by Robin Sukhu (firstname.lastname@example.org)
The primary reason for me writing this article is to pass on the notes I made at the January 22, 2015 meeting of the Ontario Energy Board’s public meeting held in Kanata. Before I get into the details, I want to state the main points up front hoping that it will make for an easier read.
Here are the main points:
1. There is little economic benefit for Ontario – only $3.5 million.
2. There is a lot of profit to be made but that profit will end up in the hands of multi-nationals.
3. TransCanada Pipeline (TCP) has not submitted an Emergency Response Plan.
4. The TCP submission is incomplete (see page 4 of this link). This is acknowledged in writing and verbally by the independent consultants. For some unknown reason, my MPP Jack Maclaren, insists that the submission is complete.
5. The public will have little oversight over the pipeline operations – even the Emergency Response Plan will not be made public.
7. The National Energy Board, the regulator, appears to be biased. The Harper government has identified the NEB as an ally in their energy strategy. (See paragraph 2 of this link.)
I am personally impressed that the Ontario government is taking this issue seriously (full disclosure: I have no political affiliation). I only wish my MPP and my local municipal council would do the same. (No time to read this article? Check out this funny video – it is informative too.)
NOTES FROM THE OEB PUBLIC MEETING
On Thursday January 22, 2015 I attended the Ontario Energy Board’s public meeting on the Energy East Pipeline. My intention is to describe what happened at that meeting, to share some of the things I learned and make the occasional observation. TransCanada Pipeline has submitted to the National Energy Board (NEB) a 30,000 page document describing the Energy East Pipeline. The submission is being evaluated by various independent consultants (1) who have been hired by the OEB. The Ontario government decided to conduct public meetings to get feedback from the community and to conduct a formal process to evaluate the Energy East submission. The plan that the OEB developed for doing this is described here.
As stated by the moderator, one of the goals of the OEB Consultation is to provide MPPs with an opportunity to contact their constituents to gauge the level of support for, or opposition to, the Energy East Pipeline. As far as I am aware, my MPP has made no attempt to poll his constituents. There were about 350 people attending the meeting, seated at about 35 tables. Following the formal presentations, each table was given the opportunity to voice their opinions – the feedback was overwhelmingly against the Energy East Pipeline. To the best of my recollection, there was not one pro pipeline comment. I noticed that my MPP was in attendance – I do hope that he noted what his constituents were saying.
Representatives from each of the independent consulting firms presented their findings. The first presenter spoke about the climate change impact, the second spoke about pipeline safety and the third spoke about the environmental impact.
The following are the notes from that meeting.
In the preamble to the first presenter’s talk there was a discussion of the tax benefits. It was stated that the tax benefits are small, estimated to be only $3.5 million.
Presentation on Climate Change/Greenhouse Gases
The consultant’s report on the TCP submission claims that there will be minimal additional greenhouse gases produced because the oil that is produced from the tar sands will mean that somewhere else in the world, there will be less production. The decreased production elsewhere will offset the tar sands increased greenhouse gases.
In the audience was an environmental studies (I think it was environmental studies) prof from Ottawa U. He called the analysis of the greenhouse gases useless and called for the firing of the consulting firm that did the analysis.
The next section of the presentation was on Pipeline Safety.
Gas pipeline requirements are higher than the requirements for an oil pipeline. The pipeline to be converted to carry tar sands oil is a gas pipeline.
The presenter stated that something called the “notch property” is more stringent for gas pipelines. I am not sure what the “notch property” is. The book “Piping and Pipeline Engineering: Design, Construction, Maintenance” by George A. Antaki describes it as something to do with testing the resistance to the pipeline tearing using a drop weight test.
The two types of welding were described. DSAW (Double Submerged Arc Weld) is the superior type and this is the type that will be used on the Energy East Pipeline.
The wrapping of the pipeline will be Fusion Board Epoxy and this is superior to the fibreglass wrapping. The superior method will be used on 95% of the pipeline. The remaining 5%, which is 99 km, will be the inferior fibreglass wrapping method. (None of the 5% of inferior pipeline is in our area. It is still an issue that should be addressed.)
The part of the line that runs in our area is Line 1200-2 and it was installed between 1991 and 2006.
There is a tool called the “in-line inspection tool” that is used to detect corrosion from inside the pipeline. This tool is inserted into the pipeline and travels along the inside of the pipe.
Running an in-line inspection tool is not cheap. See the section below “Questions to TransCanada Pipeline”, specifically Question 2 on how frequently the in-line inspection tool is used. Also note in Question 3 that TCP will not make the inspection results public!
