Category: oil spill

Two days left for public input on BC “heavy oil” spill response plans

oilspillresonsepaperResidents of British Columbia have just two days to file information and opinions on the province’s  plans for “options for strengthening BC’s spill preparedness and response policies and capacity.”

A page on the BC Ministry of the Environment’s web site  wants public input as part of “BC’s five conditions necessary for support of heavy oil projects.”

Premier Christy Clark announced her controversial five conditions for pipeline development in BC in July 2012. Clark’s announcement was aimed both at the Northern Gateway Pipeline which would have its terminal in Kitimat, and the proposed Kinder Morgan pipeline expansion which has its terminal in Vancouver.

It is not clear how long the web page has been up,  but the call for input from the public has received little, if any, publicity. The deadline for public submissions is February 15, 2013.

(Northwest Coast Energy News was alerted to the story by a Kitimat-based hiking club)

A separate call for academic papers had a deadline of January 25. The province plans a conference on oil spill response  in Vancouver from March 25 to March 27. The website says”

As part of British Columbia’s commitment to a world leading preparedness and response regime for land based spills, it is hosting a symposium March 25-27, 2013 in Vancouver, BC. Due to the anticipated high interest in the symposium, attendance is by invitation only.

One question would be if invitation only is designed to exclude activist groups who may wish to participate or demonstrate. The Northern Gateway Joint Review panel banned public input at hearings in Vancouver and Victoria earlier this year to try, not always successfully, to head off demonstrations. The webpage says:

In keeping with the established polluter-pay principle, and recognizing the increase in development activities across the province, the Ministry of Environment (the ministry) is reviewing industry funded options for strengthening BC’s spill preparedness and response policies and capacity. Land based spill refers to any spill impacting the terrestrial environment, including coastal shorelines, regardless of the source.

This review addresses three aspects of land based spill preparedness and response: World leading regime for land based spill preparedness and response

Effective and efficient rules for restoration of the environment following a spill

Effective government oversight and coordination of industry spill response The ministry has developed a policy intentions paper for consultation (intentions paper) on the three aspects of the province’s land based spill preparedness and response regime under consideration.

The purpose of this intentions paper is to describe the ministry’s proposed policy direction and seek input on enhancing spill preparedness and response in BC. The intentions paper is a discussion document and your feedback will influence the policy approach.

Although the call for input is on the ministry website, the contact is a management consulting firm C. Rankin & Associates.

New US pipeline safety report finds more problems with Enbridge, problems also found in other big pipeline companies

Leak detection report coverA new draft report for the U.S. Congress from the United States Pipeline and Hazardous Materials Safety Administration takes new aim at Enbridge for failures in its pipeline leak detection and response system.

Not that the PHMSA is singling out Enbridge, the report is highly critical of leak detection systems on all petroleum and natural gas pipeline companies, saying as far as the United States is concerned, the current pipeline standards are inadequate.

The release of the “Leak Detection Report” written by Kiefner & Associates, Inc (KAI) a consulting firm based in Worthington, Ohio, comes at a critical time, just as Enbridge was defending how it detects pipeline leaks before the Joint Review Panel questioning hearings in Prince George, where today Enbridge executives were under cross-examination by lawyers for the province of British Columbia on how the leak detection system works.

In testimony on Wednesday, October 12, Enbridge engineers told the Joint Review Panel that the company’s pipelines are world-class and have a many prevention and detection systems.

Northern Gateway president John Carruthers testifed there is no way to eliminate all the risks but the company was looking for the best way of balancing benefits against the risk.

However, the KAI report points out that so far, all pipeline company cost-benefit analysis is limited by a short term, one to five year point of view, rather than looking at the entire lifecycle of a pipeline.

Two Enbridge spills, one the well-known case in Marshall Michigan which saw bitumen go into the Kalamazoo River and a second in North Dakota, both in 2010, are at the top of the list in the study for PHMSA by the consulting firm.

On the Marshall, Michigan spill the KAI report goes over and adds to many of the criticisms of Enbridge in the National Transportation Safety Report in July which termed the company’s response like the “Keystone Kops.”

The second spill, in Neche, North Dakota, which, unlike the Marshall spill, has had little attention from the media, is perhaps equally damning, because while Enbridge’s detection systems worked in that case–the KAI report calls it a “text book shutdown”– there was still a spill of 158,928 gallons (601,607 litres) of crude oil, the sixth largest hazardous liquid release reported in the United States [between 2010 and 2012] because Enbridge “did not plan adequately for containment.”

(The KAI report also examines problems with natural gas pipelines, including one by TransCanada Northern Border line at Campbell, Wyoming in February 2011. Northwest Coast Energy News will report on the natural gas aspects of the report in a future posting.)

The highly technical, 270-page draft report was released on September 28, as Enbridge was still under heavy criticism from the US National Transportation Safety Board report on the Marshall, Michigan spill and was facing penalties from the PHMSA for both the Marshall spill and a second in Ohio.

Looking at overall pipeline problem detection, KAI says the two standard industry pipeline Leak Detection Systems or LDS didn’t work very well. Between 2010 and 2012, the report found that Computational Pipeline Monitoring or CPMs caught just 20 per cent of leaks. Another system, Supervisory Control and Data Acquisition or SCADAs caught 28 per cent.
Even within those acronym systems, the KAI report says major problem is a lack of industry standards. Different companies use different detector and computer systems, control room procedures and pipeline management.

The report also concludes that the pipeline industry as a whole depends far too much on internal detectors, both for economic reasons and because that’s what the industry has always done. External detectors, the report says, have a better track record in alerting companies to spills.

