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APPENDIX G
Drilling Mud Containment, Response, and Notification Plan
FEIS Alberta Clipper Project
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FEIS Alberta Clipper Project
Enbridge Energy, Limited Partnership Enbridge Pipelines (Southern Lights) L.L.C.
Drilling Mud Containment, Response, and Notification Plan
Alberta Clipper and
Southern Lights Diluent Pipeline Projects
March 20, 2009
Enbridge Energy, Limited Partnership
Enbridge Pipelines (Southern Lights) L.L.C. Drilling Mud Containment, Response, and Notification Plan
TABLE OF CONTENTS 1.0 Introduction ....................................................................................................... 1 2.0 On-Site Observation during Construction ......................................................... 1 3.0 Response to Inadvertent Releases .................................................................. 2
3.1 Upland Locations ......................................................................................... 2 3.2 Wetland Locations ....................................................................................... 2
4.0 Containment ..................................................................................................... 3 4.1 Upland Locations ......................................................................................... 3 4.2 Wetland and Waterbody Locations. ............................................................. 4
5.0 Notification and Resumption of Suspended HDD Operations .......................... 5 6.0 Winter HDDs ..................................................................................................... 5 7.0 Clean-up ........................................................................................................... 6 8.0 Restoration and Post-Construction Monitoring ................................................. 7
Attachments
• North Dakota Environmental Incident Report Form (web page) • Minnesota Pollution Control Agency – Reporting Spills and Leaks • Wisconsin BMP Field Manual; Chapter 4—Fuels, Lubricants, Waste and
Spills
Drilling Mud Containment, Response, and Notification Plan Enbridge Energy, Limited Partnership
Enbridge Pipelines (Southern Lights) L.L.C. March 20, 2009
Enbridge Pipelines (Southern Lights) L.L.C.
Drilling Mud Containment, Response, and Notification Plan 1.0 Introduction Construction of an Enbridge Energy, Limited Partnership and Enbridge Pipelines (Southern Lights) L.L.C. (Enbridge) pipeline may include the use of a trenchless excavation method known as horizontal directional drilling (HDD). HDD is a widely used construction technique that accomplishes the installation of buried utilities with minimum environmental impact. However, HDD is not entirely without impact. The primary environmental impact potentially associated with HDD is the inadvertent release of drilling fluids/mud to the surface during construction (sometimes referred to as “frac-out”). The HDD drilling fluids/mud consists of primarily water mixed with inert bentonite clay. Under certain conditions an additive may need to be mixed with the drilling fluids/mud for viscosity or lubricating reasons. Only non-hazardous additives will be used and a Material Safety Data Sheet (MSDS) for the drilling fluid will be maintained on-site. The objective of this plan is to provide procedures that will minimize the potential for release of drilling fluids/mud into wetlands, waterbodies or onto the adjacent surface soils. HDD is to be conducted in accordance with Enbridge’s Environmental Mitigation Plan (EMP). As such, HDD will be conducted in a manner to prevent inadvertent releases of drilling mud. This “Containment, Response and Notification Plan” elaborates on measures to be implemented if a release occurs despite prevention efforts. The plan is to be implemented as appropriate by the contractor under the supervision of Enbridge to contain, control and clean up any release of drilling mud during HDD crossings conducted during pipeline construction. Prior to the commencement of HDD operations, Enbridge’s construction contractor will inform construction personnel involved in the HDD as to the responsible party(ies) for release containment and response. Enbridge’s construction contractor will ensure that the appropriate response personnel and containment equipment are on site for each HDD. 2.0 On-Site Observation during Construction During construction of a directionally-drilled crossing, pipeline construction personnel will monitor the pipeline route throughout the process, as follows: • The drill path will be continually monitored during active drilling with mud
circulation;
• Construction observers will be briefed on what to watch for and will be made aware of the importance of timely detection and response actions to any release of drilling mud;
• Construction observers will have appropriate, operational communication equipment (e.g., radio and cell phones) available at all times during installation of
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Drilling Mud Containment, Response, and Notification Plan Enbridge Energy, Limited Partnership
Enbridge Pipelines (Southern Lights) L.L.C. March 20, 2009
the directionally drilled crossing, with the ability to communicate directly with the HDD operations control center;
• If the HDD operator realizes a sustained loss in fluid pressure or loss of circulation, the operator will immediately notify the construction observers of the assumed position of the drill head; and
• Construction observers will have the authority to order installation of containment structures, if needed, and to require additional response measures if deemed appropriate.
