Accufacts Inc.

Clear Knowledge in the Over Information Age

4643 192nd Dr. NE

Redmond, WA 98074
Ph (425) 836-4041
Fax (425) 836-1982
kuprewicz@comcast.net

Date: April 24, 2015

To:

Mr. Gatlin Smeijers

Gowlings Lafleur Henderson LLP
550 Burrard Street, Suite 2300, Bentall 5
Vancouver, BC
V6C 2B5 Canada

Re: Accufacts Report to First Nations on the Trans Mountain Expansion Project
(TMEP)
1. Introduction.
Accufacts Inc. (Accufacts) was asked to assist the Shxwowhamel First Nation and the
Peters Band, together collectively referred to as the First Nations, in evaluating certain
aspects of the Trans Mountain ULC (Trans Mountain) proposal to expand their existing
pipeline system across the First Nations lands and interests, where a pipeline release could
have serious consequences. In the segments that could affect the First Nations interests, the
proposed project will consist of:
Line 1 - a 24-inch existing pipeline installed in 1953 that will increase capacity from
300,000 bpd to an annual average of 350,000 bpd. Modifications will permit
batching refined and light crude oils but will also be designed to transport heavy
crude oil at a reduced rate. This additional flexibility will occur mainly through
pump station additions/modifications increasing operating pressure on the existing
pipeline. The Line 1 segment is bracketed by the upstream Hope and downstream
Wahleach pump stations.
Line 2 - a new 36-inch diameter pipeline capable of moving an annual average of
540,000 bpd of heavy crude, but will also be designed to transport light crude oils
as well if necessary. In the area of the First Nations reserves, Line 2 may take a
slightly different right-of-way (ROW) given that the final new pipeline ROW
has not been finalized. In addition, the larger diameter Line 2 segment traversing
the First Nations is bracketed by the upstream Kingsvale and downstream
Accufacts Inc.

Page 1 of 12

Westridge pump stations that span a much greater pipeline segment than that for
Line 1. 1
For this analysis, though the First Nations may be impacted by the TMEP elsewhere in their
Traditional Territories, Accufacts scope for this study was limited to the First Nations
reserves. For this review, Accufacts has assumed that the above pipeline segments that may
impact the First Nations reserves lie approximately between kiloposts (KPs) 1000 and
1065, although there appears to be some slight differences as expected between the Line 1
and Line 2 kilopost indications.2 These kilopost ranges should be considered, however, the
general area of concern in relation to the First Nations reserves and may be subject to some
slight adjustment.
Accufacts was asked to provide an independent review of the proposed pipeline(s) integrity
management, operation and maintenance approaches, and oil spill prevention and response
measures based on information for the proposed project submitted to date to the National
Energy Board, or NEB.
2. Major Pipeline Integrity Management Concerns.
Accufacts has reviewed various documents related to Trans Mountains integrity
management and risk assessment approaches and finds numerous statements indicating the
approaches are incomplete and deficient as to the possible major threat categories that could
affect the pipelines and impact the First Nations.
2a) Manufacturing Threat Assessments for Line 1 Vintage Pipe are Incomplete.
The 24-inch pipeline was manufactured in 1952 and become operational in 1953 based
on information from threat assessments for other 24-inch pipeline segments on this
system.3 It is recommended that Trans Mountain identify the 24-inch pipeline segment
crossing, or that could impact, the First Nations as to its:
1. pipe grade,
1

Capacities in the NEB filing are stated in annual capacities, so actual daily throughputs will be
much higher, depending on the barrels per stream day and barrels per calendar day conversion
factor for each pipeline. Heavy crude is often used to convey that dilbit, or diluted bitumen.
will be shipped on the pipelines.
2
Trans Mountain, 007 Technical Updates No 1 and Consultation Update No 2 Part 2 Risk
Update Exhibit 248.pdf, Overland and Stream Flow Modeling of Potential Full-Bore Rupture
Releases, Scale 1:25,000, pp. 99 & 100 of 111, July 25, 2014.
3
Trans Mountain Response to GoC Parks IR No. 2, page 438 of 467.
Accufacts Inc.
Page 2 of 12

