Record of Meeting between:
Mr. B .J. Arnold – TCPL; Mr. G. Trask; Mr. B. Adamson; of TCPL, and
Mr. D. Paquin – Concentric Public Affairs Ltd.
From: The Whiteshell Cottagers Association – Environment Committee
(Gary Kennedy; Garry Parker; Deborah Sequin); represented by Alan Roberts (Chair); and
Dan Klass – Past President; Ronald Smith – President
Date: July 20, 2016
The Whiteshell Cottagers Association (WCA) responded to TCPL’s request for support for the Energy East Pipeline conversion project – wherein one of their multi-tube cross Canada pipelines is to be converted from transporting natural gas, to transporting crude oil with consistency ranging from heavy bitumen to light crude.
The WCA as an association of cottage owners, neither supports nor opposes the delivery of oil from Western Canada to Eastern Canada by pipeline. However, because the Whiteshell area would be severely affected by even small leaks or spills from this pipeline, our association and its members are intensely sensitive to:
– the measures being proposed to minimize the potential for leak development ;
– the measures being proposed to ensure the existence and effectiveness of leak detection and monitoring equipment; even to detection and arresting of very small leaks; and
– the responsiveness of the management protocol that you apply to leak detection and spill control.
The Whiteshell area is comprised of exposed bedrock, and shallow burial bedrock overlain by highly permeable organic soils, swamps, lakes, and creeks. In addition, much of the bedrock is highly fractured and subject to rapid subterranean dispersion of any leaks that may occur. As a result, complete cleanup of spills of any size would be virtually impossible. Therefore, we have selected portions of the Energy East project proposal to the NEB for review (specifically Vol. 19 regarding “Accidents and Malfunctions”) with a view to minimizing the risk and frequency of leaks in the Whiteshell, and specifically with a view to eliminating where possible, the delay in pipeline shutdown following detection of a leak. With these objectives, we have developed a list of the conditions that would have to be met in order to gain our support for TCPL’s project proposal.
Generally, we found the technology to minimize the risk was being made available, however, not being used with a frequency sufficient to assure ongoing minimum risk. The issues of concern identified by this committee include:
1. Exterior corrosion protection and Stress Corrosion Cracking protection for the entire length of the pipe within the park must be provided. The only acceptable means is the fusion bonded epoxy (FBE) applied to new pipe prior to installation, with field connections being coated with field applied liquid epoxy. Conversion of pipe that is not so coated is not acceptable. We were assured by the representatives of TCPL in attendance that the existing pipeline that is to be converted, is relatively new, and was equipped with the FBE coating prior to initial construction throughout the Whiteshell Provincial Park area.
Cathodic Protection as proposed (and as currently installed on the pipeline to be converted) is acceptable. Inspection of the line for weld integrity and stress corrosion cracking assessment by use of an In-Line Inspection tool is also acceptable, providing the inspection frequency is at least annual.
We were advised that the frequency of use of in-line inspection tools is prescribed and monitored by the NEB. Further, that the most valuable information available from this type of testing is the trends evident from comparing each test run to previous runs. We were assured that trend lines indicating an escalating risk are acted upon as soon as an unacceptable risk of leakage is evident. We were pleased to hear this from a management perspective, but management decisions must be secondary to an automated spill detection response.
2. Internal corrosion shall be monitored by the use of In-line Inspection tool on at least an annual basis. Prevention of water and sediment accumulation and your proposed methods of removal are commendable, though further information on how monitoring of the oil quality being introduced into the pipe is needed. Use of tariffs to control the quality is not seen as a sufficiently positive means of management.
The representatives undertook to provide additional information on monitoring methodology.
3. The risk of faulty materials used (in selection of both pipe and control devices) shall be limited by ensuring they are produced by qualified North American manufacturers in accordance with published (proven) standards.
We were assured that all materials would be inspected prior to installation, and that they would all satisfy the specifications provided to the NEB
4. 100% of longitudinal welds shall be monitored on both new and converted pipe by being inspected by in-line instrumentation tools on an annual basis.
Representatives were unwilling to increase the monitoring frequency beyond that stipulated by the NEB which only calls for hydrostatic testing at the completion of initial construction.
5. All pipe and sub-assemblies shall be hydrostatically tested at least once every 5 years to 110% of the maximum operating pressure.
The representatives present believe the monitoring procedures specified by the NEB and offered in the Energy East Proposal, were thorough and reliable. They felt that hydrostatic testing created the risk of premature pipe failure, and deferred to the in-line electromagnetic monitoring tool as being reliable and more effective in submerged and / or underground installations. We indicated that the suggested reduction in test pressure to 110% of a normal hydrostatic test was deliberately intended to reduce the propensity for premature failure of the pipe. Further, that the hydrostatic test was the only proof positive means of demonstrating that leaks do not exist in the operating pipe line.
The representatives deferred to the NEB standard test protocol for location of leaks and potential leaks, though agreed to consider the suggestion for hydrostatic testing at a lower pressure further, and advise our committee of their decision.
6. Over pressure protection shall be provided to all operating components by relief valves operating at not more than 110% of Maximum Operating Pressure. Further, that these would be located adjacent to automated shut-off valves located on either side of the Park to aid in reducing the spill volume in case of a leak developing.
It was explained to us that pressure relief valves were located at the pumping stations only, without secondary relief at shut off valves located adjacent to high risk locations along the length of the pipe. The lack of distributed PRV’s was the reason for not permitting automation of the strategically located shut-off valves.
7. Because of the effect of even very small leaks, the WCA request that “Instantaneous” Flow Interruption capability be added to the line passing through the Whiteshell, enabled to work in conjunction with pressure monitoring devices and cause fully automated shut down of the line. These pressure monitors would be located adjacent to strategically located emergency shut-off valves, and work in conjunction with other leak detection monitoring systems being installed.
This is recognized as not being conventional technology – probably requiring the installation of temporary storage containers / devices adjacent to at least 2 automated shut-off valve locations. Shut off valves should have a full stroke operating time of not more than 30 seconds, and be located at each side of the Park as well as each side of submerged installations. Shut-off valves shall be proven operable by annual testing to full stroke position.
TCPL representatives recognized the merit of this suggestion, and the benefit of reduced leakage volume which would result from such a “venting” capability. They were concerned about increasing the potential for leaks in the system by increasing it complexity. They undertook to examine this concept further, and assess whether it has sufficient benefit in spill volume reduction to warrant incorporation in the Whiteshell Provincial Park.
In addition, the WCA would like to see considerably more detail in the description of remedial measures that shall be in place in case of failure of any of the preventative measures that have been discussed in items 1-7 above. Despite all preventive steps, the likelihood of failure remains significant. The physical state of the terrain of the Whiteshell, and its position as a major recreational site in Manitoba, demands something close to a warranty to provide full clean-up services, should a spill ever occur. Such a warranty must be included as a condition of the NEB Approval and / or the approval of the Government of Canada.
The TCPL representatives recognized the essence of this concern, and undertook to do their utmost to prevent a spill from ever occurring within the park boundaries. They also recognized that zero risk operation of a pipeline was not possible, and that they expected there would be a warranty provision required as a condition of granting the permission to construct.
We thanked the representatives for their candor and willingness to consider our stipulations. We indicated that we expected to hear from them on the matters discussed above – as well as concession in those areas where the technology is available to reduce both the risk and the size of potential spills which could occur within the Park.
Sincerely Alan Roberts – WCA Director Chair – Environment Committee