Enbridge Line 9 Reversal

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There is a new tar sands pipeline in town and it goes right through Durham

Click here for the pipeline route through Durham - pdf file

Unlike the proposed Northern Gateway Pipeline in British Colombia and the proposed Keystone XL Pipeline in the US, the Line 9 pipeline already exists. For over thirty years Line 9 has pumped conventional oil from Montreal through southern Quebec and southern Ontario to oil refineries in Sarnia, Ontario. Enbridge (operator of Line 9 and the company behind the Northern Gateway project) wants to reverse the flow of Line 9 (i.e.. flow from Sarnia to Montreal) so tar sands crude can be sent to Montreal. From Montreal, it looks like the plans are to pipe tar sands crude through Vermont, New Hampshire, and Maine to be exported by tanker from Portland, Maine. Plans for the Montreal-Portland pipeline are conditional on the Line 9 reversal being approved. And that's why Americans are not a big fan of Line 9 either.

Ontario (as well as Quebec) both have a chance and a choice in regards to Line 9. Ontarians could choose to throw their arms up in the air and say "what you gonna do?" The pipeline already exists so there is no way to stop its construction.  The vast majority of tar sands crude in Line 9 will be exported so Ontarians can take some comfort in the fact that they will not be filling up their cars with "dirty oil" from the tar sands.

Councils from all five affected Durham municipalities unanimously approve motions urging EA on Line 9

As of March 24th, all five lakefront communities in Durham (the ones that Line 9 passes through) have approved motions calling on the province to require a proper environmental assessment on Line 9, and in addition, asking that the pipeline be upgraded over a reasonable time period to 3/8" thickness rather than the current 1/4" That constitutes 97% of the existing pipe.

These motions were urged on the Councils by DurhamCLEAR president, Doug Anderson, who made delegations to all of them.

NEB fulfills expectations - approves Line 9 with a few reasonably good conditions

As most people expected, The National Energy Board issued its decision on Mar. 6 in which it gave Enbridge most of what it asked for. It gave approval to all 3 of Enbridge's 'asks'

Why the Province should require a provincial Environmental Assessment on Line 9

Now that the national Energy Board has all but ignored the suggested conditions that Ontario laid done in its submission on Line 9, the province should move forward on requiring a provincial EA.

DC asking all lakefront communities to urge Province to stick to its conditons re Line 9

DurhamCLEAR president, Doug Anderson is making the rounds of the lakefront communities in Durham to urge their Councils to support the conditions laid out by Rick Jennings, Assistant Deputy Minister, Ontario Ministry of Energy.as part of hisoral submission to the NEB on behalf of the Government of Ontario.

While these conditions do not go anywhwere near as far as DC would like, they should be considered as the minimum acceptable for the safe operation of the pipeline:

Durham Region doubly at risk: Thin walls and highest concentration of water crossings

This analysis is based in part on a chart of watercrossings released by Enbridge in response to an information request by Equiterre which showed that Durham Region had the highest concentration of watercrossing over the whole line.

Pipelines and CSA Z662

In researching Line 9, I kept reading references to CSA Z662. I did some research and found that this is the standard to which pipelines in Canada are built - even ones outside the jurisdiction of the NEB. The NEB is the regulator but CSA (Canadian Standards Association) writes the standards. And they are out of date.

I also found out that the standards are subject to periodic public review and that CSA Z662 is currently in the midst of a 60 day review period which started over Christmas and ends on Feb. 23.

DC's Final Argument to the National Energy Board

This is the NEB's official transcript minus some of the ums and ahs


4043.  MR. ANDERSON:  Anyway, good afternoon, Madam Chair and Members of the Board, I
want to thank you for the opportunity to address this hearing.

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


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!

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,

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?

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'.


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."


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.

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?


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

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?


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.


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?


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.


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?


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.


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.


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?


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

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