2. pipe wall thickness,

3. the manufacturer,
4. the pipe type (e.g., Low Frequency Electric Welded, or LF ERW, Flash Welded,
or FW, seamless, Single Submerged Arc Welded, or SSAW, and Double
Submerged Arc Welded, or DSAW, etc.),
5. maximum operating pressure (MOP),
6. whether the pipeline operator still has the original mill certifications,
7. key parameters associated with the last performed hydrostatic pressure test,
8. the hydrotest results in psig and percent specified minimum yield strength, or
%SMYS,
9. and the pipes coating.
Depending on this information, pipe of this vintage can contain manufacturing threats
related to a family of cracking that cannot be reliably assessed via inline inspection
(ILI) tools and their associated engineering assessments, but that can quickly and
unpredictably grow to failure at pressures well below MOP, especially on pipelines
moving diluted bitumen, or dilbit. This has become obvious in the U.S. where such
vintage pipe containing such manufacturing threats tends to fail due to rupture, large hole
pipe fractures, releasing significant volumes and high rates of oil, especially on pipe
changing its service or product transported.4
2b) Slope threats that could affect the pipeline(s) impacting the First Nations have not
been properly identified or analyzed.
A category of possible threats that could affect either Line 1 or Line 2 possibly impacting
the First Nations does not appear to have been clearly addressed. Based on the Line 2
elevation profile submitted with the filings to the NEB indicating a pipeline elevation
change of about 4,000 feet in approximately 50 kilometers, the First Nations are in the
impact zone of a very unique steep downhill sloping terrain if a pipeline release should
occur.5
Trans Mountain needs to confirm the elevation profiles and slope stability for both the
Line 1 and the Line 2 capturing this steep terrain to assure that neither line has been
located in a site of steep unstable slope that can result in a landslide or other abnormal
4

PHMSA Advisory Bulletin, ADB-2014-04, Pipeline Safety: Guidance for Pipeline Flow
Reversals, Product Changes and Conversion to Service Docket No. PHMSA-2014-0040,
September 18, 2014.
5
Trans Mountain, 007 Technical Updates No 1 and Consultation Update No 2 Risk Update
Exhibit 248.pdf, Outflow Volumes Kingsvale to Burnaby indicating elevation profile, Volume
7 Appendix B 12 not dated but indicates for May 2014 Route.
Accufacts Inc.
Page 3 of 12

loading situations that could threaten the pipelines. Steep slope areas that contain or may
contain pipelines need to be carefully reviewed for possible failure because of factors
such as heavy rainfall or water diversion that could cause sudden breakaway landslides or
other abnormal loading forces on the pipeline(s) that can cause rupture. No pipeline can
be designed to sustain such severe loading forces from associated massive landslide.
Pipelines in steep sensitive areas where such abnormal loading conditions can exist need
to be rerouted out of the area.
3. Operational and Maintenance Approaches Do Not Adequately Capture the Risks to the
First Nations from the TMEP.
Accufacts has reviewed various documents supplied to the NEB concerning TMEP. There
appears to be too many documents submitted in this NEB application related to the operation
and maintenance practices that lack critically important details or specificity, leaving parties
to have to guess or assume what information is relevant and what practices will actually be
utilized to effectively address very real threats. Accufacts has identified several areas of
importance that appear to be critical gaps in the application in the areas of integrity
management, risk assessment, siting, leak detection and oil spill response. Trans Mountain
needs to supply additional information to assure the TMEP will not negatively impact the
First Nations.6
3a) Baseline and subsequent reassessment information should already be available for
the Line 1 pipeline segment.
TMEP is proposing to make serious major changes to the operation of Line 1 that
necessitate increasing operating pressure to increase throughput. As an existing pipeline,
Trans Mountain should have already completed Line 1 base line, subsequent
reassessments and related integrity management responses for Line 1. Trans Mountain
should be compelled to produce the results of the baseline, reassessments, and related
integrity management responses for the current 24inch pipeline. Such critically
important details will help identify whether Trans Mountain has a complete and adequate
risk identification and mitigation program for this 24-inch pipeline. Given:
1. the vintage and type of pipe identified in Line 1,
2. indications of many previous hydrostatic pressure test failures on Line 1,

