Line 9 hearings move to Toronto; Enbridge feeling the heat.

The final oral arguments on Enbridge's Line 9 oil pipeline began last week in Montreal and will finish up in Toronto this week

 

Metro Toronto Convention Centre, South Building
222 Bremner Boulevard, Toronto
Wed. Oct 16 - Sat. Oct 19, 9:00am - 6pm
Our submission will be made either late Wednesday (the 16th) or early Thursday (the 17th) depending on the length of preceding submissions
Listen in online - see link below

Hearings are being streamed live (audio only) over the internet at
http://www.meetview.com/neb/index.php?enter

 

Enbridge made two important concessions to its critics in its opening statement. They announced they would add 17 new valves to the line (a 50% increase). Two of those valves will be in Durham Region, one near Anderson St. in Whitby and one near Hwy 35/115 in Clarington. 

Also, in response to criticism of its inadequate emergency response plans, they announced "the establishment of a pipeline maintenance work crew in Mississauga commencing in the third quarter of 2014. This crew would provide emergency response to any pipeline incident in the Greater Toronto Area."

These concessions are welcome but they fall well short of what is needed.

We contend that Enbridge's claims of safety and environmental sustainability are not justified by its record and that the changes proposed in Enbridge's application to reverse the flow and increase its capacity would be a serious risk to Durham Region and should not be approved without considerable improvements.

Our concerns are:

  • Pipeline integrity: Our own questions and those of other intervenors have uncovered numerous problems such as untreated corrosion. We are asking that the pipe should be rebuilt to new 'modern' standards and that much more robust monitoring programs be put in place to ensure safety.
  • Environmental Assessment: We also believe that a full environmental assessment is required. In our investigations we have found no evidence that such as assessment was undertaken when it was first built in 1975 and nothing since. This is a particular concern because Durham Region has a higher concentration of water crossings than any other stretch of 9B. There are currently only 2 valves in Durham with 85,300 barrels of oil between them.
  • Inadequate emergency response: Enbridge has its spill response teams in Belleville and Waterloo and admit that it will take a minimum of 90 minutes to respond to a spill in Durham. This is a concern cited by many intervenors.
  • Inadequate leak detection: Enbridge has admitted that their much touted computerized leak detection will not detect a leak under 3.7 barrels per minute. They also admitted that 30% of all leaks are first reported by 3rd parties from odours and oil slicks. Far more sensitive leak detection systems are available but the pipeline industry doesn't use them because they cost money. We are asking the NEB to require Enbridge (and all pipeline companies) to install systems which will detect even small leaks in real time.
  • Dilbit: Dilbit is a mixture of bitumen (heaviest grade of crude oil - consistency of honey) which is more corrosive than regular crude oil, and a light volatile diluent which is highly flammable, explosive and an inhalation hazard. Not wanted in Durham!

Important Meetings about Algae & Airports

Toronto Region Conservation Authority Public information Forum
October 24th, 5:00 - 9:30 pm, formal presentation @ 7pm 
HMS Ajax Room at the Ajax Community Centre, 75 Centennial Rd

TRCA will present results of an 'extensive' water quality sampling program along the waterfront. We have seen some preliminary results which suggests the report may be flawed and we may need to challenge this.


Land over Landings Public Meeting
Featured speaker will be Carl Cosack, the farmer who led the successful mega-quarry fight and who now heads up Food & Water First.

Also: Why a Pickering airport would fail, and why preserving farmland – the land that feeds us – is essential to our future.

October 22,
Doors open at 7 p.m.; meeting starts at 7:30

Claremont Community Centre,4941 Old Brock Road, Claremont


Public Information Forums
Duffin Creek Sewage Plant Outfall EA
October 29 - Pickering
October 30 - Ajax

Locations have not yet been announced
Check at DurhamCLEAR.ca or saveourwaterfrontnow.com for updates

 

Important Meetings on Airports and Algae

Toronto Region Conservation Authority Public Information Forum
October 24th, 5:00 - 9:30 pm, formal presentation @ 7pm 
HMS Ajax Room at the Ajax Community Centre 75 Centennial Rd
TRCA will present results of an 'extensive' water quality sampling program along the waterfront. We have seen some preliminary results which suggests the report may be flawed and we may need to challenge this.

Land over Landings Public Meeting
Featured speaker will be Carl Cosack, the farmer who led the successful mega-quarry fight and who now heads up Food & Water First.

Also:
Why a Pickering airport would fail, and why preserving farmland – the land that feeds us – is essential to our future.

October 22, Doors open at 7 p.m.; meeting starts at 7:30

Claremont Community Centre,4941 Old Brock Road, Claremont

 

Public Information Forums


Duffin Creek Sewage Plant Outfall EA
October 29 - Pickering                                October 30 - Ajax
Locations have not yet been announced

Old concrete can protect aquatic ecosystems

 
Thu, 08/22/2013 - 10:27am
copied from http://www.rdmag.com/news/2013/08/old-concrete-can-protect-aquatic-ecosystems

Melanie Sønderup collecting water samples from full-scale experiment. Credit: Lene Esthave/SDUMelanie Sønderup collecting water samples from full-scale experiment. Credit: Lene Esthave/SDULakes and streams are often receiving so much phosphorous that it could pose a threat to the local aquatic environment. Now, research from the University of Southern Denmark shows that there is an easy and inexpensive way to prevent phosphorus from being discharged to aquatic environments. The solution is crushed concrete from demolition sites.

Usually we think of demolished concrete walls and floors as environmental contaminants, but in fact this material may turn out to be a valuable resource in nature protection work. This is the conclusion from researchers from University of Southern Denmark after studying the ability of crushed concrete to bind phosphorus.

"We have shown that crushed concrete can bind up to 90 per cent of phosphorus, "says PhD student and environmental engineer, Melanie Sønderup, Department of Biology at the University of Southern Denmark.

Contributors to the research are also postdoc, PhD, Sara Egemose and associate professor Mogens Flindt from the same place. Since March 2013 the researchers have tested the technique in a full-scale experiment, which will run until March 2014. But already now they find that the technique is very effective.

Large amounts of phosphorus can be washed out into lakes and streams when it rains. Rainwater that runs off from catchments, especially those fertilized with phosphorus, carries the phosphor with it. This phosphorus rich rainwater is then often collected in rainwater ponds, which discharges into lakes and streams.

"The water in these rainwater ponds can be very rich in phosphorus, and if it is discharged into a lake, it can lead to an increase in algae growth.  This can lead to oxygen depletion and a reduction in the number of species that can live in the water," explains Melanie Sønderup and continues:

"By letting the pond water pass through a filter of crushed concrete, we can remove up to 90 per cent of the phosphorus”.

Phosphorus binds so well to the concrete because it contains cement. Cement is rich in calcium and also contains aluminum and iron. All three can bind phosphorus. Preliminary results show that the size of concrete grains is of importance. The smaller the grains the better they bind phosphoros. Fine concrete powder is thus more effective than millimeter sized concrete bits.

"It is also important that we do not use concrete that has been exposed to wind and rain for a long time, as this washes out the cement, which holds the essential calcium," explains Melanie Sønderup.