3.0 Response to Inadvertent Releases In the event an inadvertent drilling mud release is observed during an HDD crossing, the release will be assessed to determine the amount of drilling mud being released and potential for the release to reach sensitive resource areas (e.g., wetlands and waterbodies). Response measures will vary based on location of inadvertent release as discussed below.
3.1 Upland Locations Response measures include: • Evaluate the release to determine if containment structures are warranted
and if they will effectively contain the release.
• Order installation of containment measures as needed (see Section 4).
• Initiate immediate suspension of drilling operations if the mud release cannot be effectively contained.
3.2 Wetland Locations
This section also applies to areas immediately adjacent to wetlands and waterbodies, such as stream banks or steep slopes, where drilling mud releases could quickly reach surface waters. Response measures include: • Evaluate the release to determine the most effective containment measures;
• Order installation of containment measures (see Section 4);
• Initiate immediate suspension of drilling operations if the mud release cannot be effectively contained;
• Review and adjust drill pressures, pump volume rates, and drill profile to minimize the extent of the release;
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Drilling Mud Containment, Response, and Notification Plan Enbridge Energy, Limited Partnership
Enbridge Pipelines (Southern Lights) L.L.C. March 20, 2009
• Further evaluate the current drill circumstances and site conditions to identify
potential means to prevent further inadvertent release events;
If necessary, suspend drilling operations in accordance with Section 4 and in consultation with the EI and agency monitor, and notify appropriate regulatory agencies in accordance with Section 5. 4.0 Containment Containment, response and clean-up equipment will be available at both sides of the HDD crossing location prior to the commencement of the HDD to assure a timely response in the event of an inadvertent release of drilling mud (i.e., frac-out). Containment and response equipment includes but is not limited to:
− straw bales and staking − silt fence − plastic sheeting − shovels and other appropriate hand tools − squeegees − pails − push brooms − pumps and sufficient hose − mud storage tanks − vacuum truck on 24-hour call − pre-filled sandbags − geotextile fabric − one small boat (for larger rivers and open water wetlands) − steel box or large-diameter pipe section (or the equivalent) that, under
appropriate conditions, could be used to contain a frac-out − light plant/generator 4.1 Upland Locations
• Deploy appropriate containment measures to contain and recover drilling mud
as feasible.
• Remove excess mud at a rate sufficient to prevent an uncontrolled release.
• If the amount of the surface release is not great enough to allow the practical physical collection from the affected area, it shall be diluted with clean water and/or the fluid will be allowed to dry and dissipate naturally.
• If the amount of the surface release exceeds that which can be completely contained with hand-placed barriers, small collection sumps (less than 5 cubic yards) may be used to remove released drilling mud by the use of portable pumps and hoses.
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Drilling Mud Containment, Response, and Notification Plan Enbridge Energy, Limited Partnership
Enbridge Pipelines (Southern Lights) L.L.C. March 20, 2009
4.2 Wetland and Waterbody Locations. This section also applies to areas immediately adjacent to wetlands and waterbodies, such as stream banks or steep slopes, where drilling mud releases could quickly reach sensitive water resource areas.
• In the event of a drilling mud release in wetlands, waterbodies, or adjacent
areas:
- the release will be evaluated, and appropriate containment measures will be deployed;
- emergency containment measures will be deployed as feasible based on the site-specific conditions, including the location of the release;
- following containment, recovery measures will be evaluated to determine the most effective collection method;
- drilling operations will be suspended if, as determined by the EI and agency monitor, containment measures do not effectively control the release;
- agency and project management personnel will be notified in accordance with Section 5 below;
• Enbridge will consult with the appropriate regulatory agencies to evaluate the
circumstances of the release, discuss additional containment or cleanup requirements, and determine whether and under what conditions the HDD may proceed (see Section 6).
