A Spill Risk Assessment of the Enbridge Northern Gateway Project

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hypothetical spill based on the modeling results, characteristics of the affected environment, documented impacts from previous spills in the Alaska region (i.e. Glacier Bay and Exxon Valdez) and peer-‐reviewed studies. The Cook Inlet environmental impact statement estimates the following potentially significant 14 impacts from a 1,500 bbl (238 m 3 ) oil platform spill or a 4,600 bbl (731 m 3 ) pipeline spill: • Beach and intertidal fish habitat impacts could last more than a decade from residual oil • Mortality of endangered and threatened species such as sea otters and Steller sea lions could occur • Commercial fisheries could close for an entire season due to tainting concerns • Oil remaining in shoreline sediments for up to 10 years could impact clam and shellfish sport fisheries • Recreation and tourism areas could close partially or completely • Oil spill cleanup activities could disturb archaeological resources • Negative effects could occur to intrinsic values of National and State parks. In addition to significant effects, the environmental impact statement also identifies the following spill effects to other marine-‐related resources that could occur from a 238 to 731 m 3 oil spill in Cook Inlet: • The spill could impact an area between 618 and 1,100 km 2 • Between 17 to 38 km of shoreline could be contaminated for up to a decade • Water quality in the vicinity of the spill would be at chronic toxicity levels for up to 30 days • Local intertidal and lower trophic-‐level organisms could be depressed measurably for about one year • Mortality of adult fish, fish fry, and eggs could occur, although there would be no measurable loss to overall fish populations • Mortality of hundreds to tens of thousands of birds could occur and recovery could take from a few years to a few generations • Mortality of small numbers of resident marine mammals and recovery could take from one to five years, although no measurable decline in regional populations are expected 14 The US DOI uses a definition for significance consistent with the Council on Environmental Quality National Environmental Policy Act (NEPA) regulations, which defines significance in terms of context and intensity (US DOI 2003a p. IV-‐1): “Context” considers the setting of the Proposed Action, what the affected resource might be, and whether the effect on this resource would be local or more regional in extent. “Intensity” considers the severity of the impact, taking into account such factors as whether the impact is beneficial or adverse; the uniqueness of the resource (for example, threatened or endangered species); the cumulative aspects of the impact; and whether Federal, State, or local laws may be violated…Our (US DOI) EIS (environmental impact statement) impact analyses address the significance of the impacts on the resources considering such factors as the nature of the impact (for example, habitat disturbance or mortality), the spatial extent (local and regional), temporal and recovery times (years, generations), and the effects of mitigation (for example, implementation of the oil-‐spill-‐response plan). 28
• Mortality of a small number of terrestrial mammals and recovery could take one to three years • Disproportionately high adverse effects would occur to Native populations resulting from potential contamination of subsistence harvest areas, tainting concerns and disruption of subsistence practices. In summary, DNV fails to determine the likelihood of a spill for all spill sizes that can have a significant adverse environmental impact and fails to provide supporting evidence for using 5,000 m 3 as the implied cut off for significant adverse effects. 4. Lack of clear communication of spill estimates generated in detailed technical data reports in the main ENGP application A fourth deficiency is Enbridge’s failure to clearly state spill estimates generated in the detailed technical reports in the main application report. For example, Enbridge summarizes the 139-‐page Technical Data Report Marine Shipping Quantitative Risk Analysis prepared by DNV in just 23 pages in the TERMPOL Study, in just two pages in Volume 7C, and four pages in Volume 8C of the ENGP regulatory application. The executive summary of the Enbridge application summarizes the risk of tanker spills in just one paragraph that states (Enbridge 2010b Vol. 1, p.11-‐ 35): For risk related to vessel transits within the Territorial Sea of Canada with inclusion of navigation safety mitigation (primarily the use of tethered and close escort tugs), the calculated return period of a spill of any size from a tanker carrying oil is 350 years. For condensate, the return period is 890 years. The return period for large scale releases increases (risk level decreases) substantially to a level of 550 years for a spill exceeding 5,000 m 3, 2,800 years for a spill exceeding 20,000 m 3 and more than 15,000 years for a spill exceeding 40,000 m 3. A significant amount of important information required to inform decision-‐makers is missing from both the TERMPOL study and Volumes 1, 7C and 8C of the ENGP application, including information on the methodological approach, data gaps and limitations, assumptions used throughout the analysis, any uncertainties associated with results, and the sensitivity analysis. Enbridge presents spill return periods for pipeline operations in three pages in Volume 7B and there is no reference to a technical data report or appendix containing a more comprehensive analysis of pipeline spills. Thus not only is the information on pipeline spills inadequate in Volume 7B, but no data report exists to clarify the methodology, data, assumptions, and limitations that clearly and comprehensively explain how pipeline spill return periods were evaluated 15 . The 15 Note that although the WorleyParsons (2012) report examines a full-‐bore pipeline rupture and the Bercha Group (2012b; 2012c) reports examine pipeline spills at pump stations and a pipeline spill in densely 29
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 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: Table 19: Spill Probabilities Over
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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