Compliance Verification Activity Report: CV1617-524 - Tundra Energy Marketing Limited

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2275
• Inspector In Training 1866T

Regulated company: Tundra Energy Marketing Limited

Operating company: Tundra Energy Marketing Limited

Province(s) / Territory(s):

• Saskatchewan

Discipline(s):

• Environmental Protection

Related events:

• INC2017-015

Rationale and scope:

Incident 2017-015 follow up inspection to oversee cleanup of crude oil release at Ingoldsby Terminal near Storthoaks, SK.

Compliance tool(s) used:

• None

Facility details

Facilities:

Facility Types

• Pipeline
• Pipeline right of way (ROW)
• Pump station
• Terminal

Life-cycle Phases

• Operations

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

Observations (no outstanding follow-up required)

Observation 1 - Incident 2017-015 site cleanup activities

Date & time of visit: 2017-02-02 12:26

Discipline: Environmental Protection

Categories:

• Surface Water Management
• Containment and Drainage Structures
• Soils and Soil Productivity
• Chemical Spills/Releases
• Groundwater
• Monitoring and Testing
• Chemical Spills/Releases
• Housekeeping
• Waste Management

Facility:

Observations:

• Tundra personnel indicated that the source of the spill was a failed seal on a reciprocating pump at this location.
• Tundra personnel indicated that the failure resulted in a misting of crude oil on snow and pooling of oil beneath the pump and aboveground infrastructure on the site. Oil then migrated from the release point in two different directions over frozen ground; Both towards a low lying area on the northeastern edge of the lease site and Tundra's neighbouring right of way, as well as towards the site auxiliary building and antenna to the east of the pump infrastructure.
• Tundra personnel indicated that vacuum trucks and an excavator had been used for bulk removal of free product and surficial contamination during initial cleanup, and that this had been completed prior to the NEB inspection.
• No free product was observed by NEB inspectors at the time of the inspection, only residual staining on frozen soil surface remained.
• Tundra personnel indicated that they have retained an environmental consultant to assist with clean up, sampling and site remediation.
• Tundra personnel indicated that next steps would involve both cleaning up stained material wherever accessible and conducting confirmatory sampling to verify that applicable remediation criteria have been satisfied. In areas beneath operational infrastructure, a risk management approach is proposed which will incorporate the existing groundwater monitoring program at this site. NEB inspectors are of the view that cleanup and remediation of this site are being appropriately managed and align with the Board's expectations as outlined in its Remediation Process Guide.
• Tundra personnel indicated they would provide a Remediation Summary Report which will be produced following finalization of cleanup and confirmatory sampling at this location.

Compliance tool used: No compliance tool used

Observation 2 - Ingoldsby terminal pump #1 site

Date & time of visit: 2017-02-02 12:30

Discipline: Environmental Protection

Categories:

• Surface Water Management
• Containment and Drainage Structures

Facility:

Observations:

• Surface contamination (staining) noted on frozen soil surface in the area surrounding and beneath the pump infrastructure, however no free product was observed. Tundra personnel indicated that their environmental consultant would be conducting additional cleanup and sampling in the area to verify that the site has been remediated to meet applicable criteria. Tundra personnel indicated that a Remediation Summary Report will be provided to the NEB once cleanup and confirmatory sampling are completed.
• Tundra personnel provided clarification that the groundwater monitoring program at this site is a proactive measure and not related to existing contamination.
• Tundra personnel indicated that a springtime groundwater monitoring event will be added to yearly program in order to assess any impacts on groundwater from this incident.

Compliance tool used: No compliance tool used

Observation 3 - Ingoldsby Terminal Auxiliary Building and waste handling infrastructure

Date & time of visit: 2017-02-02 12:30

Discipline: Environmental Protection

Categories:

• Surface Water Management
• Containment and Drainage Structures

Facility:

Observations:

• Waste oil storage tank observed to be free of leaks and constructed with appropriate double walled secondary containment.
• Waste wax bin inspected and observed to contain a grated shelf for pig cleaning, as well as appropriate secondary containment provided via a polyurethane liner.
• No issues noted.

Compliance tool used: No compliance tool used

Observations (company follow-up required)

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