SFU study criticizes Enbridge’s risk assessment for Northern Gateway Project

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Tom Gunton says the risk of oil spills is much greater than Enbridge has predicted

By Alison Roach

A recent study published by Dr. Tom Gunton, director of SFU’s School of Resource and Environmental Management, projects that the number of tanker and pipeline oil spills for the Northern Gateway Pipeline project will be much higher than Enbridge’s own estimates.

The report, which was released May 2, concludes that the chance of a marine tanker spill over the 30 to 50 year life of the project is between 93 and 99 per cent. The $6.5 billion project plans to put a pipeline through northern BC and a marine terminal in Kitimat.

Aside from marine tanker spills, the study also found that the number of pipeline spills along the 1,160 kilometer pipeline would be up to 15 pipeline spills per year, while Enbridge estimated only one spill ever two years.

Using Enbridge’s collected data of pipeline spills from 2002 to 2010, Gunton claims there are 28 deficiencies in Enbridge’s risk assessment model, leading the corporation to underreport the number of tanker incidents by between 38 and 96 per cent.

“The data set on which they relied on is known to underreport the number of accidents and incidents, and they made no correction for that,” said Gunton.

After pinpointing these 28 deficiencies, Gunton then tried to address them by using alternative methodologies, namely the US Oil Spill Risk Model — the standard model used by the US government to assess oil projects. Enbridge has stated they did not use the US assessment model because it doesn’t take technical advancements that mitigate risk into account.

“We used that model to estimate marine oil spill risk, and based on that, the model shows that there is a 95 to 99 per cent chance of a tanker oil spill from the Northern Gateway Project, over the operating life of the project,” explained Gunton. Enbridge has forecasted one tanker spill every 250 years, while Gunton using the US model has forecasted a tanker spill every 7 to 17 years.

The current cost estimate of a major oil spill is between $5 to $22 billion. There is also a cap of $1.2 billion on compensation that’s provided under various programs, meaning that in the case of a major oil spill, the majority of the cost of clean-up and damages would be borne by government and the impacted parties.

Enbridge has declined to accept liability for damages caused by tankers spills and pipeline spills, another issue that concerns Gunton. “People keep asking the question: ‘Well if Enbridge is so convinced that there’s no risk, then why are they unwilling to accept the cost of the damages?’”

In the case of a recent Enbridge pipeline spill in Michigan, the damage costs will exceed a billion dollars. A tanker spill would have much more impact that a pipeline spill.

Enbridge Northern Gateway Pipelines has since responded to Gunton’s study on their website, with a post entitled, “Flawed study, flawed conclusions.” The main concern pointed out about the study is that the information contained in the report was not presented during the Northern Gateway Joint Review Panel (JRP) process, a process that puts potentially environmentally hazardous projects under public process where the panel members receive and consider all the information on record.

However, Gunton says this claim is inaccurate. “We did actually submit much of this evidence to the hearing process over a year and a half ago. It was subject to cross-examination, and Enbridge raised no concerns about this evidence at that time,” said Gunton. He has acted as a witness for the Coastal First Nations organization during the JRP process.

The evidence in the report was updated based on more recently released information, and Gunton stated that it was released as soon as it was completed. This new information will not be admitted to the JRP process, as all evidence was required to be submitted a year and a half ago.

“The JRP is going to be forced to make a decision on this project based on inadequate scientific information on the risk of oil spills,” said Gunton. He also pointed to problems within the Canadian regulatory system for projects such as this as well as this problem in the JRP process for allowing this sort of discrepancy of scientific analysis.

In Canada, the risk assessment for a project such as the Northern Gateway Project is done by the project proponent, in this case, Enbridge. “In the United States this would have been done by independent scientists, who don’t have a potential conflict of interest in promoting the project,” said Gunton. “That’s certainly what we need in Canada.”

John Carruthers, president of Enbridge Northern Gateway Pipelines, has publicly dismissed Gunton’s report, saying that it does not take into account new technologies, and that bodies such as Environment Canada, Transport Canada, the Canadian Coast Guard, and the Department of Fisheries have all reviewed and accepted the Enbridge methodology, according to The Vancouver Sun.

Gunton countered, “The problem is there is no accepted methodology in Canada like the United States. This is the first major project that we’ve looked at that involves major tanker traffic.”

Enbridge says vs. Gunton says

Enbridge: The spill probability numbers are inflated: the author uses oil throughput volumes that are nearly 40 per cent higher than those applied for in this project which also inflates the number of tanker transits using these inflated volumes.

Gunton: We actually used the volume numbers they applied for, provided to us by Enbridge. We do a sensitivity analysis with higher volume numbers, which are that numbers that Enbridge says are the designed capacity of the pipeline. We do the sensitivity analysis with higher numbers, but the basic analysis is using the numbers provided by Enbridge.

Enbridge: The pipeline failure frequency methodology adopted by Mr. Gunton is flawed, and does not approximate what would be deemed a best practices approach to the scientific risk analysis of a modern pipeline system.

Gunton: The US Oil Spill Risk Model was just recently updated and incorporates impact of mitigation measures such as double-hulled tankers and uses of tugs in high risk areas.

Enbridge: Mr. Gunton based his failure frequency analysis on a small subset of historical failure incident data. Why would he limit the source of his data to two pipelines with incidents not reflective of the industry experience and not reflective of the new technology proposed for Northern Gateway?

Gunton: The pipeline statistics we used are based on Enbridge’s pipeline system, which Enbridge says does exhibit best practices, in management best safety practices. It is a relatively new, and what we’re using is Enbridge’s actual performance over the last 10 years, and we’ve seen no improvement. We see no reduction of risk over that period in Enbridge’s own statistics.

Enbridge: We question why Mr. Gunton chose to exclude this report from the JRP process when he has had ample opportunity to submit evidence through his longstanding relationship with registered intervenors Coastal First Nations. He could have also tested our risk assessment evidence through this lengthy, rigorous and transparent process, however, both he and Coastal First Nations chose not to.

Gunton: Much of the information in the report was submitted by us as evidence in the JRP process in December 2011, and was subject to cross-examination by Enbridge in September 2012. The evidence is uncontested. What we did was updated and did more research based on more recent information, and that’s what this report is based on and it was released as soon as we  completed it.

Comments taken directly from the Enbridge Northern Gateway Pipelines website.

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