Engineered to fail

Having spent the better part of a year investigating the pipeline industry as an intervenor to the NEB line 9 hearings, I have reached the unfortunate conclusion that pipelines - all pipelines, not just Enbridge's, are engineered to fail.

That doesn't mean these companies want their pipelines to fail, it's just that the engineering standards of construction and maintenance are such that failure (leaks) is inevitable. The standards are just too weak.

An analysis of the acknowledged leaks on Line 9 shows that they all occurred in parts of the line which were only a 1/4" or slightly more, regardless of the cause. (Approximately 98% of the length of Line 9 is 1/4" thickness.) This makes sense - a stronger, thicker pipe will withstand much more corrosion or physical damage before it leaks. A thickness of 3/8" might have avoided all 12 of those leaks.

So who's at fault. Ultimately, the standards are at fault. So who sets the standards. You might have thought it was the NEB but, no, it's actually the CSA, Canadian Standards Association. Most of the standards are included in CSA Z662, a mighty tome of at least 1,000 pages. I've never actually seen a copy because selling copies of their standards (and selling training around those standards) is how the CSA makes its money. I tried to get a copy through interlibrary loan and the Whitby library requested a copy from the Vancouver library but it never came. The library found that there were only a few copies located in pubic librairies anywhere in the country and just a few more in university librairies. The people who buy it are the pipeline compaines because it's their rule book.

All of which makes it difficult for people, like me and other intervenors, who want to critique the standards. In addition the review was focussed on 'line-by-line" adjustments which left no room for "broad strokes" sort of comments on the focus, intent and 'outcomes' from the regulations.

While it is easy to say that the standards are weak, it has to be recognized that when initially written, the drafters would have relied on calculations to determine how thick the pipe should be - and the standards have evolved from there. While each leak should have triggered questions as to whether the standards were strong enough, they have instead spawned a culture of buck passing - like, "We meet all the regulatory stamdards".

During the hearings there were many references to CSA Z662 accompanied by brief quotes. It was only after the hearings that I decided to dig into it deeper and when I phoned CSA I discovered that such standards are subject to "public" review on a periodic basis and that such a review was imminent for Z662. The entire standard was posted in piecemeal fashion just before Christmas and people coiuld comment on it - if they knew about it - which basically meant the pipeline companies and associated users.

I left some comments from an environmentalist point of view which probably gave them a good laugh before they were tossed in the trash.

And basically that's the problem - the standards are written by the industry - which is basically happy with the status quo.

In my submission to the NEB, I commented that the standards were weak, and I suggested that the NEB should use its influence to get CSA to tighten the standards - but they didn't.

While clearly it is appropriate to have experts writing the standards (for anything), it is equally important that there be some oversight by regular citizens to ensure that the standards and regulations create outcomes which are acceptable to the broader public.

The public review exercise that the CSA conducted on Z662 failed in that regard because regular citizens had no idea a public review was taking place.