Deuxième demande d'information de la Ville de Toronto à Enbridge

7/27/2019 Deuxime demande d'information de la Ville de Toronto Enbridge

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Enbridge Pipelines Inc. (Enbridge)

Line 9B Reversal and Line 9 Capacity Expansion Project (Project)

Application under section 58 (Application) of theNational Energy Board ActOH-002-2013

City of Toronto ("Toronto")

Information Request No. 2 to Enbridge Response

File OF-Fac-Oil-E101-2012-10 02

NOTE:

This Information Request was prepared with input from staff of other municipalities sharing similar concerns. Specifically, a

liaison group was established and met regularly regarding the Application. The liaison group was attended by staff from the

Town of Ajax, the City of Burlington, the City of Hamilton, the City of Kingston, the City of Mississauga, the City of Toronto,

and other municipal groups.

NOTE:

For continuity, Information Request No. 2 has used the same numbering system as was in place for Information Request No. 1

(eg. IR 1 1.2.b follow up request is called IR 2 2.2.b)


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Enbridge Pipelines Inc.Line 9B Reversal and Line 9 Capacity Expansion Project

Application under section 58 of the National Energy Board ActOH-002-2013

Information Request of Toronto No. 2 To Enbridge ResponseFile OF-Fac-Oil-E101-2012-10 02

Dated 09 Jul 2013Page 2 of 37

CITY OF TORONTO IR 1

Request:

ENBRIDGE RESPONSE TO TORONTO IR 1

Response:CITY OF TORONTO IR 2

Request:

1.2 System Operations

Please provide the following:

b) Enbridges operating requirementsapplicable to Line 9.

c) Enbridges operating andmaintenance procedures applicable toLine 9.

d) Enbridges preventative maintenanceprogram applicable to Line 9.

1.2b - d) In constructing and operating theProject, Enbridge will follow all applicableinternal documents and standards,including: Enbridge Engineering DesignStandards; Enbridge Operations andMaintenance Manuals (formerly referred to

as Operating and Maintenance Procedures);the Environmental Guidelines forConstruction; various other Control Centreand Integrity plans and procedures; and theLine 9 Rules and Regulations Tariff. TheEngineering Design Standards andOperations and Maintenance Manuals have

been filed confidentially with the NEB. Aredacted copy of Book 1 was filed asAttachment to OPLA IR 1.9 in the Line 9

Reversal Phase I proceeding. Please seeAttachment 1 to response to Ontario IR1.44b.v for a redacted copy of Book 7.These redactions remove irrelevantinformation, such as: information related toU.S. operations; personal information; andinformation which if released, on its own orin conjunction with other information, could

pose a security risk or safety hazard. Pleasesee Attachment 1 NEB IR 1.14 for the

2.2

b d) refers to a redacted version of Book 1filed in the Phase 1 part of the Line 9application, OPLA 1R 1.9; however, thatanswer on p. 10 of 26 simply objects to thefiling on the ground of confidentiality. Please

provide a copy or a link or advise if a copy wasprovided elsewhere.


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Request:



Request:

Environmental Guidelines for Construction(2012).The proposed Line 9 Rules andRegulations Tariff is included in Attachment10 to the Application for approval by the

NEB

1.3Pipeline Integrity

d) Enbridges opinion as to the accuracyof the statement that there were onlythree spills resulting from internal

corrosion for pipelines shipping

bitumen and blends of bitumen

between 1990 and 2005 (and only

eight from 1975 to 2010).

1.3

d) Enbridge objects to the request as the

information sought is not relevant to theissues in this proceeding.

2.3

d) If this information is not relevant to the

issues, why did Enbridge file it in Tab 4(f) ofthe application?

1.4Pipeline Integrity and DilBit, SynBit,

and DilSynBit Research


c) Enbridge's concerns on the validity ofthe CanMetMATERIALS rotating cagetests and the results presented in theSummary of the Comparison Reportdue to the tests being performed atambient temperature and pressureconditions rather than pipeline

1.4

c) Enbridge does not question the validity of

the findings by CanMetMATERIALS.Enbridge recognizes that there arechallenges inherent in bringing anyindustrial process into the laboratory, andthat extraordinary results from one set ofconditions to another must be donecautiously. However, trends at ambienttemperature and pressure can be expected to

be similar to trends observed if the testing

2.4

c) Please provide the basis, and examples,

where heavy crude and DilBit corrosivityresearch have shown that trends at ambienttemperature and pressure can be expected to be

similar to trends observed if the testing were all

performed at elevated pressures and

temperatures as stated in the response.

f) Tables 7.2.1 through 7.2.3 provide Maximumand Minimum Product Properties of Light,


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Request:

operating temperatures and pressures.

f) Crude corrosiveness test results, if any,since Enbridges response to Informa-tion Request 5.2 of the Line 9 ReversalPhase 1 Project.

were all performed at elevated pressures andtemperatures. The body of literatureidentified in the preamble show that dilbitdemonstrates similar corrosive behavior tothat of crudes derived from conventionalsources.

f) Enbridge has continued to work with

outside consultants to establish a consistenttesting protocol for use with crude oils sincethe referenced IR. Only three crudes have

been tested since the test protocol wasfinalized in 2012. The results are includedas Attachment 1 to Toronto IR 1.4.f.

All crudes tested imparted inhibitory effectson model brine, but displayed differentwettability and emulsion forming behavior.Over the next three year, Enbridge intendsto test the majority of commodities shipped.

Medium and Heavy Crude. Table 4-6 providesBaseline Product Properties that have beenused to analyse corrosion susceptibility. TheBaseline Product Properties shown in Table 4-6are the Minimum Product Properties shown inTables 7.2.1 through 7.2.3. Please: 1) confirmthat the analysis of internal corrosionsusceptibility in the Pipeline Integrity

Engineering Assessment assumes the minimumDensity and Viscosity for each type of crude,and, 2) provide the rationale for utilizing theminimum density and viscosity (rather than therange of density and viscosity) for each crude inthe analyses for corrosion susceptibility.

1.5 Amendments to Line 9 Rules and

Regulations

h) The circumstances under whichEnbridge may provide Shippers witha waiver of the Tariff Specificationsas to Quality such that Enbridgeaccepts crude oil not meeting the

1.5

h) Enbridge does not provide waivers(exceptions) to receive off specificationcrude oil. If there are circumstances whereoff specification crude oil is received,Enbridge will send the responsible feeder orshipper a violation letter informing them of

2.5

h) Please confirm our understanding that thereare in fact occasions when materials that are"off spec" are shipped through the pipeline.Please advise what percentage of the time thisoccurs in general, and specifically with respectto Line 9.


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Request:

Tariff quality specifications. the infraction. The letter will ask them toexplain what measures have been taken to

bring the commodity to withinspecifications. If a satisfactory response isnot received or a batch continues to be offspec Enbridge will shut out thefeeder/shipper until proof is provided (byway of a certificate of analysis) that the next

batch will be on spec.1.6Pipeline Construction Original and

Current Construction Specifications

a) Regarding the differences in the pipe-line construction specifications andregulatory requirements (jointlySpecifications) pertaining to pipe-line construction between: 1) the con-struction of Line 9B in 1975, and, 2)

the construction requirements of Line9B as if being built in 2013, please

provide a:

a.1) Description of the Specifi-cations that Enbridge hasimplemented since 1975that were not required in1975 but would now be re-

1.6

a.a.1 a.b.1) Enbridge objects to therequest as it is unreasonable, undulyonerous and engages in a "fishingexpedition". The time, effort and expenseinvolved in the compilation of the requestedinformation are not warranted by therelevance, if any, of the information sought,

by the significance of that information in thecontext of the proceeding, or by the

probative value of the result.

2.6

Please provide the standards and specificationsof 2013 pipeline construction which can be rea-sonably implemented to mitigate the shortcom-ings of 1975 construction standards.

