Compliance Verification Activity Report: CV1617-328 - Whitecap Resources Inc.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2507

Regulated company: Whitecap Resources Inc.

Operating company: Whitecap Resources Inc.

Province(s) / Territory(s):

• Alberta
• British Columbia

Discipline(s):

• Environmental Protection

Related events:

• CV1516-302

Rationale and scope:

An environmental information exchange meeting was held in December 2015 to inform the company of the NEB's expectations. An operations inspection of the Boundary Lake 8" Fresh Water Injection Pipeline and 10" Oil Effluent Pipeline will verify that Whitecap is meeting environmental requirements.

Compliance tool(s) used:

• Information Request (IR) (1)

Facility details

Facilities:

• 8" Fresh Water Injection Pipeline
• Boundary Lake 10" Oil Effluent Pipeline

Facility Types

• Pipeline
• Other
• Pipeline right of way (ROW)
• Valve site

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) until 1 April 2020, Canada Energy Regulatory Act (CERA) after 1 April 2020
• Plans And Procedures
• Standard Operating Procedure or Plan (SOP)
• Whitecap Resources Inc. Environmental Management Manual, June 2012
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• AO-005-XO-3-70
• AO-001-XC-I017-01-2008

Observations (no outstanding follow-up required)

Observation 1 - Fresh Water Booster Station (16-26-84-14 W6M; Fresh Water Pipeline origin)

Date & time of visit: 2016-07-06 09:48

Discipline: Environmental Protection

Categories:

• Surface Water Management
• Containment and Drainage Structures
• Vegetation
• Vegetation Control
• Housekeeping
• Waste Management

Facility:

• 8" Fresh Water Injection Pipeline (Pipeline)

Observations:

• Freshwater booster station contains booster pump, surge tank and turbine meter for freshwater pipeline, the rest of the facility is provincially regulated.
• Drainage under water pumps in building pumped into containment tank with secondary containment and high-level alarm, labeled "waste oil" due to possible small quantities of lube/hydraulic oil, etc.
• The containment tank is emptied approximately twice per month and trucked to the Boundary Lake Battery (08-02-85-14 W6M) and added to produced water.
• Appropriate identifying signage posted on the facility. 
• Blackened within majority of facility grounds.

Compliance tool used: No compliance tool used

Observation 2 - RoW walking approx. 200 m east from Fresh Water Booster Station

Date & time of visit: 2016-07-06 10:04

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Crowns/Subsidence
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• 8" Fresh Water Injection Pipeline (Pipeline)

Observations:

• Well vegetated; heavily treed with clearings adjacent to the Fresh Water Booster Station and old Texaco Freshwater Booster Station.
• Roach observed along RoW in clearings, however there is no evidence of erosion or drainage issues.
• Some weeds (clover, thistle) in clearings; company representatives stated that no weed spraying has been carried out here (to their knowledge). Company representatives committed to spot spray thistles and provide photo documentation to the NEB. A photo of the weed spraying was subsequently provided to NEB staff on 2 August 2016 and a follow-up photo of the dying weeds was provided on 15 September 2016, no further concerns.

Compliance tool used: No compliance tool used

Observation 3 - 14-25 Access Road Crossing

Date & time of visit: 2016-07-06 10:27

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs

Facility:

• 8" Fresh Water Injection Pipeline (Pipeline)

Observations:

• Pipeline signage located on both sides of road crossing.
• Signage still listed previous company ownership in addition to Whitecap identification (sticker used to change signage to "Whitecap" not large enough to cover previous company name); company representative placed Whitecap sticker over the other company name.

Compliance tool used: No compliance tool used

Observation 4 - 14-25 Access Road Crossing

Date & time of visit: 2016-07-06 10:35

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Crowns/Subsidence
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• 8" Fresh Water Injection Pipeline (Pipeline)

Observations:

• Walked E along RoW approximately 15 m; heavily treed with dense, mature vegetation.
• Roach noticeable but well vegetated, doesn't appear to be causing any erosion or drainage concerns.

Compliance tool used: No compliance tool used

Observation 5 - 16-25 Access Road Crossing

Date & time of visit: 2016-07-06 10:45

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs

Facility:

• 8" Fresh Water Injection Pipeline (Pipeline)

Observations:

• Pipeline signage located on both sides of road crossing.
• Signage still listed previous company ownership in addition to Whitecap identification (sticker used to change signage to "Whitecap" not large enough to cover previous company name); company representative placed Whitecap sticker over the other company name.

