This post is part of an ongoing series in which MLA Andrew Weaver will be sharing key information from inside the National Energy Board hearings on Kinder Morgan’s Trans Mountain pipeline proposal. To see previous posts, please click here.

Diluted Bitumen in BC Coast Waters



The ongoing dispute between the City of Burnaby and Trans Mountain has been in the news a fair amount lately. It’s evident to me that the residents of Burnaby are being well-represented by their elected leaders and civic employees. As part of the Trans Mountain National Energy Board hearings, the City of Burnaby has been asking pointed and difficult questions, raising critical issues of concern, and communicating effectively with their residents. The City of Burnaby is rightly concerned about the potential risk of a diluted bitumen spill at the proposed expanded terminal facility in Burrard Inlet, as well as the potential ramification of having an enhanced pipeline capacity through it’s neighbourhoods or underneath Burnaby Mountain. But what hasn’t received enough attention is the potential risks that our coastal communities face once diluted bitumen is loaded onto tankers.

Bitumen is the raw product extracted from the Alberta oil sands. It is heavier and more viscous than conventional crude oil and so must be either upgraded or diluted with other petroleum products in order for it to flow through pipelines. This combination of bitumen and diluent is referred to as diluted bitumen, or dilbit. There is very little research on how dilbit and the chemicals used to dilute it behave if a spill occurs in fresh water or marine environments.

A recent federal government study concludes that, unlike other crude oils, dilbit will sink in the presence of suspended particulate matter (e.g. sediment particles in the ocean). Suspended particulate matter is very common in B.C.’s coastal waters, meaning that any dilbit spill will likely lead to submerged oil. Currently we have no ability to clean up oil that sinks below the surface, making dilbit a particularly risky substance to transport.

So for coastal British Columbia, a specific reason for concern regarding the transport of dilbit is that we know very little about how it would behave if it were to be spilled into a marine environment. Evidence from the July 2010 Kalamazoo River dilbit spill in Michigan also provides a pretty clear indication that dilbit would sink when combined with sediments. One thing we have no shortage of in our coastal waters is suspended sediments. Next time you travel on a BC ferry from Swartz Bay to Tsawwassen, have a look at the water. Water originating from the Fraser River has a very distinct milky colour associated with its high sediment content.

Please provide your references



As you might imagine, the scientific uncertainty as to the fate and behaviour of a potential dilbit spill prompted me to pose a number of questions to Trans Mountain through the National Energy Board hearing process. Some of my questions were relatively straightforward:

On page 11, of the report A Comparison of the Properties of Diluted Bitumen Crudes with Other Oils, submitted to the National Energy Board as part of the Trans Mountain application, the study of Tsaprailis et al 2013 is referred to. It is the only study cited with respect to penetration of various types of oil into sand. As I could not find the reference, I simply asked the obvious questions?:

Is this study peer reviewed? Is this study published in a scientific journal? Are there any peer reviewed scientific journal studies that have examined dilbit penetration into sands? If so, please list them.

Here’s the answer I got:

Trans Mountain is unaware of the review process used for the Tsaprailis et al 2013 report but assumes that it was peer reviewed by the client (AIEES). Trans Mountain does not have this information. Trans Mountain is unaware of any scientific publication on dilbit penetration into sediment other than Brown et al. (1992).

You can imagine my frustration. I am trying to examine the scientific evidence underpinning Trans Mountain’s submission and I can’t get access to, or information about, key references they are using in their application.

It gets worse.

On page 5 of the report A Study of Fate and Behaviour of Diluted Bitumen Oils on Marine Waters, that Trans Mountain submitted in support of their application, it states: “the literature review resulted in only six reported studies focused specifically on dilbits in available on-line searches.” All I asked for was information on how I could find them:

Please list these six studies with URLs so that I can access them. Do any of these studies appear in the peer-reviewed scientific literature?

You would think it would be trivial to respond to these. But instead of an answer, I was directed to a bibliography that included 75 references which may or may not include the six that were being referred to. Fortunately the National Energy Board compelled Trans Mountain to provide a full and adequate response to my original question and I await receipt of the six references.

Does Diluted Bitumen Sink or Float on Marine Waters?