Also, please note that Enbridge transcribed theInformation Request 1.6.a.a1 incorrectly.

Original Information Request:a.1) Description of the Speci-

fications that Enbridge has im-plemented since 1975 that werenot required in 1975 but wouldnow be required if the pipelinehad been constructed in 2013.

Incorrect Transcription:a.1) Description of the Speci-

fications that Enbridge has im-


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quired if the pipeline hadbeen constructed in 2013.

b.1) Description of theSpecifications that wouldhave been required for theconstruction of Line 9B in2013 that Enbridge has not

implemented on Line 9B.

plemented since 1975 that werenot required in 1975 but wouldnot be required if the pipeline had

been constructed in 2013.

Please notify the NEB of the incorrecttranscription and advise whether Enbridge willreconsider its response.

1.7 Elements of Integrity Management

and Integration of Threats

b) Please provide an annotation of thelatest Integrity Management Planhighlighting the policies and proce-dures where Enbridge is implement-ing a methodology to integrate anoverlay or side-by-side analyses forevaluating threats.

c) In particular, please provide changesto the Integrity Management Plan thatEnbridge has implemented to developa methodology described in [NTSB]Recommendation No. 3 to overlayrisks associated crack defects coinci-dent with areas of corrosion.

1.7

b) Please see the Pipeline EngineeringAssessment ("Pipeline EA") Exhibit B1-15for the results of the Integrity ManagementProgram on Line 9B and specifically Adobe

page 84 for discussion on the integration ofdata between pipe deformations and otherdegradation mechanisms.

As part of continuous improvement, theIntegrity Management Program developed aThreat Integration process which overlays(or integrates) successive In-Line Inspection("ILI") results to assess the condition of theline. All available ILI datasets (up to sevendata sets) are compiled for overlay review.The review process has defined criteriawhich result in additional excavations to be

2.7

b)c) The answers do not address the concernexpressed by NTSB. Enbridges responseindicates that there is integration between

pipe deformations and other degradation

mechanisms and, separately, that there is aThreat Integration process which overlays (or

integrates) successive In-Line Inspection

(ILI) results to assess the condition of the

line. However, it is not clear that the EnbridgeIntegrity Management Program complies withthe NTSB recommendation that all threats areto be evaluated using an overlay or side-by-sideanalysis that would include cathodic protection,coating surveys, in-line inspection tool findings(for example, geometry, crack, and corrosion),and previous dig reports. Please provide furtherdetails of the IMP program indicating


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performed if features meeting the overlaycriteria are found. This process will continueto be applied to the 2012 and 2013 ILIreports.

c) Please refer to response to Toronto IR1.7.b.

compliance with the NTSB recommendationand procedures detailing how all threats (listedabove) are integrated to ensure the integrity ofits hazardous liquids pipelines.

1.8 Enbridge Integrity Management

Program

a)Please provide the proposed timetablefor issuing status reports that describethe progress of the repairs or otherremedial actions being undertakenfollowing Line 9B start-up.

b)Please provide the latest assessmentprocedures that highlight lessons

learned from Line 6B that havemodified Enbridges procedures forintegrity work deemed necessary onLine 9B.

1.8

a) Please refer to response to NEB IR 3.12.

b) The Enbridge Integrity ManagementProgram including the Crack ManagementProgram was enhanced following theMarshall, Michigan incident. The integritydig criteria have been modified to includeILI tool tolerances to reported defect sizes,conservative wall thicknesses, andconsideration of outliers. The Pipeline EAincludes conservatisms and analysismethods.

The Integrity Management Program hasbeen updated in the following technicalareas:

- Wall thickness used for Fitness ForPurpose ("FFP") calculations

2.8

a) Refers to NTSB 3.12. The answer indicatesthat one dig has taken place on Line 9 and that600 are scheduled before the end of the year(i.e. 2013). Does that remain accurate, and if so,can municipalities and landowners expect thatthey will be notified within that period? Howmuch advance notice will Enbridge be

providing?

b) Were any or all the changes enumerated inthe answers actually applied to the work doneor "to do" on Line 9? Please specify whichones, and when.


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Request:

- Including In-line Inspection tool tolerancesfor FFP calculations- Risk mitigation criteria added to analysis

processes- Tool performance validation methods- Selection of cracks in corrosion and threatintegration methods- Probability of Detection ("POD"),

Probability of Sizing ("POS") Trending- FPF Outliers analysis- ILI Classification of outliers- Inclusion of outliers into dig selection- Stress Corrosion Cracking ("SCC")growth rate comparisons

1.9 Pipeline Performance: Leakage,

Rupture and Replacement

a) Please provide the following for eachof the 13 leaks and ruptures listed in

Table 3-2:

c.1) The volume of material thatwas spilled for each leak orrupture.

d.1) Copies of all investigationreports for each leak orrupture including the cause

1.9

a.c.1) Please see attachment 1 to Ontario IR1.8.a.

a.d.1) Some of the information requestedhas been released by the NEB pursuant to anaccess to information request. Please seeAttachment 1 to Toronto IR 1.9.a.d.1. forthe information released. The redactionswere made by the NEB.

With respect to investigation reports relatingto the remainder of the leaks or ruptures,

2.9

a.c.1) Provides a reference to Attachment 1 toOntario IR 1.8.a which has some newinformation on Table 3.2. Note that revised Attto NEB 1.27.b (in A52577 filed June 25) hasother new information relevant to Table 3.2.Please advise why the Table has not been

provided in a consolidated form. In order tounderstand a table whose contents are providedin four different locations, will Enbridgeundertake to provide a comprehensive table?

a.d.1) As the reports were not provided until


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Request:

for each (externalcorrosion, internalcorrosion, or other specificcause).

f.1) Copies of notificationsprovided to theGovernment, Ministry, or

regulatory authorities foreach leak or rupture.

b) For leaks shown in Table 3-2occurring on 1/26/1991 and7/14/1993, both of which were in theCity of Toronto, please provide:

a.1) How the leaks wereidentified.

Enbridge objects to filing the informationrequested on the ground that is itconfidential information and Enbridge hasconsistently treated it as such.

a.f.1) Please refer to response to Toronto IR1.9.a.d.1. Enbridge objects to filing theinformation requested on the ground that it

is confidential information and Enbridge hasconsistently treated it as such.

b.a.1) Please refer to response to NEB IR1.27.

late in the review period, is Enbridge willing toconsent to more time to allow for follow-upquestions?

With respect to the 168 page pdf filed in lieu ofa placeholder at or around July 4, 2013, pleaseadvise as follows below:

Please confirm that none of the incidents forwhich reports were provided were discovered

by Enbridge (or IPL). In situ burning of oil iscontemplated in the Emergency ResponseManual (Book 7), however, the Attachment (at

p. 35 of 168) states that the burning of oil iscontrary to company policy? Is that the caseand if so, why does the Emergency Manualcontemplate it?

The reports in respect of Sainte Scholastiquesuggests that farmer upon whose land the oilwas spilled lost a subsidy for an installation of aland drainage system as a result of concernsabout contamination (see p. 89 of 168). Wasthis landowner compensated for that loss?

Please provide any other spill response reportsin Enbridge's possession especially with respectto spills that took place in Toronto.


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Request:

a.f.1) What is the rationale for concluding thatreports to governments, particularly to the Cityof Toronto, but also the Ontario Spills ActionCentre (as required under the Ontario EPA) areconfidential?

b.a.1) Refers to Attachment 1 to NEB IR 1.27which sets out another table with information

regarding the history of Line 9. Is Enbridgeprepared to file a consolidated Table and allowtime for follow-up questions if necessary?

With respect to the Attachment, please advisewhat is a "third party aerial patrol" referred toin relation to the 8/10/99 spill? Is that anEnbridge contractor? If not, why did Enbridgenot detect the spill?

