[All] Fw: Engineering concerns regarding Enbridge's data for Line 9

Mon Dec 30 13:05:18 EST 2013

Hi folks

Update regarding my efforts to secure a review of Enbridge LIne 9.

Lulu 

----- Forwarded Message -----
From: Louisette Lanteigne <butterflybluelu at rogers.com>
To: "abergeron at peo.on.ca" <abergeron at peo.on.ca>; "ddixon at peo.on.ca" <ddixon at peo.on.ca>; "daveadams at wightman.ca" <daveadams at wightman.ca>; thomas.chong at rogers.com; "sausma at peo.on.ca" <sausma at peo.on.ca>; "huangr at bennettjones.com" <huangr at bennettjones.com>; "ibhatia at peo.on.ca" <ibhatia at peo.on.ca>; "michael at wesa.peo.on.ca" <michael at wesa.peo.on.ca>; "rafraser at uwaterloo.ca" <rafraser at uwaterloo.ca>; "bdony at peo.on.ca" <bdony at peo.on.ca>; "rjones at peo.on.ca" <rjones at peo.on.ca>; "ctaylor at peo.on.ca" <ctaylor at peo.on.ca>; "dbrown at peo.on.ca" <dbrown at peo.on.ca>; "carlos.qc9z at ncf.ca" <carlos.qc9z at ncf.ca>; "csadr at peo.on.ca" <csadr at peo.on.ca>; "lking at peo.on.ca" <lking at peo.on.ca>; "ekuczera at peo.on.ca" <ekuczera at peo.on.ca>; "dchui at peo.on.ca" <dchui at peo.on.ca>; "rwillson at peo.on.ca" <rwillson at peo.on.ca>; "sgupta at peo.on.ca" <sgupta at peo.on.ca>; "vkossta at peo.on.ca" <vkossta at peo.on.ca>; "rhilton at peo.on.ca" <rhilton at peo.on.ca>; "jlee at peo.on.ca" <jlee at peo.on.ca>; "mirwin at peo.on.ca"
 <mirwin at peo.on.ca>; "croney at peo.on.ca" <croney at peo.on.ca> 
Cc: "tarsem.sharma at humber.ca" <tarsem.sharma at humber.ca>; "rshreewastav at peo.on.ca" <rshreewastav at peo.on.ca>; "sreid at peo.on.ca" <sreid at peo.on.ca>; "mstauch at peo.on.ca" <mstauch at peo.on.ca> 
Sent: Monday, December 30, 2013 1:03:17 PM
Subject: Fw: Engineering concerns regarding Enbridge's data for Line 9

Dear Members of the Board of Professonal Engineers Ontario

I am writing this to request that the PEO review the engineering data being used to support the Enbridge Line 9 pipeline reversal. I have no doubt this projects poses one of the highest engineering risks ever faced by the Province of Ontario.

As a delegate I was shocked to witness how Enbridge narrowed the scope of review to exclude significant evidence indicating how this pipeline will rupture if approved as planned.  There is evidence taken from Enbridge that reveals the pipeline will rupture in several areas if flow exceeds 740 psi due to the presence of numerous crack clusters, features and corrosion.   I tried previously to submit my concerns to the PEO but the request was declined by Mr. Ken Slack, Manager of Complaints and Investigations Regulatory Compliance. He provided me with the letter in the attachment and returned all my written data. 

I am informing you all directly in good faith, to see if this matter can be reconsidered. I only desire the chance to help relay the concern in order to prevent the risks.

Please review the following email and attachment that I have shared with provincial officials as of this morning. It goes into more details of the concerns. 

Thank you kindly for your time. 

Louisette Lanteigne
700 Star Flower Ave.
Waterloo Ont.
N2V 2L2

----- Forwarded Message -----
From: Louisette Lanteigne <butterflybluelu at rogers.com>
To: "kwynne.mpp at liberal.ola.org" <kwynne.mpp at liberal.ola.org>; "dzimmer.mpp.co at liberal.ola.org" <dzimmer.mpp.co at liberal.ola.org>; "jbradley.mpp.co at liberal.ola.org" <jbradley.mpp.co at liberal.ola.org>; "ahorwath-co at ndp.on.ca" <ahorwath-co at ndp.on.ca>; "jgerretsen.mpp at liberal.ola.org" <jgerretsen.mpp at liberal.ola.org>; "ehoskins.mpp at liberal.ola.org" <ehoskins.mpp at liberal.ola.org>; "ljeffrey.mpp.co at liberal.ola.org" <ljeffrey.mpp.co at liberal.ola.org>; "cfife-co at ndp.on.ca" <cfife-co at ndp.on.ca>; "gmurray.mpp at liberal.ola.org" <gmurray.mpp at liberal.ola.org>; "dorazietti.mpp at liberal.ola.org" <dorazietti.mpp at liberal.ola.org>; "csousa.mpp.co at liberal.ola.org" <csousa.mpp.co at liberal.ola.org>; "dmatthews.mpp at liberal.ola.org" <dmatthews.mpp at liberal.ola.org>; "kslack at peo.on.ca" <kslack at peo.on.ca>; "stephane.dion at parl.gc.ca" <stephane.dion at parl.gc.ca>; "linda.duncan at parl.gc.ca" <linda.duncan at parl.gc.ca> 
Sent: Monday, December 30, 2013 11:40:13 AM
Subject: Engineering concerns regarding Enbridge's data for Line 9

Dear Hon. Ministers, and Mr. Slack

My name is Louisette Lanteigne and I was a delegate at the National Energy Board hearings regarding Enbridge Line 9 pipeline reversal. 

