Co-authored by Anthony Swift and Susan Casey-Lefkowitz, NRDC
The Alberta Energy Resources Conservation Board (ERCB) statement would have been more relevant had it responded to information in the report released today. Today, ERCB issued a statement that it said was in response to the report Tar Sands Pipeline Safety Risks released on February 16 by the Natural Resources Defense Council, Pipeline Safety Trust, National Wildlife Federation and Sierra Club. However, the ERCB comments refer to information in an earlier version of this information that NRDC produced in December 2010. We hope that after they review the information in the report issued today, we can continue a dialogue with ERCB based on the report’s findings.
The report, Tar Sands Pipeline Safety Risks, shows that by its nature raw tar sands oil or diluted bitumen is more corrosive and more likely to result in pipeline failures. Increasingly, U.S. pipelines are being used to transport diluted bitumen instead of the synthetic crude oil that was already upgraded in Alberta before crossing the border into the United States. The risks of spills from tar sands pipelines are high and U.S. safety regulations are not enough to protect special places such as the Great Lakes, the Nebraska Sandhills and the Ogallala Aquifer. With the proposed Keystone XL tar sands pipeline in the middle of its environmental impact assessment by the U.S. State Department, getting a better understanding of what raw tar sands oil in a pipe means for our environment and safety is more important than ever. There are some simple steps that the U.S. government can take to protect communities from oil spill tragedies. The report spells these out – including the need to put proposed tar sands pipelines such as the Keystone XL project on hold until we can evaluate the need for new U.S. pipeline safety regulations and put a system in place to deal with the special characteristics of raw tar sands oil. We can do better by our communities, our special places and our wildlife.
The lack of transparency from the oil industry is part of the issue here. A clear accounting of the public health and safety issues associated with these products and the infrastructure associated with them is simply not available. The example of Enbridge’s CEO denying tar sands were involved with the Kalamazoo River disaster until pushed by reporters with undeniable evidence is one example of this lack of transparency.
We stand by the information provided in the report – which is well documented and reviewed. To respond to some of the specific points in the ERCB statement:
- In comparing the Alberta and U.S. hazardous liquid system spill rates and incidence of internal corrosion, the report made every effort to make an ‘apples to apples’ comparison. The report only considered spills greater than 26.3 gallons, which are large enough to be tracked by regulators in both the United States and Alberta. While other differences between these lines may contribute to the significant disparity of the Alberta system having sixteen times the rate of spills due to internal corrosion as the U.S. system, this high rate certainly is a warning sign of diluted bitumen’s potential risks to pipeline safety.
- In general, diluted bitumen is not used as a formal category and spills are not reported for “diluted bitumen” pipelines or as “diluted bitumen” spills. This is why the NRDC report looks at the whole hazardous pipeline system which in the United States transports all forms of oil – as it does in Alberta. When the ERCB refers to only a few diluted bitumen spills taking place, they seem to only be including pipelines formally designated as “dedicated diluted bitumen pipelines” as opposed to the many other pipelines that at times carry diluted bitumen.
- Because of ambiguities in reporting, it is more instructive to assess the entire Alberta hazardous liquid system. It is difficult if not impossible to determine the petroleum blend in any given spill in Alberta. However, in 2010, sixty-nine percent of the crude oil produced in Alberta was shipped in pipelines as diluted bitumen to Canadian upgrading facilities or to refineries in the United States.
- The ERCB statement claims that mixing diluents with bitumen makes a mixture that “more closely resembles conventional crude.” However, this mixture still contains bitumen. Even diluted, bitumen retains its characteristics as documented in the NRDC report. Mixing a very light molecule with a very heavy molecule does not create two medium sized molecules. Also, once escaped from the pipeline in the form of a leak, the natural gas liquid condensate used to dilute the bitumen separates from the bitumen – leaving the unadulterated bitumen for clean up, as well as the additional problems from the hazardous nature of natural gas liquid condensate.
- Diluted bitumen has five to ten times higher concentrations of sulfur than benchmark crudes. During the upgrading process, sulfur is removed as raw bitumen is converted to synthetic crude oil which does more closely resemble conventional crudes. However, in the case of diluted bitumen the sulfur is still very much present.