Proceedings of the 2012 9th International Pipeline Conference IPC2012 September 24-28, 2012, Calgary, Alberta, Canada

IPC2012-90622

PERMITTING AND CONSTRUCTING A LARGE PIPELINE THROUGH A STATEREGULATED, SENSITIVE WETLAND RESOURCE: ALBERTA CLIPPER AND THE GULLY 30 CALCAREOUS FEN
James Arndt, Ph.D. URS Minneapolis, Minnesota, USA Paul Turner Enbridge Energy Company, Inc. Superior, Wisconsin, USA Scott Milburn Midwest Natural Resources, Inc. Minneapolis, Minnesota, USA

ABSTRACT Pipeline crossings of sensitive, state or federally-regulated resources are occasionally unavoidable and can substantially increase project costs and negatively affect project timelines. During due-diligence surveys for invasive plants, field botanists identified an undocumented calcareous fen and associated state-listed wetland plants along the route of Enbridges LSr and Alberta Clipper pipelines in northwest Minnesota. Calcareous fens are rare peat-accumulating wetlands dominated by groundwater discharge, a high mineral content, and are protected by state law. Their hydrology and chemistry provide an environment for a suite of state-listed plants that are specifically adapted and unique to calcareous fens. By state statute, calcareous fens may not be filled, drained, or otherwise degraded by any activity unless the Commissioner of the Minnesota Department of Natural Resources (DNR) authorizes the activity under an approved Fen Management Plan. The proposed LSr and Alberta Clipper Pipeline route in the area was collocated with existing Enbridge pipelines installed before the fen was identified. State regulatory staff quickly officially recognized the Gully 30 Calcareous Fen which initiated a lengthy permitting process to authorize Enbridge to construct the LSr and Alberta Clipper Pipelines through the Gully 30 Calcareous Fen. Avoiding the fen would have involved an impracticable reroute along several miles of greenfield. The state (DNR) and federal (Army Corps of Engineers) process involved detailed characterization of the resource, development and approval of an alternatives analysis according to Section 404(b)(1) guidelines, and drafting and approval of a project-specific Fen Management Plan which stipulated specific construction mitigation procedures including winter construction and protective temporary drainage, and post construction monitoring requirements. This presentation introduces the calcareous fen resource and examines the permitting and iterative, comment-response construction-design

process as an example of successful collaboration between state and federal agencies and Enbridge to construct a pipeline through a highly regulated, sensitive natural resource while maintaining schedule.

INTRODUCTION
Enbridge expanded its existing crude-oil transportation capacity in the United States by recently constructing two new pipelines in Minnesota: the LSr Project (20-inch pipe diameter) was completed in fall 2008 and the Alberta Clipper/Southern Lights Diluent Project was completed late 2010. The LSr and Alberta Clipper pipelines were generally collocated along Enbridge Energy Company (Enbridge) existing ROW through Polk County Minnesota which occupies beaches, terraces, and the bed of early phases of glacial Lake Agassiz along with associated outwash channels, till plains, and moraines (Thorleifson 1996). Previous work performed for the installation of the LSr pipeline identified a potential calcareous fen and several areas of State-listed threatened species near the Lake Agassiz beaches in Polk County. Although there was no calcareous fen listed under Minnesota Statute at that time, Enbridge developed an approximately 2-mile (3.2 kilometers) long route alternative for the LSr and Alberta Clipper pipeline installations to avoid the potential calcareous fen and Minnesota state-listed threatened and endangered plant species in and near the existing Enbridge maintained easement. In order to facilitate the reroute, Enbridge purchased several tracts of historic wetland that were effectively and partially drained by county and private surface ditches and subsurface drain tile for agricultural use. During additional due-diligence reviews for state-listed threatened and endangered and invasive plant species along the proposed alternative pipeline corridor, Enbridge sub-

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contractors identified additional potential unlisted calcareous fen and associated Minnesota state-listed plant species near the existing Enbridge pipeline right-of-way (ROW) in portions of Section 24 T150N R39W and Section 19, T150N R 40W. Because of the existing reroute and the nearby locations of several high-value natural resource areas, an additional reroute was not considered practicable, and formal permitting to cross calcareous fen and to take state-listed plant species was pursued.

Regulation, Route Selection, and Fen Management Plans

Calcareous fens are regulated as Outstanding Resource Waters in Minnesota and are characterized by specific soils, hydrology, groundwater chemistry, and vegetation criteria as defined in Minnesota Rules chapter 8420.0935 and expanded on in Berglund (1995) and in Leete et al. (2005). Once an area meeting calcareous fen criteria is identified by Minnesota Department of Natural resources (DNR) staff, the fen area is formally acknowledged as an Outstanding Resource Water by a Commissioners order published in the State Register and becomes subject to legal protection under state statute. Calcareous fens, as identified by the commissioners written order published in the State Register, may not be filled, drained, or otherwise degraded, wholly or partially, by any activity, unless the commissioner, under an approved management plan, decides some alteration is necessary (Minnesota Statute 103G.223)." DNR staff investigated the area of the potential fen on July 7, 2009 and determined that an area including an abandoned ditch containing state-listed threatened plant species and portions of the existing Enbridge easements in Section 30 T150N R39W qualified for listing as calcareous fen. The DNR indicated in an August 17 letter to Enbridge that DNR was formally proposing the area as being within the Gully 30 Calcareous Fen that would require avoidance to obviate the need for a Fen Management Plan (FMP) under MS 103G.223. The Gully 30 Calcareous Fen was officially recognized by the Commissioners Order in the August 31, 2009 State Register. The Order for the Gully 30 Calcareous Fen included a legal description of [l]ands that have been identified as containing a calcareous fen as defined in Minnesota Rules, Part 8420.0395, subpart 2. The land identified in the Commissioners Order is not a delineation of areas meeting calcareous fen criteria. Calcareous fens often exist as a component of larger wetland complexes supported by large-scale hydrogeologic conditions and processes. Regulation of impacts to calcareous fens focuses on maintaining the overall hydrogeologic conditions as well as addressing direct, proximate impacts to the fen. Therefore, the area within the boundaries described in the Commissioners Order may include wetland components that do not meet all calcareous fen criteria as well as upland areas.