Also NEB 1R 1.27.a. indicates that leaksoccurred at a denting feature that had

previously been identified. Can Enbridgeexplain how it is that even though a dent had

been identified, a leak still occurred? DidEnbridge change its integrity criteria as a resultof situations such as this?

1.10Pipeline Risk Assessment 1.10

a) The initial volume out (in barrels) at

2.10

a-d) The Enbridge response to Toronto IR 1.10


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CITY OF TORONTO IR 1Request:



Request:

a) The initial volume out (in barrels) at240,000 B/D flow rate.

b)The initial volume out (in barrels) at300,000 B/D flow rate.

c) The increase in initial volume out (inbarrels) due to the Line 9 Capacity

Expansion (barrel equivalent to 47m3).

d)An explanation why the percentageincrease in pipeline capacity (i.e. 25%)does not correspond or translate to a

proportionate increase in volume outin a spill event which is calculated toonly increase by 0.9% (47 m3).

e) The risk assessment uses a risk as-sessment model of 305 metre (1000ft.):

b.1) Identify whether those sec-tions are identified by En-

bridge as within the highestrisk rankings for Line 9.

c.1) Identify the projects and

240,000 bpd flow rate is 2,166.7 bbls.

b) The initial volume out (in barrels) at300,000 bpd flow rate is 2,708 bbls.

c) Please refer to response to NEB IR3.11.a.

d) Please refer to response to NEB IR3.11.a.

The value for calculated volume out isdependent on topography and the placementof remote controlled sectionalizing valves.Calculated volume is based on thecalculation: (design flow rate x the time toisolate the pipeline) + (drain down of oilthat is not isolated by valves or topography).The drain down portion of the calculation isindependent of pipeline capacity or flowrate.

e.b.1) Please refer to response to Toronto IR1.10.e.a.l.

e.c.1) Please refer to response to the OntarioIR No 1.1.c.

a)-d) and NEB 3.11.a are not consistent asdifferent design flow rates are utilized. Please

provide a modification to whichever of the twothat is not correct. The initial volume outcalculations provided by Enbridge in responseto Toronto IR 1.10 a)-d) and NEB 3.11.a do notinclude "drain down". Please provide thecalculated volume out, including drain down,

for the section of Line 9B that would spill themaximum volume of oil into the Rouge, Donand Humber Rivers, and Mimico, Etobicokeand Highland Creeks.

e.b.1e.c.1) The intent of Toronto IR 1.10.e wasto ascertain whether Enbridge is addressing thehighest ranked 305 metre segments within theCity of Toronto to ensure that the public and theenvironment were being properly protected.The Enbridge Reply is incomplete: 1) Enbridgedid not Reply to the request in Toronto IR1.10.e.b.1 Identify whether those sections areidentified by Enbridge a within the highest risk

ranking for Line 9., and, 2) Enbridge did notReply to the request in Toronto IR 1.10.e.c.1Identify the projects and expenditures

Enbridge plans for mitigation of the highest risk

rankings within the City of Toronto. Pleaseprovide a response to these questions.


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expenditures Enbridgeplans for mitigation of thehighest risk rankings withinthe City of Toronto.

1.11In-Line Inspection Program


e) Advise whether the raw data for thecurrent (2012-2013) ILI program forLine 9B has been verified, reviewedand audited by a third party other thanEnbridge.

f) Provide Enbridge's or its ILIConsultant's summary andrecommendations from the report

respecting the ILI data from the 2012-2013 ILI runs.

1.11

e) Enbridge has a Pipeline Integrity

Department that reviews, verifies and auditsin-line inspection data using established

processes regulated by engineeringstandards and regulations. These processeshave been developed and are continuallyimproved with support from various third

party expert consultants. A third party hasnot reviewed, audited, or verified the in-lineinspection reports.

f) Enbridge will communicate the results of

the in-line inspection tool runs, includingthe number of digs required and where theywill take place, to affected landowners andmunicipalities.

2.11

e) Enbridge has indicated that it does not

undertake a third party review of its in-lineinspection. Enbridge relies upon engineeringstandards and regulations. Please advise if theseare the engineering standards that Enbridge hasrefused to produce (see 1.1.a). Please advisewhether there are instances when therecommendations of third party expertconsultants on the ILI program have not beenfollowed by Enbridge and provide particulars reeach such instance since the Marshall spill.Would Enbridge consider third party review of

the ILI program as a condition to the approval?

f) When will the integrity results be reported?Specifically, how long after they are received?How long before the Line is opened?

1.12 Temperature Control


1.12

b) Temperature sensors are locatedthroughout the Enbridge system, typically

2.12

b) Please provide Enbridges plan to addTerrebone Station temperature sensors to


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b) Location of pump dischargetemperature sensors available throughEnbridge's SCADA system.

situated at locations where product isreceived into the pipeline and locationswhere product is delivered off the pipeline.Some midline pump stations locations arealso equipped with temperature sensor.

SCADA. If Enbridge does not plan to addTerrebone Station temperature sensors toSCADA, provide an explanation as to why theyare not needed in SCADA.

1.14Depth of Cover


d) Areas where Enbridge has had toreplace cover or take other correctiveactions when depth of cover was lessthan required on Line 9B within theCity of Toronto:

a.1) Location (KP andlongitude/latitude).

b.1) Planned additional mitigative

and preventative measures toaddress concerns related to depthof cover and the scheduled datesof implementation.

e) Enbridge's policy for installingadditional pipeline markers whendepth of cover is less than the currentcover requirement.

1.14

d.a.1) Four locations within City of Toronto

have had to have corrective action taken:

1. Newtonbrook Creek KP 3080.012. Don River KP 3081.703. Rouge River KP 3095.354. HONI lands KP 3097.95

d.b.1) 1. Newtonbrook Creek KP 3080.01Pipe found to be exposed in bottom of creekduring slope and stream survey June 2013.A consultant has been hired to prepareremediation plan. Creek is non-navigablewaterway, the pipeline is not at risk due towater traffic.

2. Don River KP 3081.7 Enbridgeis planning to replace 700 m of pipe andinstall the pipe several meters below theriver bed. Work is scheduled to start August2013, and be completed by December 2013.

2.14

d.a.1) Were any of the four sites identified as a

result of "depth of cover" (or other) surveys? Ifnot, how was Enbridge alerted to the potential

problem?

d.b.1) Although Enbridge has concluded thatNewtonbrook Creek is non-navigable andtherefore not at risk due to water traffic, what ifany consideration was given to items that could

be waterborne during extreme weather events,such as logs, tree stumps, or other debris? Whatif any consideration has been made of the

potential for extreme erosion under abnormalflow conditions? What lessons, if any, doesEnbridge draw from the recent 750,000 litrespill from Line 37 reported on June 22, 2013 ata time when there was heavy flooding in thearea?

e) Is Enbridge's assessment of sufficient depthof cover or mechanical protection informed by


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Request:

f) Enbridges plan for the next depth ofcover survey for Line 9B including:

a.1) The start date andcompletion date for the study.

3. Rouge River KP 3095.35 Theeast bank of the river had extensive erosionexposing the Enbridge pipeline. The erosionhas been repaired by installation of a livecrib wall designed by a consultant; workwas complete in 2011.