Transmountain relied heavily on work they commissioned in the report entitled: A Study of Fate and Behaviour of Diluted Bitumen Oils on Marine Waters. This is referred to as the so-called Gainford study. This study undertook tank experiments using saline water (typical of Burrard inlet) that did not include suspended sediments. Yet according to the aforementioned federal study:

“high-energy wave action mixed the sediments with diluted bitumen, causing the mixture to sink or be dispersed as floating tarballs”

and

“Under conditions simulating breaking waves, where chemical dispersants have proven effective with conventional crude oils, a commercial chemical dispersant (Corexit 9500) had quite limited effectiveness in dispersing dilbit.“

So I asked the obvious questions, noting that the tank experiments were all conducted with conditions claimed to be typical of Burrard Inlet. Have any tank experiments been conducted:

with more saline conditions typical of the Strait of Juan de Fuca? If not, why not? with colder conditions typical of winter? If not, why not? in the presence of strong horizontal and/or vertical sheer? If not, why not? in the presence of whirlpools? If not, why not? in the presence of downwelling conditions with downwelling velocities reaching greater than 40-50 cm/s as observed in [observed tidal fronts in the region]? If not, why not?

I received, what can only be described as a very odd response: “Additional studies were conducted by the Government of Canada (2013), under more saline conditions and different temperatures.” In other words, I was referred right back to the report that I cite above claiming that dilbit has the potential to sink. In response to this reply I responded:

“This response is unacceptable. I am aware of the government on Canada studies. As noted in [the Government of Canada (2013) ] report does not provide any details of any research that may or may not get done. I submit that Trans Mountain has not adequately answered the question(s), and request that an appropriate answer be provided.”

To which all I received from Trans Mountain was:

“The requested information has been provided and Trans Mountain‘s response is full and adequate. The response provides the Board with all necessary information pertaining to this matter. There is no further response required and supplementing the original response will not serve any purpose. Trans Mountain notes that if the Intervenor disagrees with the information contained in the response, it may contest the information through evidence or final argument.“

This interaction is very troubling to me since in its report entitled Review of Trans Mountain Expansion Project: Future Oil Spill Response Approach Plan, Recommendations on Bases and Equipment, Full Report, submitted by Trans Mountain as evidence in support of its application, it states that:

“During the course of the ten days test the diluted bitumen floated on the water and could be retrieved effectively using conventional skimming equipment.“

It is clear to me that unless compelled to do so, Trans Mountain does not plan to conduct additional tank studies. The question I ask is this. Is it the responsibility of the taxpayer to fund federal government science in direct support of industry? Or should the industrial proponent of a project be required to pay for the necessary scientific studies? The answer is obvious to me.

Summary

In summary, it is clear that there is a profound gap in scientific knowledge as to what would happen if diluted bitumen were to be released into the Salish Sea.

Yet we must not forget that in British Columbia dilbit is already being piped through the existing Kinder Morgan line to Burnaby where it is loaded onto tankers. About one tanker a week laden with dilbit is passing along the coast of the Oak Bay-Gordon Head riding on its way to refineries in Asia or California.

Was there an environmental review process when dilbit replaced traditional crude in the existing line? If not, why not?

The British Columbia government has outlined five conditions that must be met for their acceptance of heavy oil pipelines projects. These are

Successful completion of the environmental review process. In the case of Enbridge, that would mean a recommendation by the National Energy Board Joint Review Panel that the project proceed;

World-leading marine oil spill response, prevention and recovery systems for B.C.’s coastline and ocean to manage and mitigate the risks and costs of heavy oil pipelines and shipments;

World-leading practices for land oil spill prevention, response and recovery systems to manage and mitigate the risks and costs of heavy oil pipelines;

Legal requirements regarding Aboriginal and treaty rights are addressed, and First Nations are provided with the opportunities, information and resources necessary to participate in and benefit from a heavy-oil project; and

British Columbia receives a fair share of the fiscal and economic benefits of a proposed heavy oil project that reflects the level, degree and nature of the risk borne by the province, the environment and taxpayers.

I support these five conditions. But in addition and for the reasons outline above, the BC Green Party and I have added a sixth condition:

A moratorium for dilbit transport along the British Columbia Coast.

The justification is clear. The BC government’s five conditions must be applied to existing as well as future projects.