The Gully 30 Calcareous Fen area as designated by the Commissioners August 31 Order consists of 200 acres (81 hectares) of historic wetland, portions of which have been effectively tile-drained or partially drained by both public and private ditches. For the purposes of FMP development the following features were defined and identified. The entire Enbridge existing ROW and the LSr and proposed Alberta Clipper ROW along with adjacent areas within ~100 feet of both Enbridge ROWs were assessed for listed plants and calcareous fen indicators. No other areas within the survey corridor for both Enbridge ROWs were examined in detail. The 200-acre (81 hectare) area identified in the Commissioners Order will generally be referred to as the Gully 30 Calcareous Fen in the following discussion. Because calcareous fen FMPs are required under MS 103G.223 to authorize activities that may adversely affect designated calcareous fens, Enbridge retained consultants with local expertise in calcareous fens and in obtaining listed plantspecies Take Permits. To facilitate the timely approval of construction activities, Enbridge collaborated early and often with DNR staff in the preparation of FMP to construct the Alberta Clipper pipeline through the Gully 30 Calcareous Fen. By consensus it was agreed at that the most efficient procedure would be to provide DNR with a document that would: 1. Provide an alternatives analysis under the Section 404(b)(1) guidelines to support a determination that the route through the Gully Fen was the Least Environmental Damaging Practicable Alternative (LEDPA). Characterize the resource to support an evaluation of potential impacts. Present Enbridges avoidance/minimization options. Present the essential features of a site-specific construction plan to minimize potential hydrologic and floristic impacts. Develop a fen monitoring plan to evaluate the presence and magnitude of any adverse post construction impacts. Present potential mitigation options for listed plant species that may be affected by the planned construction.

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DNR would evaluate the information provided, request additional information if needed, and consider the resulting plans and documentation for both a listed plant species Takings Permit and as a FMP required under MS 103G.223.

Alternatives Analysis
Guidance provided by the DNR as adapted from the Minnesota Wetland Conservation Act Chapter 8420.0520 indicates an alternative is considered feasible and prudent if it meets the following requirements: 1. 2. It is capable of being done from an engineering point of view. It is in accordance with accepted engineering standards and practices.

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3. 4. 5.

It is consistent with reasonable requirements of the public health, safety, and welfare. It is an environmentally preferable alternative based on a review of social, economic, and environmental impacts. It would create no truly unusual problems.

(4) proposed a monitoring plan to assess any adverse impacts of construction.

Three route alternatives were evaluated (Natural Resource Group 2009). The preferred route alternative as approved for the Alberta Clipper Project was found by the agencies to be the LEDPA for the following reasons, consistent with the 404(b)(1) and state guidelines when constructed under the conditions of the Gully 30 Calcareous Fen FMP. 1. Given the location of the existing Enbridge corridor and other infrastructure, the preferred route could not practicably avoid the east-west trending contact between Glacial Lake Agassiz and the Erskine moraine that is associated with conditions that would favor the presence of extensive historic calcareous fen and associated marsh, bog, and other wetlands. The preferred route was collocated with the LSr installation for which a route suitability analysis has been performed and avoids additional disturbance that would be associated with the establishment of another greenfield route alternative that would result in three Enbridge corridors contained within an area with diverse, environmentally sensitive features including historic prairie remnants, identified and potential calcareous fens, and state managed land. If an additional route were pursued, it was shown to be highly likely that additional listed plants and environmentally sensitive features would be identified along any of the additional alternatives. The preferred route minimized wetland impact by utilizing pastured upland and the only available, extensively disturbed agricultural land in the immediate area. The preferred route completely avoided other listed calcareous fens in the area. The preferred route traversed no undisturbed natural lands that are extensive along other practicable routes and maximized the use of effectively drained historic wetland and partially drained farmed wetland. Listed plants were avoided during the construction of LSr, and impacts to calcareous fen components and listed plant species were shown to be minimized during construction of Alberta Clipper under the FMP for the Gully 30 Calcareous Fen. While the preferred route could not practicably avoid traversing a portion of the Gully 30 Calcareous Fen that Enbridge identified during due-diligence field surveys, Enbridge, in cooperation with the DNR developed a FMP that: (1) characterized the area from a soils, hydrology, geochemistry, and floristic perspective; (2) identified the locations of listed species and calcareous fen components potentially impacted by construction; (3) proposed sitespecific construction procedures to minimize impacts; and

Resource Characterization: Gully 30 Calcareous Fen

Enbridge sub-contractors characterized all important environmental components of the hydrology, land use history, and calcareous fen criteria to support an analysis of the potential impacts to the Gully 30 Calcareous Fen. Hydrogeologic setting The hydrogeologic setting was evaluated by a detailed analysis of the Polk County Soil Survey, County geological atlases and regional hydrogeologic assessments, including analysis of borelogs for 183 wells available from the County Well Index (CWI), and an on-site analysis of peat thickness and peat substrate characteristics. The hydrogeologic setting of the Gully 30 Calcareous Fen and the surrounding area was found to be suited to the development of calcareous fens typically associated with sandy beach and nearshore areas of Glacial Lake Agassiz. However, the hydrogeologic setting in the Gully-Trail area that included the subject fens was found to be uniquely situated to support extensive calcareous fens (present as peat blankets sloping north to the deeper portion of the glacial lake) as the result of the presence of a large delta from a Pleistocene outwash channel of coarse textured sands and gravels being confined by discontinuous, relatively fine-textured lacustrine sediments and possible till that were deposited during successive transgressions of Glacial Lake Agassiz combined with glacial advances and recessions. All of the topographic, CWI, and soils data suggested that groundwater flow in the area of the Gully 30 Calcareous Fen is driven by recharge in adjacent sandy and loamy uplands to the south. Sandy areas are characterized by coarse surface textures and high infiltration rates that would maximize groundwater recharge, and high hydraulic conductivity values and hydraulic gradients that result in rapid downslope water flow. Potential hydraulic gradients indicated in the CWI data are steep and could be as much as 50 to 100 vertical feet (15 to 30 meters) over a distance of a few miles. The presence of confining lacustrine and till layers was thought to result in discrete areas of strong groundwater discharge where the confining layers were absent or thin. Given these conditions groundwater discharge was identified in areas relatively distant from the recharge zone as indicated by: (1) the presence of non-acid and calcareous peat soils on strongly sloping surfaces near the edges of the lake plain; (2) the presence of a nearby flowing well; and (3) the presence of leached mineral soils further out into the lake plain. The disruption of thin, confining lacustrine layers by trenching in areas where the surface stratigraphy is peat underlain by a fine-textured lacustrine layer that is itself

