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The following is the text from a April 5, 2014 letter to the Premier of Ontario relating to the pipeline known as Enbridge Line 9.

20190 Kennedy Road,
Sharon, Ontario
L0G 1V0
Tel: (905) 473-1704

April 5, 2014

Ms. Kathleen Wynne,
Legislative Building,
Queens Park,
Toronto, Ontario
M7A 1A1

Re: Enbridge Line 9

Dear Premier. Wynne:
You are probably aware of Enbridge Line 9, an old buried large diameter oil pipeline that crosses the GTA east-west at approximately the Finch hydro corridor. When this pipeline was originally constructed most of the pipeline route was rural rather than urban as it is today. Further, at the time of original pipeline construction modern fusion bonded epoxy (FBE) pipe coating technology was in its infancy and was not used. These two circumstances have led to Line 9 having both numerous corrosion related cracks and almost no material thickness safety margin. There are devices that can internally scan pipelines for cracks, but unfortunately these devices do not reliably detect external corrosion related cracks adjacent to welds, where many old pipeline dielectric wrap defects actually occur.

Under Ontario safety codes Line 9 would not be approved today at the planned operating pressure, even if the pipe and dielectric coating material were brand new and defect free. Ontario safety codes require a hydraulic pressure test to 150% of maximum approved operating pressure and additional design safety margin at locations where the life safety and/or property damage consequences of a pipeline rupture failure are high. The corresponding federal pipeline code, CSA Z662.1 -11, which primarily applies to rural pipelines with FBE coatings, contemplates a pressure test to 125% of maximum approved operating pressure. CSA Z663.1-11 provides little tolerance for ongoing corrosion in pipelines with pre-FBE pipe wrap and provides negligible extra safety margin at high risk locations.

The National Energy Board has ignored the submissions of Ontario safety authorities and has chosen to apply CSA Z662.1-11 but to EXEMPT Enbridge from any hydraulic pressure test requirement and from any public liability insurance requirement commensurate with the potential risk.

I do not believe that any fully informed arms length insurer is ready, willing and able to take on the full public liability risk related to Line 9 in its present state.

Enbridge has not been frank about its inability to identify all relevant pipe cracks or its inability to adequately deal with a pipeline rupture in the proximity of a high rise development or its failure to conform to its undertakings with respect to oil pipeline safety in Ontario.

In short this pipeline, which is destined to carry Bakken crude (same flammable liquid as destroyed Lac Megantic) is a major uninsured accident waiting to happen during your tenure as premier of Ontario.

In my view Enbridge and the NEB should not be imposing such a risk on the people of Ontario, especially with no compensation.

If this pipeline ruptures in the GTA the direct cost to the government of Ontario of the ensuing loss of life and property could easily exceed $10 billion. Further, due to practical engineering limitations of the GTA potable water and sewer systems, a Line 9 rupture failure could make much of the fresh water in the GTA unsuitable for human consumption for a prolonged period.

For example, if the oil flowed into an underground parking lot or storm sewer catchment the high capacity sump pumps intended for flood prevention would inject the oil into the Toronto storm sewer system at an unprecedented rate. The untreated storm sewer runoff would then flow into Lake Ontario and then find its way into Toronto fresh water intakes. There are various ways that the damage might be mitigated by promptly sacrificing certain major buildings, but by the time the parties with the necessary expert knowledge argued about who would be financially responsible the damage would be irreversible.

I am proud that Ontario government regulatory personnel have stood their ground on this issue, but I am extremely disappointed that your Minister of the Environment, Jim Bradley, has failed to stand behind the Ontario regulatory personnel. Mr. Bradley is avoiding this matter by calling it a federal responsibility. He may be legally correct, but if he fails to intervene and then a Line 9 rupture failure occurs in the GTA you and the Liberal party will be a foot note in history.

I strongly recommend that you use your authority as premier of Ontario to force Enbridge to immediately do all necessary to make this pipeline comply with relevant Ontario safety standards. In addition to improving public safety and reducing cost risk, the consequent pipeline upgrade work would provide immediate and substantial employment.

The simplest interim solution to the Line 9 problem is for you to order a reduction in the pipeline's maximum approved operating pressure to 66% of the hydraulic test pressure that Enbridge is prepared to immediately implement. Such an order would meet the intent of the relevant safety codes and would permit pipeline use at a reduced pressure and hence a reduced flow rate until such time as Enbridge executes the necessary pipeline upgrades.

You have distinguished yourself as a leader on transit issues. You and your party could achieve much more support in the numerous ridings along the Line 9 corridor simply by insisting that Enbridge Line 9 conform to Ontario safety regulations.

Numerous parties, including the City of Toronto and the Province of Ontario, made valid fact and engineering based representations to the NEB regarding the risks and state of deterioration of Line 9 and the failure of Enbridge to comply with pipeline safety undertakings. However, the NEB simply ignored all of these representations. I believe that the NEB is acting under political direction and is presently not performing its safety regulation role. I am in possession of NEB documents which support this belief.

I look forward to your prompt written response with respect to this matter.


Charles Rhodes, P.Eng., Ph.D.
Chief Engineer

This web page last updated June 15, 2014.

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