A significant number of spills are also first reported by the public or first responders, rather than through the pipeline company system and as KAI says of Enbridge, “Operators should not rely on the public to tell them a pipeline has ruptured.”

The consultants also say there are far too many false alarms in spill detection systems.

Although the KAI report concentrates on the United States, its report on Enbridge does raise serious questions about how the company could detect a pipeline breach or spill in the rugged northern British Columbia wilderness where the Northern Gateway Pipeline would be built, if approved by the federal government.

The report comes after the United States Congress passed The Pipeline Safety, Regulatory Certainty, and Job Creation Act, which was signed into law by President Barack Obama on January 3, 2012. The law called on a new leak detection study to be submitted to Congress that examines the technical limitations of current leak detection systems, including the ability of the systems to detect ruptures and small leaks that are ongoing or intermittent. The act also calls on the US Department of Transportation to find out what can be done to foster development of better technologies and economically feasible ways of detecting pipeline leaks. The final report must be submitted to Congress by January 3, 2013.

(The draft report does note in some ways, Canadian standards for detecting pipeline leaks are better than those in the United States. For example, Canada requires some pipeline testing every year, the United States every five years. It also finds European pipeline monitoring regulations also surpass those in the United States).

The spills studied in the report all found weaknesses in one or more of those three areas: people, company procedures and the technology. It appears that the industry agrees, at least in principle, with executives telling the consultants:

The main identified technology gaps – including those identified by operators – include: reduction or management of false alarms; applicable technical standards and certifications; and value / performance indicators that can be applied across technologies and pipelines.

The report echoes many of the findings of the US National Transportation Safety Board in its examination of the Enbridge Marshall, Michigan spill but it applies to all pipeline companies, noting:

Integration using procedures is optimal when it is recognized that alarms from the technology are rarely black-and-white or on/off situations. Rather, at a minimum, there is a sequence: leak occurrence; followed by first detection; followed by validation or confirmation of a leak; followed by the initiation of a shutdown sequence. The length of time that this sequence should take depends on the reliability of the first detection and the severity of the consequences of the release. Procedures are critical to define this sequence carefully – with regard to the technology used, the personnel involved and the consequences – and carefully trained Personnel are needed who understand the overall system, including technologies and procedures.

We note that there is perhaps an over-emphasis of technology in LDS. A recurring theme is that of false alarms. The implication is that an LDS is expected to perform as an elementary industrial automation alarm, with an on/off state and six-sigma reliability. Any alarm that does not correspond to an actual leak is, with this thinking, an indicator of a failure of the LDS system.

Instead, multiple technical studies confirm that far more thought is required in dealing with leak alarms. Most technologies infer the potential presence of a leak via a secondary physical effect, for example an abnormal pressure or a material imbalance. These can often be due to multiple other causes apart from a leak.

The report takes a critical look at the culture of all pipeline companies which divides problems into leaks, ruptures and small seeps. Under both pipeline practice and the the way problems are reported to the PHMSA in the US a “rupture is a situation where the pipeline becomes inoperable.” While a rupture means that a greater volume of petroleum liquid or natural gas is released, and is a higher priority than a leak or seep, the use of language may mean that there is a lower priority given to those leaks and seeps than the crisis created by a rupture.

(Environmental groups in British Columbia have voiced concerns about the cumulative affect of small seeps from the Enbridge Northern Gateway that would be undetectable under heavy snow pack either by an internal system or by external observation)

Overall, the report finds serious flaws to the way pipeline companies are conducting leak detection systems at the moment, including:

  • Precisely the same technology, applied to two different pipelines, can have very different results.
  • Leak Detection Systems do not have performance measures that can be used universally across all pipelines. Compounding the problem are different computer systems where software, program configuration and parameter selection all contribute, in unpredictable ways, to overall performance.
  • Many performance measures present conflicting objectives. For example, leak detection systems that are highly sensitive to small amounts of lost hydrocarbons are also prone to generating more false alarms.
  • The performance of a leak detection system depends critically on the quality of the engineering design, care with installation, continuing maintenance and periodic testing.
  • Even though an internal technology may rely upon simple, basic principles, it is in fact, complex system that requires robust metering, robust SCADA and telecommunications, and a robust computer to perform the calculations. Each of these subsystems is individually complex.
  • Near the inlet and the outlet of the pipeline a leak leads to little or no change in pressure. Flow rates and pressures near any form of pumping or compression will generally be insensitive to a downstream leak
  • Differences in any one of these factors can have a dramatic impact on the ultimate value of a leak detection system.

The report goes on to  say:

There is no technical reason why several different leak detection methods can not be implemented at the same time. In fact, a basic engineering robustness principle calls for at least two methods that rely on entirely separate physical principles.

The report strongly recommends that pipeline companies take a closer look at external leak detection systems. Even though the US Environmental Protection Agency began recommending the use of external detection as far back as 1988, the companies have resisted due to the cost of retrofitting the legacy pipeline network. (Of course if the pipeline companies had started retrofitting with external detectors in 1988 they would be now 24 years into the process).

KAI says:

  • External leak detection is both very simple – relying upon routinely installed external sensors that rely upon at most seven physical principles – and also confusing, since there is a wide range of packaging, installation options, and operational choices to be considered.
  • External leak detection sensors depend critically on the engineering design of their deployment and their installation.
  • External sensors have the potential to deliver sensitivity and time to detection far ahead of any internal system.
  • Most technologies can be retrofitted to existing pipelines. In general, the resistance to adopting external technologies is, nevertheless, that fieldwork on a legacy pipeline is relatively expensive.
  • The report goes on to identify major bureaucratic roadblocks within pipeline companies. Like many other big corporations, walls exist that prevent the system from working well
  • A particular organizational difficulty with leak detection is identifying who “owns” the leak detection system on a pipeline. A technical manager or engineer in charge is typically appointed, but is rarely empowered with global budgetary, manpower or strategic responsibilities. Actual ownership of this business area falls variously to metering, instrumentation and control, or IT.