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underlain by the conductive outwash sands was indicated to potentially result in increased groundwater discharge in the trenched area. This increased groundwater discharge could result in the possible reestablishment of persistent saturation to the surface by calcareous groundwater after construction in areas of the Gully 30 Calcareous Fen that were partially drained by surface ditches. Land Use History Land use history is important to evaluate historic disturbance to the Gully 30 Calcareous Fen and was interpreted from historical aerial photography beginning in 1939 and extending through 2008, including Farm Services Agency (FSA) photography providing a continuous history from 1979 to 2002. This analysis provided land use history for the entire Gully 30 Calcareous Fen area that was identified in the Commissioners Order, but emphasized (1) the excavated ditch (referred to hereafter as the Ditch Fen) that contained the greatest amount of fen indicator species fo any feature within the Gully 30 Calcareous Fen, and had several state-listed plants and calciphiles as dominant species, and (2) the proposed construction ROW for the Alberta Clipper project that was contained within the Gully 30 Calcareous Fen area. The Gully 30 Calcareous Fen The hydrology of the area contained within the boundaries of the Gully 30 Fen was found to be substantially impacted by (1) the establishment of a county ditch, (2) associated public and private lateral ditches, and (3) the installation of subsurface drain tile. Extensive portions within the designated fen area had been partially drained, and field investigation suggested that additional areas affected by subsurface drain tile may be effectively drained and non-wetland. Earlier FSA air photos indicated intermittent plowing which may have been more prevalent south of the ditch containing the Ditch Fen. Portions of the Gully 30 Calcareous Fen have been physically impacted by soil disturbance resulting from pipeline construction. The Gully 30 Calcareous Fen area contains two Enbridge pipeline rights-of-way. The southernmost ROW was established in the 1950s and currently contains five pipelines with the last installation occurring in 1999. A second Enbridge ROW was established in 2008 and approved for the construction of the LSr and proposed Alberta Clipper projects to avoid listed plant species within the construction ROW. Construction ROW and the Ditch Fen Area An analysis of aerial photography from 1939 to 2002 indicated that the Ditch Fen was associated with a disturbed agricultural landscape. Agricultural use intensified from the period where the county ditch system was established (prior to 1939) to 1992. The ditch that includes Ditch Fen was established sometime between 1974 and 1979, and was a component of active agricultural land use to 1992. The field containing the Ditch Fen appeared to have been abandoned in 1992. Several periods of probable ditch

maintenance that exposed the ditch bottom were evident as light grey signatures associated with exposed soil in the ditch and on the ditch banks, and dark signatures associated with ponding in the ditch prior to 1992. Relatively frequent ditch maintenance was also suggested by the rapidity with which the ditch signature becomes less distinct after 1992. The ditch was barely distinguishable in the 1994 through 1997, 1999, and 2002 aerial photographs, and was likely largely filled in by 2008. While the ditch may have supported populations of calciphiles prior to 1992, abandonment was thought to result in the progressive, increased establishment of calciphiles in the ditch bed, especially the sod-forming calciphile beaked spikerush (Eleocharis rostellata, threatened in Minnesota). Historic photographic evidence combined with the field assessment of calciphile distribution suggested that the calciphiles in the Ditch Fen are opportunistic and are taking advantage of the presence of wetter conditions and active discharge of calcareous groundwater that occurs within the historic ditch. The air photo history is strongly suggestive that the Ditch Fen was incidental to the legal establishment of an agricultural ditch that was excavated for the purpose of converting adjacent fields formerly partially drained by the county ditch system to agricultural use. The LSr pipeline constructed in 2008 crossed the Ditch Fen and the county ditch using trenchless guided bore methods that avoided all impacts to listed plant species within the construction ROW. Calcareous Fen Criteria Current criteria to determine calcareous fens in Minnesota are in Leete et al. (2005). 1. Chemical Criterion. The pH is 6.7 or more; calcium of 30 mg/l or more; alkalinity of 1.65 meq/l or more; and, specific conductance of 500 S/cm or more. 2. Soils Criterion. Soils are characterized by the presence of either a Histosol or a histic epipedon. 3. Hydrology Criterion. Hydrology is characterized by having stable, typically upwelling groundwater inflows sufficient to maintain saturation for the development of a Histosol or a histic epipedon soil. 4. Vegetation Criterion. The area has a natural community index value of 50 or more by summing the appropriate regional index values of the vascular plant plus the bryophyte calcareous fen indicator species. Where both bryophyte and vascular plant data are available and the sites latitude is greater than 47 degrees, the natural community index value must exceed 80. 5. Conditional Fen. The current draft DNR vegetation criteria also consider areas that have been demonstrably disturbed as potential calcareous fen if soil, chemistry, and hydrology parameters are met but the vegetation community index value is between 30 and 50. Chemistry

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Sediments in recharge areas in sandy uplands south of the glacial lake plain are typical of water-sorted sediments derived from calcareous Des Moines till that was glacially eroded from exposures of carbonate bedrock to the north in Canada. Groundwater originating as generally acidic atmospheric precipitation percolating through the soil rapidly dissolves the carbonate to equilibrium. Carbonate rock is more soluble in cold water, and in water with a high partial pressure of CO2 gas. Both conditions are characteristic of soils and confined underlying sediments, and result in super-saturation with respect to calcium carbonate. When this groundwater discharges, it warms up, degasses CO2 to atmospheric levels, and evaporates. The result is the precipitation of the dissolved carbonate rock as secondary pedogenic calcite (Arndt and Richardson, 1992; Arndt and Dejoode, 2006) that is universally found in upland and wetland soils in the area of the Gully 30 Calcareous Fen. In active groundwater discharge locations, the upward hydraulic gradient maintains a high water table that is persistently at or near the surface (within 1 to 1.5 feet, 0.3 to 0.5 meters) in areas that are not tile drained. The resulting persistent chemically reducing environment retards the oxidation of organic carbon to CO2 and water, which historically resulted in the development of organic (peat) soils. All groundwater within the 200-acre (81 hectare) Gully 30 Calcareous Fen area and in areas extending well beyond the boundaries established in the Commissioners Order would be expected to meet calcareous fen chemical criteria. Soils and Hydrology Soils within and adjacent to the Gully 30 Calcareous Fen were identified as Markey soils (Sandy or sandy-skeletal, mixed, euic, frigid Terric Haplosaprists) that would be characteristic of calcareous fens formed in shallow peat over outwash sands in the Gully-Trail area. Markey soils are common peat soils in northwestern Minnesota and do not by themselves indicate the presence of a calcareous fen, though all would meet the calcareous fen soils criterion. The soils within Ditch Fen feature were found to be truncated and disturbed variants of adjacent Markey soils that are consistent with ditch excavation, subsequent sidewall collapse and infill, and ditch maintenance. It is unlikely that any excavation occurred below the sand layer due to the low strength and flowing nature of the sand substrate. Ditch spoil was observed covering the native Markey soils at several locations. A horizon of fine-textured lacustrine material overlying the sandy outwash was common and of sufficient depth to restrict focused groundwater discharge. All of the physical and hydrologic conditions exhibited within the ditch feature would favor the reestablishment of calciphile vegetation from seed present in the seed bank. The presence of partial drainage introduced by the ditch itself and the intact, relatively impermeable lacustrine layer in the soils away from the ditch would retard re-establishment of

