Kinder Morgan Realignment IR#1

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Kinder Morgan has applied for a small route change in Chilliwack to their Trans Mountain Expansion Project. The route change, if approved, would move the pipeline out of a BC Hydro right-of-way to instead cross Watson Elementary School and run through back yards of residential neighbourhoods. The change would also move the pipeline closer to City of Chilliwack drinking water wells.

WaterWealth is an intervenor in the NEB hearing for the route change. We oppose the route change, primarily for the added risk to children attending Watson Elementary School and to our community's drinking water supply.

What follows is our Information Request #1 to Trans Mountain on the proposed route change. (Formatted to appear similar to the original document)

[Update: The City did a very thorough information request. It is not available on the NEB website yet, but a pdf copy is here. One note, there is mention in it of "two pipeline leaks in 2013 in the Sardis-Vedder Aquifer area." That is in error. The 2013 leaks were near the Coquihalla Summit (one at the summit and one about 40 km east). An easy error to make as the document referred to in that part of the City's IR is largely about the aquifer and the context of the mention of the two spills is not immediately apparent if one does not know what "Kingsvale North and KP966" refer to.]


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"Our Wealth is in Our Water – Let’s Protect It"

23 October 2017

Mr. D. Scott Stoness
Vice President, Regulatory and Finance
Kinder Morgan Canada Inc.
Suite 2700, 300 – 5th Ave SW
Calgary, AB T2P 5J2
Mr. Shawn H. T. Denstedt, Q.C. /
Ms. Terri-Lee V. Oleniuk
Osler, Hoskin & Harcourt LLP
Suite 2500, 450 – 1st Street SW
Calgary, AB T2P 5H1
Ms. Sheri Young,
Secretary of the Board
National Energy Board
Suite 210, 517 Tenth Ave SW
Calgary, AB T2R 0A8

 

Re:     File Number OF-Fac-Oil-T260-2013-03 13
  Trans Mountain Expansion Project (TMEP)
  Chilliwack BC Hydro Route Realignment (Realignment)
  Hearing Order OH-001-2017
  Information Request from The WaterWealth Project

In their Realignment application Trans Mountain propose to move the route of a small portion of the TMEP in Chilliwack out of a BC Hydro right-of-way to instead cross Watson Elementary School and run through residential neighbourhoods on an alignment that would put the new pipeline even closer to four City of Chilliwack drinking water wells that are already at risk even without the Realignment.

Relative to the BC Hydro right-of-way the Realignment route would increase the risks imposed on children attending Watson Elementary School and the security of our community’s drinking water supply. The WaterWealth Project (WaterWealth) is opposed to the Realignment requested by Trans Mountain.

However it must be understood that neither of the routes that are the subject of this hearing are acceptable. The TMEP route lies across Chilliwack for approximately 26 kilometres of which 13.5 kilometres is over the Sardis-Vedder Aquifer that supplies drinking water for Chilliwack including Yarrow. The route also crosses some of the most ecologically sensitive areas of our community, and areas of exceptional recreational value. Whatever the outcome of this hearing, which focuses on less than 2 kilometres of the proposed route, the issues that prompted over 200 Chilliwack residents to file statements of opposition to the TMEP route will remain unresolved. We look forward to announcement of detailed route hearings at which the concerns of our community will be heard.

Sincerely,
[Original signed by]
Ian Stephen
Program Director
The WaterWealth Project

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"Our Wealth is in Our Water – Let’s Protect It"

 

1.1 Leak Detection

References:

i.   Hearing OH-001-2014, Trans Mountain Response to Province of B.C. Information Request #2, Filing ID B316-34

Preamble:

In reference (i), response 2.15 (b) says that “For proposed Line 2, threshold sensitivities in the range of 2% to 5% are expected from both the API 1149 calculations and the in-service testing.”

Request:

a)   Have the threshold sensitivities been refined since, or is the range 2% to 5% still expected?
b) Please describe industry best practices for detection of leaks below the threshold of detection of the computational pipeline monitoring system.

1.2 Pipeline Construction

References:

i.   Trans Mountain Chilliwack BC Hydro Reroute Application Document Filing ID A82269-2
ii. Trans Mountain Groundwater Management Plan, June 2017 Rev 1, Filing ID A84106-26

Preamble:

Paragraph 33 of reference (i) includes “Trans Mountain recognizes the Sardis-Vedder aquifer is a very important resource and is an unconfined aquifer and therefore has proposed the use of heavy wall pipe 14.7 mm wall thickness over the aquifer”.

Paragraph 37 of reference (i) includes “The mitigation includes the use of heavy wall pipe 14.7 mm wall thickness over the aquifer”.

Request:

a)   Please confirm that pipe of 14.7 mm wall thickness will be used over the aquifer, which Appendix B of reference (ii) describes as extending from KP 1091.6 to KP 1105.5.
b) If not confirmed, please identify which portion of the pipeline will include heavy wall pipe 14.7 mm wall thickness for protection of the Sardi-Vedder (aka Vedder River Fan) Aquifer.