4. Lot 5, Con. 4 (Scarborough)

Toronto KP 3097.95 This area is a non-cultivated field which requires addition ofapproximately 75 yards of fill. Work isscheduled for completion in 2013.

e) Enbridge ensures that the pipeline hassufficient depth of cover or Enbridge

provides mechanical protection to protectthe pipe from external damage.

f.a.1) Enbridge's Pipeline DepthMonitoring Program has set a 10 year cycle(with the exception of pipeline crossings ofwatercourses). The next depth of coversurvey on Line 9B will commence in 2018;however, the start and end dates have notyet been confirmed.

extreme weather events? If the depth of coverdeemed sufficient at the time of constructionwould not be sufficient by 2013 standards, arethese areas grandfathered so that no furthersteps need be taken to bring the Line up to 2013standards?

f.a.1) Refers to a ten year cycle for DOC

surveys. Should an extreme weather eventoccur prior to that, would Enbridge takeintermediate steps to assess DOC, or would itwait for the next cycle? What if there was anearthquake or other event that could affectdepth of cover? Does Enbridge have any

policies or protocols to prescribe under whatconditions it would go beyond the regular cyclefor DOC surveys? Please provide same.


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Request:

1.16 Pump Station Integrity

Management

b) Please provide details of the directassessment plan for corrosion mitigationat pump stations and other facilities.

1.16

b) The Enbridge direct assessmentmethodology utilizes a threat basedinspection program (as mentioned in Table3.15 of the Facilities EA). The programconsists of identifying assets (pipingsections) assessing risk based on identified

threats, and performing inspections attargeted locations. For underground pipethat cannot be inspected with ILI tools,inspections generally consist of exposingthe pipe, performing any repairs, reapplyingthe external coating and then backfilling the

pipe. Research and development is ongoinginto alternative assessment technologiesincluding real-time corrosion monitoring.Inspection results determine re-inspectionintervals and help to determine other actionsthat may minimize risk such as inspectingother locations.

2.16

b) Refers to corrosion management forunderground pipe that cannot be inspected withILI tools, but does not respond respecting

pumping stations. Is the answer applicable topumping stations as well?

1.17 Sediment and Water Content


b)For a batch of crude, when are S&W

1.17

b) Test results are available typically 1-4days prior to injection. However, there aresome cases in which the results may not be

2.17

b) What percentage of batches are inserted intothe system before test results are received:generally in Enbridge operations; and,


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Request:

test results available (length of time inadvance of injection or length of timeafter the batch is injected) in relationto when the crude oil was injected intothe pipeline?

f) Enbridges plan to sample and testS&W removed during cleaning pig

runs on Line 9B.

available until one day after inspection. Thisdepends on whether or not batches are tightline receipts or received into tankage andhow the batches are scheduled.

f) Enbridge will sample the S&W removedfrom Line 9B on an occasional basis tomonitor for potentially problematic bacteria,

and to observe changes in pipeline sedimentcomposition.

specifically on Line 9?

f) Please advise as to what Enbridge considersis occasional and what are the criteria tosample the S&W. Would Enbridge consider as acondition to LTO the same requirements asSpecial Condition 34 applicable to theKeystone XL application as set out below? If

not, what is Enbridges opposition to suchrequirements?

Special Condition 34:

Internal Corrosion: Keystone shall limit basicsediment and water (BS&W) to 0.5% by vo-lume and report BS&W testing results toPHMSA in the annual report. Keystone shallalso report upset conditions causing BS&Wlevel excursions above the limit.a) Keystone must run cleaning pigs twice in

the first year and as necessary in succeedingyears based on the analysis of oil constitu-ents, liquid test results, weight loss couponslocation in areas with the greatest internalcorrosion threat and other internal corrosionthreats. At a minimum in the succeedingyears following the first year Keystone mustrun cleaning pigs once a year, with intervalsnot to exceed 15 months.


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b) Liquids collected during the cleaning pigruns, such as BS&W, must be sampled, ana-lyzed and internal corrosion mitigation

plans developed based upon the lab test re-sults.

c) Keystone shall review the program at leastquarterly based upon the crude oil qualityand implement adjustments to monitor for,

and mitigate the presence of, deleteriouscrude oil stream constituents.

1.18 Stress Corrosion Cracking Hydro

Testing

a) Please provide the latest plan for hy-drostatic retesting of Line 9B.

b) Given the long period of operation ofLine 9B under significantly differentconditions since the last hydro test in

1997, please advise whether Enbridgeis prepared to conduct a further hydrotest of Line 9B to confirm the pipelineintegrity prior to the reversal.

c) If Enbridge concluded that it was im-portant to hydro test Line 9B prior tothe reversal in 1997 but does not planto hydro test Line 9B prior to this re-

1.18

ae) Please refer to response to Ontario IR1.14.a.

2.18

ae) Refers to Ontario IR 1.14.a., whichindicates that the prior requirement that Line 9

be hydrotested was a result of its being inactivefor 12 months. What constitutes "inactive" forthe purpose of a hydrotest requirement and arethere any portions of Line 9 that may beexpected to have persisted in an "inactive" state

prior to the reversal LTO being granted?


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Request:

versal, please provide an explanationas to why a hydro test would not be inthe best interest to confirm the currentintegrity of the pipeline.

d) In the alternative, please advisewhether Enbridge is prepared to agreeto the conducting of such a hydro test

within a specific time period as a con-dition to be imposed on any approvalof this application by the NEB.

e) Please advise whether the require-ments of the NEB or Enbridges In-tegrity Management Plan whichwould mandate a future hydro test ofLine 9B.

1.19 Crack Management Program


a) In Section 3.4.3 System Flow Ratesand Pressures, an addition to Tables3.9 through 3.14 to include the MOPof the respective stations discharge

pressure for a direct comparison be-tween the Post Project Max./Min. and

1.19

a) Enbridge was unable to identify thetables noted in the request.

2.19

a) The reference in Toronto IR 1.19.a to Tables3.9 through 3.14 in Section 3.4.3 of Attachment7, Pipeline Integrity Assessment, should have

been a reference to Section 3.4.3.1 throughSection 3.4.3.6 of Attachment 8, FacilitiesIntegrity Engineering Assessment (Adobe pages16 through 18 of 23), consisting of thefollowing tables:


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ENBRIDGE RESPONSE TO TORONTO IR 1Response:


the MOP. Table 3.9 SA Proposed Operating Pressureand Flow Rate

Table 3.10 NW Proposed Operating Pressureand Flow Rate

Table 3.11 HL Proposed Operating Pressureand Flow Rate

Table 3.12 CD Proposed Operating Pressureand Flow Rate

Table 3.13 TB Proposed Operating Pressureand Flow Rate

Table 3.14 ML Proposed Operating Pressureand Flow Rate

The request in Toronto IR 1.19.a still stands

Please reply to the request now that thereference to the tables is corrected.

1.21Material Balance System


a) The smallest leak rate on Line 9 thatwill trigger an MBS alarm.

1.21

a) Please refer to response to NEB IR3.10.c.

c-d) Enbridge objects to the request as theinformation sought is not relevant to the

2.21

a) Please provide a timetable as to when thedetailed engineering referred to in NEB IR3.10.c (para.2) will be finished.

Also, in its response to NEB 3.10.c, Enbridge


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c) MBS alarms across the Enbridge sys-tem due to DRA inconsistencies dur-ing 2010, 2011, and 2012.

d) Leaks not detected by the MBSacross the Enbridge system during thelast five years due to improper ad-

justments of MBS settings.

issues in this proceeding. lists five primary detection methods. Pleaseadvise if the five primary detection methods arelisted in the order that Enbridge expects to bethe most effective at detecting leaks, or theorder that Enbridge relies on the particularmethod for leak detection (with the highest

preference listed first). In other words, isController monitoring (first item listed), in

Enbridges experience, the most effective leakdetection method and the most reliable, whereasis Acoustic line inspection (last item listed) thedetection method which Enbridge relies on theleast, and, is the least likely of the five methodsto detect a leak?

c-d) Given the Odessa, SK spill in 2009, asreferenced, there is a concern about theEnbridge "track record" on issues related toadjustments of the MBS for DRA injection. The

Enbridge reply is important because the historyof MBS alarms and leaks that were not detected

by MBS will assist in understanding: theeffectiveness of the MBS; the reliability of theMBS; and the availability of data to test MBSeffectiveness. Please provide the requested data.What assurances can Enbridge provide that thestatement "The Enbridge system properlymodels the impact of DRA" is true?