calcareous fen conditions that may have been present prior to the establishment of area ditches. Groundwater recharge is expected to occur on coarsetextured Pleistocene terraces, a large stratified ice-contact ridge immediately to the south of the near-shore lake plain and in stratified ground moraine in upland positions to the south of the lake plain. Groundwater flows downslope through coarsetextured outwash to the glacial lake plain and becomes saturated with calcium carbonate because of the calcareous mineralogy of the sediments through which the groundwater is flowing. Groundwater discharge may be reduced in areas with overlying fine-textured lacustrine material with the reduction in discharge dependent upon the thickness and texture of the underlying fine-textured material. Active groundwater discharge would be associated with areas where lacustrine material is thin or non-existent. Diffuse and focused groundwater discharge through the partially confining lacustrine sediments maintains a high water table and provides continuous saturation sufficient for the development of extensive peat soils in spite of the fact that such soils are moderately sloping. The area of potential groundwater discharge is large, and would be impracticable to avoid completely by linear projects traversing the area. Vegetation An assessment of listed plants within and adjacent to the existing Enbridge maintained ROW within the Gully 30 Calcareous Fen identified several calciphiles characteristic of calcareous fens, including populations of Sterile sedge (Carex sterilis), Eleocharis rostellata, and hair beak rush (Rhynchospora capilliacea) (all state-threatened). Listed plant populations were not common but were scattered within and adjacent to the existing maintained ROW. The bed of the ditch containing the Ditch Fen feature met the criteria established for calcareous fens and contained calciphiles and state-listed species as dominants (especially C. sterilis, E. rostellata, and R. capilliacea); however, the area outside of the ditch bed meets the conditional calciphile vegetation criteria. This is consistent with information provided above suggesting that (1) the presence of persistent saturation with calcareous groundwater within the ditch is sufficient to maintain a high-quality calciphile community in spite of the disturbance, (2) it is possible that the disruption of the fine-textured lacustrine layer above the outwash sands has permitted a greater amount of groundwater discharge than present under undisturbed conditions, and (3) that partial drainage associated with the bounding county ditches and the two excavated ditches has reduced the duration of persistent saturation and affects surface chemistry sufficiently that large numbers of diverse calciphiles are not present outside of the ditch feature. However, the presence of C. Sterilis and several low point calciphiles in the partially drained land adjacent to the ditch strongly suggests that the entire area was calcareous fen prior to county ditching and may have been of much higher

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calcareous fen quality prior to disturbance. The presence of a diverse calciphile community with the Ditch Fen further suggests that there is a seed bank present that can take advantage of suitable conditions to re-establish calciphiles when the opportunity presents itself.

Avoidance and Minimization

Enbridge evaluated several crossing methods for the Gully 30 Calcareous Fen construction and tentatively proposed two Open Cut crossing modifications including Push-Pull for the mainline crossing and Sheet-Pile construction for the crossing of the Ditch Fen. During discussions with agency representatives late in 2009 it became apparent that more soil and substrate data was required to select an appropriate crossing method that would minimize impacts to the Gully 30 Calcareous Fen while being practicable from an engineering and safety perspective. A test pit investigation consisting of a series of up to seven backhoe pits dug to the approximate trench depth (7 to 8 feet, 2.1 to 2.4 meters) and evenly distributed along the proposed Alberta Clipper centerline was proposed by Enbridge and approved by the DNR and the Corps of Engineers (COE) as an existing permit modification. The analysis was completed October 2009. The analysis of sediment characteristics was evaluated in the field and office by contractor construction supervisors and Enbridge management with extensive experience in pipeline construction. They concluded the following: 1. Push-Pull methods were precluded by the fact that flowing sand rapidly filled the hole to above the minimum required depth of 7 feet. If Push-Pull methods were attempted, the likelihood that there would be insufficient depth of cover to satisfy Pipeline and Hazardous Materials Safety Administration (PHMSA) requirements would be great, and would require additional post-construction adjustments to reset the pipe to the proper depth. These remedial construction procedures would probably have more subsequent impact than the original construction and the impacts would be additive. 2. Push-Pull methods are not a feasible or prudent alternative for pipeline construction because they are not capable of being done from a construction point of view to achieve the desired depth of pipeline cover. 3. Sheet pile methods were not a feasible alternative due to the depth the sheet pile needed to be installed and the subsequent disturbance to the fen upon removal. 4. The ability of the material removed from the test pits to maintain piles without excessive slump and flow indicates that three-lift segregation, storage, and backfill are feasible and will be done. Enbridge consulted with the DNR and proposed that, based on the fen characterization provided above and the test pit study, the most feasible and prudent alternative for the installation of the Alberta Clipper pipeline is the use of