Compliance tool used: No compliance tool used

Observation 6 - 16-25 Access Road Crossing

Date & time of visit: 2016-07-06 10:50

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Crowns/Subsidence
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• 8" Fresh Water Injection Pipeline (Pipeline)

Observations:

• Observed RoW from road crossing; mature vegetation, heavily treed, similar to that observed at 14-25 access road crossing

Compliance tool used: No compliance tool used

Observation 7 - 14-30 Access Road Crossing

Date & time of visit: 2016-07-06 10:57

Discipline: Damage Prevention

Categories:

• RoW Maintenance
• Vegetation
• Pipeline Identification
• Signs

Facility:

• 8" Fresh Water Injection Pipeline (Pipeline)

Observations:

• Signs on both sides of road require brushing, aren't visible from road.
• Called emergency number posted on sign, went to company's responders.
• Company representative committed to brush back vegetation to make signs visible and provide photo documentation to the NEB. A photo was provided to the NEB on 15 September 2016, no further concerns.

Compliance tool used: No compliance tool used

Observation 8 - 14-30 Access Road Crossing

Date & time of visit: 2016-07-06 11:01

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Crowns/Subsidence
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• 8" Fresh Water Injection Pipeline (Pipeline)

Observations:

• Walked W along RoW approximately 8 m; heavily treed with dense, mature vegetation, consistent with natural surroundings.
• Roach is approximately 1 m width x 30 cm height; well vegetated, doesn't appear to be causing any erosion or drainage concerns.
• Large poplar tree (20 cm diameter) growing on roach.

Compliance tool used: No compliance tool used

Observation 9 - 14-29 Access Road Crossing

Date & time of visit: 2016-07-06 11:14

Discipline: Damage Prevention

Categories:

• RoW Maintenance
• Vegetation
• Pipeline Identification
• Signs

Facility:

• 8" Fresh Water Injection Pipeline (Pipeline)

Observations:

• Sign missing from east side of road crossing.
• Sign on west side of road crossing requires brushing, visibility obscured from road.
• Company representatives comitted to replace the missing sign as soon as possible, brush back vegetation, and provide photo documentation to the NEB. A photo was provided to the NEB on 15 September 2016, no further concerns.
• Given the observations of required brushing around signage at multiple locations along the Fresh Water RoW, company representatives subsequently committed to inspect signage for brushing needs at each Fresh Water RoW crossing from the Fresh Water Booster Station to the Alberta border, brush as required, and provide confirmation of completion to the NEB. Confirmation was provided on 19 September 2016, no further concerns.

Compliance tool used: No compliance tool used

Observation 10 - Highway 64 Crossing, just west of AB/BC Border

Date & time of visit: 2016-07-06 11:29

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Crowns/Subsidence
• Restoration
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• 8" Fresh Water Injection Pipeline (Pipeline)

Observations:

• Private pasture to the west of the crossing:
  • no roach apparent, based on observation from the road
  • vegetation (in pasture and along road) consistent on and off RoW
  • RoW indiscernible from surrounding area other than by signage
• Natural riparian vegetation to the east of the crossing:
  • roach present, located approximately 7 m from adjacent pond, but no evidence of drainage or erosion issues due to the roach
  • vegetation (along road and adjacent to pond) consistent on and off RoW
• Pipeline signage present and clearly visible on both sites of highway crossing.

Compliance tool used: No compliance tool used

Observation 11 - 08-32 Access Road Crossing

Date & time of visit: 2016-07-06 11:50

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Crowns/Subsidence
• Vegetation
• Vegetation Control
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• Boundary Lake 10" Oil Effluent Pipeline (Pipeline)

Observations:

• RoW was recently mulched along almost the entire length of the oil effluent line. Company representative stated that all equipment was washed prior to entering site to conduct work.
• Company representative stated that the RoW will be periodically mown (or mulched if necessary) to maintain visibility for aerial patrols.
• RoW was not reseeded as the seed bed was not affected by the mulching and RoW is expected to naturally revegetate.
• No roach or erosion concerns noted, very flat topography.
• Signage present on both sides of access road crossing.