As the experiments have only run for six months, the scientists do not yet know the durability of crushed concrete, but they believe that a filter of crushed concrete can last for a long time, probably several years.

“Only when the concrete cannot bind more phosphorous, it will be time to switch to a new layer of crushed concrete―and then the disposed layer can be recycled as road fill,” says Melanie Sønderup.In its first months the filter of crushed concrete needs some assistance:

"In the first app. six months, the water flowing through the filter has a high pH value. This is because the cement in concrete is alkaline, and therefore, the water that comes in contact with the cement, is also alkaline. This can be compared to the water that bricklayers often work with when they mix cement or limewash.  

“Water discharged to a lake or stream must not be this alkaline. In order to reduce its pH value, we add a little acid before we discharge it into the receiving water body.  After running our full-scale experiment for approx. six months, enough cement has been washed out of the crushed concrete so that we no longer need to reduce the water’s pH value, and then I believe that the system can take care of itself,” says Melanie Sønderup.

Source: Univ. of Southern Denmark

Enbridge responds to second round of questions

Enbridge Response to Durham Citizens Lobby for Environmental Awareness & Responsibility Inc. ("DurhamCLEAR") Information Request No. 2

Many of the responses refer to answers providerd to other intervenors - most them can be found here: https://www.neb-one.gc.ca/ll-eng/livelink.exe?func=ll&objId=976803&objAc...

2  Reference:  A316R3 – Response to DurhamCLEAR IR no. 1
Preamble:  a)  Given that Enbridge is already paying $600,000.00+ in taxes to local municipalities in Durham Region and given that this will not change if the current proposal is granted,

Request: 
i)  why would it not be more appropriate to pay the municipalities in the Region of Durham a tax based on the volume of the flow?
ii)  Please delineate how much is paidto each municipality in the Region of Durham.
iii)  What is the highest tax Enbridge pays/will be paying for their pipeline network to any municipal jurisdiction in Canada?

Response: 
a.i)  Municipal taxes are set by the municipality and based on provincial legislation. It is not appropriate for Enbridge to comment on how the municipality chooses to set its tax rate.
a.ii) The following identifies the 2012 taxes paid in each of the Region of Durham municipalities:
Clarington $ 299,757.70
Oshawa  $ 83,440.24
Ajax  $ 62,578.18
Whitby  $ 75,598.85
Pickering $ 92,997.20
a iii)  Enbridge does not have any control over the taxes it pays. Enbridge objects to the requestas the information sought is not relevant to the issues in this proceeding.

4  Reference:  A316R3 – Response to DurhamCLEAR IR no. 1
Preamble:   The rivers noted in your answer are all 'navigable waters'.

Request: 

i)  Please provide your rationale for limiting such valve placements to these locations?
ii)  Please provide your justification for ignoring the following comment from the NEB on page 43 of the 1975 decision by the NEB to permit Interprovincial Pipelines to build Line 9, it states "Navigational use of the river as the basis for the identification of "major" river crossings is not necessarily consistent with environmental aspects. The Board feels that what is important is that relevant environmental considerations be taken into account in locating and designing river crossings regardless of whether such crossings should be designated as major or minor from any particular viewpoint."

Response: 

a.i)  Please refer to response Nicole Goodman IR 2 Question 2.1.

a.ii)  There is no evidence to suggest Enbridge ignored any part of the NEB decision in 1975. Further, Enbridge notes that the Board was referencing environmental measures in relation to construction of river crossingsat page 43 of the OH-1-74
Decision. The Board was not addressing the location of valves, which are addressed on page 27 of the OH-1-74 Decision.

4  Reference:  A316R3 – Response to DurhamCLEAR IR no. 1
Preamble:  b)(i)  In your response to this question, you indicate that you do not have maximum flow rates for the streams listed in
However, further on in your response, you indicate that you will use flow rates as part of your emergency response procedures.

Request:
Please advise as to the following with respect to flow rates:
a)  You indicated that you do not have maximum flow rate data, do you have other flow ratedata. If so, please provide.
b)  If you do not possession flow rate data, will you take measurements of the flow rates at the time of arrival at the release site?
c)  Do you have some other method of measuring flow rates on the spot?
d)  Do you have access to flow rate data or connection to another agency that will provide you with this information in a timely manner? Who would provide such information?

Response: 

b.i.a)  In the unlikely event of a release, flow rates at the time of the incident would be assessed in order to use the information most applicable to the circumstances of the incident.
  b.i.b)  Yes, if flow rate data was not available, Enbridge would take flow rate measurements.
  b.i.c)  A number of methods are available to measure or estimate surface water flow quickly, including:
  in-stream calculations where the velocity is measured with a portable flow meter or other similar device, and the flow rate is determined by multiplying the stream velocity by the cross-sectional area;
  government gauging stations including specific Conservation Authorities and Environment Canada, in partnership with the Water Survey of Canada, where real-time online hydrometric data from flow gauging stations can be used for quick and accurate flow estimation (e.g., http://www.wateroffice.ec.gc.ca/index_e.html); and
  the development of water course crossing rating curves (water level : discharge relationship) where the flow rate of the water course is charted relative to the water level.
  b.i.d)  Please refer to response to DurhamCLEAR IR 2 Question
  b.i.c. If the flow rate needed to be measured in the field, Enbridge or Enbridge’s qualified third party consultant would complete the measurement.

4  Reference:  A316R3 – Response to DurhamCLEAR IR No. 1
Preamble:  b)(iii)  Enbridge failed to respond to this information request.
Request:  b.iii.a)  Is this omission an acknowledgement that Enbridge does  not have this information?
Response:  b.iii.a)  Please refer to response to DurhamCLEAR IR 1 Question  4.b.iiiR filed July 16, 2013.

4  Reference:  A316R3 – Response to DurhamCLEAR IR no. 1
Request: 

e)  Please advise how the figure 14,560 bbls (2,315 m3) for the 'worst case release' relates to the figures at page 8 of the Revised Risk Assessment (A316Z1) which states a potential loss of 95.2m3.
i)  Is the 14,560 a static flow due to gravity after the valves are closed? If so, which section would drain that amount?
ii)  Is the 95.2m3 a dynamic flow under pressure before the valves are closed?
iii)  Would the 2 amounts not be additive?

Response: 

e.i)  The maximum volume out (i.e., 14,560 bbls) is the total of the initial volume out plus drain down (all product that is at a higher elevation and not isolated by elevation or remote controlled valves). The maximum volume out for Durham County is at KP 3112.9.
e.ii)  Please refer to response to NEB IR 3.11.a.
e.iii)  The two amounts are not additive; they represent different measurements. 95.2 m3 is the increase in the amount of product released before isolation, as a result of the Project. Please refer to response to NEB IR 3.11.a for a description of how the value of 95.2 m3 is calculated.
14,560 bbls is the maximum volume out, which is comprised of the initial volume out at the design capacity of 333,333 bpd plus the drain down volume (all product that is at a higher elevation and not isolated by elevation or remote controlled valves). Please refer to response to Toronto IR 1.10.d for an explanation of how the volume out is calculated.