traditional open cut construction using a timber mat travel lane, with the trench and adjacent areas dewatered with sock tile installed below the level of the pipe lay. Typical Open Cut methods were used during LSr construction to cross the Gully 30 Calcaresous Fen and caused no unusual problems. Several additional impact minimizations were proposed: To minimize impacts to sensitive peat soils and substrates, construction would be planned for winter 2009 to 2010 to limit compression of the peat topsoil. All construction equipment would operate off of clean timber mats installed on frozen soils adjacent to the pipeline trench. To prevent trench wall collapse, the trench would be dewatered prior to excavation using a 12-inch diameter sock tile installed below the installed depth of the pipe. Piezometers would be installed in specific locations near the trench and monitored by trained geotechnical engineers to determine when the water table had been drawn down sufficiently to begin trenching. Three lift separation would be used within the trenched area. Topsoil (top 12 inches, 30 centimeters), the peat substrate (12 inches (30 centimeters) to the sand contact), and the underlying sand would be removed in order, stored separately on the ROW and replaced to the locations from which they were removed in reverse order (sand first, then peat substrate, then peat topsoil). Intact, native sod mats would be removed from the trenched area of the Ditch Fen that contained listed species. These sod mats would be removed, stored and protected under plastic until completion of construction. Sod mats would be restored to the exact locations from which they were removed and would be monitored subsequent to the restoration of the ROW. Because the 36-inch (0.91 meters) diameter Enbridge pipeline would displace sandy soil within the trenched area, the presence of a persistent trench mound and its affect on wetland character, surface hydrology, and fen function was a particular concern to prevent adverse impacts to fen hydrology. In collaboration with the DNR, Enbridge proposed to haul off approximately of the volume of sand calculated to be displaced by the pipe and dispose of the sand on nearby uplands owned by Enbridge. Topography across the trench and the construction ROW would be subsequently monitored as a component of the project-specific monitoring plan provided as a condition of the FMP.

Construction Related Features of the FMP Implemented During Construction

Several features of the FMP were developed by Enbridge and the DNR as conditions to the approved FMP. The

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following list provides the major features of pipeline construction through the fen that were developed in cooperation with the DNR to construct the Alberta Clipper Pipeline through the Gully 30 Calcareous Fen under the conditions in the approved FMP. Construction and ROW Preparation 1. Cleaning Mats. Construction timber mats were prepared using a rotating wire brush attachment and compressed air to ensure that mats used to support construction equipment were clean and free of excess soils that could potential provide a source of invasive weed seeds. 2. Signage and Access. Restricted entrance/egress signs were placed at the Gully 30 Calcareoous Fen boundaries, and the location of the Ditch Fen as an environmentally sensitive area was established with signs posted. 3. Timber mats. Clean timber mats were installed adjacent to the trenched area to support construction equipment while minimizing disturbance to the soil surface. 4. Free-span Bridges. Free-span bridges were installed at the two crossings of the County ditch, and the crossing of the Ditch Fen. 5. Topsoil Stripping and Topsoil Storage Location. Twelve inches of topsoil was stripped across the trench area with a buffer adjacent to the trench to minimize potential mixing of the surface topsoil with subsoil. The topsoil was stored on the existing ROW as appropriate to facilitate topsoil storage and replacement. Most topsoil was stored adjacent to and south of the timber mat road. Some topsoil was stored to the north of the trench near the LSr pipeline corridor. All topsoil was stored and maintained within the permitted construction corridor. 6. Ditch Fen Sod Removal and Storage. The stripping and storage of the sod in the Ditch Fen that contained statelisted plant species was performed under the supervision of agency staff and fen experts approved by the DNR and Environmental inspectors representing Enbridge. The stripping was initiated by a backhoe with a large blade that cut the sod into approximate 6 foot by four foot mats. The sod pieces were sequentially numbered and placed on plywood nailed to timber mats. These mats were then moved to a nearby area prepared to store the sod for subsequent return to the locations from which they were removed. When it became evident that the construction was going to last longer than anticipated, the MnDNR was contacted, and the sod was covered with clear plastic in order to prevent desiccation. 7. Socktile. A series of test pits indicated that trench stability issues would require a procedure to stabilize trench walls during construction. The chosen method involved installation of a sock-tile (perforated plastic pipe) installed such that it would be up to two feet under the pipeline once the pipeline was installed. Water removed

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from the drain-tile would lower groundwater sufficiently to stabilize the trench walls where sandy subsoil was present. Tests with the sock-tile installation machine indicated that there would be problems with the extreme cold temperatures resulting in breakage of the sock-tile segments as they were installed. The solution required the construction of a trailer mounted, heated enclosure that would pre-heat the coiled plastic pipe prior to installation. The trailermounted enclosure was pulled by a truck along the timber mat road. The trailer-truck combination closely followed the sock-tile installation machine as it installed segments of sock-tile. The sock-tile installation machine travelled along timber mats placed at a sufficient distance to support the tracks of the machine while leaving the area between the tracks for the sock-tile installation. At the end of the segments the tail of sock-tile pipe riser was cut off above ground level and the installation of the next segment began. The butting ends of the segments were separated by 20 to 30 feet (6.1 to 9.1 meters) of trench line with no sock-tile installed. During trenching, the segments of the un-perforated sock-tile riser that were above trench depth were cut off with the backhoe bucket, and the remaining pipe crushed by the bucket to ensure that no hydrologic connection would exist between the sock-tile segments. Piezometer Installation, Sock-tile Dewatering and Discharge and Groundwater Monitoring. Piezometers were installed to monitor the drop in groundwater in the trench area. Groundwater removed via high-capacity pumps attached to sock-tile risers was directed through a manifold system to a sediment control structure designed to release treated water to the county ditch. Consulting hydrologists designed and located piezometers at varying distances from the sock-tile drainage system to monitor groundwater drawdown. roundwater levels were monitored and tracked. When groundwater levels adjacent to the planned trench had been drawn down to near the planned trench depth, trenching commenced using backhoes operating with the tracks straddling the trenched area.

Trenching, Lowering in, installation of Ditch Plugs, replacement of Subsoil Lifts 1. Trenching and Two-lift Subsoil Storage. Trenching involved removal of subsoil peat and underlying sands as separate lifts. Subsoil peat consisted of peat underlying the 12-inch layer of topsoil that had been previously stripped from the trenched area and buffer. Subsoil sand consisted of unconsolidated mineral sands underlying the peat.

