A Spill Risk Assessment of the Enbridge Northern Gateway Project

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disconnect between data reports and the main ENGP regulatory application, as well as the complete absence of a data report for pipeline spills, reduce accessibility to critical information, present barriers to the effective communication of spill likelihood to stakeholders, and could negatively impact the decision-‐making process. 5. Failure to clearly address the effective implementation of mitigation measures that reduce risk Another consideration related to clarity concerns the presentation of mitigation measures that purportedly reduce risk without discussing the effective implementation of risk management measures. In the marine shipping QRA, DNV identifies mitigation measures that it claims will reduce the likelihood of a spill. Enbridge’s consultants state “Should any of these requirements not be met the risk reduction effect would decrease accordingly.” (Brandsæter and Hoffman 2010 p. 8-‐ 120). Ensuring effective implementation is the responsibility of the company and the NEB, which is responsible for regulating companies’ activities. The enforcement and monitoring record of the NEB raises serious doubts about the effectiveness of implementing risk management. According to an audit performed by the Commissioner of the Environment and Sustainable Development (2011 p. 10), nearly two-‐thirds (64%) of the compliance verification files reviewed by the NEB identified deficiencies and only 7% of those files provided evidence the NEB followed up with companies to determine if deficiencies were corrected. Further, 100% of the emergency response plans reviewed had deficiencies and there was a follow-‐up to address the deficiencies in only one case (CESD 2011 p. 11). Thus, if Enbridge fails to implement mitigation measures and the NEB fails to take corrective action, spill likelihood could significantly exceed Enbridge’ s estimates that assume effective implementation of all risk-‐reducing mitigation measures. Furthermore, inadequate monitoring and enforcement have implications for emergency response in the event that a spill from the ENGP occurs. If the NEB fails to enforce emergency response initiatives outlined by Enbridge in the ENGP application to respond to a spill, a similar situation may result as the 20,000-‐bbl diluted bitumen spill that shutdown sections of the Kalamazoo River near Marshall, Michigan in July 2010 (NTSB 2012). Factual reports from the NTSB investigation into the spill characterize Enbridge’s response as incompetent in the detection and shutdown of the spill and suggest that Enbridge demonstrated inadequate preparation to contain the spill. Indeed, Enbridge control room operators failed to detect or attempt to shutdown the ruptured pipeline for 17 hours even though monitoring systems repeatedly sounded alarms and displayed low-‐pressure readings (NTSB 2012). After the spill was detected, Enbridge experienced considerable difficulties locating contractors and other resources in the region to contain the spill and waited for the US Environmental Protection Agency to eventually provide the contact information for contractors (NTSB 2012). populated areas, both of these reports are standalone studies that are independent from Volume 7B and were submitted two years after the initial application. 30
In its regulatory application for the ENGP, Enbridge outlines a general spill response plan and claims that equipment will be pre-‐staged to improve response time (Enbridge 2010b Vol. 8C p. 5-‐1). However, the weak monitoring record of the NEB (CESD 2011) and Enbridge’s recent mismanagement of the Line B spill in Michigan suggest that any mitigation measures identified in the ENGP application to reduce spill likelihood and minimize spill damage must include a risk assessment of the likelihood of implementation failure and must be accompanied by a detailed implementation plan that clearly outlines a comprehensive monitoring and verification program 16 . Evaluation: There are five major deficiencies related to the clarity criterion and thus this criterion is not met. Reasonableness Reasonableness: The analytical approach ensures quality, integrity, and objectivity, and meets high scientific standards in terms of analytical methods, data, assumptions, logic, and judgment. The methodological approach estimating spill return periods for the ENGP contains five major deficiencies related to the reasonableness criterion. Major deficiencies include: 1. Inappropriate definition of the study area to estimate spill return periods for tanker operations DNV calculates return periods for tanker spills based on an inappropriate definition of the study area. Although a sensitivity analysis extends the transit area to 200 nm off the BC coast, DNV does not calculate the likelihood of a spill for the entire tanker voyage to any key export markets in Asia or the US, nor does it examine the potential effects of a spill outside of the narrowly defined BC study region. DNV limits its analysis of tanker incident frequencies to three shipping routes within Canada’s Territorial Sea that represent an average of 233 nm. Yet, one-‐way sailing distances from Kitimat, BC to the three key Northeast Asia markets of Shanghai, China, Yokohama, Japan, and Ulsan, South Korea range from 4,041 to 4,865 nm (Enbridge 2010b Vol. 2 App. A p. 13) and the approximate one-‐way distance from Kitimat to San Francisco and Los Angeles, California are respectively 1,051 nm and 1,391 nm (Sea Distances -‐ Voyage Calculator undated). Thus, DNV ignores an average of nearly 4,200 nm to key markets in Asia and 1,000 nm to markets in the US per tanker route, which represents a significant exclusion of the distances navigated by tankers (Table 20). Assuming 149 oil tankers sail at least one leg of their voyage to Asia or the US, one-‐way distance shortfalls per tanker 16 We acknowledge that the Enbridge spill in Michigan occurred in a different jurisdiction than that regulated by the NEB. However, we reference the mismanagement of the spill to demonstrate that poor implementation of a spill response plan can have serious consequences. 31
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 and 40: Table 19: Spill Probabilities Over
Page 41: • Mortality of a small number of
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
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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
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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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