW at the time of the inspection.  NEB Inspectors noted that the released water was flowing between the topsoil and subsoil/seconds piles, and was eroding the bases of both piles. 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Enbridge will choose an appropriate dewatering location and move the filter bag to this location.

 

Due date: 2017-09-27

Date closed: 2017-09-27
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

Observation 5 - Corrected Non-Compliance (CNC) #2 - Hazardous materials storage in yard

Date & time of visit: 2017-09-28 09:30

Discipline: Environmental Protection

Categories:

Facility:

Observations:

NEB Inspectors observed 5 vehicle batteries on a wooden pallet on the loading dock in front of the mechanics quonset. NEB Inspectors issued IR #1 to gather additional information on Enbridge compliance with provincial requirements and conformance with its own waste management procedures.

Response to IR #1 indicated the battery storage observed during the inspection did not meet the requirements of the Enbridge Waste Management Plan.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Enbridge will store the waste batteries such that they meet the requirements of its Waste Management Plan.

Due date: 2017-09-28

Date closed: 2017-09-28
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 6 - Notice of Non-Compliance (NNC) #1 - Fuel leaks and spills at Spread 3 construction yard

Date & time of visit: 2017-09-28 08:30

Discipline: Environmental Protection

Categories:

Facility:

Observations:

NEB inspectors observed the following at the aboveground fuel storage tanks at the Spread 3 construction yard: 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Enbridge will:

  1. Complete an assessment of all diesel and gas storage tanks and complete any needed repairs. A response summarizing the findings of the assessment and the repairs will be provided to NEB Inspectors.
  2. Complete a cleanup of observed areas of contamination at this location and provide photographic evidence of completion.
  3. Develop and implement a plan for managing spread of contamination from fuel tank dipsticks and provide a response summarizing actions taken to NEB Inspectors.
  4. Amend any applicable procedures and practices to ensure that fuel storage locations are added to the scope of Enbridge's environmental inspections. Enbridge will provide a response summarizing any changes or improvements.

Due date: 2017-11-16

Date closed: 2017-12-13
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:

- 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