A Spill Risk Assessment of the Enbridge Northern Gateway Project

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Table 16: Summary of Spill Return Periods for the ENGP Type of Spill Tanker Spill Return Period (in years) Any size spill Oil/Condensate Oil 78 -‐ 250 110 -‐ 350 > 5,000 m Oil spill exceeding a certain size 3 200 -‐ 550 > 20,000 m3 1,750 -‐ 2,800 > 40,000 m3 Terminal Spill 12,000 -‐ 15,000 Any size spill Oil/Condensate Oil 29 -‐ 62 34 -‐ 90 Small spill (< 10 m3) Oil/Condensate Oil 77 110 Medium spill (10 -‐ 1,000 m3) Pipeline Spill Oil/Condensate Oil 46 -‐ 294 49 -‐ 430 Leak (94 m3) Oil/Condensate Oil 2 4 Rupture # Tanker, Terminal, or Pipeline Spill Oil/Condensate Oil 128 239 Spill from ENGP* Oil/Condensate Oil 2 4 Source: Brandsæter and Hoffman (2010); Worley Parsons (2012). Note: Range represents mitigated and unmitigated spill probabilities with the exception of pipeline spills * Overall spill probability for ENGP based on spill probabilities for any size tanker spill, any size terminal spill, and pipeline leaks. # Average size oil pipeline rupture is 2,238 m3 and average size condensate rupture is 823 m3 (WorleyParsons 2012). 4. Evaluation of ENGP Spill Estimates The following section evaluates spill return periods presented in the ENGP regulatory application. The objective of the assessment is to examine whether the methodological approach used by Enbridge and its consultants adequately assesses the likelihood of significant adverse environmental effects as required in the CEAA. To achieve this objective, we assess methodologies estimating return periods for tanker, terminal, and pipeline spills in the ENGP application with best practice criteria and identify any deficiencies. We examined several sets of guidelines for risk assessment practices and principles and synthesized the literature into a single evaluative framework (Table 17). We use the following four-‐point scale to assess the degree to which each criterion is met: • Fully met: no deficiencies • Largely met: no major deficiencies • Partially met: one major deficiency • Not met: two or more major deficiencies. 16
Table 17: Evaluative Criteria for Assessing the Quality of Methodological Approaches to Estimating Risk Criterion Description Source Transparency Replicability Clarity Reasonableness Reliability Validity Risk Acceptability Documentation fully and effectively discloses supporting evidence, assumptions, data gaps and limitations, as well as uncertainty in data and assumptions, and their resulting potential implications to risk Documentation provides sufficient information to allow individuals other than those who did the original analysis to obtain similar results Risk estimates are easy to understand and effectively communicate the nature and magnitude of the risk in a manner that is complete, informative, and useful in decision making The analytical approach ensures quality, integrity, and objectivity, and meets high scientific standards in terms of analytical methods, data, assumptions, logic, and judgment Appropriate analytical methods explicitly describe and evaluate sources of uncertainty and variability that affect risk, and estimate the magnitudes of uncertainties and their effects on estimates of risk Independent third-‐party experts review and validate findings of the risk analysis to ensure credibility, quality, and integrity of the analysis Stakeholders identify and agree on acceptable levels of risk in a participatory, open decision-‐making process and assess risk relative to alternative means of meeting project objectives BC MoELP (2000); US EPA (1998); US EPA (2000); US EPA (2004); IALA (2008) US EPA (1998); IALA (2008); NRC (1996) US EPA (1998); US EPA (2000); US EPA (2004) BC MoELP (2000); US EPA (1998); US EPA (2000); NRC (1996) BC MoELP (2000); US EPA (2000); US EPA (2004); NRC (1996) US EPA (2000); US EPA (2004); IALA (2008) BC MoELP (2000); IALA (2008); NRC (1996) Transparency Criterion: Documentation fully and effectively discloses supporting evidence, assumptions, data gaps and limitations, as well as uncertainty in data and assumptions, and their resulting potential implications to risk. There are six major deficiencies related to transparency