5  Reference:  A316R3 – Response to DurhamCLEAR IR no. 1

Request:  a)  Can you advise as to what the highest psi is that Line 9B has operated at and for how long.

Response:  a)  In the past 10 years, the highest pressure on Line 9B was 666 psi at Cardinal Station on October 23, 2005 for approximately 5 minutes.

5  Reference:  A316R3 – Response to DurhamCLEAR IR no. 1
Preamble:  j)  You indicated that Enbridge does not use elbows in its pipelines.

Request: 

i)  Can you please advise how Enbridge accommodates hills, valleys, bends and curves in its pipelines?
ii)  If these are accommodated through bending an otherwise straight pipe, what are the implications of the compression and extension forces on the inside and outside radii?
iii)  What is the radius of the tightest bend in Line 9B in the Durham Region?
iv)  Since watercourse crossings are meant to have double thickness walls (1/2"), what procedures or modifications are made to accommodate the obvious need for bends in watercourse valleys?

Response: 

j.i)  Enbridge accommodates changes in direction and elevation through the use of cold bends or induction (hot) bends in accordance with CSA Z662, CSA Z245 and/or ASME B16.49.
j.ii)  The industry standards referenced in response to DurhamCLEAR IR 2, Question 5.j.iestablish limits to bends and conditions of bending to ensure the pipe is within permissible limits. Codes and standards have been developed based on industry experience, research, and testing.
j.iii)  The tightest bend radius inthe Durham Region is 12.4 pipe diameters.
j.iv)  Watercourse crossings are designed and constructed in accordance with industry standards including CSA Z662.
Please refer to response to DurhamCLEAR IR 2 Question 5.j.i for the design standards applicable to bends to accommodate changes in elevation and direction, including construction in watercourse valleys.

5  Reference:  A316R3 – Response to DurhamCLEAR IR no. 1
Preamble:  k)  You stated in your response that, during the annual cathodic protection survey, “performance is evaluated by obtaining sacrificial anode currents where accessible.”

Request:  i)  What situation would lead to the non-accessibility? How does Enbridge determine the status of the anode when its current is non-accessible?

Response:  k.i)  There are some locations where the sacrificial anodes are connected directly to the pipeline below grade and therefore inaccessible for obtaining absolute measurements specific to the anode.
Enbridge determines protection levels through evaluation of structure-to-soil potential measurements obtained directly from the pipeline and coupons. Adequate protection levels are indicative of effective anode performance.

6  Pipeline Monitoring
Reference:  NEB IR 3.10.c
“Visual surveillance and reports – Enbridge conducts aerial and ground line patrols of its pipelines.In addition, it manages third party reports of oil or oil odours through its emergency telephone line, and communicates with affected publics and local emergency officials through its publicawareness program.”

Preamble:  Given your reply in NEB IR 3.10.c that Computation Pipeline Monitoring systems (CPM) will not detect a leak below “70.5 m (443 bbl) over a 2 hour period”,this question refers to smaller leaks which would be detected visually or from reports.

Request: 

i)  How often are aerial patrols conducted? How many otherwise undetected leaks have been identified in this manner? What percentage of all leaks are detected in this manner? When was the most recent such patrolconducted over the stretch in Durham Region?
ii)  How often are ground line patrols conducted? How many otherwise undetected leaks have been identified in this manner? What percentage of all leaks are detected in this manner? When was the most recent such patrol conducted over the stretch in Durham Region?
iii)  How many otherwise undetected leaks have been identified through “3rd party reports of oil or oil odours”? What percentage of all leaks are detected in this manner?

Response: 

a.i)  The Enbridge aerial patrol iscompleted over Line 9 every two weeks. One release was detected by aerial patrol, meaning 7.7% of the Line 9 releases weredetected in this manner. The latest Enbridge aerial patrol over Durham Region is scheduled during the week of July 22, 2013.
  a.ii)  Ground patrols are completed through the Toronto area each day, five days per week. No leaks have been detected by the Toronto ground patrol. The ground patrol does not cover Durham Region, but Enbridge pipeline maintenance staff travel the right of way intermittently at various locations along Line 9 to access work sites.
  a.iii) Four Line 9 releases were detected by a third party, meaning 30.8% of the Line 9 releases were detected in this manner.

6  Pipeline Monitoring
Reference:  NEB IR 3.10.c
“Visual surveillance and reports – Enbridge conducts aerial and ground line patrols of its pipelines.In addition, it manages thirdparty reports of oil or oil odours through its emergency telephone line, and communicates with affected publics and local emergency officials through its public awareness program.”

Preamble:  Given a typical depth of 3 ft., the soil around a small leak could be saturated with several barrels of oil before it was visually detected, and this oil could be contaminating the groundwater wherever the pipeline lies near or under the water table.

Request: 

iv)  When you conduct integrity digs, do you ever find otherwise undetected leaks which are slowlyleaking into the soil? How many such leaks have occurred on Line 9? What percentage of total leaks are detected in this way?
v)  If such a leak is detected, what tests do you perform on the ground water? What corrective action would you undertake if you find that the ground water is contaminated?
vi)  How is the contaminated soil treated?
vii)  When leaks are found through aerial patrols, ground line patrols, 3rd party reports or through integrity digs, does Enbridge conduct a forensic analysis to determine why the leak was not detected by any of its other means. If so, what conclusions have you reached? If not, why not?

Response:  .

iv) Some low volume pipeline releases are discovered as part of the integrity dig program. These discoveries are evidence of the ability of the Integrity Management Program, including in-line inspection and the integrity dig program, to identify areas of potential defects and remediate the pipeline before a large volume release could occur. The pipeline releases discovered on Line 9 as a resultof the integrity dig program are listed in Attachment 1 to NEB IR 1.27a. Please refer to Attachment 1 to Ontario IR 1.8.a for the summary of pipeline releases on Line 9.
 v)  The standard hydrocarbon laboratory analysis would include, but not necessarily be limited to, benzene, toluene, ethylbenzene, xylenes (BTEX), petroleum hydrocarbon fractions F1 and F2, and polycyclic aromatic hydrocarbons. Please refer to response to Les Citoyens au Courant IR 1, Question 6.12 for potential remedial measures for groundwater.
vi)  Please refer to response to AFN and COTTFN IR 1 Question 2.10.a.
vii) Enbridge conducts an analysis of the conditions surrounding releases, including means of detection. Conclusions and resulting recommendations are evaluated. Appropriate corrective actions are applied to ensure continuous improvement as well as system performance.

6  Reference:  A316R3 – Response to DurhamCLEAR IR no. 1
Preamble:  Given the wide range of compounds and mixtures listed in your answer to Les Citoyens au Courant 5.17bin response to our question about diluent composition, we note that most of these are quite toxic and many contain carcinogens and mutagens.

Request: 

i)  If a rupture were to occur at any particular point in the line would you be able to tell the response workers at the site exactly what they were dealing with?
ii)  If not immediately, how long would it take to provide them with accurate WHMIS information?

Response: 

c.i – c.ii) In the unlikely event of a release, the Enbridge Control Centre would be able to provide responding personnel with the type of crude being transported at that location. The Material Safety Data Sheet information related to the crude type would be made available by fax or email to all responders involved with the incident.

