file: adv-pe-landmc 02 national energy board land...

File: ADV-PE-LandMC 02

NATIONAL ENERGY BOARD

LAND MATTERS CONSULTATION INITIATIVE - STREAM 3

ENBRIDGE PIPELINES INC.

ABANDONMENT PHYSICAL PLANS

MAY 25, 2011

schmeils

Typewritten Text

schmeils

Typewritten Text

schmeils

Typewritten Text

Attachment JRP IR 2.11(a)

schmeils

Typewritten Text

schmeils

Typewritten Text

INTRODUCTION

National Energy Board File: ADV-PE-LandMC 02

Enbridge Pipelines Inc. Abandonment Physical Plans

1. In its RH-2-2008 Reasons for Decision dated May 26, 2009, the National Energy Board

("Board" or "NEB") set out a time line for the Land Matters Consultation Initiative ("LMCI")

Stream 3 process. An Action Plan was presented, which included deadlines for various

submissions. On March 7,2011, the NEB issued a letter stating that in order to allow additional

time for consultation, the deadline for Group 1 physical plans (not for approval) remains at May

31, 2011, but the deadline for the cost estimates and updates to physical plans has been changed

to November 30, 2011. This submission provides the physical plans for abandonment of

Enbridge Pipelines Inc. ("Enbridge").

2. The physical plans for abandonment that are discussed in this submission have been developed

for the purpose of creating preliminary estimates of abandonment costs. The methods of

abandonment that will ultimately be undertaken for any specific facilities or pipelines will be

determined at the time of the application to abandon. Enbridge is committed to basing any

decision that it will make regarding the actual method of abandonment - including with respect

to removal versus abandonment in place - on the most current sound scientific studies and

accepted industry practice.

ENBRIDGE PIPELINES

3. The Enbridge pipeline system and the Lakehead System in the United States ("U.S.") together

transport liquid petroleum eastbound for delivery primarily to markets in the U.S. Midwest and

in Ontario. Appendix A to this submission is a map illustrating the routes of the Enbridge

pipeline system and the Lakehead System.

4. The Enbridge pipeline system includes:

• Lines 1, 2, 3 and 4 (all originating in Edmonton, Alberta), Line 67 (Alberta Clipper,

originating in Hardisty, Alberta), and Line 65 (LSr Pipeline - Light Sour Capacity

Replacement, originating in Cromer, Manitoba). All of these lines extend to the

CanadalU.S. border near Gretna, Manitoba where they connect with the Lakehead

System.


Enbridge Pipelines Inc.

• The Canadian sections of Line 5 and Line 6B extend from connections with the

Lakehead System on the CanadalU.S. border under the St. Clair River to Samia,

Ontario.

• Line 7 extends from Samia to Westover (Hamilton), Ontario where it connects with

Line 10 and Line 11. These two pipelines in tum extend from Westover to,

respectively, the CanadalU.S. border under the Niagara River near Chippawa, Ontario

and to Nanticoke, Ontario on the north shore of Lake Erie.

• Line 8 extends from Samia to Millgrove Junction in Hamilton, Ontario.

• Line 9 extends from Montreal, Quebec to Westover, Samia and Corunna, Ontario.

• The Shell lateral and Suncor lateral extend from takeoff points on Enbridge Lines 5,

6B and 9 to the associated refineries in Samia, Ontario.

5. In addition to its active pipelines, Enbridge has a number of deactivated lines, pipeline segments

and terminals, all of which are included in the overall scope of the physical plans for

abandonment that are reflected in this submission. These include the following:

• Line 7 - Westover Junction, Hamilton, Ontario to Bronte Junction, Oakville, Ontario

as per Board Order MO-II-2006;

• Line 8 - Millgrove Junction, Hamilton, Ontario to Bronte Junction, Oakville, Ontario

as per Board Order MO-Jl-24-95;

• Line 12 and Bronte Lateral- Bronte Terminal, Oakville, Ontario to Clarkson Terminal,

Oakville, Ontario as per Board Order MO-II-2006;

• Line 22 - Ninth Line Junction, Mississauga, Ontario to Clarkson Terminal, Oakville,

Ontario as per Board Order MO-II-2006; and

• 508 mm (20") mainline pipe lying between Clarkson Terminal, Oakville, Ontario and

Port Credit, Oakville, Ontario as per Board approval DI793-Jl-20.