Trans Mountain Expansion Project, An Application Pursuant to Section 52 of the National

Energy Board Act, Volume 4c, Project Design & Execution Operations & Maintenance,
December 2013.
Accufacts Inc.
Page 4 of 12

3. the comment that the number and causes of the hydrostatic test failures is not
well documented,7
4. a PHMSA Advisory Bulleting issued for certain vintage pipelines that are prone
to cracking rupture failure that ILI inspection and engineering assessment are not
currently capable of reliably evaluating,8
5. the recent issuance of a report regarding Pre-Regulation Pipelines and cracking
risks,9 and
6. the lack of more detailed information in the TEMP Engineering Assessment,
Accufacts believes the Line 1 pipeline is at much greater risk of rupture from the new
operation than the optimistic integrity management forecast in the submissions to the
NEB.10
3b) ILI technology cannot reliably ascertain certain rupture threats to both the Line
1/Line2 segments that could affect the First Nations.
Trans Mountains integrity management program is predicated on ILI technology and
appears to be overstating this assessment approachs capabilities. This is a common
problem that Accufacts has observed following too many recent pipeline rupture
investigations such as the Enbridge Line 6B Marshall, MI and ExxonMobil Pegasus
Pipeline Mayflower, AR ruptures related to cracking threats that were missed or poorly
evaluated. ILI technology is not currently capable of identifying or remediating the most
likely threats which can lead to rupture failure on the segments that could impact the First
Nations such as manufacturing related cracking or landslide threats that could cause a
rupture. No ILI technology and associated assessment can reliably determine/evaluate
either manufacturing crack threats on Line 1, nor unstable slope threats that may be
possible on both Line 1 and Line 2 pipeline segments. For example engineering
assessments associated with at-risk early vintage manufacturing pipeline steel containing
low toughness make associated engineering assessment related to this type of ILI
assessment method highly unpredictable and unreliable on time to failure estimates.

TMEP, Engineering Assessment, August, 2014, p. 15. B259-4__TMEP_Engineering_Assessment3Active_NPS_24-NPS_30_in_Line1_Service_-_A4A7Q3.pdf

8
PHMSA Advisory Bulletin, ADB-2014-04, Pipeline Safety: Guidance for Pipeline Flow
Reversals, Product Changes and Conversion to Service Docket No. PHMSA-2014-0040,
September 18, 2014.
9
J.F. Kiefner and M. Van Auker, Final Report Repair/Replace Consideration for Pre-Regulation
Pipelines, PHMSA Final Report No. 15-019, March 11, 2015.
10
TMEP, Engineering Assessment, August, 2014, pp. 14 17. B259-4__TMEP_Engineering_Assessment3Active_NPS_24-NPS_30_in_Line1_Service_-_A4A7Q3.pdf
Accufacts Inc.
Page 5 of 12

It is Trans Mountains responsibility to provide sufficient information to prove that these