After the hearing took place I submitted a written complaint to Professional Engineers Ontario (PEO) that was received on November 4, 2013. The request was intended to facilitate are review of the Environmental Assessment data being used for the approval of Enbridge Line 9 pipeline reversal because the scope of the review was unreasonably limited and significant risks exists that could result in catastrophic ruptures of the pipeline if approved. 

The data I submitted was presented at the NEB hearing. The concerns voiced to the PEO were specific to structural integrity issues of the pipeline and engineering data submitted as sworn evidence.  

In response, I received a letter as seen in the attachment, sent on December 19 2013 from Ken Slack, P.Eng Manager, Complaints and Investigations Regulatory Compliance which states the following:

"PEO has no record of Enbridge Pipelines Inc. as being a holder of a Certificate of Authorization issued by PEO. Subsequently, this firm does not fall within our regulatory jurisdiction. As a result, PEO cannot process this complaint and your materials are being returned to you hearin."

I find the response of the PEO to be insufficient. It appears that discretionary powers are being used to negate a reasonable review of this matter opening up the province to significant economic and environmental risk.

Here is the weblink to Enbridge's  Engineering Standards and Specifications.
http://www.enbridgetechnology.com/Products/Engineering-Standards-and-Specifications.aspx

Here is a list of Engineering jobs with Enbridge
http://jobs.enbridge.com/careers/engineering-jobs

Enbridge is a member of the American Society of Mechanical Engineers
http://www.enbridgetechnology.com/About.aspx

Under what logic can the PEO or the Province reasonably exclude an assessment of engineering concerns specific to the activities of Enbridge when clearly there is no plausible deniability that Enbridge is providing engineering services in Ontario.

PEO's mandate, as described in the Professional Engineers Act, R.S.O. 1990, CHAPTER P.28 is to ensure that the public is protected and that individuals and companies providing engineering services uphold a strict code of professional ethics and conduct.  
PEO protects and serves the public by:
-Ensuring ALL licensed professional engineers are qualified - and by licensing all who qualify;
-disciplining professional engineers found guilty of professional misconduct;
-taking action against unlicensed individuals who illegally describe themselves as engineers. Similarly, the association can prosecute companies or entities who illegally provide engineering services to the public;
-investigating all complaints brought to it about unlicensed, unprofessional, inadequate or incompetent engineering services;
-conducting dispute resolution and hearings; and 
-prepairing performancce guidelines as benchmarks for quality of service in the engineering profession. 

The passage was taken from the PEO's website at: http://www.peo.on.ca/index.php/ci_id/1801/la_id/1.htm

It would seem prudent that the Province facilitate a reasonable review of the engineering work being used to support the Enbridge Line 9 reversal project due to the fact Enbridge limited the scope of the review to the area of their pumping stations which only makes up 2% of the entire length of Line 9.  It is not logical to exclude 98% of the pipeline's length from the review process but that is what happened. Enbridge limited the scope of study using discretionary powers leaving Ontario vulnerable for the potential consequences. 

According to Enbridge's own data, there are several areas of crack clusters and corrosion that will rupture if the system is run at 740 psi or lower yet Enbridge is requesting the transportation of diluted bitumen at 1000 psi without conducting hydrostatic testing.  That's not reasonable.  

The highest pressure the pipe ever ran at was 666 psi in Cardinal Ontario for a total duration of 5 minutes. It has never been run higher. A reasonable engineer would test the entire length at 1500 psi if the system is to run at 1000 psi. Seeing that Taxpayers rely on the PEO to protect the public interest it would seem reasonable to me that the PEO should be involved to some extent, if only to review if Enbridge' proposal is actually up to code.

The data supporting this project, or lack thereof, is in my view a National Security Risk that could adversely impact public health, economic and ecological concerns. Potential impacts exists along municipal water intakes along the Grand River. It could contaminate the Great Lakes within hours hurting municipalities, tourism, fisheries in some of the most highly populated areas of Canada.

The pipeline is only buried one meter down. It's well over 30 years old and Enbridge admits in writing they only inspect pipelines crossing tributaries once ever 5 years. This is not reasonable. We can do better than this. We must if we are to protect the public interest.

What provincial agency or official is responsible to address such concerns if it's not the PEO? Please inform me in writing so I can provide them with my written information. 

Thank you kindly for your time.

Louisette Lanteigne
700 Star Flower Ave.
Waterloo Ont.
N2V 2L2
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