The tools to detect cracks in the pipeline are not as reliable as the “in-line inspection tool”. The figure below shows what cracks in a pipeline looks like – note that some of these cracks can be hairline cracks and can result is slow, hard to detect leaks. Detecting cracks in the pipeline under a river seems to be near impossible – it appears that the solution for this is to monitor the river for oil in the water.
Valves will be placed on both sides of significant water crossings (significant has not been defined).
TransCanada Pipeline has not identified the significant water crossings.
The Emergency Response Plan (ERP) has not been submitted. This means that TCP has not defined how it will deal with failures to the pipeline. TCP claims that the ERP will be submitted to the National Energy Board at a later date. The public will not have access to the ERP!
See TCP’s response to Q5 in the section below “Questions to TransCanada Pipeline”. Note that they unambiguously state that the ERP will not be made public. This was re-confirmed at the public meeting.
TCP states that it has the financial capability of $1 billion to be used to clean up spills. But the consultant’s report states that TCP should “Demonstrate financial capability ($1 Billion) to respond to a pipeline failure and remedy the situation” (this quote is taken from here). My interpretation of this is that TCP’s claims are unsubstantiated.
A lot of emphasis was given to TCP’s leak detection system. They claim that they can respond to a leak within 22 minutes and the most oil that would spill in 22 minutes is about ¾ of a Olympic sized swimming pool. Here is what the consultant’s report had to say about the leak detection system: “The application states that Energy East will implement a leak detection strategy that meets current regulatory requirements and industry standards, using both real-time (SCADA) and non-real-time (e.g. ILI, right-of-way patrols) methods. It is unclear whether the leak detection system will meet the Recommended Practice set out in Annex E of CSA Z662-11. Further, the application does not provide sufficient information on the performance metrics (i.e. reliability, sensitivity, accuracy, robustness) to be considered in the selection of the leak detection system” (quote taken from here).
The consultant’s report states emphatically: “The Application is incomplete” (quote taken from here).
Key elements are missing from TCP’s submission ESA Volume 6 is missing lots of information. Volume 6 deals with “Accidents and Malfunctions”.
Volume 8 “Environmental Protection Plans”– no detailed site specific information. This information was supposed to be supplied before Christmas 2014.
The fact that the section on how to deal with Accidents and Malfunctions and the section on Environment Protection is inadequate is concerning.
The independent consultant stated that they cannot assess the application’s conclusions of “no significant adverse effects” on the environment because TransCanada Pipeline did not supply adequate information. The report made the following points about the submission:
- For most of the 1900 km route there is no information on water intakes.
- Independent assessment to produce a full bore rupture modelling for every kilometer should be done.
- Map all surface water intakes and springs.
- Designate significant water crossings.
- Produce the ERP.
The presenter then talked about a section of the pipeline called “The Rideau Shortcut”. It will be a new 42 inch pipeline.
The application proposes trenchless drilling to cross the Rideau River and Canal. If trenchless drilling (horizontal drilling under the river) does not work, an open-cut technique will be used. TransCanada Pipeline has not prepared a detailed protection plan for either trenchless or open cut method. The consultant recommends that a detailed plan be produced. (See page 45 of this document)
According to the consultant, ESA Vol 6 Section 4.2.4 does not describe what happens in the event of a spill near river.
Strongly stated conclusion: The Environment Impact submission is incomplete.
There is zero information on the 125 km of needed power lines to support the pipeline’s operation.
Questions from the Audience
Q. How to deal with the solvent in the pipeline?
A. No answer available. TCP will not say what is in the pipeline; they claim it is proprietary information.
Q. How to detect slow long term leaks?
A. These are difficult to detect. No clear answer. People with wells should be particularly concerned about this type of leak.
Q. Not really a question but a comment from a member of the audience. She pointed out that the submission paints an optimistic picture of TCP’s intentions and capabilities. She asked: why is the submission not judged on TCP’s past performance of which there is a historical record rather than the positive forward looking promises that TCP is making in its submission. She went on to verbally enumerate the numerous pipeline spills that occurred in the last 10 years.
Q. How to detect leaks in the pipeline under the river?
A. see the NEB submission – they don’t have a good answer.
Q. Regarding the diluents, the benzene mix to make the tar sands flow, how are these diluents returned to Alberta? What? I had no idea that the chemicals are extracted and returned to Alberta!
A. They will be returned either by rail or via another pipeline! Note: that stuff is even more dangerous than the tar sands diluted bitumen. Ignoring how the return of this toxic material is irresponsible and ignores at least half of the problem.