The report calls for better internal standards at pipeline companies since with leak detection “one size does not necessarily fit all”.

It also notes that “flow metering is usually a central part of most internal leak detection systems,” but adds “flow meter calibration is by far the most laborious part of an internal system’s maintenance.

Also, the central computer and software technology usually has maintenance requirements far greater than most industrial automation and need special attention.”

While a company may do a cost benefit analysis of its leak detection system and risk reduction system it will generally emphasize the costs of the performance and engineering design of the leak detection system, the companies usually place less emphasis on the benefits of a robust system, especially the long term benefits.

At present the pipeline companies look at the benefit of leak detection as a reduction in risk exposure, or asset liability, “a hard, economic definition… understood by investors.” But the report adds that leak detection systems have a very long lifetime and over that life cycle, the cost-benefit approaches the reduction in asset liability caused by the system, when divided by annual operational costs. However, since pipeline companies budget on a one to five year system the long term benefit of robust, and possibly expensive spill detection is not immediately apparent.

Enbridge

The consultants studied 11 US oil spills, the top two with the greatest volume were from Enbridge pipelines. The others were from TE Products Pipeline, Dixie Pipeline, Sunoco, ExxonMobil, Shell, Amoco, Enterprise Products, Chevron and Magellan Pipeline. Not all US spills were used in the KAI report, the 11 were chosen for availability of data and documentation.

The largest spill in the KAI study was the pipeline rupture in Michigan at 843,444 gallon (3,158,714 litres) which has been the subject of continuing media, investigative and regulatory scrutiny. The second spill in North Dakota, has up to now received very little attention from the media. That will likely change once the US Congress gets the final report. Even though the Neche, North Dakota spill, has been described as “text book case” of a pipeline shutdown, there was still a large volume of oil released.

Marshall, Michigan spill

On the Marshall, Michigan spill that sent bitumen into the Kalamazoo River the report first goes over the facts of the 843,444 gallon spill and the subsequent release of a highly critical report from the US National Transportation Safety Board. It then looks at the failures of Enbridge’s detection system from the point of view mandated for the report to Congress:

The pipeline was shutting down when the ruptured occurred. Documentation indicates that a SCADA alarm did sound coincident with the most likely time of the rupture. It was dismissed. The line was shut down for around 10 hrs and crude oil would have drained from the line during this time.

On pipeline start up, alarms in the control room for the ruptured pipeline sounded. They were dismissed. This was repeated two more times. The pipeline was shut down when the control room was notified of the discharge of the crude oil by a member of the public. The time to shut down the pipeline is not relevant here because of the 17 hours that elapsed after the rupture occurred.

The review identified issues at Enbridge relevant to this Leak Detection Study:

1. Instrumentation on a pipeline that informs a controller what is happening to the pipeline must be definitive in all situations.
2. However, the instrumentation did provide warnings which went unheeded by controllers.
3. Instrumentation could be used to prevent a pump start up.
4. Operators should not rely on the public to tell them when a pipeline has ruptured.
5. Pipeline controllers need to be fully conversant with instrumentation response to different operations performed on the pipeline.
6. If alarms can be cancelled there is something wrong with the instrumentation feedback loop to the controller. This is akin to the low fuel warning on a car being turned off and ignored. The pipeline controller is part of an LDS and failure by a controller means the LDS has failed even if the instrumentation is providing correct alarms.
7. If the first SCADA alarm had been investigated, up to 10 hours of pipeline drainage to the environment might have been avoided. If the second alarm had been investigated, up to 7 hours of pumping oil at almost full capacity into the environment might have been avoided.
8. CPM systems are often either ignored or run at much higher tolerances during pipeline start ups and shutdowns, so it is probable that the CPM was inoperative or unreliable. SCADA alarms, on the other hand, should apply under most operating conditions.

Neche, North Dakota spill

At approximately 11:37 pm. local time, on January 8, 2010, a rupture occurred on Enbridge’s Line 2, resulting in the release of approximately 3000 barrels or 158,928 gallons of crude oil approximately 1.5 miles northeast of the town of Neche, North Dakota, creating the sixth largest spill in the US during the study period.

As the report notes, in this case, Enbridge’s detection system worked:

At 11:38 pm., a low-suction alarm initiated an emergency station cascade shutdown. At 11:40 pm., the Gretna station valve began closing. At 11:44 pm., the Gretna station was isolated. At 11:49 pm., Line 2 was fully isolated from the Gretna to Donaldson pump stations.

Documentation indicates a rapid shut down on a low suction alarm by the pipeline controller. From rupture to shut down is recorded as taking 4 minutes. The length of pipeline isolated by upstream and downstream remotely controlled valves was 220,862 feet. The inventory for this length of line of 26-inch diameter is 799,497 gallons. The release amount was around 20 per cent of the isolated inventory when the pipeline was shut down.

The orientation of the 50-inch long rupture in the pipe seam is not known. The terrain and elevation of the pipeline is not known. The operator took around 2 hours and 40 minutes to arrive on site. It is surmised that the rupture orientation and local terrain along with the very quick reactions by the pipeline controller may have contributed to the loss of around 20 per cent of the isolated inventory.

The controller was alerted by the SCADA. Although a CPM system was functional the time of the incident it did not play a part in detecting the release event. It did provide confirmation.