• If the amount of the surface release is not great enough to allow the practical physical collection from the affected area without causing additional impacts, it shall be diluted with clean water and/or the fluid will be allowed to dry and dissipate naturally.
• If the amount of the surface release exceeds that which can be contained with hand-placed barriers, small collection sumps (less than 5 cubic yards) may be excavated to collect released drilling mud for removal by the use of portable pumps and hoses.
• Excess mud will be held within the containment area and removed using pumps or other appropriate measures at a rate sufficient to maintain secure containment.
• Removed mud will be stored in a temporary holding tank or other suitable structure out of the floodplain and/or wetland for reuse or eventual disposal in an approved disposal facility
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Drilling Mud Containment, Response, and Notification Plan Enbridge Energy, Limited Partnership
Enbridge Pipelines (Southern Lights) L.L.C. March 20, 2009
5.0 Notification and Resumption of Suspended HDD Operations For all drilling mud releases during HDD crossings, the Contractor will notify the Environmental Inspector (EI). If the EI determines the release affects wetland or in-stream areas, he or she will immediately notify Enbridge and the appropriate regulatory agency (e.g., Minnesota State Duty Officer). If notifications are necessary during non-business hours they will be done according to prior arrangements made between Enbridge and the regulatory agencies. Follow-up notifications will be made as necessary and practicable. Contact information for reporting petroleum releases in North Dakota, Minnesota, and Wisconsin is presented in the Webpage downloads that are included as attachments to this document, and is also summarized as follows:
• North Dakota: o Department of Health, Environmental Health Section, 701.328.5210 or
5166, o Department of Emergency Services, 701.328.8100, or o State Radio 24-Hour Hotline, 800.472.2121;
• Minnesota, Duty Officer, 651.649.5451, or 800.422.0798; and
• Wisconsin, 24-Hour Emergency Hotline, 800.943.0003.
The conditions under which HDD operations can resume will be discussed with appropriate regulatory agencies and/or field representatives. If containment measures are functioning, and the circumstances and potential impacts of the release are understood, HDD operations will resume. There may be exceptional situations when large and difficult to control releases in very sensitive areas may require additional planning and review of the crossing and coordination among appropriate regulatory agencies and Enbridge will endeavor to coordinate proper communications in these situations.
6.0 Winter HDDs Enbridge does not currently propose to conduct HDD activities during the winter construction season. However, if the proposed HDD crossings are not completed prior to snow cover, Enbridge will develop site-specific monitoring plans for the remaining HDD crossings. The site-specific winter frac-out plans will include a description of Enbridge's proposed monitoring methods along the drill path, as well as Enbridge's proposed methods for monitoring potential in-stream drilling mud releases under ice-covered waterbodies. These site-specific plans will be provided to the applicable agencies prior to the initiation of each remaining HDD.
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Drilling Mud Containment, Response, and Notification Plan Enbridge Energy, Limited Partnership
Enbridge Pipelines (Southern Lights) L.L.C. March 20, 2009
7.0 Clean-up Clean-up measures following mud releases in uplands, wetlands, and waterbodies will be implemented as determined by this plan and in consultation with the appropriate regulatory agencies. The following measures are to be considered as appropriate: • Drilling mud will be cleaned up by hand using hand shovels, buckets and soft-
bristled brooms as possible without causing extensive ancillary damage to existing vegetation. Clean water washes may also be employed if deemed beneficial and feasible.
• Containment structures will be pumped out and the ground surface scraped to bare topsoil without causing undue loss of topsoil or ancillary damage to existing and adjacent vegetation.
• Material will be collected in containers for temporary storage prior to removal from the site.
• Potential for secondary impact from the clean-up process is to be regularly evaluated and clean-up activities terminated if physical damage to the site is deemed to exceed the benefits of removal activities in consultation with the appropriate regulatory agencies and/or field representatives.
Sealing and Abandonment of the Drill Hole
The following measures will be implemented in the event that drilling cannot continue along the designated drill path due to excessive leakage:
• Beginning from a point behind where the leakage occurred, the hole will be redrilled along a different alignment path. • The initial drill hole will be abandoned if continued drilling along a new alignment is not possible. This will be accomplished by filling the hole with the bentonite slurry used for the initial drilling and plugging the surface opening with a cement grout.