6  Reference:  A316R3 – Response to DurhamCLEAR IR no. 1
Request:  k)  In the event of a release, should Enbridge product enter the cooling intake mechanism ofeither OPG Darlington or Pickering reactors without OPG’s knowledge, what would the impact be on the cooling system and/or the nuclear reactors?

Response:  k)  Enbridge cannot comment on OPG operations or the potential effects of oil entering the cooling water in a nuclear reactor. In the unlikely event of a release, Enbridge would initiate emergency response procedures as described in Attachment 1 to Ontario IR 1.44.b.v. These procedures include notifying the public and those who may be directly affected, monitoring release behaviour and extent to contain the release and identifying water intakes in the area. As a result, OPG would be contacted if there were to be a risk of oil entering its cooling water intake. As described in response to DurhamCLEAR IR 1 Question 6.k, in the unlikely event of a release, Enbridge would work with OPG to manage water issues and protect water intakes.

2.2  Pipeline Risk Assessment
Reference:  A316Z1 - 01 Revised Risk Assessment
Request:  Page 8 of your revised risk assessment yields this table. Is this correct?

Capacity Increase in risk from current configuration
240,000bbls/d 0%
300,000 bbls/d 0.8%
333,000 bbls/d 2.2%


Response:   The table is incorrect in that it implies that there is an increase of 2.2% of risk for all of Line 9 as a result of the reversal and capacity expansion when in fact, as described in response to Toronto IR 1.10.d, 2.2% (or 60 of 2,730) of the assessed 305 m pipeline sections display an increase in risk. The Revised Pipeline Risk Assessment compares the result of changing from the current design capacity of 266,965 bpd (current state; thus increase inrisk from current configuration is 0%) to the post Project design flow rate of 333,333 bpd (increase in risk for 2.2% by length of Line 9). Please refer to response to OPLA IR 1.19.cR (Document A3J0Q3) for a description of the indexed risk assessment methodology.

2.2  Reference:  A316Z1 - 01 Revised Risk Assessment
Request:  a.i)  What would be the decrease inassessed risk if the capacity was reduced by 20,000 bbls/day from the current capacity? – 40,000 bbls/day? Could you create graph showing actual risk numbers rather than percentages.

Response:  a.i)  A response to this question would require Enbridge to conduct two additional pipelinerisk assessment studies. Enbridge objects to the request as it is unreasonable and unduly onerous. The time, effort and expense involved in the compilation of the requested information are not warranted by the relevance, if any, of the information sought, by the significance of that information in the context of the proceeding, or by the probative value of the result.

2.2  Reference:  A316Z1 - 01 Revised Risk Assessment Graphs on pages 19 & 21 – ‘Fig. D Risk Profile for Line 9B
Current Configuration vs Reversed Flow’ & ‘Fig. F Line 9 Capacity Increase: Risk Results’

Request:  a.ii)  Please provide graphs showing the area of Line 9B through Toronto, Durham and Northumberland in greater detail so that the individual 1,000 ft sections can be delineated and mapped. Also provide the likelihood and consequence factors which combine to form the risks for each section under each scenario.

Response:  a.ii)  Graphs of the Greater Toronto Area, Durham and Northumberland in greater detail are included as Attachment 1 to DurhamCLEAR IR 2 Question 2.2.a.ii.
Graphs A and B are two different versions of Figure D in the Revised Pipeline Risk Assessment and are both provided due to resolution difficulties with the software that produces the graphs. Graph A shows the risk increase on the new discharge side of Hilton Station due to the reversal and Graph B shows the risk decrease on the new suction side of Hilton Station due to the reversal. Graph C represents Figure F in the Revised Pipeline Risk Assessment in greater detail. Please refer to response to OPLA IR 1.19.cR for a description of the indexed risk assessment methodology.

2.2  Section Replacement in Clarington
Preamble:  b)  We have received information (which was apparently confirmed at the Enbridge Open House at the Whitby Curling Club on June 19) that a section of Line 9 through Clarington (part ofDurham Region) was recently rerouted to accommodate the construction of Hwy 407.

Request:  i)  Is this correct?
ii)  If so please specify the location and length of this realignment and when it was done?
iii)  Was this reconstruction done to the same specifications as the original pipeline?
iv)  Was the piece which was removed examined forensically to compare actual ‘features’ to those which may or may not have been ‘seen’ with ILI? If not, why not?

Response: b.i – b.iv)   Enbridge objects tothe request as the information  sought is not relevant to the issues in this proceeding.

2.2  Exposed sections at watercourses
Reference:  A316X8 - Enbridge Response to City of Toronto (“Toronto”) Information Request No. 1

In the response to the information requests from the City of Toronto p 34, you acknowledge, in regards to ground cover
“d.a.1) Four locations within city of Toronto have had to have corrective action taken:
1.  Newtonbrook Creek - KP 3080.01 – Pipe found to be exposed in bottom of creek during slope and stream survey June 2013.
2.  Don River - KP 3081.70 Enbridge is planning to replace 700 m of pipe and install the pipe several meters below the river bed. Work is scheduled to start August 2013
3.  Rouge River - KP 3095.35 The east bank of the river had extensive erosion exposing the Enbridge pipeline. The erosion has been repaired by installation of a live crib - work was complete in 2011.”
(Note: I have been informed by the person who first reported the exposed pipe at the Rouge River that it was reported in July of 2012 and the repair was completed in late 2012.)
Preamble:  c)  Given that these three instancesare all of recent discovery & correction, Line 9 would appearto have a problem with erosion at rivers and streams.

Request:  i)  When last were the multitude of rivers, streams and creeks in Durham Region surveyed for erosion? What was found?

Response:  c.i)  All water crossings in the Durham Region will be surveyed for erosion during the summer of 2013. Results will be reviewed once the survey is complete, and Enbridge will determine if mitigation is required such as pipeline relocation or slope reconstruction.
Prior to that, a depth of cover survey was conducted in 2009, and there were no areas of concern noted in Durham Region.

2.2  Wall thicknesses under watercourses
Reference:  "NEB Report to the Governor in Council OH-1-74" (Original approval of Line 9) p.27 “With respect to river crossings, the Applicant mentioned that the wall thickness of all pipe under watercourses flowing into the Great Lakes and the St. Lawrence Seaway would be increased to 0.500 inches.”

Request:  d.i) Please indicate which watercourse crossings in Durham have increased wall thicknesses?
d.ii) How many metres on either side of these watercourses does this increased wall thickness extend?
Response:  d.i – d.ii)  The pipeline crossing each watercourse in the Region of Durham has increased wall thickness, which spans from top of bank to top of bank

Successful Line 9 Public Meetings

Three public meetings were held in Bowmanville, Whitby & Pickering July 23, 24, 25, 2013. The Powerpoint presentation can be viewed HERE. (Note this is a very large file.) Participants were then asked to express their opinions of Enbridge's pipeline proposal on a questionnaire.

A total of 26 questionnaires were submitted.

Results: Note - Answers do not add up to 26 because not all people answered all questions and a few people indicated duplicate answers.