specific threats will not lead to pipeline rupture. Trans Mountain needs to explain in
further detail how vintage manufacturing threats will be assessed and addressed on the
existing Line 1, and how both the Line 1 and Line 2 segments will be protected from
unstable slopes that can result in pipeline rupture from sudden breakaway abnormal
loading associated with landslide. Accufacts further advises that the movement of dilbit
on Line 1 may initiate and accelerate vintage manufacturing crack growth rates in a
highly unpredictable manner. Given the information reviewed to date, Accufacts must
conclude that Trans Mountains application is incomplete and does not properly assess,
nor prudently deal with, threats to the First Nations.
In addition, it is worth noting that the risk assessment performed for the project has
indicated that: Rather than managing the prioritization of assessments for stress
corrosion cracking (SCC) and material defects through a risk assessment, Trans Mountain
has made a decision to perform in-line inspections to address these two threats along the
entire length of TMPL. This inspection is currently scheduled for completion by 2015.11
This document goes on to state, Geohazard failure frequency estimates are not provided
in the risk assessment results, since geohazards for TMPL are being managed through the
Natural Hazards Management Program.12, 13 Thus the two most likely threat risks facing
the First Nations from this project, especially the existing Line 1, are either not detailed
in the risk assessments, or else they rely on ILI technology that is questionable, especially
for cracking threats such as those associated with earlier vintage manufacturing processes
and their associated possible rupture failure mechanisms. Trans Mountain should be
compelled to specifically address whether landslide or other abnormal loading threats
exist on both TMEP pipelines in the area of approximately KP 1000 to KP 1060, and if
so, define TMEPs solution to mitigate or eliminate this risk (usually through rerouting of
pipeline out of the risk area).
3c) Leak detection capabilities via SCADA are being overstated.14
The SCADA leak detection system will be incapable of timely identifying a pipeline
rupture in the pipeline segments that could affect the First Nations because of slack line
11

Dynamic Risk, Trans Mountain Pipeline (TMPL) Risk Results, Volume 8, Technical Update
No 2 Part 6.2 Risk Results Report Exhibit B255.pdf, August 11, 2014, section 4.
12
Ibid.
13
Trans Mountain Response to NEB IR No. 3., Section 3.097 Natural Hazards Management
Program, pages 481 493.
14
Trans Mountain Expansion Project, An Application Pursuant to Section 52 of the National
Energy Board Act, Volume 4c, Project Design & Execution Operations & Maintenance,
December 2013, Section 7.
Accufacts Inc.
Page 6 of 12

operation that complicates rupture identification.15 Trans Mountains response to a

previous NEB IR request concerning slack line or column separation, in which the
pipelines are not operated liquid full, indicates that there will be potential for both Line 1
and Line 2 to operate in slack line downstream of the Coquihalia summit.16 Such
nonliquid full operation creates more noise that generates false leak alarms in leak
detection systems that can seriously delay timely SCADA identification of a pipeline
release, even rupture by remote leak detection systems.17 I must indicate, that from Trans
Mountains responses, they clearly understand the importance of maintaining a liquid full
operation to assist leak detection if possible. They also appear to be sincere in their
response as to the inability of installing a back-pressure regulator to prevent Line 1 from
operating in slack line on the segment that could affect the First Nations. Ironically,
Accufacts believes Line 1 is likely at greater risk to pipeline rupture in this segment.
Since the First Nations segments are downstream of the Hope pump station, a possible
backpressure control station, Trans Mountain should confirm whether final design will
incorporate slack line operation in either line downstream of the Coquihalia summit.
While slack line substantially complicates and delays prompt rupture detection, even a
non-slackline or liquid full operation is no assurance that a pipeline rupture will be
determined in a timely manner via SCADA, especially for systems that change or batch
many different oils. Accufacts has an obligation to comment that the nature of the
submissions provided in the leak detection section of the System Operations, Control, and
Leak Detection Project Design and Execution Volume, and associated control room
organization and procedures, resemble the processes and rules that were in place during
the Marshall, MI Enbridge Line 6B pipeline rupture which released dilbit from a pipeline
rupture for more than 17 hours. Leak detection systems, and mass balance analysis
approaches operating in slack line, especially if they generate too many false leak
detection alarms, can be very ineffective, and set up control room operators for failure to
not recognize a true pipeline rupture. On many pipelines slack line indications looks very
similar to rupture signals.
4) Risk Results Fail to Adequately Address the Segments True Pipeline Risks That Could
Affect the First Nations.18
15