But the KAI review identified a number of issues, including the fact in item (7) Enbridge did not plan for for containment and that containment systems were “under-designed.”

1. This release is documented as a text book shut down of a pipeline based on a SCADA alarm.
2. The LDS did not play a part in alerting the pipeline controller according to
documentation. However, leak detection using Flow/Pressure Monitoring via SCADA
worked well.
3. Although a textbook shut down in 4 minutes is recorded, a large release volume still occurred.
4. The release volume of 158,928 gallons of crude oil is the sixth largest hazardous liquid release reported between January 1, 2010 and July 7, 2012.
5. The length of pipeline between upstream and downstream isolation valves is long at 41.8 miles.
6. If not already performed, the operator should review potential release volumes based on ruptures taking place at different locations on the isolated section.
7. The success of a leak detection system includes planning for the entire process: detection through shutdown through containment. In this case, the operator did not plan adequately for containment so that although the SCADA leak detection technology, the controller and the procedures worked well, the containment systems (isolation valves) were under-designed and placed to allow a very large spill.”

 

 

 KAI Draft report on Leak Detection Systems at the Pipeline and Hazardous Materials Safety Administration website

 

Kitimat LNG progressing–or is it?

At the District of Kitimat Council meeting on Monday, October 1, as part of Mayor Joanne Monaghan’s regular “good news” briefing, she told council that the Kitimat LNG  project continues to “progress positively.”  The news from Calgary on Tuesday, however, was not as promising.

Both Bloomberg News and the Calgary Herald reported that  Apache, which owns 40 per cent of the KM LNG partnership is worried about a recent decision by a rival gas company to sell natural gas to world markets at low North American prices rather than, as been customary up until now, as percentage of the world oil price. That differential gives the North American gas companies a profit in Asia and it is that profit difference that makes Kitimat attractive for LNG projects.

At the council meeting, Monaghan reported, quoting Apache’s  Apache’s Manager of Public and Government Affairs Natalie Poole-Moffatt, as saying that  Kitimat LNG will be opening a full time community office in downtown Kitimat near the City Centre mall in the near future.  Apache says renovations are nearly complete and they will be holding an open house in the near future.

Monaghan said that work on the Kitimat LNG site at Bish Cove continues with blasting to create proper elevation, crushing and sorting of rock and constructing an access route to the forest service road. This summer work began on the two year $25 million upgrades to the old forest service road “which will improve conditions on the road.”

However, in Calgary, the Herald quoted KM LNG vice-president David Calvert as saying “things are going so well that it has been decided to risk spending on clearing ground before completion of the front end engineering and development study and final investment decision.”

But according to several media reports,  Calvert told an Energy Roundtable in Calgary on Tuesday that a final go-ahead for Kitimat LNG is not a done deal. the Herald quoted Calvert as saying: “We remain convinced that oil-linked pricing is critical to the viability of our Canadian LNG industry.”

Bloomberg reported that a recent deal by Cheniere Energy Inc. to sell liquefied natural gas based on North American pricing (also known as Henry Hub pricing) means that it is difficult for Apache to find Asian customers to sign the long term LNG contracts needed to make the Kitimat project viable. (Asian LNG prices are based on the “Japan Customs Cleared Price” set by the Japanese government as a percentage of the price of crude oil).

Bloomberg quoted Calvert as saying: “It created quite a ripple through the marketplace,” and Bloomberg said, the Cheniere deal has created “unrealistic expectations.”

Related

Globe and Mail

Canadian gas producers dreaming big – again 

Canada losing the race to sell LNG

Updated

The Haynesville Shale

Cheniere Deal Hurts Canadian LNG Project

Cheniere is less sensitive to prices given its role as a middleman, while Apache, Encana and EOG are producers, for whom the price is very important.  One advantage of Kitimat is its west coast location, but that is only a minor cost advantage over Gulf Coast facilities.

The clock is ticking on Kitimat.  It sounds like Asian buyers are sitting on the sidelines waiting for lower prices.  Right now the U.S. government is sitting on future LNG approvals pending the release of a study around year-end.  If the U.S. approves the pending applications, a proverbial flood of LNG will come to market with Henry Hub-based pricing.  At that point Kitimat’s owners will be in a tough spot.  Kitimat is vital to B.C., but the economics might not work.

Wall Street Journal

Cheniere Lights a Match in the Gas Market

 

Minor oil leak at Bish Cove

In a report to District of Kitimat Council, Apache’s Manager of Public and Government Affairs,  Natalie Poole-Moffatt,  also reported that on September 19, an oil leak was spotted on a piece of heavy equipment at Bish Cove.  The report says;

WestCoast Marine was notified and booms were deployed as a preemptive measure in Bish Cove, no machine oil has migrated to Bish Cove. Environmental crews are on site executing a remediation plan.  Both the [BC] Provincial Emergency PLan (PEP) and Aboriginal and Northern Affairs Canada  were notified of the incident.

The piece of equipment  is currently being repaired and will undergo operational tests to ensure  the equipment can function without further concern.  Environmental staff will remain on the site 24/7 until remediation is complete.

US calls for study that could relax double-hulled oil tanker regulations, citing costs to build, energy consumption

The United States Department of Transportation Maritime Administration has issued a call for a study that is calling into question the future of double-hulled oil tankers.

On August 6, 2012 the Maritime Administration, also known as MARAD, issued a “solicitation” for a study on the Safety, Economic and, Environmental Issues of Double Hulls.

In the call for the study, MARAD says:

Following the Exxon Valdez disaster, the passing of the Oil Pollution Act of 1990 (OPA 90) led to the requirement to replace single hull petroleum tankers with double hull tank vessels sailing in U.S. waters. This requirement was soon adopted by the International Maritime Organization (IMO) and became a worldwide regulation. This means that, today, tank vessels worldwide are carrying thousands of extra tons of steel in order to meet the double hull requirements.