When did you first hear about line 9?
8  more than a year ago,         15  less than a year ago,         2  ads/information for this meeting

Where did you first find out about Line 9?
9  Newspaper   1  TV    1  radio    11  Email/Internet    4  Stories/ads about this meeting

Have you attended any previous meetings on Line 9?
1 - Enbridge Information Meeting Whitby/Clarington  June 19
1 - NEB information meeting - Ajax Town Hall April 9
2 - DurhamCLEAR Info Mtg -Ajax Town Hall March 21
2 - Enbridge Presentation to Council Meeting    0  Ajax   0  Whitby   3  Regional

Are you opposed to further expansion of the oil sands in Alberta?       21 Yes       2 No

Prior to this meeting, how would you rate your level of knowledge about this issue?
answers were on a 7-point scale with the distribution as follows
very poorly informed    1   3   3   5   9   3   3   highly informed

Assuming that oil will continue to be transported in large quantities, Rank the following options as the most appropriate transportation method for oil?
Totals of all the individual rankings were added together (in brackets) to determine the overall rankings
#1 (34) New ‘modern’ pipeline built farther north away from populated areas and avoiding environmentally sensitive areas
#2 (49) New Pipeline on the current alignment rebuilt to ‘modern’ standards
#3 (64) Rail & Road transport
#4 (66) Current Pipeline “as-is” with increased safety, more valves, better leak detection and emergency response
#5 (87) Current Pipeline “as-is”

Rate Canada’s regulations for transportation of hazardous materials like crude oil:
14  Grossly inadequate     9  Inadequate     2  About Right      0  Too Strict      0  Oppressive

What are your principle concerns about Line 9?
21  Safety and protection of people and their property
23  Protection of the Environment and wildlife habitat
14  Greenhouse gases
10  Economic growth and prosperity

Check as many of these options as you feel appropriate
0    Spills are just a cost of doing business
14  With proper monitoring and better regulation, spills could be virtually eliminated
20  Avoidable spills of hazardous materials should be regarded as criminal acts with executives subject to heavy fines and possibly imprisonment
 

Should the Ontario government require Enbridge to undergo a full Environmental Assessment on these changes to Line 9?       23  Yes      1   No

In regards to Enbridge’s application to reverse the flow of Line 9, the NEB should:
11  deny the application
0    allow the application without conditions
14  allow the application, but with conditions
    13  upgraded to ‘modern’ structural standards
    13  better emergency response times to a spill - how long - 15 min x 3, 30 min x 1, 30-60min x 2
    11  more frequent In Line Inspections and timely correction of any defects
    11  better detection of ‘small’ leaks - 3 barrels per minute or less
    11  increase the number of remotely controlled valves
        8  both banks of all watercourses
        1  average 10 km apart               6  average 5 km apart

In regards to Enbridge’s application to increase the capacity of Line 9 to 300,000 barrels per day, the NEB should:
16  deny the application
0   allow the application without conditions
8   allow the application, but with conditions
    8  upgraded to ‘modern’ structural standards
    6  better emergency response times to a spill - how long _____________________
    6  more frequent In Line Inspections and timely correction of any defects
    4  better detection of ‘small’ leaks - 3 barrels per minute or less
    6  increase the number of remotely controlled valves
        3  both banks of all watercourses
        1  average 10 km apart               3  average 5 km apart

In regards to Enbridge’s application to carry dilbit in Line 9, the NEB should:
15  deny the application
0    allow the application without conditions
7    allow the application, but with conditions
    6  upgraded to ‘modern’ structural standards
    6  better emergency response times to a spill - how long  - 15 min x1,, 30-60 min x 1
    4  more frequent In Line Inspections and timely correction of any defects
    5  better detection of ‘small’ leaks - 3 barrels per minute or less
    5  increase the number of remotely controlled valves
        1  both banks of all watercourses
        1  average 10 km apart               4  average 5 km apart

Following this meeting, do you have a better understanding of crude oil transportion, and the risk of pipeline leaks?      20  Yes        1  No

Great website on Line 9

Another intervenor, Emily Ferguson, has created a great website on Line 9: http://www.line9communities.com/.

It has maps, and information on integrity digs that she assembled by sifting through years of Enbridge's communications with the NEB. Also, there's information about leaks, and a whole lot more.

We want your input on Line 9 to take to the National Energy Board

DurhamCLEAR is hosting a series of public meetings during the week of July 22 in order to provide information on Line 9 and also to gather feedback from ordinary residents and local experts on Line 9.

Three meetings are planned across the Region: 

Tues. July 23, 7:30pm

St Paul’s United Church

178 Church St at Silver St.
BOWMANVILLE

Map Photo

Wed, July 24, 7:30pm

WHITBY Main Library
Room 1

405 Dundas St. W at Henry

Map

Thurs, July 25, 7:30pm

PICKERING Rec Complex
(1867 Valley Farm Road)

O’Brien Room B
Enter off Diefenbaker Ct.
on the E side of the complex

Map


These meetings were part of our request for funding from the NEB and we told them that the feedback from these meetings would be included in our final 'evidence'. We feel that it's important that the public voice is heard above din of technocrats arguing the finer points of pipeline design.

Round 2 - Questions for Enbridge

DurhamCLEAR Followup Information Requests (IR) for Enbridge

July 8, 2013

Reference: A316R3 (these numbers are file numbers for the National Energy Board (NEB)) if interested the entire documentary file including all intervenors can be found HERE.

Response to DurhamCLEAR IR no. 1  - (the numbering below refers to the numbers of the previous set of questions and Enbridge's answers)

2(a)  Given that Enbridge is already paying $600,000.00+ in taxes to local municipalities in Durham Region and given that this will not change if the current proposal is granted,

i) why would it not be more appropriate to pay the municipalities in the Region of Durham a tax based on the volume of the flow?

ii) Please delineate how much is paid to each municipality in the Region of Durham.

Enbridge Answers

Our apologies for the weird formatting and symbols - this was converted from a pdf file. To download the original, click HERE.
Many of the answers refer to other documents most of which can be found in one of these links:

1.       http://www.neb-one.gc.ca/fetch.asp?language=E&ID=A52563
2.       http://www.neb-one.gc.ca/fetch.asp?language=E&ID=A52565
3.       http://www.neb-one.gc.ca/fetch.asp?language=E&ID=A52576
4.       http://www.neb-one.gc.ca/fetch.asp?language=E&ID=A52581

Enbridge Response to Durham Citizens Lobby for Environmental Awareness & Responsibility Inc. ("Durham CLEAR") Information Request No. 1

PROLOGUE: The preambles to and/or premises of several of the information requests include assertions that may not be factually correct. Unless expressly stated otherwise, Enbridge does not concede the accuracy of any preamble or part thereof. Similarly, Enbridge does not concede the relevance of any request to which it has provided a response.

1 The need for the Project (a) Has Enbridge explored alternative scenarios for transportation of crude? If Request: so, what were those alternatives? (b) Has Enbridge investigated the construction of a modern pipeline along Line 9B? If so, what are the results of that investigation? (c) Given the age and construction of Line 9B, Why had Enbridge chosen this proposal rather than construction a new pipeline? Response: (a) Please refer to response to NEB IR 2.3. b - c) Please refer to response to A2A IR 5.j.