Compliance tool used: No compliance tool used

Observation 12 - Boundary Lake Battery 08-02 (08-02-085-14 W6M, Effluent Pipeline origin)

Date & time of visit: 2016-07-06 12:58

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Chemical Spills/Releases
• Vegetation
• Vegetation Control
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• Boundary Lake 10" Oil Effluent Pipeline (Pipeline)

Observations:

• Currently pigging the line.
• Secondary containment placed on ground beneath pig receiver, and used pigs placed in second container next to it.
• Area around the pig receiver is blackened, with some stinkweed, foxtail, etc. in vicinity.
• RoW between battery and 207 Road crossing to SE is well vegetated with long grasses, shrubs and small trees (not mulched), no weed issues noted.

Compliance tool used: No compliance tool used

Observation 13 - Road 207 Crossing, Private Agricultural Land

Date & time of visit: 2016-07-06 13:10

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Soil Integrity
• Crowns/Subsidence
• Vegetation
• Invasive Plant Management
• Vegetation Reclamation
• Crop Productivity

Facility:

• Boundary Lake 10" Oil Effluent Pipeline (Pipeline)

Observations:

• Signage present at road crossing
• Pipeline crosses agricultural land east of 207 Road, did not have access to property so observed from road.
• Vegetation (field and along road) consistent on and off RoW; RoW indistinguishable from surrounding area.

Compliance tool used: No compliance tool used

Observation 14 - Boundary Creek Crossing

Date & time of visit: 2016-07-06 13:25

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Erosion
• Crowns/Subsidence
• Water Bodies - Fish-bearing
• Reclamation
• Vegetation
• Vegetation Control
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• Boundary Lake 10" Oil Effluent Pipeline (Pipeline)

Observations:

• Travelled WNW along mulched RoW from Airport Road crossing to east side of Boundary Creek crossing
• Less than 10 m buffer left between the mulched RoW and creek; discussed with company: vegetation between RoW signage and end of mulching near creek was primarily grasses and expected to grow back quickly, no disturbance of creek.
• Relatively dense vegetation visible on RoW on west side of creek crossing (not accessed during inspection); company representative said west side was too wet to be mulched.
• Large beaver dam observed in creek.
• No weed, erosion or drainage issues noted.
• An approximately 0.3 to 0.4 m deep, 1 x 1.5 m hole observed on RoW filled with water, natural organic sheen on top; appears to be a wet area of RoW emphasized by recent mulching.

Compliance tool used: No compliance tool used

Observation 15 - Boundary Creek Crossing

Date & time of visit: 2016-07-06 13:31

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs
• Watercourses

Facility:

• Boundary Lake 10" Oil Effluent Pipeline (Pipeline)

Observations:

• RoW signage present on east side of creek. Company representative added a Whitecap sticker over previous company name on sign (all other information was up-to-date).

Compliance tool used: No compliance tool used

Observation 16 - RoW between Airport Road crossing and wetland south of Boundary Lake, including Intersection with Provincial Line (per GPS coordinates)

Date & time of visit: 2016-07-06 13:43

Discipline: Damage Prevention

Categories:

• Pipeline Identification
• Signs

Facility:

• Boundary Lake 10" Oil Effluent Pipeline (Pipeline)

Observations:

• Travelled SE along pipeline RoW from Airport Road crossing to wetland south of Boundary Lake
• Intersection with newly constructed provincially regulated Whitecap pipeline (at GPS coordinates); new provincially-regulated line has signage at the RoW intersection.
• RoW signage present at 203 Road crossing, and at 8-32 access road crossing as previously noted

Compliance tool used: No compliance tool used

Observation 17 - RoW between Airport Road crossing and wetland south of Boundary Lake, including Intersection with Provincial Line (per GPS coordinates)

Date & time of visit: 2016-07-06 13:45

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Crowns/Subsidence
• Water Bodies - Fish-bearing
• Reclamation
• Vegetation
• Vegetation Control
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• Boundary Lake 10" Oil Effluent Pipeline (Pipeline)

Observations:

• Travelled SE along pipeline RoW from Airport Road crossing to wetland south of Boundary Lake
• RoW mulched, except for wetter areas where mulching was narrowed or omitted and shrubs and grasses were left intact
• RoW in general relatively wet and soft with organic-rich soils and organic material left on surface
• No drainage, erosion or weed issues noted
• Riparian vegetation left intact through wetland area south of Boundary Lake: vegetation consistent on and off RoW; RoW not distinguishable from surroundings

Compliance tool used: No compliance tool used

Observation 18 - Shared RoW in AB (1) either side of BP 14-28 Access Road (to wetland south of Boundary Lake to NW, then continuing SE down RoW)