• In case of abandonment an additional attempt at completing the horizontal directional drill may be made in proximity to the previous route. A new hole would be drilled in the same general area as the initial drill hole. No alternative crossing methods would be implemented (i.e. wet trench) without the proper agency notification and approvals.
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Drilling Mud Containment, Response, and Notification Plan Enbridge Energy, Limited Partnership
Enbridge Pipelines (Southern Lights) L.L.C. March 20, 2009
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8.0 Restoration and Post-Construction Monitoring Following cleanup activities, restoration and revegetation of affected areas will be completed in accordance with Enbridge’s Environmental Mitigation Plan and Revegetation and Restoration Monitoring Plan. Enbridge will monitor the release site as appropriate to assure adequate restoration.
Attachments
• North Dakota Environmental Incident Report Form (web page) • Minnesota Pollution Control Agency – Reporting Spills and Leaks • Wisconsin BMP Field Manual; Chapter 4—Fuels, Lubricants, Waste
and Spills
If this is an emergency, or for additional assistance, please call the Department of Health or North Dakota Department of Emergency Services at the numbers shown above.
Environmental Incident Report This form is not for RCRA-exempt Oilfield Related Incidents.
(for RCRA-exempt Oilfield Incidents Click Here) (if you are not sure which form to use Click Here)
Fill out information as completely as possible. Use the <Tab> key or mouse to move between fields.
Pressing the <Enter> key while in the form will submit the report. Required fields shown in red.
North Dakota Department of Health Environmental Health Section
1.701.328.5210 or 5166
North Dakota Dept. of Emergency Services 1.701.328.8100
1.800.472.2121 State Radio 24-Hour Hotline
Reported By: First Name Last Name
Date Reported: (mm/dd/yyyy) Time Reported: (hhmm 24-hour military time; no colon)3/26/2008 1127
This space for State Agency use only. State Agency Person Who Received Call:
First Name Last Name
Responsible Party:
Contact Address: Line 1Line 2
City: State: Zip:
Contact Person: First Name Last Name
Contact Telephone: (e.g. 999.999.9999)
Property Owner if not the Responsible Party:
Has or will the incident be reported to Property Owner? Yes No Unknown
Date of Incident: (mm/dd/yyyy) Time of Incident: (hhmm 24-hour military time) (if unknown enter date of discovery) (no colon, i.e. 1330)
Estimated Duration of Incident/Release:
minutes hours days
Location of Incident:
County: Township: Range: Section: << Select County >>
Quarter Section:Quarter-Quarter Section:
Quarter-Quarter-Quarter Section:
NE NW SW SE NE NW SW SE NE NW SW SE
Page 1 of 3Environmental Incident Report
3/26/2008http://www.health.state.nd.us/ehs/eir/eir_general.htm
Description of Incident Location: (911 address or location from nearest town)
Distance to Nearest Residence or Occupied Building: feet miles
Type of Incident: pipeline leak tank leak tank overflow pump leak
vehicle accident fire OR type in other>>
Agriculture/Ag Chemical Related: No Yes
Description of Substance Released or of Concern: (include Trade and/or Chemical name if applicable)
Is this substance on EPA's Extremely Hazardous Substance List? No Yes Unknown
To find out if this substance is on the EHS list Click Here
Estimated Volume of Release:
gallons barrels pounds cubic yards
Describe Cause of Incident:
Immediate Risk Evaluation: (explosive atmosphere, immediate health hazards, etc.)
Number of Fatalities:
Number of Injuries:
0
0
What medium has been affected: << Select Affected Medium >>
Potential Environmental Impacts: (Describe impacts to, or likelihood of impacts to surface water, groundwater, soils etc.)
Action Taken and Recommended/Planned Future Action: (how spill was contained, soil excavated, emergency approval to
burn contaminant, evacuation of nearby personnel, etc.)