SCADA stands for Supervisory Control and Data Acquisition, a computer system that helps
remotely monitor and operate the pipelines, usually from a centralized control center manned by
control center personnel 24/7.
16
B306-2_-_Trans_Mountain_Response_toNEB_IR_No_3_-_A4H1V2.pdf, Trans Mountain
Response to NEB IR No. 3, page 362 of 525.
17
Trans Mountain Response to Farquhar T IR No. 3, pages 3 - 5 of 23.
18
Dynamic Risk, Trans Mountain Pipeline (TMPL) Risk Results, Volume 8, Technical Update
No 2 Part 6.2 Risk Results Report Exhibit B255.pdf, August 11, 2014.
Accufacts Inc.
Page 7 of 12

4a) Steep slopes are critical rupture risks for Line 1 and Line 2.
The First Nations are in areas of high geohazards. Accufacts has independently
concluded that for the new Line 2 36-inch pipeline that could affect the First Nations,
natural hazards (geohazards) represent the highest risk to rupture failure.19 Sufficient
information has not been provided that demonstrates that the very steep slopes for the
Line 1 and Line 2 proposal that could affect the First Nations will not result in pipeline
rupture. More detailed information as to slope stability and other abnormal loading
threats from approximately KP 1000 to 1060 are warranted to assure a prudent route has
been selected. Just following the Line 1 segment in this general area may be unwise and
inject unwarranted risks.
4b)The risk assessment approaches based on history are inappropriate.
Risk assessment or risk management approaches that overly rely on historical databases
do not reflect the future operational risk of a specific pipeline in a specific location.
While one needs to look at historical failures to help identify the type of threats that steel
transmission pipeline might experience, the exact threats on a particular pipeline are
pipeline segment specific. Pipeline risk assessments need to include location threat
issues that may significantly increase the likelihood of failure, especially rupture.
History has demonstrated that the true cause of a pipeline failure in past database files
may not be complete, and can be very inaccurate as to the failures true cause. For
example, while improvements have been made in the past decade in reporting pipeline
incident data to the Pipeline and Hazardous Material Safety Administration (PHMSA)
the U.S. federal agency charged with the jurisdiction of pipeline safety there is no real
penalty for introducing incomplete, false, or misleading information into the PHMSA
reporting databases. PHMSA is not even allowed to correct such misinformation. The
fact of the matter is that government pipeline accident databases are not auditable by
an independent party to assure completeness or accuracy. Historical databases must be
used with caution when trying to determine threat risks to a particular pipeline.
5) Oil Spill Outflow Modeling Is Not Conservative and Seriously Understate Potential Oil
Release Volumes.

19

Dynamic Risk, Trans Mountain Expansion Project, Preliminary Risk Results for TMEP Line
2 and New Delivery Lines, (Technical Update No. 1 and Consultation Update No. 2 Part 2 Risk
Update Exhibit248.pdf), Section 4 Overview of Preliminary Results for Line 2. No page
numbers, July 24, 2014.
Accufacts Inc.
Page 8 of 12