in the methods estimating spill return periods in the ENGP regulatory application. Major deficiencies include: 1. Lack of supporting evidence for LRFP tanker incident frequency data The frequency assessment in chapter five of the Marine Shipping Quantitative Risk Analysis and described in section 3.1, which is the foundation for estimating return periods for tanker spills, fails to provide the necessary supporting evidence. First, there is inadequate information describing the LRFP data that contains grounding, collision, foundering, and fire/explosion incidents. DNV fails to provide proprietary data in an appendix or data file that includes information on the type of accident, location, date, factors contributing to the incident, and whether or not the incident resulted in a spill. Instead, DNV simply states that LRFP data are obtained from 1990 to 2006 “…since the type of vessels in operation and the incidents that have occurred after 1990 are considered to be more representative of modern tanker operations, such as the one planned by Northern Gateway.” 17
Page 1 and 2: A Spill Risk Assessment of the Enbr
Page 3 and 4: Table ES-‐1: Results for the Qu
Page 5 and 6: These findings show that the defici
Page 7 and 8: Table ES-‐4: Probabilities for
Page 9 and 10: increases to 99.9% if the volume of
Page 11 and 12: List of Equations, Figures and Tabl
Page 13 and 14: 1. Introduction This report provide
Page 15 and 16: Enbridge expects that tankers calli
Page 17 and 18: Major facilities at Kitimat Termina
Page 19 and 20: affecting risk are equal to the wor
Page 21 and 22: Table 5: Estimated Reduction in the
Page 23 and 24: medium size oil/condensate spills f
Page 25 and 26: Table 12: Return Periods for Spills
Page 27: adjustments ranging from 60 to 90%.
Page 31 and 32: Pollution from Ships (MARPOL) and N
Page 33 and 34: of escort and tethered tugs will re
Page 35 and 36: ENGP regulatory application. Furthe
Page 37 and 38: We acknowledge the difficulty in re
Page 39 and 40: Table 19: Spill Probabilities Over
Page 41 and 42: • Mortality of a small number of
Page 43 and 44: In its regulatory application for t
Page 45 and 46: accidents in Canada, the LRFP datab
Page 47 and 48: Evidence suggests that sulphur conc
Page 49 and 50: anging between 16 and 20 years 22 a
Page 51 and 52: The absence of expert review for th
Page 53 and 54: Risk Acceptability Risk Acceptabili
Page 55 and 56: the likelihood that environmental a
Page 57 and 58: 5. Extended Sensitivity Analysis fo
Page 59 and 60: Table 25: Five-‐Percentage Poin
Page 61 and 62: Sensitivity 6: Aggregating Paramete
Page 63 and 64: effects of different assumptions on
Page 65 and 66: combined, the NEB data suggests tha
Page 67 and 68: United States of America with the O
Page 69 and 70: 2. Estimate the volume of oil and c
Page 71 and 72: 1994 to 2008 international data and
Page 73 and 74: 6.3. Spill Probability Estimates fo
Page 75 and 76: 6.4. Summary of ENGP Spill Probabil
Page 77 and 78: The OSRA method clearly estimates s
Page 79 and 80:
Evaluation: There is one major defi
Page 81 and 82:
7. Comparison of Spill Estimates fo
Page 83 and 84:
operation. Our application of the O
Page 85 and 86:
8. Conclusion This report evaluates
Page 87 and 88:
Figure 5: Number of ENGP Terminal S
Page 89 and 90:
References Alberta Energy and Utili
Page 91 and 92:
Enbridge. (2004). 2004 Corporate So
Page 93 and 94:
MacDonald, K. (2012). Northern Gate
Page 95 and 96:
United States Department of Transpo
Page 97 and 98:
• Tankers sail in coastal areas w
Page 99 and 100:
• Major Damage: Damage to the tan
Page 101 and 102:
25% for a collision (Brandsæter an
Page 103 and 104:
the overall tanker spill return per
Page 105 and 106:
Table A-‐11: Sensitivity Analys
Page 107 and 108:
Group estimates risks from spills t
Page 109 and 110:
In the event a tanker is struck by
Page 111 and 112:
a spill. Expressed as a return peri
Page 113 and 114:
2012 as a response to an informatio
Page 115 and 116:
Table A-‐23: Return Periods for
Page 117 and 118:
The first Bercha Group (2012c) stud
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A Spill Risk Assessment of the Enbridge Northern Gateway Project

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