A map which includes the locations of these deactivated facilities is attached as Appendix B to

this submission.

PHYSICAL ABANDONMENT PLANS



6. For the purposes of this submission, Enbridge has adopted the definition of "abandonment" that

appears in the Glossary of the NEB Discussion Paper for LMCI - Stream 3: "to permanently

cease operation such that the cessation results in the discontinuance of service".

Framework for Land Use Analysis

7. For purposes of its land use analysis, Enbridge utilized the three broad categories as reflected in

Table A-2 of Appendix A to the Board's March 4, 2010 letter, as well as the recommended ten

sub-categories.

8. Enbridge retained Stantec Consulting Ltd. ("Stantec") to define the Board's categories and

classify the lands along the Enbridge pipelines according to these categories. These definitions

are provided below. A copy of the Stantec report entitled "Land Matters Consultation Initiative"

and dated April 29, 2011 ("Stantec Report") is included as Appendix C to this submission.

Agricultural

a. Cultivated - Canada Land Inventory ("CLI") 1-4 class soils (Agricultural

Interpretation).

b. Cultivated with Special Features Arable lands (CLI - 1-4 class soils) where the

depth of cover is less than 2 feet (0.6m).1

c. Non-cultivated - topsoil/sod production, native prairie, pastures and crops that

inhibit cultivation.

Non Agricultural

a. Existing Developed Lands urban and rural settlement areas within

municipalities (cities, towns, villages and hamlets) that are built up areas where

development is concentrated with a mix of land uses.

1 Enbridge has a Pipeline Depth Monitoring Program ("PDMP") in place for Lines 65 and 67 and is evaluating the potential for extending this program to others of its pipelines. The PDMP is a process designed to routinely test, evaluate, and where required, take appropriate action to ensure a standard minimum depth of cover is achieved. As a result, Enbridge does not anticipate any difficulties concerning pipeline depth of cover at the end of service life.



b. Prospective Future Development - undeveloped areas located in urban areas and

rural settlement areas within municipal boundaries.

c. No Future Development Anticipated - areas where potential for future

development is low (e.g. forest, landfills, mine sites, National and Provincial

Parks, conservation areas, areas with land use protection, as well as Crown lands,

etc.)

Other

a. Environmentally Sensitive Areas - areas that contain a natural feature which is

protected by government (federal or provincial) regulations. This land use can

include, but is not limited to: sandy soils (Alberta), wetlands, valley/coulee

breaks, significant woodlands, endangered wildlife habitat, and areas with

permafrost.

b. Roads and Railway Crossings - a system consisting of corridors and rights of way

for the movement of people and goods, and associated transportation facilities

including transit stops and stations, cycle lanes, bus lanes, high occupancy vehicle

lanes, rail facilities, park 'n' ride lots, service centers, rest stops, vehicle

inspection stations, inter-modal terminals, harbours, and associated facilities such

as storage and maintenance.

c. Water Crossings - watercourses, rivers, streams, and small inland lakes or water

bodies that have a measurable or predictable response to a single runoff event.

d. Other Crossings (Utilities) - sewage and water systems, septic treatment systems,

waste management systems, electric power generation and transmission,

communications/telecommunications, transit and transportation corridors and

facilities, oil and gas pipeline and associated facilities.

9. To locate the applicable land use areas, Stantec used a Geographic Information System model

populated with numerous data sources from each of the provinces. The Enbridge right of way



was then overlaid on the resulting output to categorize the Enbridge pipeline facilities according

to land use.