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1.23Enbridge Safety Initiatives

b) Enbridge indicated that "appropriateoperational and procedural changes"were implemented in 2010, 2011.Please advise what these changes are,whether any further changes weredeemed necessary as a result of the

release of the NTSB report, andwhether and how such furtherchanges have been implemented.

c)Enbridge advised it has utilizedenhanced procedures for leak detectionanalysis. Please provide particulars onthese measures.

d) Enbridge indicated it had reviewed andstrengthened its public awareness

programs. Please advise what measureshave been taken and how they have beenimplemented in Toronto and generallyalong the course of Line 9.

f) Enbridge advised that $50 Million willbe spent (projected) between 2012 and2013 to improve emergency responsecapabilities. Please advise what amounts

1.23

b) Please refer to response to Ontario IR1.44.a.

c) Please refer to response to Ontario IR1.44.b.iv.

d) Enbridge has strengthened its PublicAwareness Program. These measures have

been implemented enterprise-wide withinOntario, along Line 9 and along all ofEnbridge's system. Specific measuresinclude:

Developing an industry-leading onlineeducation tool to provide Enbridgespecific information to emergencyresponders;

Improved the landowner/tenantdatabase;

Developed a landowner newsletter; andEstablished Community Relations

positions in each region.

f) Please refer to Ontario IR 1.42.b and c.

g) Enbridge has contracted with TheResponse Group to develop specific detailed

2.23

b) In Ontario IR 1.44.a, under the sub-headingLeak Detection, Enbridge refers to a LeakDetection Analysis and Communication

procedure that was implemented in Q4 2011.Please advise at what stages of this proceduremunicipal authorities are contacted and what is

the nature of the information relayed.

Under the same sub-heading, Enbridge advisesthat it has implemented a Leak DetectionInstrumentation Improvement Program to addand upgrade instrumentation across theEnbridge system. What are the specific detailsof additions and upgrades that have been, andare being, made to Line 9B under this program?

In Ontario IR 1.44.a, under the sub-heading

Public Awareness, Enbridge indicates that ithas developed and deployed an industry-leadingonline and in-person training tool to provideEnbridge specific information to emergencyresponders. Please confirm that Toronto andother municipal emergency responders have

been included in the deployment.

In Ontario IR 1.44.a, under the sub-heading


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have been spent and how those amountshave been spent to date.

g) Enbridge advised that it is developingbetter tools and techniques for worst-case waterborne spills. Please advisewhat steps have been taken in relationto worst-case waterborne spills in and

around Toronto and the north shore ofLake Ontario.

h) Enbridge indicated it was conductingan emergency response preparednessassessment. Please provide a copy ofthat assessment. Please also advisewhat steps have been taken as a resultof that assessment in relation to Line9.

i) Enbridge advised that it had a renewedfocus on risk assessment and researchand development. Please advise whatspecific steps have been taken as aresult of this renewed focus,

particularly with respect to theconclusions reached by the NTSB inrelation to: inadequate integritymanagement, inadequate public

tactical response plans for key riversflowing into Lake Ontario. These plans are

being developed to supplement Enbridge'sexisting extensive library of control pointmaps. Tabletop exercises will be performedon tactical plans to ensure first respondersare aware of the plan content and how to usethat content effectively.

In addition to the enhancement of itsresponse plans, Enbridge conducts regularon water exercises to test deploymenttechniques for hard boom, soft boom,skimmers, weirs, and other responseequipment. Through these exercisesEnbridge learns how best to respond toscenarios at different locations along the

pipeline.

h) Enbridge objects to filing the informationrequested on the ground that it isconfidential and contains safety sensitiveinformation that Enbridge has consistentlytreated as confidential, the disclosure ofwhich could reasonably be expected toresult in a security risk to Enbridge and itsoperations. Enbridge is taking measures toenhance its emergency response program

Emergency Response, Enbridge advises thatRegional Incident Management Teams have

been identified across the system. How many ofthese teams have been identified for Line 9B?Where are they located? Who are on the teams?What are the qualifications of the teammembers? What liaison has been established

between these teams in proximity of Toronto

and the municipal first responders?

In Ontario IR 1.44.a, under the same sub-heading Emergency Response, Enbridgeindicates that numerous new tools have beendeveloped to provide resources to responders tosupport an effective, coordinated response.Does the distribution of these new tools extendto the City of Toronto or other municipalresponders?

In Ontario IR 1.44.a, under the sub-headingSafety Culture, Enbridge notes that it hasimplemented Lifesaving Rules and trainingfor its employees and contractors. Please

provide details of these Lifesaving Rules.

c) Enbridge refers to its response to Ontario IR1.44.b.iv, which refers to the response to NEBIR 3.10.c, which indicates that Enbridge


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awareness, and the need for furtherresearch on the properties of dilbitmaterials. Please also advise howEnbridge intends to incorporate thework currently underway by the

National Academies with respect tothe properties of dilbit in relation tothis renewed focus on research.

system-wide. Please refer to response toOntario IR 1.44.a.

i) Please refer to response to Ontario IR1.44.a and Mississauga IR 1.11.a.

conducts aerial and ground line patrols of itspipeline. Please advise how often such patrolsare conducted for Line 9B?

d) Please provide copies of the newsletter asdelivered on Line 9 within the last three years.How often are these newsletters published?Please advise what specific information has

been provided to the public as to how theymight identify odours or spills as crude, andwhat steps they should take. Please confirm ourunderstanding that Enbridge makes no specialinformation available to the public in relation tovolatiles such as naphtha associated with dilbit.

f) Since Lake Ontario is identified as a "highconsequence area" as per Enbridge response toIR 1.30.i), does Enbridge agree that it is all themore imperative that municipal first respondersalong the north shore of Lake Ontario be awareof the detailed site-specific plans? What otherareas along Line 9 are identified as highconsequence areas? Would Enbridge bewilling to share with municipalities, on aconfidential basis, information on the locationof each type of equipment so that municipalitiescan adequately plan their response, especially atthe initial stages of a spill before Enbridge


24/37








personnel or contractors arrive on site?

g) What are the "key rivers flowing into LakeOntario" for which "specific detailed tacticalresponse plans" are proposed? When will those

plans be developed? Will they be shared withmunicipal authorities and emergencyresponders? Will Enbridge agree to defer

approval pending the completion of the plans?What plans are in place or proposed forwaterways that do not fall into the "key rivers"category?

h) At a minimum, would Enbridge agree tomeet with municipal emergency responders togo over site/response specific plans to assess ifthey meet local needs and to identify any gapsthat need to be addressed?

i) Refers to the integration of research resultson dilbit. Given that the recently published

NRC report on dilbit [link below] explicitlystates that "the committee was not asked to orconstituted to study whether pipeline releases ofdiluted bitumen and other crude oils differ inconsequences", what if any further researchdoes Enbridge intend to take on the propertiesof dilbit in the natural environment once it is


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spilled given its commitment in the pressrelease to "renewed focus on risk assessmentand research and development"?

http://onlinepubs.trb.org/onlinepubs/sr/sr311.pdf

1.24Financial Assurance

a) What assurances can Enbridge provide

that it has either insurance in placeand/or the funds available tocompensate the City for any/all lossesand expenses, direct or indirect, arisingfrom or related to an oil spill?

b) Specifically:

i. Will Enbridge identify and describewhat insurance arrangements are cur-rently in place for operational risk as-

sociated with Line 9?

ii.Will Enbridge advise whether insur-ance coverage limits are based on in-dividual incidents or apply to the sumof all incidents within its system inthe coverage period?

iii.Will Enbridge indicate whether it will

1.24

ad) Refers to NEB 3.7

e) No such measures are currently in place.Whether or not compensation would be

paid, to whom, for what reasons, and inwhat amounts would depend upon thespecific circumstances in question.