Though these double hulls reduce the threat of oil pollution as a result of grounding, they significantly increase the amount of energy needed to propel a vessel and increase the amount of air pollution into the atmosphere. As a result, the maritime industry’s carbon footprint and criteria pollutant emissions are increased.
In addition to the need to burn more fuel, it is acknowledged that double hulls can cause several other problems which will be detailed in this study.

Here in Canada, Enbridge Northern Gateway and its supporters, in briefings on maritime and tanker safety on the west coast of British Columbia, have always said that the changes following the Exxon Valdez disaster in Prince William Sound and the subsequent US Oil Pollution Act as almost guaranteeing that such a disaster could not happen again.

Now it appears that some people in the U.S. Department of Transportation may be worried that increased use of double-hulled tankers will cost too much. There’s also the apparent question of balancing the carbon footprint of increased emissions from tankers with the danger from a hydrocarbon spill.

The request for the study was covered by tanker industry sites such as Marine Link but only surfaced in major media on Sunday, when The National, an English-language newspaper in Abu Dhabi broke the story, “US maritime agency considers overhaul of oil-spill regulation”

Reporter David Black notes:

In July last year, the IMO adopted binding regulations to limit the expected gas emissions increase by reducing fuel consumption of ships by as much as 15 million tonnes in 2020, a 14 per cent reduction, and by 2050, by as much as 1,013 million tonnes. This will lead to savings in fuel costs for the shipping industry of up to US$200 billion a year, says the IMO.

Black says that the US agency seems “to suggest by abandoning the additional weight of double hulls the savings would increase and pollution be cut further, adding “On the other hand, since the introduction of double hulls, pollution from major oil spills has been reduced to practically zero.”

The National story says even the tanker industry itself is worried about the move, quoting the the international tanker owners’ organization.

“We have noted reports about Marad’s intended study on tanker double hulls but, except for what we gather from press articles, we have little knowledge on the reasoning behind this,” said Bill Box, Intertanko’s senior manager for external relations.
“From our members’ experience, double-hull designs have evolved into safe and reliable ships with an excellent safety and pollution prevention record. We might provide comments when such a study would be released by Marad.”

 

The requirements for the double-hull study, as posted by the US government are:

1. The Contractor shall conduct an assessment of the history in the evolvement of “The Double Hull Rules”.

2. The Contractor shall conduct the assessment of any rules that are being proposed in bodies such as the IMO, U.S. Congress and other such bodies’ worldwide as they relate to additional hulls for environmental reasons.

3. The Contractor shall assess all the relevant safety issues related to double hulls for each class of vessel. E.g. Double bottoms are difficult and expensive to maintain and can result in corrosion problems. Unchecked corrosion in older double hull vessels can lead to cargo leakage into a double bottom and the buildup of dangerous vapor which could cause an explosion under certain conditions. The Contractor will obtain data from appropriate organizations which details the issues in double bottoms on older vessels including cracking, leakage, and the potential for vapor buildup.

4. The contractor shall conduct a complete economic study of the consequences of Double Hulls. E.g. they significantly add to the construction cost of vessels. They result in the loss of cargo space which also adds to the carbon footprint since an additional vessel(s) is needed to carry the same cargo tonnage.

5. The contractor shall assess the complete consequences of the carbon footprint of designing, constructing, maintaining and operating vessels with double hulls. E.g. Apart from the extra propulsive forces and fuel needed, the carbon footprint of double hull maintenance is substantially increased.

6. The Contractor shall prepare a report on the results of the project. The report shall be grammatically correct and must be professionally written to a high level of competence in the English language. The report must clearly specify the safety, economic and environmental issues details above.

 

US pipeline agency slams Enbridge, calls for independent oversight of Wisconsin cleanup

The US agency that looks after pipelines, the Pipeline and Hazardous Materials Safety Administration, has issued an updated “Corrective Action Order” on the oil spill at Grand Marsh in Wisconsin, slamming Enbridge because the company’s “integrity management program may be inadequate.”

The order goes on to say:

PHMSA has communicated its longstanding concerns about this pattern of failures with Respondent [Enbridge] over the past several years. Given the nature, circumstances, and gravity ofthis pattern of accidents, additional corrective measures are warranted.

The Corrective Order tells Enbridge to file its cleanup plans with the PHMSA and to have its actions checked by an independent, outside agency.

Before the PHMSA allows Enbridge to restart Line 14, which runs from Superior, Wisconsin, to Mokena, Illinois, and is a part of the 1,900 mile-long Lakehead Pipeline system, which transports “hazardous liquid” from Neche, North Dakota, to Chicago, Illinois, with an extension to Buffalo,

Enbridge must (1) submit, for review and approval, a comprehensive written plan, including timelines for specific actions to improve the safety record of Respondent’s Lakehead pipeline system and (2) hire an independent third party pipeline expert to review and assess the written plan, which the third party will submit to PHMSA and to Respondent concurrently. Further, the third party expert must oversee the creation, execution and implementation of the actions identified in the plan, and must provide monitoring summaries to PHMSA and Respondent concurrently. Respondent must commit to address any deficiencies or risks identified in the third party’s assessment, including repair and replacement of high-risk infrastructure. The plan must be sufficiently detailed with specific tasks, milestones and completion dates.

