ARCHIVED - Letter and Order AO-002-SO-E102-002-2011 to Enbridge Pipelines (NW) Inc.
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Letter and Order AO-002-SO-E102-002-2011 to Enbridge Pipelines (NW) Inc. [PDF 117 KB]
File OF-Surv-Inc-2011 74 01
22 March 2013
Mr. Al Monaco
Chief Executive Officer
Enbridge Pipeline Inc.
3000 Fifth Avenue Place
425 - 1st Street S.W.
Calgary, AB T2P 3L8
Dear Mr. Monaco:
Enbridge Pipeline (NW) Inc. (Enbridge) reported incidents in February and March 2013
The National Energy Board (Board) requires companies to take effective actions to prevent the occurrence of pipeline leaks and ruptures. The Board also expects pipeline companies to continually evaluate and improve the effectiveness of its integrity management program. This includes improving a company’s integrity management practices to prevent an incident from occurring anywhere on its pipeline systems under the Board’s jurisdiction.
Subsequent to the crude oil release that occurred on 9 May 2011, the Board issued Order SO-E102-002-2011 (Order) to Enbridge on 9 June 2011, imposing a pressure restriction on the Norman Wells to Zama Pipeline (Line 21). The Board subsequently issued Amending Order AO-002-SO-E102-002-2011 on 8 March 2013 which imposed an additional pressure restriction.
On 8 and 9 February 2013 as well as 14 and 19 March 2013 Enbridge reported four separate crude oil releases to the Board which were discovered while conducting planned integrity excavations. Further, the Board notes the four reported releases were all on the same segment of Line 21 as the 9 May 2011 release.
In light of these recently reported incidents, the Board is of the view that additional measures and analysis are required for the continued operation of Line 21. Accordingly, the Board has issued Amending Order AO-002-SO-E102-002-2011 which requires Enbridge to complete an additional Engineering Assessment on the Wrigley to Mackenzie segment of Line 21. The Order also requires Enbridge to submit an assessment of the currently available leak detection technologies to determine which is most applicable to Line 21 and the submission of a plan outlining how and when Enbridge will implement the selected technology.
The Board notes Enbridge’s engagement efforts with local affected parties including Aboriginal communities. The attached Order provides direction from the Board requiring further ongoing consultation. This includes a requirement that Enbridge file regular consultation reports with the Board.
Secretary of the Board
c.c. Chief Tim Lennie, Pehdzeh Ki First Nation
Grand Chief Herb Norwegian, Dehcho First Nations
Acting Chief Steven Jose, Liidlii Kue First Nation
Ms. Marie Lafferty, President, Fort Simpson Métis
Mr. Ernie Campbell, Assistant Deputy Minister, Operations, Environment and Natural Resources, Government of Northwest Territories
Ms. Kathryn Bruce, Regional Director, General NT, Aboriginal Affairs and Northern Development Canada
Ms. Abby Dorval, Regulatory Affairs, Enbridge Pipelines
Ms. Sarah McKenzie, Regulatory Affairs, Enbridge Pipelines
IN THE MATTER OF the National Energy Board Act (the Act) and the regulations made thereunder; and
IN THE MATTER OF the four incidents on the Norman Wells, NT to Zama, AB pipeline (Line 21) reported by Enbridge on 8 and 9 February as well as 14 and 19 March 2013.
BEFORE the Board on 20 March 2013.
WHEREAS on 9 June 2011, the Board issued Order SO-E102-002-2011 to Enbridge Pipelines (NW) Inc. (Enbridge), pursuant to sections 12 and 48 of the NEB Act, the effect of which was to impose a pressure restriction on the Norman Wells to Zama Pipeline (Line 21);
AND WHEREAS on 8 March 2013, the Board issued Amending Order AO-001-SO-E102-002-2011 to Enbridge, pursuant to sections 12 and 48 of the Act, the effect of which was to impose an additional pressure restriction on the Mackenzie to Zama section of Line 21;
AND WHEREAS Enbridge operates Line 21;
AND WHEREAS Enbridge has recently reported contaminated soil discovered during the hydro-vac activities at KP 457, KP 391, KP 382 and KP 387 integrity excavation sites;
AND WHEREAS the Board is of the view that Enbridge has implemented several measures in detecting and mitigating cracking features on Line 21;
AND WHEREAS Enbridge will continue to conduct weekly aerial patrols of Line 21 to monitor for leaks;
AND WHEREAS Enbridge has initiated and will continue to conduct quarterly high-resolution in-line leak detection inspections of Line 21;
AND WHEREAS Enbridge has initiated and will complete axial crack in-line inspections of Line 21 and has initiated and will complete the investigation into the cause of the defect;
AND WHEREAS Enbridge has initiated and will continue integrity excavations on Line 21;
AND WHEREAS the Board is of the view that interim precautionary measures are necessary for public safety and protection of the environment;
IT IS ORDERED THAT, pursuant to sections 12 and 48 of the NEB Act, the Board hereby amends Amending Order AO-001-SO-E102-002-2011 by inserting Paragraphs 6-9:
6. Enbridge shall, by 30 June 2013 provide an engineering assessment, in addition to the assessment referenced in condition 2, for the Wrigley to Mackenzie section of Line 21 that evaluates the fitness-for-service of the line section from a leak-dependent perspective.
7. Enbridge shall, by 5 April 2013 provide an assessment of leak detection methodologies including but not limited to, walking the line, chemical traces, bore hole surveys or aerial sensors, to verify whether any locations with leaks and contaminated soil exist. The assessment shall include a tabulated summary comparing the effectiveness, safety considerations and timeline for implementation of the various methodologies. Along with this assessment, Enbridge shall select the most appropriate leak detection methodology(s) and submit a plan and schedule detailing when and how it will implement the selected leak detection methodology(s).
8. Enbridge shall undertake a leak detection and soil contamination assessment using bore holes at any remaining excavation site which will not be assessed before the spring 2013 break up. The results of this program shall be submitted to the Board within 15 days following the cessation of 2012–2013 winter excavation programs.
9. Enbridge shall continue to consult with potentially affected people, including Aboriginal groups, about the incidents, remediation and additional measures to be taken on Line 21. Enbridge shall file with the Board summaries of its consultation efforts and results with all potentially affected people, including Aboriginal groups. The first consultation summary shall be filed by 5 April 2013 followed by one in August 2013. Enbridge shall then file consultation summaries monthly from November 2013 until May 2014.
NATIONAL ENERGY BOARD
Secretary of the Board
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