TransCanada has completed filing their application with the National Energy Board (NEB) bringing us collectively one step closer to the review of this flawed pipeline proposal increasing facing opposition all along its path.
Guide to the amended filings
Folder containing new docs
Many of the new maps are here
New risk assessment
Like the earlier filings, this is a maze of information – good luck to all committed researchers!
I’ve taken a preliminary look at key areas, here are my findings.
End of the Line: Things just got more intense for Red Head, Saint John and the Bay of Fundy
In cancelling the proposed Cacouna port in Quebec (due to widespread opposition), much of the oil that would have been shipped there is now destined for the proposed new port in Saint John.
Based on the filing, we also now can confirm more than 75 per cent of what is being shipped is for export.
As we’ve said all along – this is first and foremost and export pipeline. Quebec refineries have little need for the crude and the Saint John refinery has limited capacity for it, particularly heavy tar sands crude which requires additional equipment to refine.
Oil super tanks on the Bay of Fundy jump from 115 to 281, ranging in size from the 700,000 barrel Aframax, to the 2 million barrel Very Large Crude Carrier (VLCC)–with destinations at refineries primarily n New Jersey, Delaware, Louisiana, and Texas. Add source NRDC blog
The oil storage facility in Red Head is now confirmed in increasing from 7.65 million barrels to 13.2 million barrels
The oil storage tanks will be much larger, including some the height of a six story building
TransCanada has yet to file an updated version of the Human Health Risk Assessment for the Red Head area. This is critical not only because their original assessment had critical gaps as identified by an independent expert commissioned by the Council of Canadians, but also because they plan on doubling the amount of oil stored in the scenic rural community that is part of Saint John.
TransCanada did file a worst case scenario assessment for the tank farm. Upon quick glance, a number of things stand out to me.
The company they hired determined that 4300 m3, or 4.8 million litres of oil could spill at the tank farm, in a worse-case scenario spill.
It also reports that nearby homes could be affected in the wake of a ‘pool fire’ at the Saint John Terminal, meaning radiant heat and sulphur dioxide levels could damage properties (p 100 of 299).
They also calculate different wind speeds for the area, but I wonder if they consulted anyone locally about this. When I recently visited, residents flagged this as a key concern, noting winds off the Bay of Fundy towards their homes could be intense.
They also emphasized that there is only one road feeding the Anthony’s Cove area – what happens if this is affected by a spill or other event?
Other potential ‘events’ considered: “Loss of containment events · Tank fires · Pool fires · Toxic smoke evolved from fire events · Tank boilover events · Vapour cloud explosions · Boiling Liquid Expanding Vapour Explosions (BLEVE’s) · Jet fires”
Some of them weren’t fully assessed as they determined the likelihood was so small to justify not doing it.
I would love to see an expert in this area verify this. Certainly the modeling used for assessing the frequency of spills is something we’ve been quite critical of and I wonder if the same applies here.
Spill Modeling – same old…
In their most recently filed risk assessment, a bunch of numbers are spewed out in assessing the likelihood of a major spill.
The firm hired by TransCanada again uses statistics to base their spill frequency numbers on both the NEB and PHMSA (US equivalent) databases.
We have been quite critical of this, finding that if TransCanada’s own spill record in Canada is used instead, there is a 15% likelihood of Energy East rupturing somewhere along the pipeline path every year.
In using these databases (standard practice, they will say), and calculating the frequency per km, as opposed to the entire pipeline route, they come out with some wild numbers. Laughable in fact. When similar numbers were presented at an Ontario Energy Board consultation I attended the crowd practically roared.
Looking solely at incidents caused by Corrosion and Stress Cracking (SCC – the number one cause of pipeline ruptures based on TransCanada’s Canadian record – link to our safety report), they predicted there would be 0.000274 cases of an SCC incident, per km, per year or one every 3,651 years. Nothing to worry about, right?
Their use of scientific notation and breaking down the incidents per km entirely obfuscates the risk.Keep in mind EE will be 4400 kms long so multiply 0.000274 by 4400 and you get 1.2 incidents somewhere on the pipeline every year.
This means that, according to their figures, we can expect an SCC incident every 293 days along the Energy East pipeline path.
From here they go on to modify the numbers in their favour based on the various safety measures they will put in place. Of interest, even using their obfuscated numbers, there is clearly a greater risk of a rupture along the converted portion of pipeline from Saskatchewan to Cornwall, ON, compared to the new pipeline planned from Cornwall area to Saint John NB (for the numbers, check out p. 33)
Responding to a spill
The same document also contains three scenarios evaluating the effects, response and costs of a large scale spill. One of these looks at a spill of 19,800 barrels (3148200 litres) of heavy crude oil (Access Western Blend) spilling into the Jock River near Ottawa. The Jock River flows into the Ottawa river in 21 km.
It talks about how to go about responding to the spill, estimating it would take around 32 hours before it reached the Rideau River. They conclude that this is a sufficient timeframe for response teams to be on site and recovering the oil.
I question this conclusion.
One scenario sticks out in my mind. The spill monitoring system is only capable of detecting a leak of greater than 1.5% the capacity of the Energy East pipeline. This means that up to 2.63 million litres could spill in one day without even being detected. In other words, someone nearby, be it a TransCanada employee, local resident or passerby would need to witness the spill before a response started (by the way, this is how 8 of the 9 ruptures along their Mainline pipeline system were discovered in recent years).
How many hours would it take for someone to find? Days? In less than two days we could be looking at the worst case scenario evaluated by TransCanada for the Jock River… and their electronic monitoring equipment wouldn’t even register it as a spill.
The assessment does acknowledge that heavy crude can sink when spilled, eventually. This is something the Council of Canadians, and many other groups has emphasized. We know this project will be carrying diluted bitumen from the tar sands, proven in the case of the Kalamazoo spill to be far more destructive and costly to clean up from a river because it sinks and sticks to everything it touches.
I’m afraid this assessment does not fully account for the heightened risks of diluted bitumen.
A recent study released this month by the National Academy of Sciences found diluted bitumen is more likely to sink quickly following a spill, and first responders at the local, state and national level in the U.S., as well as the oil industry, were not prepared to handle a major spill into water.
They have also provided an assessment of worst case scenarios for the port and Bay of Fundy (p. 167) I’ll be eager to hear comments about this.
What of these many re-routes?
And what of the 700 re-routes widely highlighted in the media? Well good luck to you in finding them. TransCanada has provided all new maps meaning you need to go through each one and compare the updated version to the older version to see where the route has changed. I took a quick peak at the North Bay and Ottawa area maps – I don’t see any significant changes.