 

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"Our Wealth is in Our Water – Let’s Protect It"

 

1.3 Pipeline Location

References:

i.   Letter from Chilliwack Mayor Sharon Gaetz to the National Energy Board dated August 14 2017, Filing ID A85446-1
ii. Hearing OH-001-2014, Trans Mountain Response to Province of B.C. Information Request #2, Filing ID B316-34
iii Trans Mountain Chilliwack BC Hydro Reroute Application Document Filing ID A82269-15
iv. Trans Mountain Chilliwack BC Hydro Reroute Application Document Filing ID A82269-2
v. Trans Mountain Chilliwack BC Hydro Reroute Application Document Filing ID A82269-4
vi. Trans Mountain Chilliwack BC Hydro Reroute Application Document Filing ID A82269-14

Preamble:

Reference (i) reads in the fifth paragraph on page 2 that “The firm of Golder & Associates is currently completing the Sardis-Vedder Aquifer Groundwater Model Update Study. The preliminary study results indicate that well pumping influences the ground water table to a distance of 450m from the well head.”

Reference (ii) responses to Province of British Columbia IR 2.10a and IR 2.10b refer to “AMEC Earth and Environmental. 2007. City of Chilliwack Sardis Aquifer 60-Day Capture Zone Figure 1.” to assert that “local well capture does not extend as far as the [then] proposed pipeline corridor.”

Reference (iii) PDF page 30 shows a table of property impacts that indicates “P2 -- TMPL Corridor” having 47 homes within 20 m of pipe centreline while “P1 -- Revised Hydro” has only 44. The document that table is from was dated October 28, 2015.

Paragraph 28 of reference (iv.) includes “BC Hydro notified Trans Mountain in a letter dated November 10, 2016 letter (Appendix B), the closest distance acceptable would be 12 m from their southern outside conductor.” (emphasis added)

The letter in reference (v.) second paragraph, last sentence reads “The permissible minimum horizontal distance was calculated to be 12m to the closest foundation of a BC Hydro transmission tower in the studied Chilliwack Corridor.” (emphasis added)

The final sentence of reference (v.) reads “Due to the above concerns, the proposal to install the new Trans Mountain pipeline closer than 12m horizontal distance to tower foundations of BC Hydro circuit 2L078 in Chilliwack is not acceptable to BC Hydro.” (emphasis added)

It is also noted that in reference (vi.) maps shown in the City of Chilliwack Routing Update December 14, 2016 [so later than the November 10 2016 BC Hydro letter, reference (v.)] also refer to BC Hydro conductors on P1 and P1 Alternate maps. Page 9 of the Routing Update [PDF page 55 of reference (vi.)] includes “November 10, 2016: BC Hydro letter stipulated a minimum offset requirement of 12m” but it does not say offset from where. Page 10 of the Routing Update [PDF page 56 of reference (vi.)] includes reference to a BC Hydro conductor at “P1 Alternate (8.0m offset from BC Hydro 230kV conductor)”

 

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"Our Wealth is in Our Water – Let’s Protect It"

 

Request:

a)   Given the discrepencies in well capture zone extents between reference (i) and reference (ii), please provide copies of the latest groundwater information in Trans Mountain’s possession for the area that is subject of the Realignment application.
b) Is it correct now that the Realignment would place the TMEP within 20 m of more houses than would the BC Hydro route option?
c) Please confirm that other measurements used in Trans Mountain’s evaluation of the BC Hydro route alignment and in the Realignment application in relation to the BC Hydro alignment option, such as distances to houses, were based on placing the pipeline 12m from tower foundations and not 12m from BC Hydro’s southern outside conductor. Provide sufficient documents such as survey notes to confirm that field measurements were correct.
d) If not confirmed, please reeveluate the BC Hydro route option and provide updated copies of documents affected by the error. Also please ensure that those with interests in the area such as the City of Chilliwack, Stó:lō First Nations, and area residents are informed of the error and provided updated documents.
e) Please confirm that communications in meetings with the City of Chilliwack and City of Chilliwack Technical Working Group provided information to the City based on correct distances from BC Hydro tower foundations and not incorrect distances based on measurements from BC
Hydro conductors.
f) If not confirmed, please confirm that the City and City TWG have been informed of the error and provided updated information.

1.4 Maintenance

References:

i.   Kinder Morgan Canada Baseline Assessment for Time Dependent Cracking, Trans Mountain Pipeline System Pre-70’s Pipe, Final Report Jan. 2016
ii. National Energy Board website, Trans Mountain ULC, Notification of Operation and Maintenance Activities https://apps.neb-one.gc.ca/REGDOCS/Item/View/552813

Preamble:

Reference (i) on PDF page 27, indicates 185 digs completed out of 845 features detected in the baseline assessment. Since that report was filed in January 2016, records on the NEB website [reference (ii)] show 89 notifications of operations and maintenance activities. Clearly integrity digs are on-going. It seems possible integrity digs could be a factor decisions relating to the the Realignment corridor.

Request:

a)   Are any integrity digs pending on the existing Trans Mountain pipeline in the area of the Realignment? If so please provide details.

 

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