5a) The 10 minute time used for determining release before pump shutdown (i.e.,
Shutdown Volume) is arbitrary and unrealistic.
An Accufacts detailed review of the Outflow Modeling for the segments of pipeline that
could affect the First Nations leads to a conclusion that the modeling seriously
underrepresents the potential oil releases associated with rupture. The modeling assumes
that a control center operator will immediately recognize a rupture event, but A time
interval of ten minutes has been used for the release prior to pump shut-down.20 History
is replete with liquid pipeline ruptures where trained and experienced control center
operators failed to promptly recognize such a rupture event for various reasons, and the
time to finally recognize a rupture via SCADA, if ever, was well beyond the arbitrary 10
minutes utilized in the Line 2 oil spill volume modeling. In fact, Accufacts after
investigating many pipeline ruptures spanning almost 40 years, cannot identify any
pipeline rupture where the rupture was properly identified by control room operators
within 10 minutes.
A recent example of delayed rupture recognition would be the Marshall, MI Enbridge
Line 6B pipeline rupture where, over three different 12-hour control room shifts and four
levels of pipeline operations management, the control center failed to properly shut down
and isolate the pipeline, even proceeding through two pipeline restart attempts, increasing
oil released out the rupture. This lengthy rupture release event occurred despite having a
10 minute shutdown rule imposed after a previous rupture on another Enbridge system,
requiring that a pipeline be shut down within 10 minutes.21 Ten minutes can pass very
quickly in a complex control room where many alarms are being activated, especially on
a pipeline moving batches of different oils and operating in slack line conditions that add
considerably to confusion and complexity in monitoring the system.
5b) Pump shutdown oil spill estimates should include sensitivity cases in half hour
increments.
While even a half hour may not be long enough to take appropriate action, especially if a
pipeline is operating in a sparsely populated remote area where field identification and
notification to the control center may not occur quickly, a one-half hour sensitivity case
will suggest the more likely Shutdown Volumes associated with pipeline rupture that will

20

Trans Mountain, B18-1 V7_1.0_TO_5.2.8.3_RISK_ASSESS_MGMT_SPILLS

A3S4V5.pdf, Section 3.1.6 Oil Spill Modeling, page 7-16.
21
National Transportation Safety Board, NTSB, Enbridge Incorporated Hazardous Liquid
Pipeline Rupture and Release Marshall, MI July 25, 2010, NTSB/PAR-12/01, adopted July 10,
2012.
Accufacts Inc.
Page 9 of 12

be much higher than current estimates. To be consistent, spill volumes should be given
in barrels as well as cubic meters.
5c) Oil spill volumes appear to underestimate potential releases by at least an order of
magnitude.
Based on Accufacts experience, a review of the highly challenging elevation profiles,
indicated valving, and control room actual expected reaction time, the reported outflow
volumes that could affect the First Nations appear to be low by at least one order of
magnitude (2,500 M3 is more likely 25,000 M3, or 15,735 bbls more likely 157,352 bbls)
in the event of a rupture. Trans Mountain needs to provide further information as to
assumed response time and drain down volumes associated with the challenging segment
between approximately KP 1000 to 1060 where a pipeline rupture could seriously impact
the First Nations.22 Without further detailed explanation as to how in the oil outflow
volume estimates in this section were derived, Accufacts must conclude the outflow
volumes shown are relying on overly optimistic remote identification, especially in a
slack line operation that can be very challenging, and remote valving effectiveness in a
serious downhill gradient. Once pumps are shut down, gravity can still release oil out of
a rupture at very high rates in such steep elevation profile gradients.
The serious underestimating of potential oil spill volumes will result in highly underresourced staging of oil spill response equipment, most likely rendering oil spill response
ineffective. Depending on the ruptures location, the approximate two to three hour oil
equipment staging response implied in submissions to the NEB (even with the Hope
pump station serving as a storage site), and the large potential rupture release volumes, as
well as the nature of the oils that will be moved, all conspire to assure that any oil spill
response plan will be ineffective in recovering most of the oil in these more remote but
sensitive and important areas.23 History is filled with major pipeline oil spill releases,
such as the recent pipeline rupture releases into the Yellowstone River, where the amount
of oil that was actually recovered, especially in fast flowing rivers, was insignificant to
the amount of oil actually released. It is critical for both the Line 1 and Line 2 pipelines,
that siting and integrity management practices instill the highest effectiveness toward
avoiding rupture, as control room and oil spill response for these uniquely challenging
and sensitive segments will likely be ineffective, should a rupture occur.

