Our Questions to Enbridge re Line 9

As an intervenor in the National Energy Board hearings of the reversal (etc.) of Line 9, we get to ask questions which Enbridge is required to answer. On June 10, DurhamCLEAR sent them the following list of questions:

 

Enbridge Pipelines Inc. (Enbridge) Line 9B Reversal

And Line 9 Capacity Expansion Project (Project)

Application under section 58 (Application) of the National Energy Board Act

OH-002-2013

 

Information Request to Enbridge

File OF-Fac-Oil-E101-2012-10 02

 

June 11, 2013

 

Questions Relating to the Stated Issues:

 

  1. The need for the project

 

(a)    Has Enbridge explored alternative scenarios for transportation of crude? If 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?

 

  1. 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?

 

  1. The appropriateness of the rules and Regulation tariff

 

(a)    Has consideration been given to compensating the local municipalities for this proposed project?

 

 

  1. 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

 

(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 amount 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.

  1. 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 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?

 

(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.

 

  1. 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 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?

(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.

 

  1. Aboriginals

 

 

  1. 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 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.

 

  1. 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 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.