Susan Casey-Lefkowitz and Anthony Swift
The year 2010 was full of preventable disasters. Better safety regulations could have prevented the Gulf oil spill disaster. They could also have prevented, the nearly one million gallons of tar sands oil that spilled into the Kalamazoo river watershed in Michigan just a few weeks later from an Enbridge pipeline. Enbridge had been issued a warning in January 2010 for not properly monitoring corrosion on that line.
On February 18 the Natural Resources Defense Council, the Sierra Club, the National Wildlife Federation, Plains Justice, Western Organization of Resource Councils, and Dakota Resource Council responded to a request by the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) to identify gaps in pipeline safety regulations. In particular, our comments highlighted areas where stronger pipeline regulations are needed to address risks associated with corrosive tar sands diluted bitumen pipelines, about which we had just recently released a report. Given the fact that pipeline safety regulations are currently undergoing review, the United States should put a hold on decision-making processes around permits for new tar sands pipelines such as TransCanada’s proposed Keystone XL pipeline project that would bring diluted bitumen from Alberta to Texas crossing sensitive regions such as the Ogallala Aquifer and the Nebraska Sandhills. Just this weekend a TransCanada natural gas pipeline exploded in northern Ontario. We have learned this year that our safety should not be entrusted to oil and gas companies, but should be guided by solid safety regulations and government oversight.
Our pipeline safety report shows that increasing volumes of diluted bitumen in the United States creates new risks. Despite claims by the Alberta government to the contrary, diluted bitumen is significantly more corrosive to pipelines systems than conventional crude. The risks of tar sands oil should be thoroughly investigated, as called for in a new pipeline safety bill by Senator Lautenberg, and these risks should be addressed through the development of updated and strengthened standards and regulations.
Specifically, our comments asked for the following regulatory changes:
- Develop stronger internal corrosion regulations to deal with diluted bitumen. Currently, internal corrosion regulations for the vast majority of pipelines simply require that pipeline operators investigate the corrosive effect of their product and take adequate steps to mitigate internal corrosion. This regulation is vague and insufficient. Pipeline regulators should develop new internal corrosion regulations to address the risks of increasing volumes of acidic corrosive diluted bitumen.
- Develop regulations for high temperature product pipelines such as diluted bitumen pipelines. High temperatures increase the risks of chemical corrosion in pipelines and may cause safeguards to fail over time. However, current pipeline regulations do not take this important element into account as they should.
- Increase hazardous liquid pipelines protected by Integrity Management Programs. Currently, only pipelines in so-called “high consequence areas” are required to have additional safety requirements in place. Unfortunately, most areas with hazardous liquid pipelines are not considered high consequence areas. Unprotected areas include ranches, farms, certain suburban neighborhoods, many community water supply areas, open aquifers such as the critical Ogallala aquifer, and habitat for endangered species.
- Allow the public to participate in identifying high consequence areas. Currently, communities along pipeline routes are not told whether an Integrity Management Plan is in place. Regulators should allow the public a say in determining which areas deserve heightened protection.
- Develop leak detection standards that address new risks of diluted bitumen pipelines. Tar sands diluted bitumen presents new challenges to leak detection systems as it often causes false alarms. Investigations suggest that the Kalamazoo diluted bitumen spill in Michigan was initially interpreted to be a false alarm. As a result, the Enbridge pipeline gushed for twelve hours before finally being shut down. New leak detection standards must be developed to address this issue for diluted bitumen pipelines.
- Develop regulations that address increased risks of stress corrosion cracking. As increasing volumes of high sulfur, hot, viscous diluted bitumen travel on the U.S. pipeline system, new standards must be adopted that address increase risk of pipeline failure caused by sulfide stress corrosion cracking.
Perhaps 2011 will be the year that our pipeline safety regulators demonstrate they have the foresight to address these risks before our pipeline system begins to show springing those universally recognized signs of corrosion – leaks. We certainly hope so.