At a minimum, the plan must address:
a. Organizational issues, including the promotion of a safety culture and creation of
a safety management system;
b. Facilities response plan;
c.Control room management;
d.Priorities for pipe replacement;
e.Training;
f.In-line inspection result interpretation;
g.Current engineering and probability of failure modeling;
h.Leak detection systems;
1.Sensor and flow measuring and valve replacement;
J.Integrity verification;
k.Quality management system; and
1.Any other risk, task, issue or item that is necessary to promote and sustain the
safety ofits pipeline system.

The agency notes also that

After receiving and analyzing additional data in the course of this investigation, PHMSA may identify other corrective actions that need to be taken. In that event, Respondent will be notified of any additional measures required and further amendment of the CAO will be considered. To the extent consistent with safety.

The order says Enbridge will be given an opportunity for a hearing prior to the imposition of any additional corrective measures.

The PHMSA  Corrective Order was issued about the same time as Canada’s National Energy Board announced that it was conducting its own safety audit of Enbridge operations.

PHMSA Amended Corrective Action Order_08012012

NEB conducting safety audit of Enbridge

The National Energy Board is following up a highly critical report by the US National Transportation Safety Board on the Marshall, Michigan spill by conducting an overall safety audit of Enbridge pipeline management and practices.  The NEB says the review began even before the NTSB report was released:

even prior to the release of the final report, we have been reviewing Enbridge’s management practices. In the next weeks and months, we will be conducting safety audits to review and confirm that improvements, particularly to their control room practices in Edmonton, are satisfactory.

In a letter to the public from NEB chair, Gaétan Caron, posted on the NEB website, the agency says: “Pipeline safety is and always has been of paramount concern to the National Energy Board and we recognize it is of growing concern to Canadians.”

The letter goes on to say:

Given recent events, it is important that Canadians understand how we hold companies accountable for public safety and protection of the environment and take swift and appropriate action when they do not.

The Board takes a proactive approach to preventing spills and releases, with the ultimate goal of seeing none at all. We require pipeline companies to anticipate, prevent, manage and mitigate potentially dangerous conditions associated with their pipelines.

To do this, we conduct compliance verification activities which include things such as inspections, compliance meetings, emergency exercises, audits and investigations on a regular basis with all companies we regulate. In the specific case of Enbridge, in recent years the NEB has conducted approximately 25 compliance verification activities per year, focusing on every aspect of their management system. In addition, the NEB imposed two precautionary pressure restrictions on Enbridge pipelines, one in 2010 and another in 2011, which remain in effect.

When the NEB identifies deficiencies in a company’s systems, projects or programs, we require the company to immediately implement changes to correct those deficiencies or to develop a corrective action plan for NEB approval. It is important to note that we aim to prevent incidents from occurring in the first place and we will take all available actions at our disposal to protect the environment and the public. The NEB may revoke authorizations, impose safety orders that restrict operations, issue stop-work orders and monetary penalties as well as pursue criminal prosecution.

The NEB has also reviewed the synopsis of the National Transportation Safety Board’s report on Enbridge’s Line 6B rupture in Michigan in 2010 to see what we can learn in the interests of public safety and environmental protection. A thorough review of the final report will be conducted in order to identify all lessons that may be applied to pipelines and companies under the Board’s jurisdiction, however even prior to the release of the final report, we have been reviewing Enbridge’s management practices. In the next weeks and months, we will be conducting safety audits to review and confirm that improvements, particularly to their control room practices in Edmonton, are satisfactory.

The NEB goes on to stay that Jobs, Growth and Long-term Prosperity Act (formerly Bill C-38) is giving the agency more bight:

 the Government of Canada will be adding another tool to our compliance and enforcement toolkit: administrative monetary penalties (AMPs). The new AMP sections in the NEB Act set out the maximum daily penalties for both individuals and companies. For individuals the maximum daily penalty is $25,000 for each violation and for companies the maximum daily penalty is $100,000 per violation.

The Act stipulates that each day a violation continues is considered to be a separate violation. This means that separate penalties could be issued per infraction, per day with no maximum total financial penalty.

Some of the details of the AMPs design are described in the government amendments to the NEB Act, but other details, such as what activities will be considered violations, will be written in a new regulation. We have committed to have these new regulations ready to use by July 6, 2013.

The NEB says it will continue to make public any enforcement measures it takes.

As a part of our Action Plan on Safety and Environmental Protection, we began posting all documents related to Board-initiated safety and environmental compliance actions to our website in fall of 2011.

The Board is committed to continually improving the way we do business and we welcome any opportunity that allows us to do so in the interests of pipeline safety and environmental protection.

Enbridge has not yet responded to the NEB release.

Haisla ask Gateway JRP to force Enbridge to release more Kalamazoo spill information

The Haisla Nation have asked the Northern Gateway Joint Review panel to force Enbridge to reveal more information about the pipeline rupture and oil spill near Kalamazoo, Michigan, in July 2010. The Haisla are also asking for more and better information about the $500 million project upgrades that Enbridge announced last month.

In a notice of motion filed July 30, with the JRP, lawyers representing the Haisla Nation note that they had previously asked Enbridge “a number of questions relating to Enbridge’s spill of 3,785,000 litres of diluted bitumen into the Kalamazoo River at Marshall, Michigan (the ‘Kalamazoo Spill’).”

The notice then notes that “Northern Gateway refused to reply as the matter was under investigation by the United States National Transportation Safety Board… The NTSB’s Accident Report was adopted on July 10, 2012 and has now been released to the public. The basis for Northern Gateway’s refusal to answer the Haisla Nation’s information requests is, therefore, no longer present.”