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Subsoil peat was temporarily stored on the side opposite from the previously removed topsoil. Subsoil sand was generally stored on the timber mat access road. Trenching proceeded rapidly. Ultimately water discharged to the bottom and sides of the trench resulted in a spring run of clear groundwater that discharged to the county ditch. Lowering-in, Placement of Bag Weights, Installation of Trench and Ditch Plugs. Pipe that was previously strung, welded, coated, and inspected was on timber cribs on a narrow timber mat lane immediately adjacent to and to the north of the timber mat road. Trackhoes operating off of the timber mats rapidly lowered in the pipe. Sack (bag) weights consisting of large, sand-filled polyethylene bags were trucked in along the access road and were set on the installed pipe by backhoes also operating off the timber mats. Contractor crews placed trench and ditch plugs consisting of sand bags installed in the trench at the boundaries of the Gully 30 Calcareous Fen (2 plugs), on both sides of the Ditch Fen (2 plugs), and on both sides of the county ditch (2 plugs). Two-lift Subsoil and Topsoil Replacement. Sand subsoil that was placed on the timber mats or in areas adjacent to the trench was replaced to the trench and was brought to the approximate level of undisturbed sand observed in the trench wall. Excess sand that was displaced by the pipe and sack weights was removed to a suitable offsite location north of the Gully 30 Calcareous Fen in an area of historic agricultural land that was purchased by Enbridge to support the LSr/Alberta Clipper Fen reroute easement. Peat subsoil consisting of frozen and unfrozen peat was then mounded on the trench and was left to melt and subside in preparation for final restoration in spring 2010. Topsoil was thoroughly frozen preventing final restoration until spring 2010. Timber mats were left in-place until final restoration. Ditch Fen Sod Replacement and Final Leveling. Trenching, application of sack weights, establishment of sandbag ditch plugs, replacement of sand and peat subsoil, and replacement of frozen sod mats to areas of the Ditch Fen from which they were removed was observed by DNR-approved fen experts, environmental inspectors, and agency staff. Replacement of peat subsoil was complicated by the peat pieces being frozen and in large clods which precluded the leveling of the peat subsoil in preparation for sod replacement.

Native frozen peat subsoil from the Ditch Fen area was subsequently ground up to a fine consistency in a special backhoe bucket called a padder bucket that is typically used to break up clods and remove stones from soil placed in contact with the buried pipe to ensure the integrity of the pipe coating. Ground-up peat was replaced to the top of the sand and appropriately leveled in preparation for receiving the sod pieces. Clear plastic was removed from the frozen peat mats and each mat was returned to the area from which it was taken. However exact matching of sod edges and establishing the original level was not possible due to the irregular thickness and perimeter, and the frozen nature of the sod pieces. In the interim, the entire area was covered with black plastic and left to thaw. Final leveling of the peat pieces was performed during final grading and clean-up, spring 2010.

Replacement of Topsoil, Final Grading, and Restoration of the Ditch Fen to Pre-construction Contours 1. Interim Environmental Monitoring. Construction exclusive of topsoil replacement and final grading was completed by the end of January 2010. Environmental inspectors monitored topsoil pile thaw and the effectiveness of erosion control devices and repaired/replaced these as necessary. Topsoil piles were extremely slow to thaw because as the peat surface thawed, it dewatered, resulting in a relatively dry layer of peat that effectively insulated the underlying peat and maintained a frozen condition well into spring. The peat subsoil mounded over the trench did subside and was reduced in volume. 2. Grading, Topsoil Replacement, Trench-Mounding and Subsidence. Because of the slow thaw of topsoil piles, it was decided to break the topsoil piles up and spread them out to facilitate a more rapid thaw. Once topsoil piles were thawed and suitable for replacement, the subsoil peat mound over the trench was graded down with excess material removed to a suitable off-site location on Enbridge land north of the Gully 30 Calcareous Fen. Topsoil was returned to the trench area and was graded to leave an approximate 12-inch high mound over the trench to accommodate future settling. The 12-inch mound was deemed more appropriate than the planned 6-inch mound based on the amount of subsidence that had occurred over the previous LSr construction. 3. Reestablishing Original Contours in the Ditch Fen. Review of the sod mat pieces that were returned to the bottom of the Ditch Fen indicated that, as expected, thicker

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pieces were above grade while thinner pieces were covered with shallow water. Resetting sod pieces to original contours was considered; however, the sod was watersaturated and sufficiently plastic to preclude resetting them. Mat Removal and Clean-up. Mats were removed, and erosion controls were established and monitored throughout summer 2010 until sufficient vegetation had been re-established to remove the erosion controls.

Postconstruction Monitoring
Enbridge proposed a 5-year monitoring program for hydrology and 10-year monitoring program for vegetation to determine any effects pipeline construction may have on the Ditch Fen calcareous feature and to other areas within the boundary of the Gully 30 Calcareous Fen area identified in the Commissioners Order that could be affected by pipeline construction. If adverse effects remain after 10-years, Enbridge will negotiate with the DNR to appropriately mitigate such impacts as remain. The monitoring program included: Hydrology Hydrologic monitoring was required under the FMP during the frost-free period for each of five consecutive postconstruction years at four locations. Hydrologic monitoring will compare water levels in up-gradient and down-gradient piezometer nests established within the Ditch Fen feature with piezometers established outside of the Ditch fen Feature. Hydrologic monitoring may cease earlier than five years if approved in writing by DNR. However, if monitoring indicates that adverse impacts to fen hydrology as a result of the Alberta Clipper construction have not stabilized after a period of five years, additional monitoring including length of time and required procedures will be negotiated between Enbridge and the DNR. Reestablishment of Pre-construction Contours Monitoring the re-establishment of pre-construction contours by noting and observing the hydrologic and vegetative conditions along the trench line where a 6-inch (15 centimeter) mound was proposed to remain to account for settling. If necessary, Enbridge will re-establish contours as approved by the DNR by re-grading with small footprint, low ground pressure equipment. Chemistry Monitoring groundwater chemistry (pH, electrical conductivity and major cations (calcium, magnesium, sodium, and potassium) and anions (alkalinity, sulfate, and chloride) from piezometers and water table wells during the summer sampling was required under the FMP for post-construction sampling during years 1, 3, and 5.

