A Spill Risk Assessment of the Enbridge Northern Gateway Project

Executive Summary
1. The objective of this report is to evaluate Enbridge’s spill risk analysis and to
determine if spills from the ENGP are likely to cause significant adverse environmental
effects as defined by the Canadian Environmental Assessment Act (CEAA).
2. The CEAA evaluation criterion requires assessment of two components to define risk:
the severity of an adverse impact and the likelihood of an adverse impact occurring.
This report focuses on evaluating the likelihood of an adverse impact (oil spills)
occurring. Another report completed by Gunton and Broadbent (2012b) addresses the
severity of the impact of an oil spill and concludes that oil spills as small as 238 m 3
(1,500 barrels) could have significant adverse environmental impacts.
3. The ENGP consists of an 1,172 kilometre (km) oil pipeline to ship oil from Alberta (AB)
to Kitimat, British Columbia (BC), a condensate pipeline to ship condensate from
Kitimat to AB, and a marine terminal for tankers. The planned capacity of the oil
pipeline is 525 thousand barrels per day (kbpd) with potential to expand to 850 kbpd
and the planned capacity of the condensate pipeline is 193 kbpd with potential to
expand to 275 kbpd. The ENGP would require an average of 220 tankers per year,
which could increase to 331 tankers per year with expansion of the pipeline to full
capacity.
4. Enbridge provides separate estimates of the likelihood of spills for each of the three
major components of the project: tanker operations, terminal operations, and the oil
and condensate pipelines. Enbridge does not combine these separate estimates to
provide an overall estimate of the probability of spills for the entire project and
therefore does not provide sufficient information to determine the likelihood of
adverse environmental effects as required by CEAA.
5. Forecasting spill risk is challenging due to the many variables impacting risk and the
uncertainties in forecasting future developments affecting risk. To improve the
accuracy of risk assessment, international best practices have been developed. This
report uses these international risk assessment best practices to evaluate Enbridge’s
methodology for estimating spill rates for the ENGP based on the following rating scale:
• Fully met: no deficiencies
• Largely met: no major deficiencies
• Partially met: one major deficiency
• Not met: two or more deficiencies.
6. The evaluation concludes that Enbridge’s spill risk analysis meets none of the seven
best practice criteria (Table ES-­‐1). In total there are 28 major deficiencies in the
Enbridge risk analysis for ENGP tanker, terminal and pipeline spills. The results show
that Enbridge understates the risk of spills from the ENGP.
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