2 The potential commercial impacts of the project (a) Please set out the direct economic and commercial benefits of this proposal to Durham Region. (b) Had Enbridge been in communication with the various Boards of Trade and Chambers of Commerce in the Durham Region? If so, were those communications in writing or in person? If they were in writing, please provide copies?

(a) The Project will allow the pipeline to remain in service, thus continuing its contribution to the Durham Region tax base. The right of way taxes paid in 2012 directly to the Durham Region exceeded $600,000.

(b) Enbridge has been in communication with the following Boards of Trade and Chambers of Commerce in the Durham Region: • Town of Whitby: Enbridge met with the Chief Executive Officer of the Whitby Chamber of Commerce on Friday, May 24, 2013. At this meeting, Enbridge provided an in-person overview of the proposed Project. In addition, Enbridge outlined the local economic benefits of the proposed Project, and the municipal taxes Enbridge pays to the Town of Whitby annually (approximately $76,000). Enbridge discussed the open house that would be taking place in Whitby on Wednesday, June 19, 2013, and asked assistance from the CEO to spread the word of the open house to its membership. • Bowmanville: Enbridge met with the President and Executive Director of the Clarington Board of Trade on Wednesday, June 19, 2013. Enbridge provided an overview of the Project and economic benefits of the proposed Project, and the municipal taxes Enbridge pays to the Municipality of Clarington annually (approximately $300,000). Enbridge discussed the open house that would be taking place in Bowmanville on Wednesday, June 19, 2013, and asked assistance from the Board of Trade to spread the word of the open house to its membership. Throughout the life of the Project, Enbridge will continue its efforts to meet with all Boards of Trade and Chambers of Commerce along the ROW.

3 The appropriateness of the rules and Regulation tariff (a) Has consideration been given to compensating the local municipalities for  this proposed project?

(a) No. However, municipalities receive property tax revenue in relation to Response: Line 9. Please refer to response to Durham CLEAR IR 2.a.

4 The potential Environmental and socio-economic effects of the proposed project, including the potential effects of malfunctions or accidents that may occur and any cumulative environmental effects that are likely to result from the proposed project Request:

(a) In Inter Provincial Pipelines (IPL) original submission to the NEB in 1974 "POLICIES, PRACTICES AND PROCEDURES TO MITIGATE ENVIRONMENTAL IMPACT" (OH-1-74 IPL Policies-1.pdf, pg 7- River & Stream Crossings

(b)-3 it states in relation to “Major River Crossings”, "Motorized block valves will be installed on each bank." Where are these block valves located? - which rivers?

Note also on page 27 of the NEB decision (OH-1-74) in 1975 (pg 32 of the pdf), end of 2nd paragraph, it is reiterated that IPL "stated that at major river (navigable stream) crossings circumferential welds would be X-rayed 100 per cent and that motorized block valves would be installed on each river bank."

However on page 43 of the decision the Board stated that "Navigational use of the river as the basis for the identification of "major" river crossings is not necessarily consistent with environmental aspects. The Board feels that what is important is that relevant environmental considerations be taken into account in locating and designing river crossings regardless of whether such crossings should be designated as major or minor from any particular viewpoint."

(b) Durham Region extends for approximately 40 kilometers along the North shore of Lake Ontario. Line 9 runs across the full width of the region and in so doing crosses numerous rivers and streams that flow into the lake. Please provide for each of the following rivers and streams:

i) Maximum flow rates

ii) Time that it would take for oil from a spill to reach Lake Ontario from the time it first reached the water at maximum flow rate

iii) Aquatic life forms that would be affected if oil of any kind were to enter the water of each of these rivers and streams. Note that Line 9 crosses 2, 3, or more branches of each of these, all of which have individual flows and individual potential for spreading an oil leak

Petticoat creek Duffins Creek Carruthers Creek Lynde Creek Pringle Creek Corbett Creek Oshawa Creek Harmony Creek Farewell Creek Black Creek Tooley Creek Darlington Creek Bowmanville Creek Soper Creek Bennett Creek Wilmot Creek Graham Creek

(c) Please provide all environmental studies done by Enbridge or by Interprovincial Pipelines concerning the section of the pipe within Durham Region including studies done as part of the approval process of Line 9 in 1975. Include all studies and reports which pertain to Durham Region, either specifically or more generally.

(d) What is the longest distance of the pipeline in Durham Region between shut off valves?

(e) What is the volume of oil in barrels between two shut off values?

(f) What is the largest aount of oil that can theoretically spill between the shut off vales in Durham Region in the time it takes the spill response team to arrive on the scene (90 minutes)?

(g) With respect to the flow rate of oil from the pipeline (i.e. how many barrels of oil can/would escape the pipe in the event of a leak or burst), please provide information with respect to:

i) the flow rate of an undetected leak;

ii) the flow rate of a burst/pipe failure that is detected. a) Motorized valves are located on both sides of the following major water

Response: crossings: • Trent River • Rideau Canal • Gananoque River • Buells Creek and Reservoir • Ottawa River • Rivière des Milles-Isles • Rivière des Prairies

b.i) Enbridge does not have maximum flow rate data for each of the rivers and streams requested. However, in the unlikely event of a release, Enbridge would immediately implement its emergency response procedures to contain released product and mitigate the impacts. These plans include processes for assessing resources at risk, spill trajectories, and travel times based on the circumstances of the incident and using flow rate information applicable at the time and location of the incident. b.ii) Please refer to response to TRCA IR 1.f.iii.

c) No environmental studies were completed within the Durham Region as part of the Project, because no Project work is taking place within Durham Region. Any environment studies that may have been completed in 1975 are not relevant to the issue in this proceeding.

d) The greatest length of pipeline between shut off valves in the Durham Region is 31 km.

e) Between valve MP 1922.23 and MP 1932.91 there is 47,300 bbl of oil. Between valve MP 1932.91 and MP 1949.02 there is 71,300 bbl of oil Between valve MP 1949.02 and MP 1968.28 there is 85,300 bbl of oil. In the unlikely event of an incident on the pipeline, the amount of oil released would be substantially less than shown above. Natural high points in the pipeline elevation profile would hinder the release of oil; resulting in an estimated worst case release of 14,560 bbls within these sections.

f) Refer to response to Durham CLEAR IR 1.4.e g - i) Please refer to response to NEB IR 3.10.c) for information on the performance of the computational pipeline monitoring system.

g - ii) Leaks would be detected by one or all of the overlapping leak detection methods. Please refer to response to NEB IR 3.10.c)

5 The engineering design and integrity of the proposed project

(a) Has the pipeline ever operated at the 1,000 psi during its time of service? If Request: so, please advise when and for how long?

(b) At what speed is the oil travelling through the pipe?

(c) What is the life expectancy of the pipeline? - what are the limiting factors?

(d) Because its buried, you can't visually inspect it - how do you know it's not corroding?

(e) How many integrity digs have been conducted in Durham Region over the life of the line? How many since the application? How were the locations determined? What was found? Remedial action taken? Please provide a list all integrity digs performed and findings/reports on Line 9B in Durham Region since its construction to date.