Plant Restoration Success Including State Listed Species Monitoring of plant restoration success within the portion of the Ditch Fen within the Alberta Clipper construction ROW would be performed during post-construction monitoring years 1, 3, 5, 7, and 10 in a series of fixed-area quadrats permanently established at six locations within the construction ROW of the Ditch Fen (two quadrats within the trenched area, one each on the working side and spoil storage side, and one off-ROW quadrat on each side of the construction ROW but within the Ditch Fen; and at 15 additional locations established along three transects (3 quadrats each transect representative of the working side, the trench, the spoil storage side, and one offROW quadrat for each side of the construction ROW). Miscellaneous Monitoring Conditions Soil descriptions by a Professional Soil Scientist licensed in the State of Minnesota will be collected at all piezometer nest and vegetation sampling locations (quadrats or releves). Additional monitoring conditions will be applied as necessary as negotiated between the DNR and Enbridge Energy or its delegate. Release Criteria Ditch Fen Area Enbridge agreed to continue monitoring according to the schedule proposed above for post construction years 1 through 10. Enbridge will be released from further monitoring if plant distribution data indicate that the on-ROW plant distribution within the disturbed area of the Ditch Fen is within 80% of the off-ROW plant distribution (but still within the Ditch Fen) and groundwater monitoring well results establish a clear equilibrium indicating that the up-gradient and down-gradient groundwater levels and chemistry establish that no significant construction-related hydrologic alterations have resulted. Specifically, the FMP established the following vegetation release criteria for the portions of the Ditch Fen that were be stripped of sod and trenched through: 1. Eighty percent or more of the species that were documented in pre-construction surveys shall be present at the end of the 5th growing season (41 species x .80 = 33 species). 2. The species observed in pre-construction surveys shall collectively comprise 80 percent or greater areal cover at the end of the 5th growing season. 3. The state-listed species Eleocharis rostellata shall comprise 50 percent or greater areal cover (pre-project conditions were 50 percent to 75 percent) at the end of the 5th growing season. 4. All invasive and/or non-native plant species shall be controlled using DNR-approved methods for 5 growing seasons. If a major problem with invasive species arises (e.g., Canada thistle (Cirsium arvense), reed canary grass

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(Phalaris arundinacea)), Enbridge will contact the DNR to determine the best course of action. 4. Gully 30 Calcareous Fen Outside of the Ditch Fen Area Enbridge proposes to utilize the same survey methods to evaluate the re-establishment of native vegetation in areas adjacent to the trench outside of the Ditch Fen area. However, because representative pre-construction plant surveys were not obtained in the Gully 30 Calcareous Ffen adjacent to the construction ROW outside of the Ditch Fen area, on-ROW data would be compared to off-ROW data obtained late spring in 2010. 1. Eighty percent or more of the species listed in releves established in 2010 shall be present at the end of the 5th growing season. 2. The species listed by releves established in 2010 shall collectively comprise 80 percent or greater areal cover at the end of the 5th growing season. 3. All invasive and/or non-native plant species shall be controlled for 5 growing seasons as described above. 5.

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Lessons Learned
The experience that the DNR and Enbridge developed in dealing with calcareous fens in and near the listed Gully 30 Calcareous Fen represents valuable information illustrating how regulatory agencies and an applicant can collaborate in the development and implementation of a FMP, and was requested by the DNR in lessons learned document to be used in future pipeline construction (Arndt 2011). A successful FMP avoids adverse impacts to the extent practicable, minimizes unavoidable impacts, and mitigates these impacts as required by statute. The following are important lessons learned by both the DNR and Enbridge while constructing the Alberta Clipper 36-inch pipeline through the Gully 30 Calcareous Fen. General 1. There may be certain situations where project impacts to calcareous fens cannot be practicably avoided. As the distribution and nature of the calcareous fen resource becomes better characterized, it is likely that landdevelopment conflicts and project with unavoidable impacts will occur. 2. Some areas in Minnesota likely supported extensive calcareous fen of potentially several thousand contiguous acres. The Gully 30 Calcareous Fen area is an example of such an area. 3. Agency and client collaboration are necessary to determine avoidance strategies when the presence of extensive calcareous fens are indicated or known. The identification of potential calcareous fen habitat and characterization of potential calcareous fen soils, vegetation, and hydrology along potential minimization/avoidance alternatives is an 8.

essential first component of a minimization/mitigation strategy when complete avoidance is not practicable. Avoidance/minimization route alternatives should be closely examined for feasibility. If avoidance is demonstrably impracticable, a FMP should be developed that characterizes the resource, identifies potential minimization routes, and informs a constructability assessment with geophysical and hydrologic features that are important construction considerations. Applicants should be aware that agencies take their regulatory responsibilities seriously and that impact issues can slow or stop a project for several months or longer. Construction procedures with the potential to minimize impacts need to be supported not only from an economic perspective, but from a resource impact minimization perspective in order to select the least damaging practicable alternative. Agency staff directly involved in regulating a specific project with potential fen impacts should understand applicant construction, cost, timing, and practicability constraints on large projects especially. Prescriptive hypothetical minimization procedures, especially if untested, may not be feasible, and alternatives in the event that a minimization procedure is impracticable need to be discussed. The FMP should include a process to effectively and efficiently manage change to accommodate necessary but minor adjustments to the conditions of the plan. Necessary changes to the plan may result from adverse field conditions or other demonstrable constraints on expected construction practices.

Construction 1. Winter construction is a viable construction alternative that minimizes adverse impacts because matting frozen soils significantly reduces traffic impacts to sensitive peat sod when the sod is frozen. First post-construction growing season (2010) recovery was excellent based on initial field reviews. It is unknown how effective matting would be to minimize impacts when the surface peat is saturated and unfrozen. However, compaction and consolidation of peat and sand may be substantially greater under unfrozen conditions. 2. Test pit analysis performed to determine hydrologic characteristics of the sand substrate and trench wall stability within the Gully 30 Calcareous Fen indicated that temporary manipulation of groundwater in the trench was an alternative to minimize/avoid trench stability issues and the resulting impacts on undisturbed fen adjacent to the trenched area. Other options include sheet-pile and push-pull methods as suited to the construction setting. Sheet pile was successful for the crossing of the county ditch, however, staging a long sheet pile crossing through extensive areas of calcareous fen was