Please refer to response to NEB 3.7.

2.24

ad) What are the relevant "standard coverage

exclusions" found in most insurance policiesreferred to by Enbridge, and how do they applyto extreme weather events? Did Enbridgemodify its insurance coverage as a result of thecost associated with the Kalamazoo cleanup?Given the announcement by Canada's Ministerof Natural Resources on June 26, 2013 [see link

below] that the government intends to propose aregulatory amendment to require $1 Billion infinancial capacity for crude oil pipelineoperators, is Enbridge able to confirm that it

will meet that standard now on a voluntarybasis? Will Enbridge agree to a condition to thateffect? Is Enbridge prepared to make a financialassurance that is dedicated to Line 9 and if so,in what amount?

http://www.nrcan.gc.ca/media-room/news-release/2013/7229
http://onlinepubs.trb.org/onlinepubs/sr/sr311.pdfhttp://onlinepubs.trb.org/onlinepubs/sr/sr311.pdfhttp://www.nrcan.gc.ca/media-room/news-release/2013/7229http://www.nrcan.gc.ca/media-room/news-release/2013/7229http://www.nrcan.gc.ca/media-room/news-release/2013/7229http://www.nrcan.gc.ca/media-room/news-release/2013/7229http://www.nrcan.gc.ca/media-room/news-release/2013/7229http://onlinepubs.trb.org/onlinepubs/sr/sr311.pdf


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be varying its insurance arrangementsor policy coverage for operationalchanges associated with the Line 9capacity, flow reversal and tariffchanges? If yes, please provide par-ticulars in coverage changes?

iv.Regardless of the sufficiency of in-

surance coverage would Enbridgemake a representation upon which theCity could rely that Enbridge wouldmake good, direct or indirect, for anyspill costs or damages from Line 9 inthe event of a spill?

c) Is there a risk that costs associatedwith a large spill will exceed theinsurance coverage Enbridge has? Ifso, what other financial means can

Enbridge identify to cover costsarising from a possible large spill?

d) What is Enbridge's position oncompensation in the event of a

pipeline spill not caused by the fault ofEnbridge?

e) What measures are in place or

e) Refers to NEB 3.7; however, there is noreference in NEB 3.7 to compensation forevacuees. Further, in its response to Ontario IR1.4, Enbridge states that Enbridge willcompensate "all damage sustained" with nolimitation. However, in responding to Toronto1.24.e, it states that compensation to evacuees,indeed to all claimants by virtue of the answer

to 1.24.d, would "depend on the specificcircumstances". Can Enbridge assure residentsadjacent to Line 9 that they will not end up incostly and protracted legal action over liabilityif they claim for evacuation costs arising as aresult of a spill?


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proposed to compensate residents andbusinesses or other third parties alongLine 9 in the event they need to beevacuated? In relation to other costs?

1.26 Clean Up Response for Non-

Conventional Heavy Crudes (DilBit,

SynDilBit and SynBit)

c) Considering difference in viscosityand temperature and presence ofNaphtha, the rationale as to whyspecialised instructions are not

provided for DilBit, SynBit orDilsynbit on page 11 of Enbridge's"Important Safety Information for

Emergency Responders Enbridge

Pipelines Inc."

d) What accounts for the difference in the

behaviour of Dilbit in the SL RossEnvironmental Research undercontrolled laboratory conditions andthe behaviour of Dilbit in the openenvironment as noted by the NTSB inits review of the Marshall spill on

page 62-63 which describes denser oilfractions sinking and incorporatinginto river sediment?

1.26

c) Dilbit, synbit and dilsynbit are bitumenbased products diluted with either diluents,

synthetic oil, or a combination of the two.Once the products are mixed and broughtinto accordance with transmission pipelinespecifications the resulting product is aheavy crude oil. The table provided in"Important Safety Information for

Emergency Responders Enbridge Pipelines

Inc."includes an entry for crude oil.

d) Reference iv), the SL Ross studyprovides the results of a laboratory study

designed to investigate the weathering ofCold Lake diluted bitumen, with the

preliminary goal of investigating the densitychange of the diluted bitumen as it weathersunder weather conditions more realistic thanthat simulated in standard laboratory testing.The study was designed to supplement andimprove on previous testing of evaporationrates under controlled conditions in a

2.26

c) Given that dilbit generates volatiles, thevolatilization of which resulted in evacuation

notices to about 50 houses in Marshall (see p.18, NTSB report), would Enbridge agree todeveloping additional information to assist withevacuations resulting from dilbit spills? If not,why not?

d) Given that sediment and water turbulenceplay a significant role in sinking of oil productsand given that the factors that contribute towhether or not oil sinks are "complex, canchange rapidly"? (see Citoyens au courant IR

5.37) and given that the NRC report explicitlydid not deal with the properties dilbitdemonstrates after it has been spilled, whatcommitment is Enbridge prepared to make todevelop a better understanding of the way dilbit

behaves under various environmentalconditions?


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laboratory wind tunnel, and to examine ifdilbit would sink through weathering

processes alone. This study was notdesigned to simulate all of the various

processes influencing fate and behaviour ina real-world environment. The SL Rossstudy utilized fresh water with no sedimentcontent.

1.27Emergency Response Book

d) Book 7 refers to emergency exercisedocumentation (p. 5 of 173) andreports (p. 20 of 173). Please advise:

iv) Who was provided a copy of theexercise results and weremunicipalities or conservationauthorities provided with results?Please provide a copy of any

materials so provided.

e) Book 7 refers to an "incidentcommand system" and an "incidentcommander" at pages 5 and 8 of 173.The Public Safety and EmergencyManagement Unit of the TorontoPolice Service (TPS) also uses anincident management system. Please

1.27

d.iv) Results of the Don River Exercise,including the results of the exerciseobjectives, were discussed orally withrepresentation from all involvedstakeholders during the review sessions heldat the end of the exercise.

Please refer to Attachment 1 to Toronto IR1.27.d.i.

e) In the case of an incident such as the oneexercised on the Don River and IncidentCommand Structure ("ICS") would beestablished as part of the response. The ICSorganizational structure would be identifiedwhich would lay out each of the positionsinvolved with the response and the party or

person responsible to fulfill that role. As

2.27

d.iv) Can Enbridge advise why written reportsof the emergency exercises were not providedto municipal staff in view of the reference towritten reports in Book 7 (as provided toToronto in Enbridge's response of February 5,2013 to a City informal request for information)as "essential" (p. 5 of 173) and given that themanual also notes that "verbal instruction areunreliable" and "documents form a permanent

record"?

Attachment 1 to Toronto IR 1.27.d.i what wasthe "stakeholder confusion leak site location" asnoted on p. 2? What if any further discussion orinstruction has been provided to Toronto FireService re the Toronto Fire Service"improvising using our equipment until[Enbridge] get there" as noted on p. 2,


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advise how "command" roles havebeen coordinated between Enbridgeforces and the TPS, Toronto FireService, the Office of EmergencyManagement, and other CityDivisions, as well as Ministry ofEnvironment (Ontario), andEnvironment Canada, on site. Have

City Divisions been made aware ofany expectation that they will have arole? What role would they have?

f) Book 7 refers to cooperativeagreements to provide Enbridge withadditional emergency responseequipment and services (p. 11 of 173).Please advise whether sucharrangements or agreements are in

place on Line 9 currently, or are

proposed to be put in place?

j) Book 7 contemplates that evacuationmay be required if necessary (p. 25of 173). Please advise that constitutesa condition of necessity for the

purposes of evacuation? Who makesthat decision? What plans are in placeto liaise and cooperate with local

part of this structure Toronto Police Serviceand Toronto Fire Service would be

providing a support role in order to protectthe public and assist in achieving theresponse objectives. A Liaison officer wouldalso be in continuous communication withall other agencies to receive and provideinformation concerning the response.

