1 Dec 2016
National Energy Board
I am writing for the WaterWealth Project. WaterWealth is a community group working for protection of freshwater in BC and was an intervenor in the recent hearing on the proposed Trans Mountain Expansion Project. Information acquired during that process very much heightened our concern about the ageing Trans Mountain pipeline that is in operation now.
I am told that you were one of the National Energy Board representatives at a meeting recently coordinated by Lynn Perrin of the PIPE UP Network regarding the currently operating Trans Mountain pipeline. I regret that I was unable to attend that meeting, but hope that you might be able to help with some concern about that old pipeline now.
As you are no doubt aware, the existing Trans Mountain pipeline runs across the Sardis-Vedder Aquifer within capture zones of City of Chilliwack wells and then crosses the Vedder River close to the Vedder Mountain Fault and just above Yarrow Waterworks wells which are in the same aquifer, next to the river. Understandably, residents of Chilliwack and Yarrow have an interest in the integrity of that old pipeline.
In 2012 the NEB ordered Kinder Morgan to conduct inline inspections (ILI) of the Trans Mountain Mainline. That work was under way when the two leaks on the pipeline were discovered in June of 2013. ILI tools had missed those leaks. They were discovered by people on the ground. Following the discovery of the leaks the NEB ordered Kinder Morgan to reduce the operating pressure of the Trans Mountain system.
In a document EA-TM-2014-004 (attached) dated 14 March 2014 Kinder Morgan sought to lift the pressure restriction on the Hargreaves to Darfield section of the system, a section 274 kilometres long. On the sixth page of that document Kinder Morgan state that the ILI assessment of the Mainline will be “completed by the end of 2014”. Kinder Morgan also stated that following the discovery of the two 2013 leaks they asked their ILI vendors to re-analyze all of their data. As shown on a table on that page, the ILI analysis identified 119 features that met Kinder Morgan’s dig criteria in that Darfield to Hargreaves section. Averaged over those 274 km that gives one feature requiring excavation every 2.3 km.
I was among a group of Chilliwack residents who went to see the spill sites in 2013. We had heard that there had been two spills so went expecting to see two excavations for repairs. To our surprise we found many excavations and repairs to the pipeline in roughly seven km of the route that we hiked.
In response to a question in WaterWealth’s information request #2 in the NEB hearing on the expansion project Kinder Morgan said that the ILI work on the old line had been delayed by unavailability of one of the tools and that the inspections would be completed and a final report submitted to the NEB “by the end of 2015.”
If the Hargreaves to Darfield section was typical that would suggest that six features meeting Kinder Morgan’s dig criteria could be expected over the Sardis-Vedder Aquifer that is the sole source of water for the City of Chilliwack and for Yarrow Waterworks. I regret that I did not count excavations when we hiked the Coquihalla Canyon after the 2013 spills, but I think that what we saw there was a similar frequency of digs, if not greater. Yet while we have seen excavations on the pipeline from the area of those 2013 spills to as far west as about five km east of Bridal Falls, and know from the document regarding the Darfield to Hargreaves section that many more digs occurred in at least that section to the east, we have seen none across Chilliwack. None where the pipeline lies over the aquifer.
It seems unlikely that the pipeline would be in better condition across Chilliwack to the degree that no digs would be required here. But then how to explain the absence of excavations here in the year (approximately) since the ILI testing was expected to be completed? I am hoping that you could provide us with a copy of the ILI report that Kinder Morgan said would be submitted to the NEB by the end of 2015, so that residents can see those ILI results and assure themselves as to the safety of the water supply we rely on and drink from daily.
The WaterWealth Project