A Spill Risk Assessment of the Enbridge Northern Gateway Project

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other scaling factors that adjust powered grounding, drift grounding, collision, foundering, and incidents involving fire or explosion to the BC context. Furthermore, DNV does not clearly identify whether it assesses scaling factors based on the comparison of the ENGP route to all other routes in the world for which the data is collected or whether it assesses factors for the routes that are close to shore in an area similar to the BC study area. Each approach would produce significantly different estimates that result in material changes to incident frequencies. Consequently, there is no basis on which to assess the validity of the scaling factors. 4. Lack of information provided to compare incident frequencies at the proposed Kitimat Terminal to marine terminals in Norway DNV does not provide adequate evidence to support its claim that “Incident frequencies from terminals in Norway are most representative of the operation planned for the Kitimat Terminal and should provide an appropriate forecast of the possible incident frequency at the Kitimat Terminal” (Brandsæter and Hoffman 2010 p. 5-‐71). Given that the organization, DNV Maritime and Oil & Gas, is headquartered in Norway, it seems appropriate that DNV use proprietary research from its country of origin. However, DNV fails to make any comparison of marine terminals in Norway to the proposed terminal in Kitimat. What are the geographic, physical, biological, and socioeconomic similarities between terminals in both regions? What are the differences in regulatory environments and marine safety practices between Canada and Norway? How do historical incident frequencies compare at terminals in Canada and Norway? These questions represent only some of the comparisons that should be made to support DNV’s decision to use incident frequencies from Norway to forecast possible incident frequencies at Kitimat Terminal. 5. Lack of transparency for mitigation measures that reduce the likelihood of tanker and terminal spills The fifth major deficiency concerning transparency relates to mitigation measures and their risk reducing effect on spill return periods. In Chapter 8 of the Marine Shipping Quantitative Risk Analysis, DNV examines risk reduction measures for tanker and terminal operations. The evaluation largely consists of a qualitative assessment of the characteristics of tug operations, enhanced navigational aids, and vessel traffic management system, among others. The only quantitative risk reduction factors considered in the methodological approach estimating spill return periods are escort tugs for tankers and a closed loading system at the marine terminal for cargo transfer operations. DNV estimates that both mitigation measures significantly decrease spill return periods. DNV bases the risk reducing effect of escort and tethered tugs for tanker incidents on a confidential study it completed in 2002 for tug escort operations at Fawley Terminal in the United Kingdom. According to this study, DNV claims that the use 20
of escort and tethered tugs will reduce the frequency of powered and drift grounding events 80% to 90% and will reduce collision incidents 5% (Brandsæter and Hoffman 2010 p. 8-‐120). DNV determines that the use of escort and tethered tugs will increase return periods from 78 years to 250 years for any size oil or condensate spill thus producing a three-‐fold risk reduction effect compared to unmitigated return periods. Given the significant increase in return periods forecast to occur with the use of escort and tethered tugs for tanker traffic, it is important for DNV to transparently provide quantitative analysis documenting the impact of mitigation. DNV must disclose specific information related to the number of observations on the role of these mitigation measures and the reliability of the data set regarding their impact from the confidential study DNV prepared in 2002 that is the foundation for reductions from mitigation measures in the marine shipping QRA. Similar concerns exist for mitigation measures at the marine terminal. In its limited assessment of mitigation measures for terminal operations, DNV claims that the closed loading system installed at Kitimat Terminal will eliminate the likelihood of spills from overfilling cargo tanks. Even in the event cargo tanks are overfilled, the closed loading system would redirect oil into nearby empty ship tanks “thereby eliminating the risk of an oil spill” (Brandsæter and Hoffman 2010 p. 131). DNV does not provide any historical evidence or data on the performance of closed loading systems to support this statement, which is concerning given that this single assumption eliminates any risk of a cargo tank overloading and more than doubles the unmitigated spill return period of 29 years to a mitigated return period of 62 years. Furthermore, given that the average loading/discharge operations at Kitimat Terminal is approximately 30 hours per year for each tanker (Brandsæter and Hoffman 2010 p. 5-‐74), there is no guarantee that a nearby tanker will be berthed at Kitimat Terminal in which to redirect oil into empty ship tanks. 6. Inadequate evidence supporting the reduction of spill frequencies for pipeline operations The methodological approaches in the ENGP application estimating return periods for pipeline spills in Volume 7B and pipeline failure frequencies that affect public safety in the Bercha Group (2012b) study lack transparency. Both studies incorporate downward adjustments into calculations for pipeline spill frequencies without providing adequate evidence. Enbridge estimates return periods for a pipeline spill in Volume 7B by adjusting spill frequency data from the NEB without disclosing how it made the downward adjustments and fails to provide evidence to justify the reductions. According to Enbridge (2010b Vol. 7B p. 3-‐1), NEB data from 1991 to 2009 7 includes pipelines up to 50 years old that use older technology and standards of building materials, 7 Note that there is a discrepancy on page 3-‐1 of Volume 7B, since Enbridge references NEB data from 1991 to 2000 as well as data from 1991 to 2009. 21
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 and 28: adjustments ranging from 60 to 90%.
Page 29 and 30: Table 17: Evaluative Criteria for A
Page 31: Pollution from Ships (MARPOL) and N
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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