Q. In the case of a spill, TCP claims that drinking water will be supplied. Where will they get this water?
Q. The existing gas pipeline (the one that will be converted) currently supplies gas to Eastern Canada. If the pipeline is converted, who will supply gas to the existing consumers and how?
A. I did not record the answer and I cannot recall the answer to this important question, sorry.
My Observations and Concerns
One of my concerns is about the regulator, the National Energy Board (NEB). If this pipeline becomes operational for carrying tar sands oil, it is the NEB who will enforce safety practices. I tried to determine if there are rules for how often the “in-line inspection tool” must be run. The best information I can get is in response to Question 2 (see section titled Questions to TransCanada Pipeline below). According to TCP:
The Integrity Management Program and Associated Assessment Plan will be reviewed annually. Primary integrity inspections will be conducted at five-year intervals, and our primary integrity inspection plans will be updated in three-year intervals.
Who will ensure that the Integrity Management Program is adequate? Is that TCP or will it be the NEB? How will we the public know? It seems that we simply have to trust the NEB.
The results of the inspection will not be made public. The public will have no way of knowing if the pipeline has degraded and no way of monitoring the operations. For example, how does the public enforce the running of the “in-line inspection” tool every five years?
The “in-line inspection” tool is expensive to run. A rough estimate is that it costs $35,000 per mile or $22,000 per km (go here for the source of this data). For the 1900 km of pipeline in Ontario that translates to a cost of $41,800,000. It would be very tempting for a company to try to “save” $41.8 million by foregoing or delaying such an expensive test. I would like some way to guarantee that these tests be run on a schedule with no exceptions and that the results be made public. How else can we the public judge the risks that we are in and more importantly, manage the risks.
A concern about the NEB. The Federal government has classified the NEB as an ally in its energy strategy.
Energy companies, the National Energy Board, Environment Canada, business and industry associations, meanwhile, are listed as “allies” in a public relations plan called the “Pan-European Oil Sands Advocacy Strategy.” It is dated March 2011.”
Quote taken from here. Why would I trust the NEB to rule objectively given this piece of information?
“Pipelines don’t leak, they have been in the ground for years without problems” – this is a close paraphrase of what my MPP had to say in defense of the Energy East pipeline. For those who actually believe this claim, go here and see for yourself how wrong this statement is.
Some interesting links:
- http://www.cbc.ca/news/technology/bitumen-spill-effects-on-waterways-oceans-unknown-draft-federal-report-says-1.2940083 http://activehistory.ca/2013/11/tracking-canadas-history-of-oil-pipeline-spills/
Where exactly is this Pipeline in our community?
Notice that the pipeline crosses the Madawaska River, Waba Creek, the Mississippi River and goes directly through the Burnt Lands Provincial Park.
Questions to TransCanada Pipeline
This section is not from the OEB meeting. I provide it as background information.
The following five questions were submitted to TCP in April, 2014. Five months later I received the following answers:
Q1. How do you monitor the pipeline for cracks that may be developing – what type of technology do you use?
Ensuring the integrity of the Energy East Pipeline begins with proper construction practices. All of TransCanada’s pipelines, including the pipeline that will be converted as part of the Energy East Pipeline Project, were constructed using only the highest quality materials and best construction practices. Implementing these proper practices in accordance with CSA Z662-11 is one of the first steps taken to avoid deterioration due to corrosion. All welded joints are examined with radiographic or ultrasonic technology, sandblasted and coated with a fusion bonded epoxy coating. Prior to the coating application, each weld is individually examined to ensure that a high quality weld was achieved. Once the weld is accepted, the coating process begins. Before a new pipeline is put into service, it is pressure tested by a means of a hydrostatic test that subjects the pipeline to a much higher than normal operating pressure, ensuring the material’s strength. Once the pipeline is constructed, an extremely low-voltage electric current called “cathodic protection” is installed, which helps to prevent corrosion while the pipeline is in operation.