The Haisla are asking the JRP

that Northern Gateway is required to file evidence relating to the Kalamazoo Spill
which identifies the cause of the pipeline rupture and the extent to which
Enbridge’s pipeline maintenance, monitoring and response approach caused and
contributed to the volume of the spill by a date to be fixed by the Panel;

As for the upgrades, the Haisla notice of motion notes

Northern Gateway has identified additional design features, which it states will “enhance the safety and reliability of the pipelines over and above standard industry practice”. The design features identified in the Reply Evidence include increased wall thickness of the pipeline, additional increases in pipe thickness for crossings at major tributaries to the Fraser, Skeena and Kitimat River, the placement of remotely operated isolation valves on each side of major tributaries of the Fraser,Skeena and Kitimat Rivers, and dual remote monitoring systems ….
Northern Gateway has not provided any details relating to these proposed design
features. Their relevance and suitability to enhancing safety and reliability of the
pipelines cannot, therefore, be assessed.

The motion asks

that Northern Gateway is required to provide details of its proposed additional
design features for thicker pipes for the pipeline generally and at identified
watercourse crossings, for additional valve placements, and for additional remote
monitoring, as well as all studies and reports that support how these additional
design features enhance pipeline safety, by a date to be fixed by the Panel.

The Haisla motion also asks for more details on various environmental and other questions.

The Joint Review Panel has not yet ruled on the Haisla motion.

Haisla Nation Notice of Motion  (pdf)

New US report slams Enbridge for spill record, as scientific investigation opens into diluted bitumen

A new US report is slamming Enbridge for its record on oil spills, just as the BC government set out strict new conditions for building pipelines and tanker traffic in the province.

The United States National Wildlife Association issued a report today called Importing Disaster, The Anatomy of Once and Future Oil Spills. (pdf of report at the bottom of this page)

At the same time,  the US Academy of Sciences has opened a new investigation into diluted bitumen.

 

 

 

A letter critical of Enbridge, previously overlooked by the US media is getting new traction, as the anniversary of the Marshall, Michigan, Kalamazoo River spill approaches on July 25.

Enbridge, so far, has not responded to the National Wildlife Federation report.

The environmental group opens the report by saying:

As the biggest transporter of Canadian tarsands oil into the U.S., Enbridge has aresponsibility to the American public to manage their operations in a manner that protects our comm unities and natural resources. But tarsands oil is a very different beast than conventional crude oil, and it is difficult to transport the former safely through pipelines that were designed for the latter. That’s because tarsands oil is more corrosive(due to its chemical mixture)and abrasive(due to high-gritminerals), weakening the pipes to the point  that they are more susceptible t oleaks and ruptures. Remarkably, there are no standards in place to ensure that new pipelines are built, maintained and operated with this fact in mind.

The National Wildlife Association goes on to say:

 fossil fuel companies have a ‘stranglehold’ on our political establishment, preventing even modest initiatives that could make our energy safer and cleaner. That lobby strategy keeps in place a system that’s led to 804 spills by Enbridge alone in the last decade, and a total of 6,781,950 gallons of oil spilled in the U.S. and Canada.

“Rather than focus on safety and cleanup, Enbridge is recklessly moving ahead with plans to expand their pipeline network in the Great Lakes region and the Northeast, and to double down on high carbon fuel that is proving nearly impossible to clean from Michigan’s waters,” said Beth Wallace, NWF’s Great Lakes outreach advisor.

NWF’s report recommends comprehensive reforms to break the cycle of spills and pollution that continue to threaten communities and speed global warming.  Among them, the report calls for stronger safety standards that account for increased dangers associated with heavy tar sands oil, increasing investment in clean energy and efficiency, and campaign and lobbying reforms that would put impacted citizens on a level playing field with Big Oil in the halls of Congress.

The NWF report then says:

 The Kalamazoo spill may have been a poster child for corporate negligence but it is far from the company’s only black mark. According to Enbridge’s own reports, between 1999 and 2010, they have been responsible for at least 800 spills that have released close to seven million gallons of heavy crude oil into the environment — or approximately half the amount of oil that spilled from the Exxon Valdez in 1989.

Canada has seen its own share of Enbridge heartache, including a 61,000 gallon spill earlier this summer near Elk Point, Alberta.

The National Wildlife Federation report is calling for  stronger pipeline safety standards that account for the dangers of transporting bitumen sands oil from Canada amd wants more rigorous reviews of all pipeline projects. The report calls bitumen sands oil “the planet’s dirtiest oil.”

US media covering the National Wildlife release and looking to the anniversary of the Kalamazoo disaster, are now quoting an overlooked letter from the US advocacy group Public Citizen issued on June 25.  

Concerned about Keystone XL pipeline, the advocacy group sent a letter to the Texas House of Representatives, recommending that the state should not wait for US federal rules to prevent tar sands pipeline spills. Public Citizen called the industry’s track record “troubled” and asked the committee to take up legislation that would give Texas broader authority over pipelines.

The committee will examine state regulations governing oil and gas well construction and integrity, as well as pipeline safety and construction, to determine what changes should be made to ensure that the regulations adequately protect the public. Public Citizen will testify in support of stronger rules for the Seaway pipeline (an existing line repurposed to carry tar sands instead of crude oil), the Keystone pipeline (whose southern leg is not yet built) and proposed future tar sands pipelines.

“These companies keep calling it petroleum, but it’s not – these are pipelines of poison,” said Tom “Smitty” Smith, director of Public Citizen’s Texas office.

The media reports on the NWF release are pointing to a new investigation by the US National Academy of Sciences on the safety of diluted bitmenl safety in the United States, that will be part of a report to the US Congress

 An ad hoc committee will analyze whether transportation of diluted bitumen (dilbit) by transmission pipeline has an increased risk of release compared with pipeline transportation of other liquid petroleum products.  Should the committee determine that increased risk exists, it will complete a comprehensive review of federal hazardous liquid pipeline facility regulations to determine whether they are sufficient to mitigate the increased risk.