10. As quality varied among the data sources, an eight level hierarchy was developed to utilize the

data in order of accuracy. Higher accuracy data was utilized first and lower accuracy data was

relied upon only after the higher accuracy data was exhausted. Details are provided in Section

2.2 of the Stantec Report.

11. In instances where the data provided was a line or a point feature without any defined spatial

boundaries (e.g. roads, bridges, minor stream, etc.), Stantec developed standard widths to convert

the point and line data to areas with defined boundaries ..

12. For purposes of this submission, Enbridge has also adopted the pipeline abandonment methods

outlined in the Canadian Energy Pipeline Association ("CEP A") document entitled "Technical

and Environmental Considerations for Development of Pipeline Abandonment Strategies,

September 2006 - April 2007" ("CEP A 2006 Report"). A copy of the CEP A 2006 Report is

included as Appendix D to this submission. Table 1 below outlines the abandonment methods -

categorized according to facility size, type (i.e. pipeline versus above grade) and land use - that

Enbridge has assumed for purposes of determining the method of abandonment for the purposes

of cost estimation.

13. Table 1 reflects the adoption by Enbridge of the Pipeline Abandonment Matrix that appears as

Table 1 (at page 10) in the CEPA 2006 Report as well as the view that, in general, and absent

reasons to suggest otherwise, abandonment in place is the preferable method.

14. The assumptions reflected in Table 1 differ from those in Table A-2 of Appendix A to the

Board's March 4, 2010 letter in that no removal of pipeline facilities is contemplated in respect of

the Cultivated, Non Cultivated and No Future Development Anticipated land use categories.

Determinations regarding removal versus abandonment in place of each pipeline facility will be

made by Enbridge before it seeks abandonment approval from the Board, and on the basis of

sound scientific study and accepted industry practice.


Enhridge Pipelines Inc.

Table 1: Physical Assumptions by Land Use and Facility For the Purpose of Estimating Preliminary Cost Estimates

Land Use Agricultural Cultivated

Cultivated with Special Features (depth of cover issues)

Non Cultivated Non Existing Developed Lands

Agricultural Prospective Future Development No Future Development Anticipated

Other Environmentally Sensitive Areas

Roads and Railways Water Crossings Other Crossings (Utilities)

Legend: A = Abandon in Place A + = Abandon in Place with Special Treatment R = Removal

Physical Assumptions by Land Use and Facility

Pi )eline Diameter 2" to 12" 14" to 24" >26" Above 60.3 to 355.6 to 610 >660 Grade

323.9 mm mm mm Facilities A A A R

R R R R A A A R A A A R R R R R A A A R A A A R

A+ A+ A+ R A A A R A A+ A+ R

15. Table 2a below categorizes the Enbridge pipeline facilities that are subject to NEB jurisdiction

according to the diameter categories specified in Table A-I of Appendix A to the Board's March

4,2010 letter.

Table 2a: Pipe Diameter Categorization

2" to 12" (Small) 14" to 24" (Medium) >26" (Large) 60.3 to 323.9 mm 355.6 to 610 mm >660mm

Line 10* Lines 1,2, 7, 8, 9**, 10*, 11, Lines 3, 4, 5, 6B, 9**, 67, 12,22,65, Suncor Lateral, Shell Lateral

Clarkson to Port Credit deactivated pipeline

.. *Note: Lme 10 IS dIvIded between the "small" and "medmm" categones as follows: (34 km of 12" and 73 km of 20") **Note: Line 9 is divided between the "medium" and "large" categories as follows: (9 km of20" and 832 km of30")



16. Table 2b below categorizes the Enbridge pipeline facilities (expressed in kilometres of pipeline)

that are subject to NEB jurisdiction according to the land use categories specified in Table A-I of

Appendix A to the Board's March 4,2010 letter.

