[All] Fw: Line 10: Not to code

Tue Aug 30 19:32:49 EDT 2016

----- Forwarded Message -----
 From: "water.lulu at yahoo.ca" <water.lulu at yahoo.ca>
 To: "justin.trudeau at parl.gc.ca" <justin.trudeau at parl.gc.ca>; Elizabeth May <elizabeth.may at parl.gc.ca>; Tom Mulcair <thomas.mulcair at parl.gc.ca>; Premier of Ontario | Première ministre de l’Ontario <premier at ontario.ca>; Andrea Horwath <ahorwath-qp at ndp.on.ca>; MPP Catherine Fife (Kitchener-Waterloo) <catherinefife at on.ndp.ca>; Bardish Chagger <bardish.chagger at parl.gc.ca>; James Carr P.C.M.P. <nrcan.minister-ministre.rncan at canada.ca>; Minister MOECC (MOECC) <minister.moecc at ontario.ca>; "bill.morneau at canada.ca" <bill.morneau at canada.ca>; "pbellegarde at afn.ca" <pbellegarde at afn.ca> 
 Sent: Tuesday, August 30, 2016 7:32 PM
 Subject: Line 10: Not to code

Dear Hon. Prime Minister and Minsters, NEB staff and Chief Bellegarde 
On August 29th the National Energy Board made an information request to Enbridge Pipeline Inc. Their response to this IR will be considered part of the evidentiary record. Enbridge isdirected to file its response to NEB IR No. 4 by noon on 14 September 2016.  The full document is included in the attachments for your reference. 
In section 4.5 of the document it states the following: 
4.5 Emergency Shutdown SystemReference:i) A74508-13 Enbridge, Application, Section 7.1.1 Project Scope, PDFpage 1 of 17 ii) National Energy Board Onshore Pipeline Regulations (OPR), Section12 – Alternate source of poweriii) CSA Z662-15 – Oil and Gas Pipeline Systems, section 4.14.3.3, page129 
Preamble: In Reference i), Enbridge committed to complying with the OPR, CSAZ662-15 and Enbridge’s Engineering Standards and Guidelines. Further,Enbridge listed the equipment to be installed as part of the Project.However, Enbridge did not provide any detail on the design or installationof alternate sources of power and emergency shut-down systems atWestover Pump Station and other pump stations along Line 10 that mayaffect the operation of Line 10 Replacement Segment during emergencysituations. 
Reference ii) states the requirements for alternate power sources atcompressor stations and pump stations. 
Reference iii) states the requirements for emergency shutdown systems atpump stations. 
Request: Provide the following: a) Confirmation whether every pump station that may affect theoperation of the Line 10 Replacement Segment, has (or will havebefore the in-service date) an emergency shutdown system, includingbackup power supply which comply with the requirements of theOPR Section 12 and CSA Z662-15 Section 4.14.3.3; b) A description of the alternate source of power for each station; and c) A description of the means to bypass and isolate each station.