22

Part 2 Risk Update, 007 Technical Update No1 and Consultation Update No 2 Part 2 Risk
Update Exhibit 248.pdf, Outflow Volumes Kingsvale to Burnaby,. p. 1181 of 1368.
23
Trans Mountain, B18-1 V7_1.0_TO_5.2.8.3_RISK_ASSESS_MGMT_SPILLS
A3S4V5.pdf, Section 4.5 Spill Response Resources, pages 7-33 & 7-34.
Accufacts Inc.
Page 10 of 12

5d) Line 1 oil spill volumes should also be estimated from elevation profiles
incorporating the sensitivity recommendations in this report.
Ironically, Accufacts has not found any oil spill volume modeling in the TMEP
submissions for the Line 1 24-inch segment that could affect the First Nations. This may
be because it is unlikely that both Line 1 and Line 2 would rupture simultaneously,
except in the case of a landslide affecting adjoining ROWs, so volume estimates for Line
2 would be a larger release case than the possible Line 1 rupture case. However, Trans
Mountain should issue an elevation profile for the 24-inch Line 1 for the full pipeline
segment covering approximately KP 1000 to KP 1060 indicating rupture outflow
volumes, the location of sensitive areas, and identifying the valves and check valves for
this segment. Such a document would permit sensitivity cases to be independently
developed on Line 1 to assure valving is reasonable for the pipeline, especially as it
appears Line 1 must be operated in slack line condition, which will complicate and
greatly extend the time to recognize rupture, and increase the oil Outflow Volumes for
Line 1 in this area.
6) Conclusions.
In reviewing the TMEP for the segments that could affect the First Nations interests, Trans
Mountain needs to provide additional details concerning this application focused on the
follow two main items:
6a) Focus on a complete integrity management approach designed to actually prevent
pipeline rupture release.
Serious deficiencies appear to exist in the risk assessment approaches for the TMEP.
There are two major categories of pipe threats that could result in major oil spill releases
and that the TEMP application to date has not adequately addressed in sufficient detail to
instill confidence that these threats are properly addressed to prevent rupture. Accufacts
must advise that merely repeating incomplete or inappropriate assessments or engineering
analyses more frequently, such as annually, does not diminish the risk of pipeline rupture
failure. The repetition of incomplete or inappropriate risk assessments adds no level of
safety toward avoiding pipeline rupture in these highly sensitive areas, either for the Line
1 or Line 2 operation. Accufacts advises that a more thorough analysis be performed to
assure that the pipelines routed approximately between KP 1000 to KP 1060 are not
located in areas at risk to abnormal loading forces such as major landslide. Steep slopes
alone would not necessarily justify rerouting, but should the slopes be susceptible to
generating such abnormal loading forces, such as breakaway landslides, pipeline
rerouting is advised.
Accufacts Inc.

Page 11 of 12

In addition, the over 60 year old Line 1, 24-inch pipeline in this segment, appears to be
at-risk to vintage manufacturing defects that are susceptible to pipeline rupture especially
given the change in risks from the new operation associated with the TMEP. This
category of manufacturing threat anomaly is not reliably assessed by ILI technology.
Other uncertainties introduced with this vintage manufacturing pipe threat render
engineering assessment results using such ILI highly unreliable. A special hydrotest is
warranted as provided by recently provided guidance issued by PHMSA concerning
change in service for such at-risk vintage pipe.
6b) Oil spill response plans will be very ineffective in the segment that can affect the
First Nations.
Finally, given the observed overstatement of control room operational effectiveness, the
placement of valving in the highly unique elevation profiles associated with Line 1 and
Line 2 segments spanning approximately KP 1000 to KP 1060, and the two to three hour
oil spill response time for such a remote area, any oil spill response suggesting
effectiveness are illusionary. Trans Mountains TEMP application should focused on
changes to the pipeline route/design and operation, including possible Line 1 pipe
replacement and rerouting of both pipelines in this segment to avoid pipeline rupture in
this very challenging environment that could seriously impact the First Nations.

Richard B. Kuprewicz
President,
Accufacts Inc.

Accufacts Inc.

Page 12 of 12