Compliance Verification Activity Report: CV1718-341 - Enbridge Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1718-341
Start date: 2017-11-06
End date: 2017-11-09

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 1 and 2 was inspected with focus on topsoil stripping and mitigation in potentially frozen conditions, dewatering activities, backfill and general Environmental Protection Plan compliance.

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: 2017-11-07 11:00

Discipline: Environmental Protection

Categories:

Facility:

Observations:

NEB inspectors observed pipeline activities from KP0+500 to KP178 (Spread 1 and into Spread 2), and a range of operations, from clearing to backfill, taking place over the course of this inspection.  NEB inspectors also inspected the construction yard in Provost, AB.  A summary of observations is provided below. 

Biosecurity:

Backfill:

At several locations, NEB inspectors observed backfilling operations. 



 

Compliance tool used: No compliance tool used

Observation 2 - Dewatering Activities

Date & time of visit: 2017-11-07 10:20

Discipline: Environmental Protection

Categories:

Facility:

Observations:

NEB inspectors observed two types of dewatering activities. 

Trench Dewatering:
At wetland AB-045, a pump was being used to dewater the trench.   As required by the EPP, since the discharge point was within 50m of a wetland, double sediment control and containment was used - the discharge sediment bag was in a “pigpen” enclosure of sediment fencing.  Enbridge encountered several issues - Water was remaining enclosed in the pigpen rather than filtering out onto the surrounding, snow-covered landscape.  The water would then wick up the sides of the pigpen, and freeze, preventing further exfiltration.   The water remaining in the pigpen would freeze, causing the sediment bag to freeze, and then burst.   This occurred twice.  Enbridge decided to use a new discharge point, outside of the wetland area, and not within a pigpen.  
At wetland AB-032, a previously used dewatering pigpen was observed.  No issues were seen to have occurred.  The dewatering checklist was kept in a tube on posts of the pigpen, and was reviewed by NEB inspectors.  
NEB inspectors have no concerns with dewatering practices and adaptive management observed at these locations.
 
Sand point wells:
Near the Metiskow Station, the pipeline was to go through a wet, sandy area.   In order to dewater the landscape to be able to trench, Enbridge was installing sand-point wells.  Approximately 360 wells were being installed and pumped out.  The discharge was pumped approximately 800m away along an insulated line with a glycol heat-trace recirculating line, and discharged through a sediment bag in a pigpen, within approximately 20m of a wetland.   The discharge appeared sediment-free and there were no apparent issues with the sediment bag and pigpen.  An additional pig-pen was set up nearby in case of failure of the first.  This shows an adaptive management approach was being applied.  

 

Compliance tool used: No compliance tool used

Observation 3 - Topsoil Stripping Activities

Date & time of visit: 2017-11-08 11:40

Discipline: Environmental Protection

Categories:

Facility:

Observations:

Spread 1 had been entirely stripped of topsoil by the time of the inspection.  Some topsoil stripping had begun into Spread 2, and day 3 of the inspection was slated to be the last day of topsoil stripping until summer of 2018. 
NEB inspectors observed topsoil stripping in progress at KP166+800.  Snow had insulated the soil enough so that it was not frozen and was being stripped cleanly from subsoil, with no large frost-affected lumps or admixing observed. 
At KP178+500 near Kerrobert Station, an HDD pad had been set up for a drill to go under the plant.  Stripping for the pad extended into a wetland. NEB inspectors observed topsoil storage in this area.  Riparian topsoil was labelled and segregated from upland topsoil. Wetland topsoil was stored within the wetland boundary however space restrictions at this site from infrastructure, road way and drill pad site were such that this approach was considered compliant with EPP requirements at this location by NEB Inspectors.
No trespass of stored spoil materials noted by NEB inspectors on any sites visited.  
 

Compliance tool used: No compliance tool used

Observation 4 - Watercourse and wetland crossings

Date & time of visit: 2017-11-07 08:50

Discipline: Environmental Protection

Categories:

Facility:

Observations:

NEB inspectors visited several wetland and watercourse crossings, and noted the following during the inspection:  



 

Compliance tool used: No compliance tool used

Observation 5 - Information Request (IR) #1 - clear diesel tank in construction yard

Date & time of visit: 2017-11-06 15:30

Discipline: Environmental Protection

Categories:

Facility:

Observations:

NEB inspectors inspected the construction yard in Provost. 
In general, there were no environmental issues noted with regards to waste handling and storage.
NEB inspectors noted that the clear diesel tank had dark staining that ran down the side and appeared to originate from the pipe fittings at the top of the tank. On closer inspection no evidence was observed of the diesel reaching the ground surface. 
Enbridge staff immediately had the side of the tank cleaned upon this being observed on the inspection. 
Enbridge staff stated that the staining did not constitute a leak, as the diesel had not reached the ground, and that this slight overflow is a common occurrence in filling diesel tanks. They also stated that any issues would be noted on the regular yard inspections. Enbridge provided the most recent of the weekly yard inspection reports, dated 4 November (two days prior to the NEB site inspection).  This inspection report did not indicate that the staining had been observed, however Enbridge staff stated that in the future the person inspecting would make an effort to step back and observe the wider picture to catch such issues.  


 

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Enbridge is to provide a response to NEB Inspectors outlining how this potential hazard has been:

  1. shared with construction staff at the Provost yard;
  2. shared with all active construction spreads; and that
  3. the commitment made for this tank is applicable at all similar sites.

Due date: 2017-11-30

Date closed: 2017-12-14
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 - Information Request (IR) # 2 - bevelling safety

Date & time of visit: 2017-11-08 13:47

Discipline: Safety Management

Categories:

Facility:

Observations:

NEB inspectors observed bevelling operations at approximately KP118+500. Bevel shavings were being raked and swept up, and were collected for recycling.  No environmental issues were noted.  
NEB inspectors were asked to sign onto the site FLHA, which spoke about the dangers of being in close proximity with the machinery conducting the bevelling. NEB inspectors were particularly advised to remain clear of pinch-points, as the pipe could move when being bevelled.  The operator of the machine for bevelling pipe ends wore safety glasses and a respirator. This operator was not wearing a full-face shield. The operator was observed frequently being hit by bevel shavings.  NEB inspectors were informed that that face shields fog up in the cold weather, and that it was considered more of a safety issue if the beveller could not see clearly.  

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Enbridge is to provide the task-specific risk assessment undertaken to determine the appropriate PPE and other precautions for the task of running the bevelling machine.  

Due date: 2017-11-30

Date closed: 2017-12-14
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