Date & time of visit: 2016-07-06 14:08

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Crowns/Subsidence
• Water Bodies - Fish-bearing
• Reclamation
• Vegetation
• Vegetation Control
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• 8" Fresh Water Injection Pipeline (Pipeline)

Observations:

• Signs for both lines present on both sides of small dirt road crossing.
• Mulched with some very wet areas dispersed across RoW, lots of organic matter.
• Small roach located over fresh water line, doesn't appear to be causing erosion/drainage issues (topography is very flat).
• Mulching terminates to NW where ground gets too wet, approaching wetland south of Boundary Lake: vegetation NW of mulched RoW consists of shrubs and grasses, well vegetated but distinguishable from more mature vegetation adjacent to RoW

Compliance tool used: No compliance tool used

Observation 19 - Shared RoW in AB (2) BP 14-28 Access Road to Range Road 132

Date & time of visit: 2016-07-06 14:35

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Crowns/Subsidence
• Vegetation
• Vegetation Control
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• 8" Fresh Water Injection Pipeline (Pipeline)

Observations:

• Similar to rest of observed RoW: flat topography, mulched, very wet areas dispersed throughout.

Compliance tool used: No compliance tool used

Observation 20 - Shared RoW in AB (3) Range Road 132 to Highway 64

Date & time of visit: 2016-07-06 14:49

Discipline: Environmental Protection

Categories:

• Soils and Soil Productivity
• Crowns/Subsidence
• Water Bodies - Non-Fish-bearing
• Reclamation
• Vegetation
• Vegetation Control
• Invasive Plant Management
• Vegetation Reclamation

Facility:

• 8" Fresh Water Injection Pipeline (Pipeline)

Observations:

• There was a small vegetated wetland area on the RoW that was mulched around, no concerns.

Compliance tool used: No compliance tool used

Observation 21 - Boundary Lake Satellite & Pump Station / 03-23 Station L ESD Valve (03-23-84-13 W6M; Effluent Pipeline Origin and Fresh Water Pipeline Terminus)

Date & time of visit: 2016-07-06 15:06

Discipline: Environmental Protection

Categories:

• Surface Water Management
• Containment and Drainage Structures
• Surface Water Management Plan
• Soils and Soil Productivity
• Chemical Spills/Releases
• Vegetation
• Vegetation Control
• Invasive Plant Management

Facility:

• 8" Fresh Water Injection Pipeline (Pipeline)

Observations:

• Origin of Effluent Pipeline and terminus of Fresh Water Pipeline are located in otherwise provincially regulated facility.
• Pig sender and ESD valve are located at beginning of Effluent Pipeline.
• Secondary containment placed under capped pig sender. Company representative stated that cleaning pigs run monthly, and that any accumulated water in secondary containment is pumped out with sumps.
• Water accumulated in low area where pipeline goes below grade. Company representative stated that accumulated water is pumped off and discharged outside the site berm after being tested for pH, Cl, and EC and visually checked for hydrocarbon sheen (surface water release tracking forms, and sample completed form, subsequently observed at Whitecap field office).
• Dying weeds observed. Company representative stated that the area was sprayed about a week ago.
• Large dirt berm surrounds entire operational area. Some mulched material left over from installation was deposited on ground behind berm. Company representative said berm was installed about a year ago as site is within 100 m of water body.

Compliance tool used: No compliance tool used

Observation 22 - Environmental Management Manual

Date & time of visit: 2016-07-06 16:12

Discipline: Environmental Protection

Categories:

• Training and Documentation
• Documentation Available/Up to Date

Facility:

• 8" Fresh Water Injection Pipeline (Pipeline)

Observations:

The company provided the NEB with a copy of their Environmental Management Manual, June 2012, and explained that they are currently producing a new integrated Environment, Health, Safety, and Security Manual which should be completed by the end of July 2016. The pipelines are also managed in accordance with the Whitecap Resources Inc. (NEB Pipelines) Pipeline Integrity Management Program, 2016 Edition (last updated 2016-04).

Compliance tool used: Information Request (IR)

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:

Whitecap will provide NEB staff with an electronic copy of its new Environment, Health, Safety, and Security Manual via email upon completion.

Environmental Protection section (section 13) of HSE Management Manual dated August 2016 was provided to NEB staff on 15 Sept 2016, no further concerns.

Due date: 2016-09-15

Date closed: 2016-09-16
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: