The Whiteshell Cottagers Association was asked by the TransCanada Pipeline
Company to review their proposal to the National Energy Board (NEB) to
convert part of their existing natural gas pipeline into a heavy oil conduit.
Our Environment Committee reviewed selected portions of their proposal,
and met with their delegates on July 20 with the following record:
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
●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 applied 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, it is 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
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 an in-line Inspection
tool on at least an annual basis. Prevention of water and sediment accumula-
tion and the 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
3. The risk of faulty materials used (in selection of both pipeand control devices)
shall be limited by ensuring they are produced by qualified North American
manufacturers in accordance with published (and 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 five
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 they agreed to consider the suggestion for
hydrostatic testing at a lower pressure, and advise ourcommittee 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
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 two
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
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 its 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 bound-
aries. 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.