First off, I would like to thank the NEB for addressing this concern because it is important for public safety.  I like the fact they give a hard deadline and that it will be submitted as evidence. This is very good way to assure compliance. It is good to see. 
Secondly, I'd like to thank the Board for allowing me the oppertunity to make mention of this issue as a written commentor in the Line 10 Westover Segment Replacement process. In my view it is a blessing for the public to have the chance to share such concerns and in light of the challenges being faced currently by the board in Montreal, I just wanted to state that personally, that from my own experience as a delegate with the Line 9 and 10 hearings, the Board representatives have always been helpful, and process advisers have assisted me as best as they can. I feel sad when I watch the news today because I understand the story from both sides. The concerns the people have have are good things to debate but the actions they took, particularly that one bearded fella, was clearly unreasonable. Never the less it does illustrate the fact that the people are really upset about this.  
My advice for the path forward would be to secure a forum to allow people the chance to speak outside of the NEB process. The public clearly has pressures and fears right now and in voicing it we can help calm down this situation. Don't structure it so much that it is a dry written process but simply facilitate an open mike approach of 3-5 minutes each speaker to help understand what the public really wants. Is it about climate change? Is it about the pipeline? Is it about fear of another Lac Megantic or spill? Is it the fear of costs associated with yet another court challenge because we failed to secure crown consultations?  It it because we lack a National Water policy to protect supplies for the long term?  We need to listen to these people in good faith, to understand what is driving them to this point. We can't assume what the issues are and we should not limit their expression to NEB's limited criteria.  I think we really need to take the time to understand the views of the people as they are today otherwise whatever issues they have brewing in their hearts ends up fueling the kind of outbursts like the one we saw and that's not good for anybody. The people need to be heard but in my view, it's beyond the scope of the NEB to do this so approach because the public does not trust them. We need to do something to foster better social cohesion between the government and the people because under the Harper government we lost that connection for years. People want to rebuild trust but they have a lot of pain and fear to get through so keep that dialogue going to help heal people. Keep it simple by just giving them a voice at a microphone. 
Getting back to the topic of the original concern of the potentially non compliant pumping stations, it is important to know that both Line 10 and Line 9 use the Westover terminal. Line 9 goes from Sarnia to Westover (Line 9 phase 1) and Westover to Montreal (Line 9B) and it's flowing oil through an end of life pipeline right now.   I was a delegate of the Line 9 hearings and I know for a fact that the valves along major waterways are not up to code because there are simply not enough of them. I also know that the emergency measures were not up to code at Westover Terminal too. Why did the NEB allow the Line 9 Leave to Open without resolving these outrageous safety issues?    
The TSB identified Enbridge's lack of emergency measures at their pumping stations and Westover Terminal in their report regarding the Binbrook spill produced in 2001. See Attachment 32.
The NEB itself stated Westover was not to code in 2011. See Attachment 29. 
I went to Copetown on August 4th 2016 along Line 10 and I saw manual valves. No generators, no communication systems in place etc. See Attachment 34. 
These issues were part of the sworn affidavit I gave to the board regarding the Line 10 hearing. (Affidavit is online here: https://docs.neb-one.gc.ca/ll-eng/llisapi.dll?func=ll&objId=3025064&objAction=browse&viewType=1)
The way I see it, if a guy builds a house, it has to go through an inspection process. The boxes need to be checked off to assure compliance to building codes. Do we have such a process for our pipeline approval processes? If not I suggest we do that. Every pipe, every pumping station and valve system needs to go through that checklist without question because if we as a nation lack that policy, or understanding of the system as it stands today,  we as a nation assume the liability of the risks. If something isn't to code, don't put the oil in the line until those issues are resolved. Our economy, our ecology and our communities rely more on clean water than oil and we have a duty to protect water by way of Treaties and Charter Laws so it is not unreasonable to demand that people work to code. 
If Line 9 is not in compliance, don't allow the use of that line until it is safe to do so. That is common sense. 

How we invest CPP monies can be a very powerful tool to assure policy compliance. No Nafta laws to govern where we wish to invest. If industries are not following the rules, we have the choice to stop fiscally sponsoring them. I would like to see more of this as an incentive for good behavior. We need to secure short term smaller loans with CPP to support green energy infrastructure and small businesses anyways so my advice is reallocate the funds from non compliant companies to fund the good work we need to see to help Canadians and First Nation's people. 
The issue of the NEB and the public can swiftly be resolved by simply doing the right thing. Act on truth and common sense. Follow your own rules and put teeth into it with firm deadlines and firm conditions of approval with evidence to show work was done to assure companies work to code. If they can't afford to do things right at least it won't be the burden on the public to assume the risks of their inactions. 
Yours in good faith
Louisette Lanteigne700 Star Flower Ave.Waterloo Ont.N2V 2L2 

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