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not a practicable alternative for the crossing of the Gully 30 Fen. While winter construction is a viable minimization alternative, winter construction in certain locations where low temperatures are normal (e.g. Polk county MN) is (1) dangerous, and (2) complicates all pipeline construction options including several ancillary minimization construction options proposed for calcareous fens. Sheet-piling was used for the County Ditch crossings and was effective, but was not considered practicable from an engineering perspective for extensive use along the ROW. The alternative of sock-tile dewatering was effective, but had the following practicability and timing issues (with solutions). Perforated polyethylene sock-tile was brittle at low temperatures and constantly broke during installation, requiring development of a heated tile enclosure to keep the sock-tile warm until just prior to installation. Because the hydrologic characteristics of the sand substrate favored extremely rapid permeability, it took a long time (approximately two weeks) to draw the watertable down sufficiently to the level that theoretically would stiffen the trench walls. Watertable drawdown was complicated by freezing pumps and distribution water lines. Piezometer results indicate that water-table recovery was rapid when the pump for a given segment failed. However, because the trenching process was extremely quick, trenching in the Gully 30 Calcareous Fen after the groundwater had been drawn down was characterized by a minimum of trench wall failure. Groundwater discharge to the lower portions of the trench walls and through the bottom of the trench was rapid. However, because it formed a shallow spring run that rapidly discharged down-gradient to the county ditch crossing, a pool never formed that would have compromised trench wall stability. Thus the presence of a relatively steep gradient of the Gully 30 Calcareous Fen and surrounding area may have been as important in minimizing trench wall failure as the initial groundwater drawdown. If the gradient was less, the trench would have rapidly filled with water resulting in trench wall failure. When considering trench wall stability in future pipeline construction, hydrologic characteristics of the substrate (peat depth, depth to sand contact and hydraulic conductivity), length of wetland crossing, and season of construction need to be considered. Frozen soils and substrates postponed final grading and restoration. Contractors cannot practicably break-up frozen in-situ peat and substrate clods removed during trenching and massive and frozen soil in piles that had been stored for a long time on the right-of-way. However, because winter is a time of plant senescence and dormancy

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coupled with in-situ frozen surface soil, performing interim return of subsoil to the trench and leaving stored subsoil and topsoil for spring restoration did not appear to substantially affect the restoration based on the observed conditions of the right-of-way during the spring final restoration. Final restoration was characterized by the following features: As surface peat in frozen piles thawed, it dewatered and effectively insulated the underlying frozen peat. Thus, exposed peat soil in windrows and piles were solidly frozen, and frozen conditions would persist through May well into June if attempts are not taken to break-up the piles and let air and sun thaw the soil. Once thawed, the soil was easily worked and returned to the trench areas from which it was taken. Removing displaced soil is necessary. Because the 36inch pipe and the sack weights displace a volume of soil, a roughly equivalent amount of soil should be removed to a suitable off-site location to result in a final grade that presents a 6 to 12 inch (15 to 30 centimeter) mound (depending on subsoil conditions) over the trenched area. A 12-inch (30 centimeter) mound was left over the Alberta Clipper trench line to account for future settling and subsidence. The 12-inch mound (30 centimeter) was based on the presence of subsidence and a shallow depression across the trenched area of the adjacent LSr pipeline construction that employed a 12-inch mound. The persistence of the original ~12 inch mound on the Alberta Clipper pipeline will be assessed during the required 10-year monitoring period. When treated properly, fen plants reserved and protected on the ROW may overwinter well. Enbridge had originally planned to remove the Ditch Fen sod, trench, install the pipe, backfill, grade and replace the sod to pre-construction contours within a very short period of time to minimize adverse impacts to the listed species. However, the actual time between removal of the sod and its replacement extended from December 8, 2009 to January 13, 2010, well over a month. Because the sod pieces were solidly frozen when returned on January 12, 2010, final resetting to the pre-construction contour was postponed till May 26, 2010. The process complicated returning the sod to the pre-construction contours and required manually compressing raised sod and covering submerged sod pieces with native peat soil. Initial observations indicate good restoration and plant recovery. The monitoring of the Ditch Fen listed plants and the sod restoration effort is one major focus of the subsequent monitoring effort that is in the FMP.

References
Arndt, J.L. 2011. Executive summary and lessons learned. Memorandum from Dr. James Arndt to Paul Turner,

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Enbridge Energy. Prepared for Enbridge Energy Limited Partnership, Alberta Clipper and Southern Lights Diluent Pipeline Projects by Midwest Natural Resources, 744 James Avenue, St. Paul, Minnesota 55102. Arndt, J.L., and J.L. Richardson. 1992. Carbonate and gypsum chemistry in saturated, neutral pH soil environments. In Aquatic Ecosystems in Semi Arid Regions; Implications for Resource Management, R.D. Robarts and M.L. Bothwell (eds.). N.H.R.I. Symposium Series 7, Environment Canada, Saskatoon, Saskatchewan, Can. Arndt, J.L. and D.D. Dejoode. 2006. Phase 1 characterization Seminary Fen Wetland Complex TH 41 Over the Minnesota Highway Project, Carver County Minnesota. Prepared in support of the Environmental Impact Statement, Minnesota Department of Transportation. Peterson Environmental Consulting, Inc. Mendota Heights, MN. Berglund, E. (Chairman). January 1995. Technical criteria for identifying and delineating calcareous fens in Minnesota. Minnesota Department Natur. Res., St. Paul. Enbridge Energy, LP. 2009. Background and Fen Management Plan Gully 30 Calcareous Fen Alberta Clipper Pipeline Project. Natural Resource Group Leete, J.H., W.R. Smith, J.A. Janssens, and N. Aaseng. April 13, 2005. Final report to the USEPA: Test of the technical criteria for identifying and delineating calcareous fens in Minnesota and draft revised technical criteria for identifying calcareous fens in Minnesota. Clean Water Act Section 104(b)(3) Grant Number CD-97504601-3, Minnesota Department of Natural Resources. St. Paul, Minnesota. Natural Resource Group Inc. 2009. Background and fen management plan Gully 30 Calcareous Fen Alberta Clipper Pipeline Project. Prepared for Enbridge Energy Limited Partnership. Alberta Clipper and Southern Lights Diluent Pipeline Projects. Natural Resource Group Inc. 80 South 8th Street, IDS Center, Minneapolis Minnesota. Thorleifson, L.H., 1996, Review of Lake Agassiz history, in J.T. Teller, L.H. Thorleifson, G. Matile and W.C. Brisbin, 1996, Sedimentology, Geomorphology and History of the Central Lake Agassiz Basin - Field Trip Guidebook B2; Geological Association of Canada/Mineralogical Association of Canada Annual Meeting, Winnipeg, Manitoba, May 2729, 1996.

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