On June 25, the committee added three industry experts to the panel as there is growing scrutiny over dilbit in the US, which could become an issue in the presidential race.

NWF Enbridge Oil Spill (PDF)

BC’s desire for “world leading” marine standards collides with Harper’s C-38 chain saw massacre

Today BC Premier Christy Clark’s government outlined a series of “world leading” standards for environmental protection on the ocean and on land, if pipeline projects like the Northern Gateway and the Kinder Morgan expansion are to go ahead.

One has to wonder what Premier Clark told Prime Minister Stephen Harper when she gave him the “heads up” call on the new policy last week?

After all, the BC Liberal’s call for “world leading” standards comes just weeks after the Harper’s government, in Bill C-38, changed environmental assessment into a pro-industry process, gutted the Fisheries Act protection for habitat and severely cut back the Department of Fisheries and Oceans and Environment Canada.

So far, in the province of British Columbia, with both the governing Liberals and opposition New Democrats have been spectacularly unsuccessful in persuading the Harper government to reverse the closure of the Kitsilano Coast Guard station.

In the background paper released along with the news release on the five conditions for pipeline and tanker safety, the BC government is calling for greatly enhanced Coast Guard resources and tanker monitoring as well as payment for oil spill response.

Among the conditions for marine safety enhancement BC is asking:

  • Current response times and planning capacity are less stringent than other jurisdictions like Alaska and Norway. For example, for the types of tankers being proposed for Canada’s west coast, Alaska requires planning for 300,000 barrels. In Canada, response organizations are only required to maintain response plans for spills up to approximately 70,000 barrels (10,000 tonnes). Further, Alaska allows responders 72 hours to reach the spill site, while Canada allows 72 hours plus travel time, which can sometimes add days to the response.
  • In shared bodies of water, the United States’ requirements exceed Canada’s. For example, the United States requires escort tugs for laden tankers and mandates industry pay for designated and strategically placed emergency response tugs. Canada does not have any similar requirements.
  • Ensure the Canadian Coast Guard adopts a unified command/incident command structure.
  • The Canadian Coast Guard has a unique response system which is only used in B.C. The United States, companies and governments worldwide use a unified command/incident command response structure for a range of emergency responses, including marine spills. By bringing the Coast Guard under this system, an effective, co-ordinated response is better ensured while reducing layers of approvals that can delay critical, prompt decision-making.

At Enbridge community briefings in Kitimat last year, the company’s own marine experts said that the 72 hour  response time from Vancouver and Victoria for a possible spill in the Douglas Channel was completely inadequate. In its fillings with the Joint Review Panel, Enbridge has proposed setting up and funding its own response stations along the BC coast, although so far, Enbridge has not provided any details on how the response stations would be set up and how they would work.

In 2010, the auditor general reported that Transport Canada and the Canadian Coast Guard have not used a consistent or systematic approach to tanker traffic and spills nor are there formal processes for ensuring that risks are reassessed.

Sheila Fraser found that

  • Procedures are not in place to verify the Canadian Coast Guard’s readiness. In other words, there is currently no process for providing assurance that the federal component of the oil spill response system is ready to respond effectively.
  • The Coast Guard had not conducted a comprehensive assessment of its response capacity since 2000.
  • The results of the Coast Guard’s response efforts—which range from identifying the source of pollution to full cleanup—are poorly documented. There are also limitations with the Coast Guard’s system for tracking oil spills and other marine pollution incidents. These gaps affect its ability to conduct reliable analysis of trends in spills and know how well it is achieving its objectives of minimizing the environmental, economic, and public safety impacts of marine pollution incidents.

In the United States Senate, Canadian Coast Guard response for an oil spill in the Strait of Juan de Fuaca  was described as “call the Americans”

For some search and rescue missions the federal government has indicated that it will rely more on the all-volunteer Royal Canadian Marine Search and Rescue service (formerly the Coast Guard Auxiliary) which is already stretched thin in some areas of the Pacific Coast, rather than the full time professionals from the Coast Guard service itself.

On the industry response, BC says

The federal government should review its rules and requirements to ensure industry-funded response funds are sustainable and adequate to fully cover a major response without requiring public money. Currently, the total amount of ship owner insurance and industry funding available for spill response is $1.3 billion. By comparison, the U.S. federal government maintains a spill fund that is forecast to grow to nearly $4 billion by 2016.

Again given the government backs and the Conservative government’s close ties with the energy industry, one has to wonder what if those provisions can be enforced, especially since more and more of the energy industry in Canada is owned off shore, increasingly in China with its sorry environmental record. (Globe and Mail CNOOC’s Nexen bid: A new test for Harper)

If there are to be “world-leading” standards for environmental protection in this country, it has to be paid for. So the question remains, who will pay for it? The federal government is cutting back, Alberta doesn’t want to raise the relatively small royalties it charges the energy industry and Canada is not likely to get a contribution from China.

Who pays to protect the coast and the northern interior going to be a big question for Stephen Harper in the coming months. With the polls showing Adrian Dix and the NDP leading in contention for a provincial election next year, and now with Christy Clark, apparently, demanding higher standards, will Harper open the Ottawa wallet now, will he wait until he faces a much tougher BC premier in Adrian Dix next year, or will he stubbornly hold his course of forcing Canada into his vision of a conservative, limited government nation, with, in the case of an oil spill on land or sea, that will cost the federal treasury billions, even if the energy industry picks up some of the tab?

 

Auditor General 2010 Report (pdf)

Auditor General 2007 report  (pdf)