Where will recovered wastes be disposed?:
Other Agencies That Have or Will Be Notified:
State Fire Marshal State Highway Patrol Local Fire Department NDDES
Page 2 of 3Environmental Incident Report
3/26/2008http://www.health.state.nd.us/ehs/eir/eir_general.htm
NDDH Home Page
Last Updated: Tuesday, December 04, 2007 10:06:00 AM Allen Johnson - ND Dept. of Health - [email protected]
Local Law Enforcement Local Emergency Manager type in other>>
To see if this incident is required to be reported to the National Response Center (NRC) Click Here
Has or will the incident be reported to the NRC?? 1-800-424-8802
Yes No Unknown
Note: Pressing the submit button will send an E-Mail version of this completed Environmental Incident Report to NDDH Environmental Health Section and
ND Dept. of Emergency Services personnel.
Additional E-Mail Recipient to send report to: (if entering multiple email addresses, separate addresses with a comma - don't use any spaces)
This space for Department of Emergency Services use only. DES Incident Number:
Submit Report Reset
Page 3 of 3Environmental Incident Report
3/26/2008http://www.health.state.nd.us/ehs/eir/eir_general.htm
Reporting spills and leaks
Minnesota Pollution Control Agency • 520 Lafayette Rd. N., Saint Paul, MN 55155-4194 • www.pca.state.mn.us 651-296-6300 • 800-657-3864 • TTY 651-282-5332 or 800-657-3864 • Available in alternative formats
Cleanup fact sheet #1.01 • September 2006
c-er1-01
Reportable spills should be directed to the Minnesota Duty Officer by calling (651) 649-5451 or (800) 422-0798. The duty officer will record all pertinent information and then make the appropriate notifications to the state agencies.
inn. Stat. §115.061, which has been in effect since 1969, describes the duty of people to
notify the Minnesota Pollution Control Agency (MPCA) when spills and leaks occur:
115.061 — Duty to Notify and Avoid Water Pollution (a) Except as provided in paragraph (b), it
is the duty of every person to notify the agency immediately of the discharge, accidental or otherwise, of any substance or material under its control which, if not recovered, may cause pollution of waters of the state, and the responsible person shall recover as rapidly and thoroughly as possible such substance or material and take immediately such other action as may be reasonably possible to minimize or abate pollution of waters of the state caused thereby.
(b) Notification is not required under paragraph (a) for a discharge of five gallons or less of petroleum, as defined in section 115C.02, subdivision 10. This paragraph does not affect the other requirements of paragraph (a).
The law provides penalties of up to $10,000 per day for violations.
The Minnesota Department of Public Safety, Division of Homeland Security and Emergency Management, operates a 24-hour state duty officer service, establishing a one-call system for all state reporting requirements.
Reportable spills should be directed to the Minnesota Duty Officer by calling (651) 649-5451 or (800) 422-0798. The
duty officer will record all pertinent information and then make the appropriate notifications to the state agencies.
Spills that must be reported
Report spills that may cause pollution, such as spills of toxic, flammable, corrosive and dangerous industrial chemicals. Also report spills of environmentally damaging materials, including milk, coal, animal parts, batteries, etc.
Reportable quantities
Minnesota has a reporting threshold of greater than five-gallons for petroleum spills. Spills of any quantity of all other chemicals or materials should be reported. If in doubt, report.
Anyone who spills is required to report.
EVERY person who has “any substance or material under its control” must report spills and leaks. This includes:
• property owners who discover contamination;
• individuals, partnerships, companies and corporations;
• governmental subdivisions, including officers of these entities;
• owners of substances being stored or transported by another company; and
• contractors who are in physical control of a discharged substance.
Sometimes a fire department, police agency or other local or state agency
M
Reporting spills and leaks • September 2006
page 2
that responds to a spill or leak chooses to report the incident to the MPCA. In some circumstances, the entity may be required to report the spill. However, in no case does a report from someone else stand in lieu of your responsibility to report to the MPCA by calling the Minnesota Duty Officer if a substance is under your control.
Be aware that there may be other reporting requirements imposed by local ordinances, state or federal law, or permits. Understanding all reporting requirements is the responsibility of those who handle substances which can pollute.
It is the responsibility of the spiller to ensure an effective cleanup and proper management of all wastes generated. With the exception of used oil, waste generated from petroleum spills that have been reported and cleaned up immediately are exempt from Minnesota’s Hazardous Waste Rules. Waste from used oil spills must be sent to a facility for energy recovery.