(f) With respect to the internal inspection (pigs?) - how often are these apparati deployed? How fast do they move through the pipe? What inspection techniques are they using, i.e. visual, x-ray, ultrasound?

(g) Were these internal inspection apparati in use on Line 6B in Michigan? If so, what did they detect? Why did it take so long for Enbridge to apply to repair Line or why not?

(h) Given that Line 9B and Line 6B are extremely similar in age and design, what has Enbridge done to ensure that what happened on Line 6B won’t happen on Line 9B? Please provide all copies of all details, designs, internal memos and reports, consultations and any other documentation in relation to this.

(i) Are oil pipelines subject to harmonic vibrations. Assuming yes, what potential damage do they cause? What steps are undertaken to mitigate them?

(j) Are leaks/ruptures on pipelines more likely at elbows?

(k) How frequently are the sacrificial anodes replaced? How far apart are they? Does the replacement require excavation?

(l) Why in 1997 did the Proponent choose to conduct hydrostatic testing? This would have involved emptying the pipeline and pumping water in at high pressures? How high a pressure was the hydrostatic testing conducted? The results showed that there were no leaks or ruptures. Did actual experience of the following year confirm no leaks? This testing occurred when the pipeline was 21 years old, and now it is 37 years, when will this test be conducted again?

(m)The Proponent states that the pressure along the line varies, with the highest pressure just after a pumping station. What is the “peak pressure” that has occurred at this point and what will the “peak pressure” be for the new configuration?

(n) What is the burst pressure and RPR of the Proponents specified pipe? Same question, only for the HCA’s?

(o) What is the burst pressure and RPR of the Proponents specified pipe in the HCA’s?

(p) At 75% feature depth, what is the burst pressure of that pipe?

(q) If a feature is identified at 50%, does this mean the pipe wall thickness has failed by 50% at that point? At this level of feature penetration, what is the impact on pipe strength? What is the impact on operating pressure?

(r) The Proponent states “...features below the 50% excavation criterion will be monitored... “Why were the remaining 14 features meeting the excavation criterion not repaired?

(s) With over 1250 features continuing to grow, when does the Proponent decide it is time to replace the pipeline?

(t) When added protection is applied to the pipeline in HCA’s, how far beyond the HCA boundary is this added protection carried?

(u) How often are HCA’s physically monitored for features? 5

(v) With 600 leaks of various sizes on the line since start-up, has Enbridge developed a relationship between age and number of leaks? If so, has this analysis provided an indication as to the reasonable life of a pipeline? If not, why not? Please provide all documentation related to any analysis Enbridge has done on the previous 600 leaks.

Response:

a) No 

b) Please refer to response to Toronto IR 1.17.g.a1.

c) Pipelines are designed as long life assets. With regular maintenance, pipelines have an indefinite life.

d) The pipeline is safeguarded with a protective coating and cathodic protection. Corrosion is monitored regularly through ILI, and regular maintenance activities are undertaken according to the Integrity Management System detailed in Section 4 of the Pipeline Engineering Assessment ("Pipeline EA").

e) Enbridge objects to the request as it is unreasonable and unduly onerous. The time, effort and expense involved in the compilation of the requested information are not warranted by the relevance, if any, of the information sought, by the significance of that information in the context of the proceeding, or by the probative value of the result.

f) The ILI history summary for Line 9B from 1975-2013 is available in the Pipeline EA Table 3-3. The table also specifies the type of inspection technology utilized. Enbridge uses the following ILI technologies: ultrasonic, magnetic flux leakage ("MFL"), and caliper tools. The speed at which ILI tools move through the pipe is controlled to maximize detection performance. Typical tool velocities are 1.0 m/s, but vary according to vendor tool speed specifications.

g) Enbridge objects to the request as the information sought is not relevant to the issues in this proceeding.

h) Enbridge objects to the request as it is not reasonable. Durham CLEAR is engaging in a “fishing expedition.”

i) No, oil pipelines are not subject to harmonic vibrations.

j) Pipe elbows are more vulnerable to internal metal loss. However, Enbridge does not utilize elbows on its pipelines, including Line 9.

k) Cathodic protection on Line 9 is accomplished primarily through a network of impressed current cathodic protection systems, however there are some locations on Line 9 where sacrificial anodes have been installed for localized hot spot protection and alternating current mitigation in high voltage corridors. The consumption of a sacrificial anode is proportional to the total current it delivers. Sacrificial anodes become ineffective and are replaced once they are no longer capable of sufficient current output. Performance is evaluated by obtaining sacrificial anode currents where accessible during the annual cathodic protection survey. Spacing of sacrificial anodes is dictated by a number of factors including: corrosivity of the environment, soil characteristics / resistivity, geometry of the location and influence from stray/foreign current sources. Replacement requires some form of excavation; which can include less invasive techniques such as hydro-vacuuming.

l) Please refer to response to Ontario IR 1.14.a, NEB IR 1.27 and the Section 3 of the Pipeline EA for detailed information on the prior hydrotest and release history on Line 9.

m) Please refer to Table 3-1 and Figure 4.26 in the Pipeline EA for maximum allowable operating pressure information. The Project will not involve a change to the NEB-approved MOP of Line 9.

n) Please refer to Section 4 of the Pipeline Integrity EA Exhibit B1-15 for detailed analysis of the pipeline condition.

o) Please refer to response Durham CLEAR IR 5.n.

p) In general terms, the failure pressure for a specific pipe defect is dependent on both defect length and through-wall depth. Failure pressure depends on the feature type (corrosion or crack) and the unique feature depth profile over the lenght of the feature. A failure pressure cannot be calculated based on the information provided however a feature with a depth of 75% may be safe to operate at full operating pressure based on CSA Z662 and subsequent defect assessment standards.

q) When a feature is identified as being 50%, this indicates that at the thinnest point within the feature boundary, cross sectional wall thickness has reached 50% of the original design thickness. The impact that a 50% feature would have on pipe strength would depend on the extent (width and length) of the wall loss. Enbridge’s Integrity Management System requires excavation of features reported as being 50% through wall. Detailed field assessment of the feature, taking into account the profile and depth, will determine the remaining pipe strength, and the appropriate repair method. Enbridge maintains a safe operating pressure dependent upon the estimated failure pressure of non-repaired defects. A minimum 1.25 safety factor for the maximum operating pressure is maintained based on these failure pressure calculations.

r) Figure 4.7 of the Pipeline EA provides a histogram for corrosion features, while the paragraph below Figure 4.7 refers to joints. There were 49 corrosion features 50% or greater located on 35 joints. These 35 joints of pipe were excavated; those features requiring repair were repaired in accordance with CSA Z662.

s) All pipelines within Enbridge are maintained based on Integrity Management System ("IMS"), including Line 9. Enbridge carried out a comprehensive ILI program on Line 9 and, based on the identified features, determined the best course of action was to proceed with the dig repair program rather than pipe replacement. Both methods of pipeline maintenance (dig repair and replacement) preserve the integrity of the pipeline system.