A Unified Command Structure might beestablished if the response required it. TheUnified Command would haverepresentation from Enbridge, the NEB andmost likely the Ontario Ministry ofEnvironment and/or Environment Canada. Itcould also have representation from TorontoFire Services, Toronto Police Services,Office of Emergency Management and/orother city divisions. The Unified Command

would establish objectives, commitagency/company resources, agree on theincident response organization, etc.

An ICS organization structure wasestablished for the Don River exercise but aUnified Command was not included in thescope. Enbridge Emergency ResponderPublic Awareness documentation also

particularly as the response time is stated to bebetween 1.5 and 4 hours (in that case it wasactually 1 hour 45 minutes)? What are "EMS"and "TCC" referred to on p. 2? Was there anyfurther discussion with Water re protection ofsewer vaults in the event of an incident as notedon p. 2?

On p. 3 of the Attachment, it is stated that "thebank was narrow if it had been winter it wouldhave been very challenging" what if anymodifications has Enbridge made to itsemergency response procedures to account forwinter conditions or extreme weather eventssuch as that experienced in Toronto on July 8,2013?

Have the control points along the Don Riverbeen modified as noted on p. 3?

On p. 4, it is noted that the EmergencyManagement Specialist (NEB) would provide"a few pointers to Enbridge in a writtensummary later on". Please provide a copy of thewritten summary provided by the EmergencyManagement Specialist. Was a "package"respecting the exercise made available as notedon p. 4? Please provide a copy if so, and if not,


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emergency responders such as Police,Fire, the Office of EmergencyManagement or the Mayor's Officeand/or the Ontario Ministry of theEnvironment or Environment Canada,in relation to any needed evacuation?

l) Book 7 refers to "liaison officers" to

provide contact with Police, Fire andother government officials (p. 37 of173). Please advise who this person ison Line 9. What if any, protocols or

procedures are in place in relation tothis officer? Please provide a copy.What is Enbridge's view on who therelevant "government officials" are?

m) Book 7 warns that prompt first aidtreatment is crucial for people exposed

to breathing hazards, noting that"treatment varies according tomaterials" and stresses the need to be"aware of the proper first aidtreatment" (p. 88 of 173). Pleaseadvise what information has or will be

provided to municipal emergencyresponders on breathing hazardsassociated with dilbit, synbit and

describes the roles of local emergencyresponders during an incident. During anactual event, ICS roles would be established

based on the agencies involved andpersonnel available through the meansdescribed above.

f) Please refer to response to Ontario IR

1.45.a. Enbridge currently has emergencyresponse agreements in placve with variousentities including ECRC/SIMEQ orsubcontractors to ECRC/SIMEC. Theseagreements would apply to responses on allEnbridge pipelines within Ontario andQuebec including Line 9.

j) Wind condition and atmosphericmonitoring would be performed as part ofany spill response. The extent of elevated

readings of hydrocarbon vapour orsubstances of concern such as benzenewould dictate areas of required evacuation.Enbridge would work in conjunction withregulatory agencies in deciding to executerequired evacuations. Enbridge wouldcoordinate with local emergency respondersas well as local/regional emergencymanagement agencies by way of the

why not?

At what location(s) for the Don River exercisewere the crew(s) deployed? Specifically, werecrews dispatched to the mouth of the River?

e) Please provide a copy of the EnbridgeEmergency Responder Public Awareness

documentation referred to in the response. TheCity is unclear whether municipal emergencyresponders such as Fire Services would beincluded in the Unified Command structure or

just recognized to be in a supportive role andtherefore dealing through a Liaison Officer.Given the role that a municipal Fire Serviceswould have relative to the protection of life and

property, does Enbridge not agree that it wouldbe imperative that Fire Services be directlyincluded in the unified command structure,

particularly when considering the statement thatdescribes the function of the UnifiedCommand: The Unified Command wouldestablish objectives, commit agency/companyresources, agree on the incident responseorganization, etc.? How can Toronto Waterwater treatment plan operations be integratedinto the "Incident Command Structure"?


31/37








dilsynbit and particularly the volatilediluent components of these products.

o) Book 7 refers to stormwater sewerrunoff collection systems in relation tospills on land (p. 106 of 173) andredacts portions of text immediatelythereafter as "security information".

Please advise of the basis for thesecurity concern. Please also advise ofinformation available to Enbridge ofthe location of such storm sewercollection points through the City ofToronto in proximity to Line 9, andwhat steps have been taken byEnbridge to ensure that spilledmaterial does not enter the Citystormwater system. Does Enbridgehave similar information for all of

Line 9?

p) Book 7 refers to procedures to be usedin wetlands (p. 113 of 173) and rivers(p. 122 to 173). The NTSB reportinvestigating the Marshall spill of 2010was critical of Enbridge for havingfailed to ensure that proper underflowdamming equipment was in place to

designated Liaison Officer, EnvironmentOfficer and/or Incident Commander toidentify air contaminant levels that would

potentially result in recommendation forevacuation, and to establish and execute a

plan for public evacuation if required.

l) The Liaison Officer is the contact for all

responding resources and outside groups.The Liaison Officer will work with theFederal, Provincial or Municipal agenciesthat respond to the incident. The LiaisonOfficer is not established until an incidentoccurs.

m) Please refer to response to Les Citoyensau Courant IR 5.17b.

o) Please refer to response to Ontario IR

1.44.b.v.

Enbridge does not have detailed knowledgeof stormwater sewer systems in anymunicipality and instead relies on itsrelationships with municipalities and theirknowledge of their own systems. Enbridgehas met with Toronto Water numerous timesto discuss Enbridge's pipeline operation and

f) Where are the emergency contractors referredto located and what is their response time to aToronto spill?

j) Given that Enbridge has indicated that itanticipates a response time of 1.5 to 4 hours, arelocal emergency responders expected to waitfor Enbridge personnel or contractors to arrive

to make a decision on evacuation? If localemergency responders make the decision toevacuate on their own, will Enbridge be willingto fund any associated costs since they were not

part of the decision process?

l) Refers to the Liaison Officer as not beingestablished until an incident occurs. Given thatEnbridge response may take up to 4 hours, whatrelationship exists between Enbridge andemergency responders that may arrive on site

hours earlier? Please advise who is the LiaisonOfficer for Line 9. At what time during anincident is the Liaison Officerestablished/informed of the emergency? How isthe Liaison Officer identified to municipal firstresponders? Who are the relevant "governmentofficials", including City of Toronto officials,that would be engaged by the Liaison Officer?


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deal with spills in fast flowing waters(pp. 105-108).

i)Please advise what measures are inplace to ensure that equipment andtraining are in place to permit theinstallation of such equipment atmajor water crossings.

ii) Please also advise whetherlocations for spill collection points,underflow dams, contaminant damsand booms for major watercoursesflowing along the north shore of LakeOntario have been identified. If yes,

please provide details for eachcontainment measure. If no, whynot?

q) Book 7 contemplates an alternativewater supply in the event that a spillcontaminates drinking water (p. 147 of173). Please advise what if any,alternative measures could or would

be taken in the event of contaminationof drinking water drawn from LakeOntario. Please advise what, if any,discussions have taken place with

the location of facilities.

p.i) Containment using the underflow damtechnique is effective and sound; however,safety of responders must first be consideredwhen dealing with fast moving water andhazards associated with a hydrocarbonrelease. Enbridge has the resources required

as part of initial response equipment cachesto construct underflow and culvert weirdams. Please refer to Attachment 1 toToronto 1.27.p.i. The Emergency ResponseBulletin was sent out in October 2012 toremind Enbridge first responders of thisresponse tactic and the resources required.