Table 2b: Physical Assumptions by Land Use and Facility For the Purpose of Estimating Preliminary Cost Estimates (Expressed in Kilometres of Pipeline)2

Pipeline Diameter

2" to 12" 14" to 24" >26" Land Use 60.3 to 323.9 mm 355.6 to 610 mm >660mm

Line 10* Lines 1,2,7,8,9**, 10*, 11, Lines 3, 4, 5, 12,22,65, Suncor Lateral, 6B, 9**, 67,

Clarkson to Port Credit Shell Lateral deactivated pipeline Total

Agricultural Cultivated 3 2246.4 2805.4 5054.8 Cultivated with Special Features (depth of cover issues) 0 0 0 0

Non Cultivated 0 142.7 236.1 378.8 Non Existing Developed Lands 0 53.2 44.5 97.7

Agricultural Prospective Future Development 0 14.5 31.7 46.2 No Future Development Anticipated 0 4.4 5.4 9.8

Other Environmentally Sensitive Areas 29.8 603 794.3 1427.1

Roads and Railways 0.3 144.3 167.6 312.2

Water Crossings 0.4 69.7 101.8 171.9

Other Crossings (Utilities) 0 153.7 225 378.7

Total 7877.2

2 As at April 29, 2011.



17. Table 2c below categorizes the Enbridge pipeline facilities (expressed in kilometres of pipeline)

that are subject to NEB jurisdiction according to the abandonment method specified in the CEP A

2006 Report. The results of this analysis, expressed as percentages of total pipeline length, are

as follows:

• 90.6% - abandonment in place;

• 8.8% - abandonment in place with special treatment; and

• 0.6% - removaL

Table 2c: Physical Assumptions by Land Use and Facility For the Purpose of Estimating Preliminary Cost Estimates (Expressed in Kilometres ofPipeline)3

Pipeline Diameter

2" to 12" 60.3 to 323.9 14" to 24" >26"

. Land Use mm 355.6 to 610 mm > 660 mm

Line 10* Lines 1,2, 7, 8, Lines 3, 4, 9**,10*, 11, 12, 5,6B, 22,65, Suncor 9**,67,

Lateral, Clarkson to Shell Port Credit Lateral deactivated

pipeline Total

A Abandon in Place 33.2 3119.4 3987.5 7140.1

A+ Abandon in Place with Special Treatment 0.3 298 392.6 690.9

R Removal 0 14.5 31.7 46.2

Total 7877.2

18. Finally, regarding above grade facilities, Enbridge has assumed that the facilities described in

Table 3 below will be removed.

3 As at April 29, 2011.

Table 3: Facility Removal Categorization4

Above Grade Facility Basis for Sco~e Terminals Meter Manifold Typical meter manifold used

as basis: 3 - 10" (254 mm) meter complete skid, 40m piping, prover, 50m delivery recycle line, instrument building, 4 way valve, static mIxer

Terminals Valve Manifold Typical valve manifold used as basis: 2 - 36" (914 mm) tank lines, 4 - 24" (610 mm) connection valve headers

Terminals Electrical Building The count represents the electrical buildings at Terminal locations as one electrical building is already included as part of each pump station.

Terminals Maintenance Physical count of each Building building

Terminals Above Grade Total volume of installed Storage Tank tankage

Terminals Booster Pump Total horsepower of installed Station pumps

Terminals Below Grade Sump The count represents the Tank sump tanks at Terminal

locations as one sump tank is already included as part of each pump station.

Pipeline Mainline Valve Physical count of each valve

(Remote Control) Pipeline Mainline Valve Physical count of each valve

(Manual Control) Pipeline Mainline Physical count of each

Instrumentation building Building

Pipeline Pig Trap Assembly Physical count of each trag Station Pump Station Total horsepower of installed

pumps

4 As at April 29, 2011.


Enbridge Pipelines Inc. Abandonment Physical Plans

QuantliY/ Measure 63

100

58

102

15.418 million bbl

53,560 hp

29

129

255

42

119 1.164 million hp

CONCLUSION



19. Enbridge will file the required cost estimates on or before November 30, 2011. Should updates

of physical abandonment plans be required, they will be included in that filing.

file: adv-pe-landmc 02 national energy board land...

Documents