For more information
For more information on spill prevention, cleanup or disposal, call the MPCA at (651) 296-6300 or (800) 657-3864 and ask for a member of the Emergency Response Team or go to www.pca.state.mn.us/cleanup/pubs/ertpubs.html on the Internet.
Also, visit the U.S. Environmental Protection Agency site at www.epa.gov/oilspill/ for more information.
Water Quality, Best Management Practices Field Manual
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Chapter 4 - Fuels, Lubricants, Waste and Spills● Fuels, Lubricants and Waste
● Spills
Fuels, Lubricants and Waste Logging, road building and other forest activities require motorized equipment. Antifreeze, fuels and lubricants used in machinery can potentially pollute lakes, streams, wetlands and ground water. Planning for forestry operations should include practices to handle solid and liquid wastes generated in the field.
The following BMPs will help prevent nonpoint source pollution from fuels, lubricants and wastes during forest management activities.
● Use biodegradable lubricants whenever practical. Biodegradable lubricants are less toxic than other lubricants but still need to be disposed of properly. To contact distributors of biodegradable lubricants, see Sources for Help.
● Maintain equipment regularly. Check hoses and fittings to prevent leaks or spills.
● Designate specific areas for equipment maintenance and fueling. Locate these areas on level terrain, a minimum of 100 feet from all streams and lakes.
● Collect all waste lubricants, containers and trash. Store them in leak-proof containers until they can be transported off-site for recycling, reuse or disposal at an approved site. Call your local DNR regional office for more information.
● Note: It is illegal to dump fuel and lubricants on the land or waters in the state of Wisconsin.
● Separate all fluids and materials and keep in different labeled
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Water Quality, Best Management Practices Field Manual
containers to avoid creating "hazardous waste" and expensive waste disposal. Call your local DNR regional office to determine if a waste is hazardous and how to dispose of hazardous waste.
Spills
Report all hazardous substance spills immediately to the Wisconsin Department of Natural Resources by calling the 24-hour Emergency Hotline number: 1-800-943-0003. Spills of fuel, lubricants, or pesticides during forest management operations can occur as a result of fueling, hydraulic hose breaks, mechanical damage or vandalism. All spills of hazardous substances that adversely impact or threaten to adversely impact public health, welfare or the environment must be (1) immediately reported to the DNR and (2) cleaned up. In some instances, small quantities of petroleum products and agrichemicals do not require reporting to the DNR. During timber harvesting operations, reporting a spill is not necessary for a gasoline spill under 1 gallon, or for a diesel or hydraulic fluid spill under 5 gallons, as long as there is no threat to the environment. However, the spill still needs to be cleaned up.
For more details on the spill reporting requirements or clean-up, contact your nearest DNR Regional Spill Coordinator:
● Milwaukee (414) 229-0838
● Madison (608) 275-3332
● Eau Claire (715) 839-3775
● Superior (715) 392-0802
● Rhinelander (715) 365-8963
● Green Bay (920) 492-5592
The following best management practices are general guidelines for spills of fuel and lubricants used in forestry field operations. These practices complement specialized training given to persons using pesticides or other hazardous materials.
● Maintain a spill-containment and cleanup kit appropriate for the materials on the operation. At a minimum, a kit for petroleum products should include:
■ plugs and clamps to control a hydraulic line break ■ a container to catch leaking fluid
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■ a shovel; and ■ absorbent material such as sawdust to absorb fluid, especially
useful in the winter when soil is frozen.
● If a spill should occur, do the following in order: 1. Protect yourself and others. Wear protective clothing and
equipment appropriate for any hazardous materials on the operation. Avoid coming in contact with any toxic drift or fumes that may be released.
2. If you are able, control the spill; stop the leak. 3. If you are able, contain the spill; keep it from spreading. Shovel a
dike around the spill. Use absorbent material, such as sawdust or loose soil, to soak up fluid. Place a bucket under a hydraulic hose break. Keep the spill from flowing into lakes or streams.
4. Isolate the spill material. 5. Report all hazardous substance spills immediately to the
Wisconsin 24-hour Emergency Hotline number: 1-800-943-0003. 6. Contact your local DNR regional office for disposal guidance.
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