t) The entire pipeline is maintained as detailed in section 4 of the Pipeline EA regardless of the classification. Identification of HCAs, as referenced in Section 4.2.8.2 of the Pipeline EA is used to determine the re-inspection interval for metal ILI tools. The annual corrosion growth rate ("CGR") is applied to measured features and the features are aged until one such feature would exceed the Enbridge threshold level. The re-inspection interval is based on the year in which such feature would meet the threshold criteria. Regions classified as HCAs have a threshold level of 0.93 RPR. Non-HCA regions have a threshold level of 0.90 RPR. The boundaries of the HCAs used to determine the reinspection interval are as shown in figures 4.20, 4.22 and 4.24 of the Pipeline EA.

u) Enbridge monitors pipeline features through ILI. The ILI frequency is depicted in Table 3-3 of the Pipeline EA Exhibit B1-15. Typical in-line inspection monitoring frequencies are based on 5 to 7 year intervals.

v) The release history for Line 9 is presented in Attachment 1 to response to Ontario IR 1.8.a. There were 12 releases over the last 35 years. It is unclear which releases are referenced by Durham CLEAR. A correlation between pipeline age and failure history has not been found. Enbridge voluntarily participates in industry initiatives to review and assess pipeline industry release causes. Safety, security, contingency plan

6 The safety, security and contingency planning associated with the construction and operation of the proposed project including emergency response planning and third- party damage prevention

(a) How is the pipeline monitored? How would you know if there was a small Request: but steady leak?

(b) Drag reducing agents - what are they chemically? - are they consistent or do they vary according to what is being transported? - are they toxic? - have their effect on the environment or humans been evaluated? What are the effects? Do the people working with it know its composition? Has Enbridge complied with WHMIS? If so, please provide details of this compliance.

(c) What exactly is the diluent in dilbit? Is its composition always the same or does it vary according to what is being transported? Is it toxic? Have its effects on the environment or humans been evaluated? What are the effects? Do the people working with it know its composition? Please provide the ‘recipe” for the diluent, along with any and all evaluations or test results Enbridge has conducted. With respect to the diluents, has Enbridge complied with WHMIS? If so, please provide details of this compliance.

(d) Please provide a description of all past leaks on Line9 through Durham Region - even the smallest ones. How was each of these first detected? What and how fast was the response? Was there any prior indications in your diagnostics that there would be a problem? What were those indications?

(e) Can dikes and diversion systems be built where the pipeline crosses waterways so that any spill does not get into the water

(f) The Proponent states that there was one mainline rupture. How large was this rupture, i.e. how much oil was spilled? was there environmental impact? were property owners advised? how large was the rupture? what was the location of the rupture?

(g) Further to the above rupture; what was the cause? what corrective actions were identified to prevent another rupture? were these actions completed?

(h) With 600 leaks of various sizes on the line since start-up, has Enbridge developed a relationship between age and number of leaks? If so, has this analysis provided an indication as to the reasonable life of a pipeline? If not, why not? 6

(i) Since the pipeline runs through environmentally sensitive areas, what pre- emptive discussions have occurred with local conservation authorities to ensure access to the pipeline in the event of a discovered pipeline weakness which requires excavations to access the pipeline in order to repair it?

(j) With the cleanup of spills costing upwards of a billion dollars and with Lake Ontario being closer than any other major body of water supplying drinking to millions of people, what is the economic/impact justification for setting response times at 90 minutes from crew dispatch to their arrival on the spill site? Please provide all documentation and information with respect to this measure.

(k) Line 9 passes only a few miles north of 2 large nuclear power stations which use water from Lake Ontario for cooling. What information has been provided to Ontario Power Generation (OPG) with regard to contamination of cooling water supply from Lake Ontario in the event of a spill? Has OPG used this information in preparing an Emergency Response Plan which ensures the health and safety of Workers at the plant and the Public at large? Has this information been shared with Enbridge? If so, please provide copies of all such documentation relating to this matter.

Response:

a) Please refer to response to NEB IR 3.10.c 

b) Please refer to response to Les Citoyens au Courant IR 5.32 for the DRA MSDS. DRA would not represent an additional risk to the human health or the enviroment in the unlikely event of a release.

c) Diluent (also referred to as condensate) is a light hydrocarbon component mixture. This mixture primarily contains the lightest components of a light sweet crude oil. The components that make up diluent are referred to as parrafins, napthenes and aromatics. It is used to reduce the viscosity of bitumen to allow it to flow under ambient and pipeline temperatures. The composition of diluent can change depending on the type and amount of diluent used. Please refer to responses to Les Citoyens au Courant IRs 5.17b and 5.18. Line 9 will not be transporting diluent but diluted bitumen

d) Please refer to response to Ontario IR 1.8.a for a list of known events. None of the listed events was within the Region of Durham (KPs 3100.341 to 3162.390).

e) Enbridge would create temporary dams and diversions to prevent oil from an incident getting into waterways. Enbridge cannot design permanent dikes and diversion systems at waterway crossings as this would not meet environmental protection standards and would negatively impact overall land drainage.

f) Please refer to response to NEB IR 1.27 and response to Ontario IR 1.8.b for details of this incident. The landowner was advised of the incident.

g) Please refer to response to NEB IR 1.27.

h) Please refer to response to Durham CLEAR IR 5.v.

i) Please refer to response to A2A IR 5.b.

j) Please refer to response to A2A IR 1.5.e.

k) In the unlikely event of a release, Enbridge would work with OPG to manage water issues and protect the water intakes.

8 Consultation and Potential Impacts: Consultation activities and potential impacts of the project on affected landowners and land use

(a) How are the owners of the land that your pipelines cross compensated Request: for the use of their land? for the disruption when you have to excavate?

(b) Are the landowners in agreement with what you are proposing to do? If so, can you please provide evidence of such agreement.

Response:

(a) With the exception of some minor temporary workspace required for  construction and for a new densitometer, near Enbridge’s North- Westover Station, and within an industrial area in Montreal, the Project will take place within existing Enbridge properties and right of way. Generally speaking, the affected landowners will be compensated for the temporary workspace, including inconvenience and any crop loss, if applicable.

(b) Please refer to response to Les Citoyens au Courant IR 8.4

9 The terms and conditions related to the above issues, to be included in any approval the Board may issue for the proposed project.

(a) Has Enbridge considered creating an advisory/monitor site for those Request: affected by proposed project so that information can be easily obtained? If so, please provide details of such. If not, please explain why not.

(b) Has Enbridge considered putting in more shut off values to decrease the amount of crude involved in a leak, burst or spill? If so, please provide details of such. If not, please explain why not.

(c) Has Enbridge considered increasing the number of spill response teams to the Durham Region area? If so, please provide details of such. If not, please explain why not.

Response:

(a) Enbridge believes in open and transparent communication with all  landowners, communities and Aboriginal groups along the ROW and is committed to sharing information with those who are interested or who are potentially affected by the Project. To that end, Enbridge created a website for the proposed Project at www.enbridge.com/line9b, where Project information can be easily obtained.

(b) Please refer to the response to NEB IR 2.7.

(c) Enbridge reviews response team locations on a regular basis. Enbridge believes that, based on location of existing crews and location of contractor response crews, there is sufficient coverage in the Durham area.

 

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