November 6, 2012;
TransCanada's 57: Variations of the Same Ol' Stuff
All of this talk from TransCanada’s PR people about the numerous “Special Conditions" to which they’ve agreed in order to sell the idea that they are going the extra mile to guarantee the safest pipeline ever built is just that – talk. Back in August of 2011, soon after the release of the SDEIS (Supplemental Draft Environmental Impact Statement) Anthony Swift penned an analysis of the 57 purportedly “special” conditions to which TransCanada had agreed (available at NRDC).
As it turns out, the majority of these so-called “Special Conditions" are nothing but preexisting, basic Pipeline Hazardous Materials Safety Administration (PHMSA) minimum requirements for oil pipelines (Code of Federal Regulations: Title 49 - Subtitle B - Chapter I - Subchapter D - Part 195 – Transportation of Hazardous Liquids by Pipeline.). For the few remaining “Special Conditions" it is difficult to understand why they might fall into any “special” category. Keep in mind, though, that TransCanada’s Keystone XL pipeline is being built to transport something different from conventional crude oil. Instead, it will be carrying diluted tar sands bitumen, for which PHMSA has no specific data or regulations.
From TransCanada’s Keystone XL Pipeline White Paper, the 57 “Special Conditions" are categorized into four areas:
- 1-9; Pipe Design & Manufacturing
- 10-23; System Design, Construction, & Testing
- 24-49; Integrity, Operations, Maintenance, and Monitoring
- 50-57; Reporting, Record Keeping, and Certification.
In the first category, Pipe Design & Manufacturing, only “Special Conditions" 1, 3, and 7 are not necessarily based on existing minimum regulatory requirements for hazardous liquid materials. Number one deals with characteristics of the pipe steel to be used. Specifications delineated are the same as for the pipe steel used in the Keystone I, produced by the Indian company, Welspun, and later found to be flawed. TransCanada says they will continue to use Welspun steel for pipe laid in Texas.
Number 3 is, oddly enough, a basic minimum requirement for gas pipelines, and number 7 deals with puncture resistance to a 65-ton excavator. Again, the remaining six conditions in this first category are based on established minimum requirements.
Eight of the fourteen “Special Conditions" in the second category, System Design, Construction, & Testing, refer to standard minimum requirements or to the use of undamaged or proper parts. The other six would seem to based on normal expectations. Number 10 deals with “coating applied in the field” and that it “must also be applied properly and avoid defects.” (Swift)
While normal oil pipelines don’t reach temperatures of 150 degrees F, condition #15 says that the Keystone XL will not reach this temperature, either, which is a good thing because the flashpoint of the dilbit to be carried through the pipe is 100 degrees F.. Numbers 17 & 19 mandate specifics that were already spelled out in TransCanada’s original permit request, and # 22 requires a minimal upgrade of maximum pressure test duration and level. Number 23 states that “if the pipeline fails a test and does not meet minimum safety standards, TransCanada must investigate the cause of the failure and tell PHMSA about it.” (Swift)
Out of the 26 “Special Conditions" in category 3, Integrity, Operations, Maintenance, and Monitoring, 22 are again based on existing minimum requirement regulations. The four that are not includes number 24, which requires that the Keystone XL have a control room that monitors and controls the pipeline system. This SCADA system is like the one on their Keystone I line and is one that TransCanada already planned to have. It also happens to be very similar to the one that controlled Enbridge’s Line 6B which leaked over one million gallons of diluted tar sands bitumen into the Kalamazoo River.
Number 28 says that this control room’s pressure monitoring system has a model validation plan. Number 32 involves the addition of 2 intermediate valves to the pipeline, and number 38 states that the initial close interval survey should take place within the first year of operation rather than waiting for the minimum two years.
In the 4th and final category half of the eight “Special Conditions" are for existing minimums. The remaining four, numbers 51, 55, 56, and 57, involve reports, recordkeeping of reports, executive sign-off of reports, and in-person explanations of reports to the PHMSA. Of importance to note here is the fact that these reports and any oversight involving assurance that these conditions are met falls squarely on the shoulders of TransCanada – in short, TransCanada will be self-monitoring.
To summarize, 38 of the 57, or fully two-thirds of the so-called “Special Conditions" really are nothing more than specifically addressed minimums that are already in place for conventional oil pipelines. But again, diluted tar sands bitumen is not conventional oil. Of the remaining one-third of the conditions, questions arise as to how they can be considered special or not falling within basic expectations for basic quality work.
Granted, it does sound good to talk about all of these protective safety measures that a company would take on a pipeline such as the Keystone XL. But as one digs a little deeper, one finds that it’s just another sound bite.