[All] Have a say on pipeline structural integrity issues!

Thu Jan 23 12:23:39 EST 2014

FYI

----- Forwarded Message -----
From: Louisette Lanteigne <butterflybluelu at rogers.com>
To: "regionalcouncillors at regionofwaterloo.ca" <regionalcouncillors at regionofwaterloo.ca>; BRENDA HALLORAN <bhalloran at rogers.com>; "Karen.Scian at waterloo.ca" <Karen.Scian at waterloo.ca>; "diane.freeman at waterloo.ca" <diane.freeman at waterloo.ca>; "jeff.henry at waterloo.ca" <jeff.henry at waterloo.ca>; "melissa.durrell at waterloo.ca" <melissa.durrell at waterloo.ca>; "Mark.Whaley at waterloo.ca" <Mark.Whaley at waterloo.ca>; "scott.witmer at waterloo.ca" <scott.witmer at waterloo.ca>; "angela.vieth at waterloo.ca" <angela.vieth at waterloo.ca>; "dschultz at grandriver.ca" <dschultz at grandriver.ca>; "cfife-co at ndp.on.ca" <cfife-co at ndp.on.ca>; "peter.braid at parl.gc.ca" <peter.braid at parl.gc.ca>; "jmilloy.mpp.co at liberal.ola.org" <jmilloy.mpp.co at liberal.ola.org>; "stephen.woodworth at parl.gc.ca" <stephen.woodworth at parl.gc.ca>; "gary.goodyear at parl.gc.ca" <gary.goodyear at parl.gc.ca>; BobVrbanac <BVrbanac at waterloochronicle.ca>; "gmercer at therecord.com" <gmercer at therecord.com>; "Paul.Emerson at brant.ca"
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Sent: Thursday, January 23, 2014 12:16:43 PM
Subject: Have a say on pipeline structural integrity issues! 

Dear MP's and Municipal Officials

I have four articles for your review in regards to Enbridge pipelines 7, 8 and 9, all which cross Waterloo Region currently. 

Also I have information regarding CSA Z662: the standards to which pipelines are built in Canada. They are revising the policy and are looking for public comment.  Now would be an excellent time for cities to give voice to any structural integrity concerns regarding pipeline procedures. 

First the 4 articles: 

1. Lawyer Clayton Ruby states if he wins his case against the NEB for restricting participation, it will reopen the Line 9 hearings. Here is a link to an article regarding this:
http://www.cbc.ca/news/canada/hamilton/news/lawsuit-moves-to-reopen-line-9-pipeline-neb-hearings-1.2506850

2. If the Line 9 hearings are  re-open, we could introduce Environment Canada's latest report confirming the fact diluted bitumen sinks when mixed with sediment. It is relevant to our issues because the pipes will be vulnerable to rupture during periods of heavy flood risks associated with anticipated climate change. The water would mix with sediment and it is also quite possible a leak could end up in the Great Lakes and the wave factor would also come into play.  Here is the link to Environment Canada's report on this concern.
http://ec.gc.ca/scitech/F5C2D374-AC34-4429-BB1A-93FD61E2D3F3/1633_Dilbit_Technical_Report_e_v2_FINAL-s.pdf

3. Enbridge Line 7 flow increases in this 58 year old pipe that runs parallel to Line 9, was approved by the NEB in November without land owner or municipal notification.  Enbridge stated they will be using a dilutent to speed up the transfer of oil and land owners are worried an oil spill would occur with a faster flow as a result.  Will existing spills protocols be sufficient? If a pipe containing this solvent leaks, what is the projected flow rate difference? The article gives reference to the fact there are anticipated volume increases anticipated for Enbridge Line 7, Line 8 and Line 9. I haven't heard of any public process regarding Line 8 yet. Here is that article:
http://www.vancouverobserver.com/environment/enbridge-pipeline-ontario-approved-without-public-hearing-critic-calls-neb-claim

4. This article shows that the US is shipping significantly higher volumes of oil into Canada to be refined here and sold back to the US in the form of Gas. http://stream.wsj.com/story/latest-headlines/SS-2-63399/SS-2-431630/?mod=wsj_streaming_latest-headlines

If oil on Line 9 is mainly from North Dakota via the Enbridge Westover Terminal (A possibility mentioned at the NEB Line 9 hearings) it would be reasonable to state this does not qualify as a "common carrier" in Canada. Here is a recent court case from Texas regarding the use of the term "common carrier".  This issue could be revisited should the Line 9 hearings re-open. 
http://ecowatch.com/2014/01/09/landowner-over-transcanada-keystone-xl-eminent-domain-case/

Secondly, the revision of the CSA Z662

CSA Z662 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. I have heard many experts state repeatedly they are out of date.

The standards are subject to periodic public review and it just so happens that CSA Z662 is currently in the midst of a 60 day review period which started over Christmas and ends on Feb. 23.

CSA is a professional organization with a mandate to protect workers, the public and the environment. They need our input. 

Although this process is intended primarily for technical comments, it is important that we submit our non-technical comments as well. The technical comments they receive will be heavily biased towards detail and not towards the overall integrity of the system. It's the system integrity that is the main are of concern. We need to find a way to include review processes that look at the totality of the physical structure. 

Here's how the review process works.

Go to http://publicreview.csa.ca/

you will have to register - name, etc.  It will email you an activation URL and a password (that you can change)

Then go back to the opening page, and do a search for CSA Z662, Oil and gas pipeline systems is currently about the middle of the list. Click on "Draft Details". 

You are now into the draft standard. The table of contents is down the left side. If there is a plus sign, there are subheadings. Click on an item and it will appear in the main window. There are buttons on every section to comment and suggest changes. You can save your comments and then come back to them, but you have to 'submit' them in order for them to be part of the review. 

Any input you could provide would be greatly appreciated. Please feel free to relay this
 message to others as well. 

Ideas I'd like to see implimented:

Hydrostatic testing at 1 and a half the projected psi volumes required throughout the entire pipe.
Emergency valves on both sides of a river rather than simply one side since riverbeds are at a higher risk for ruptures and shut off valves may be 12 miles apart.  
Reasonable depth of coverage to protect pipelines from rupture in tributaries from heavy flood, ice scours and erosion issues at a depth that will protect for life of pipeline
Proper thickness of the walls of the pipe, perhaps double lined walls where it crosses hydrogeological risks be they aquifers or tributaries. 
Mandatory physical inspection of pipelines in tributaries during flood/icejams/seismic risk periods. 
Bump up of precautionary closures of lines during heavy flooding/icejams/seismic events to prevent leaks. 

Yours in good faith,

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