TransCanada’s ongoing Pipeline Integrity Management Program consists of many overlapping leak detection systems while the pipeline is in operation. Over the past three years, TransCanada has spent an average of $900 million per year on pipeline integrity, inspection and maintenance programs. TransCanada will continue to invest even more in future years to ensure that our pipelines, including Energy East, will continue to safely and reliably transport Canadian resources. Some of the practices in place today are cleaning inspections, in-line inspections, cathodic protection, investigative digs, aerial patrols and pipeline repair programs. Periodic internal cleaning inspections are used to sweep the interior of the pipeline and random product sampling will occur to help mitigate internal corrosion. Chemical corrosion inhibitors, biocides, corrosion coupons or probes will be used as necessary to assist in this process. Highresolution in-line inspection tools are used to detect both internal and external defects while the pipeline is operational. A Magnetic Flux Leakage Combination (MFL Combo) tool is used to inspect the pipeline for corrosion as well as mechanical damage. To detect stress corrosion cracking and coating imperfections an Electromagnetic Acoustic Transducer (EMAT) tool is utilized. In-line inspections collect internal and external pipeline integrity information for the entire length of the pipeline. As mentioned above, a cathodic protection system is monitored on a regular basis to mitigate the growth rate of corrosion features. As an extra precaution, aerial patrols are conducted approximately every two weeks along the pipeline right of way to visually identify any issues that could be caused by the integrity of the pipeline. If any defects are found within the pipeline, investigative digs and the necessary repairs will be proactively performed. Our routine inspection and repair programs ensure the integrity of the pipeline remains intact and in a safe operating condition.
In Canada, pipelines must be constructed and operated in compliance with CSA Z66211 (2) and the Onshore Pipeline Regulation, as well as any other conditions that may be written into the approval by the National Energy Board. Furthermore, a 24-hour monitoring system is used which allows our highly trained staff at the control centre to detect changes in pressure, density and temperature which would indicate a possible leak. TransCanada’s standard operating procedure requires control centre operators who detect a leak in the pipeline to shut down the pipeline immediately. The Integrity Management Program and Associated Assessment Plan will be reviewed annually. Primary integrity inspections will be conducted at five-year intervals, and our primary integrity inspection plans will be updated in three-year intervals.
Q2. How often do you monitor the pipeline for developing cracks?
As mentioned above, the pipeline is monitored 24-hours a day and 365 days a year by TransCanada’s best-in-class leak detection system. In the event of an incident, TransCanada can identify and remedy the situation within minutes. Any anomalies identified by the leak detection system are investigated by the highly trained control centre staff who can initiate remote valve closures and the shut-down of pump stations. The Integrity Management Program and Associated Assessment Plan will be reviewed annually. Primary integrity inspections will be conducted at five-year intervals, and our primary integrity inspection plans will be updated in three-year intervals.
Q3. Do you make the results of each pipeline examination public? If yes then how is this information accessed? If no then why is it not public?
The results of each pipeline examination are not made public due to confidentiality agreements with TransCanada’s vendors and the nature of the data. The raw data must be interpreted by an independent third party expert. Interpreted results of all in-line inspections will be reviewed by the National Energy Board prior to approval of the project, and used to complete all required proactive repairs to the line once it is in service.
Q4. What data are you relying on to prove that pumping tar sands oil through this pipeline does not increase the risks?
Oil sands bitumen needs to be reduced in viscosity through the addition of a diluent in order to flow through the pipeline. Some opponents claim that pipelines carrying this diluted bitumen, or “dilbit” have more internal corrosion, and therefore present safety risks. This is not true. Multiple studies conducted by some of the world’s leading and most respected scientific research organizations. The U.S. National Academy of Sciences, Battelle Memorial Institute, Penspen Institute and Natural Resources Canada (please see the links below) have all concluded that dilbit behaves the same way as conventional crude oils and does not pose any additional risks when transported through pipelines.
Corrosivity in transmission pipelines comes from two sources: water content and erosive constituents such as mud and sand. Those substances are removed before crude oil enters pipelines. Any oil transported by TransCanada’s pipelines, including the proposed Energy East Pipeline, must meet stringent quality specifications before it is accepted from the shipper.
Q5. Have you developed an action plan for cleanup of spills? If yes, is this plan public?
The Energy East Emergency Response and Preparedness team is currently finalizing an Emergency Response Plan (ERP) that will include detailed clean-up procedures that will be followed in the unlikely event of a release. The Energy East Pipeline plan is being developed in consultation with local first responders. This ERP will be submitted to the National Energy Board before the pipeline is brought online. These plans are not made public due to the inclusion of security sensitive and personal information. However, emergency response information will be shared with affected landowners and public officials.
1 These are the consulting firms that I identified:
- Swerhun Consulting – http://www.swerhun.com/currentprojects/
- Det Norske Veritas (Canada) Ltd – www.dnvgl.com
- Tera Environmental Consultants – http://www.ontarioenergyboard.ca/html/oebenergyeast/documents/Background_Report_Tera_201403.pdf
2.The following direct quote from the OEB’s independent consultant evaluating the submission should be noted: “It is unclear whether the leak detection system will meet the Recommended Practice set out in Annex E of CSA Z662-11.” This quote is taken from here. This footnote is mine and not part of the TCP answer.