Please refer to response to Ontario IR1.44.b.v. for Enbridge's EmergencyResponse Plan which discusses Dikes and

Containment Weirs in Section 04-02-04,page 124 of 173 as part of the RiverResponse Procedures.

p.ii) Yes. Enbridge has developed a numberof spill collection points along eachriver/creek the pipeline crosses for use inthe event of an incident. The details aroundeach collection point is confidential for

m) The requested information appears to havebeen created on June 23-24. When was it postedon the NEB inbox? Why was it not produced onJune 25? Has this information previously beenmade available to Toronto Fire etc. as a matterof course?

o) If City of Toronto provides mapping of

manholes, will that be integrated by Enbridgeinto its maps? Is there any procedure for how todeal with manholes so as to preventcontamination of storm sewers and sewagetreatment plants? What, if any, follow-up has

been carried out or proposed with TorontoWater staff?

p.i) Would Enbridge be willing to share withmunicipal first responders, on a confidential

basis, the amount, location of the caches and

most importantly the time it will take to put theequipment into service? If there is a spill in the

presence of "fast moving water and hazardsassociated with a hydrocarbon release" doesthis preclude the construction of underflowdams, and if so, what response would Enbridgeundertake to contain the spill, particularly if fastmoving water persists for an extended period oftime?


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Toronto Water or other waterauthorities drawing drinking waterfrom Lake Ontario's north shore.

security reasons.

q) Enbridge would work with localmunicipalities regarding implementation oftheir emergency management plansconcerning drinking water supply. Ifdrinking water sources were to be impacted,Enbridge would provide a safe temporary

supply of drinking water to residents andtake all necessary actions to restore drinkingwater supplies as soon as practicable.

p.ii) Given that Enbridge assumes up to 4 hoursbefore its responders arrive on site (seeresponse to 1.28.i), is Enbridge prepared toshare details regarding collection points inadvance, rather than after a problem hasoccurred?

q) The three City of Toronto water treatment

plants with intakes in the near shore zone ofLake Ontario have a combined capacity of2,365 ML per day. Please advise how Enbridgecommits to providing a safe temporary supplyof drinking water to 2,365 MLD.

1.28 Emergency Response and Control

Measures

a) Existence and location of all controlvalves/stations on Line 9B North Wes-tover to Montreal, how they func-

tion/operate. How often are these con-trol valves tested?

c) Please advise whether Enbridge hasadvised all municipal emergency ser-vice or fire personnel about the loca-tion of emergency shut off valves.Please also advise under what cir-cumstances or conditions it would be

1.28

a) Please refer to Attachment 1 to NEB IR2.7 (revised) for the location of all mainlinevalves.

There are 51 valves in total between NorthWestover Station and Montreal Terminal. Ofthese valves, 43 are automated and 8 aremanual. All valves in the GTA areautomated.

c) Enbridge meets annually with emergencyresponse personnel and reviews proceduresto be followed in an emergency situation

2.28

a) How many valves are there in Toronto andhow do they relate to major watercourses? Isthere any contemplation of increasing thevalves so that all major watercourses are

protected?

c) Given that Enbridge requests non-Enbridgepersonnel not touch valves in the event thatautomated valves fail, how long with Enbridgestaff take to arrive and what steps should betaken in the interim? Toronto Fire advises thatat the last meeting with Enbridge, there was nomention of valves (numbers, locations, mode of


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appropriate for municipal staff to op-erate this equipment rather than wait-ing for Enbridge personnel to arrive.Please advise what, if any, discussionshave been held with Toronto Fire orother municipal staff regarding thesevalves.

e) Please advise whether Enbridge hasprovided municipalities with specific as opposed to general - emergencyplans to deal with pipeline rupture orspills.

j) Please provide details on the location,type and quality of spill controlequipment/resources that are readilyavailable along Line 9B and the timewithin which these resources could be

mobilized to reach the major water-ways in Toronto. Please advise how orwhether these times are affected byflow rates in these major waterways.Please also advise whether Enbridgehas given any consideration to sitingresources based on population densityaround major waterways.

including expectations of responsepersonnel. During the meetings Enbridgereviews the location of Enbridge facilitieswithin the area of coverage, includingvalves, stations and pipeline locations.

e) In the unlikely event of a release,Enbridge would coordinate closely with all

impacted municipalities and the localemergency responders when developing andexecuting area response plans based on thespecific scenario that had occurred. Nodetailed response plans have been providedto municipalities.

j) Please refer to response to Ontario IR1.45.a for response times and resourcelocations. Both Enbridge and emergencyresponse contractors have response

equipment stored at their base locations.Water way flow rates will not impactresponse time but are considered whendetermining the boom deployment strategyand location.

operation) or of the specific location of thepipeline (the reference was general). How isEnbridge prepared to provide more detailedinformation to Fire Services on these issues?

e) Given the up to 4 hour wait that may beexpected, would Enbridge agree to developresponse plans for training municipalities how

to react in the interim?

To ensure that a spill response is managedeffectively, would Enbridge consider providingmunicipal first responders, on a confidential

basis, an opportunity to become familiar withEnbridge's specific emergency plans in advanceand then have an opportunity to integrateEnbridge's plan into the local operations asappropriate?

j) Does each equipment cache have all therequired equipment to address allcontingencies? Specifically, does the site closestto Toronto (i.e. North Westover) haveexcavation, underflow dam and culvert/weirdam equipment available?


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1.30 Source Water Protection


a) A copy of documentation showingEnbridge's Environmental ProtectionProgram as it relates to water bodiesand crossings and riparian areas.

d) A table listing depth of cover surveysat stream crossings where follow upremediation action is taken andincluding information on the type ofremediation action taken, the rationalefor the specific action and theexpected outcome.

e) Identify the sources and resources thatEnbridge uses to assess erosion and

flood risk on stream crossings.

f) An indication whether Enbridge has"site specific emergency response andspill containment plans" for streamcrossings and whether these plans aretailored to each crossing andconditions at the time, or are generic?

1.30

a) Please refer to response to NEB IR1.10a)a.1 and response to NEB IR1.10a)b.1.d) Please see Attachments 1 and 2 toOntario IR 1.12.b.

e) Please refer to response to TRCA IR 2.e.

f) Enbridge has boom deployment locations(control points) established along all waterways that Line 9B crosses. These control

points are specific to each water way.

Please refer to response to Ontario IR1.44.b.v for Enbridge's EmergencyResponse Plan.

i) Lake Ontario is identified as being a HighConsequence Area. High Consequence Areaanalysis was performed to determine whichsegments of the pipe could potentiallyimpact Lake Ontario via water transport;however time to reach Lake Ontario is notincluded in this analysis.

In the unlikely event of a release, Enbridge

2.30

a) How does Enbridge "ground truth" thedocumented environmental conditions in ismapping?Please explain how "reduced cover depth" isdetermined as referred to in NEB IR 1.10.a)a.1.What remediation actions does Enbridge take?

Please advise of the locations along Line 9 inthe City of Toronto and in proximity to the Cityof Toronto where Enbridge has identifiedincreased susceptibility to exposure during

potential flooding events (other than thelocations identified in 4.4.6.2 River CrossingManagement of the Pipeline IntegrityEngineering Assessment). What are the specificcriteria/metrics that are evaluated to determinewhen remediation should occur (i.e. establishremediation priorities and timelines)? Please

advise the scope and details of any riskassessment that is undertaken to determineremediation priority.

d) The list of crossings cover depths is missingToronto stream crossings; please provide.Furthermore, there was no information includedin "type of remediation action taken". Please

provide.

7/27/2019 Deuxime de

Documents

Deuxième demande d'information de la Ville de Toronto à Enbridge