A pipeline that’s flowed quietly beneath Toronto for 37 years is under increased scrutiny as its operator looks to expand, prompting the city to raise startling concerns about how it would deal with a potential disaster.

Toronto is one of more than half a dozen municipalities along the 639-kilometre stretch of the Enbridge pipeline whose submissions to the National Energy Board have highlighted alarming safety issues with proposed changes to Line 9B.

For example, at the Finch subway station, the pipeline runs less than two metres below the sidewalk and 60 centimetres above the subway structure, cinched between the stairwell of the Bishop Ave. entrance and escalators leading to the Metrolinx terminal.

“Neither the TTC, Toronto Fire Services nor Enbridge appear to have any specific contingency plan to manage a leak of petroleum should this occur near the TTC entrances,” reads the city’s final submission. “The top stair of the Bishop Avenue stairwell is at grade and provides no barrier to the flow of the product should there be a release.

“If any petroleum product was discharged either down the stairs or the escalators, or by other routes into the TTC concourse, platform or track level, there would be an enormous risk to thousands of daily passengers and TTC workers.”

Enbridge wants NEB approval to increase the capacity of Line 9B from 240,000 barrels per day to 300,000, as well as reverse its flow from westbound to eastbound, allowing it to carry heavy crude from Alberta’s oilsands to refineries in Quebec. It currently carries an average of 160,000 barrels per day.

Kingston resident Rick Munroe, an intervenor in the proceedings, whose photos of an Enbridge warning sign next to the Finch subway entrance are included in the city’s submission, called the situation “ridiculous.”

“If that pipe ever ruptured and began to flow down that open stairwell, people would be completely blindsided because they do not know. No one uses TTC Finch even thinking that it’s a possibility,” said Munroe.

Similarly, Toronto Fire Services criticized Enbridge’s emergency manual as a “generic” document that doesn’t address a Toronto-specific response.

Enbridge is responsible in the event of a spill, but its current response time of between 90 minutes and four hours has raised the hackles of municipalities along Line 9B. In most cases, municipal fire departments would be the first responders.

“Toronto Fire requires a reduction in response time … to mitigate or prevent the need to evacuate (which could be up to many tens of thousands of Toronto residents, or higher),” reads Toronto’s submission.

The fire department wants meetings with Enbridge to determine specific steps it should take in the event of a leak or spill, along with a host of information about the pipeline, such as detailed maps of the pipeline, information on control valves, and details of Enbridge’s resources should a spill occur.

Meanwhile, Hamilton’s fire services complained that Enbridge is “not prepared to provide” emergency responders with adequate information for them to prepare a response to a pipeline emergency.

And Toronto’s legal department warned that the municipality and its residents could incur “very significant” costs in the event of a Line 9 spill, as it sought assurance that the company has adequate resources to compensate residents, businesses and the city, including in the event of mass evacuations.

Ward 8 (York West) Councillor Anthony Perruzza, who pushed to have the city take a seat at the pipeline hearings, said he worries about the integrity of the pipeline and what will happen if there is a leak or a spill.

He said the “best-case scenario” would be for Enbridge to abandon its plans.

“But I understand that’s not realistic, and I also understand that’s impractical, so (the goal) is to ensure the integrity of the line is quantified as best as possible, that we’re completely assured that we’re not going to have a Kalamazoo happen here,” said the councillor, whose ward contains a section of the pipeline.

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He was referring to a 2010 Enbridge spill that spewed 3.3 million litres of oil into the Kalamazoo River near Marshall, Mich. The incident cost the company upwards of $1 billion and counting — the cleanup still isn’t complete.

That disaster, the largest on-land spill in U.S. history, highlighted some of the dangers of diluted bitumen, or dilbit, which proved far more difficult to clean up than typical light crude.

Enbridge’s proposal would see Line 9B, a 30-inch pipe that runs between North Westover, near Hamilton, to Montreal, carry dilbit at times, flowing across dozens of creeks and waterways in the GTA alone.

Enbridge spokesperson Graham White said the company can’t “provide any detailed comment or statements or information” outside of the NEB process, for legal reasons. But he said Enbridge is responsible for spills, cleanup and costs and regularly provides municipalities with training and resources “to ensure that they are able to respond effectively, quickly and knowledgeably to the release of any of our products.”

Enbridge has met regularly with municipalities over the course of the proposal to address concerns, he said.

That includes the TTC, said the transit agency’s spokesperson, Brad Ross.

“The reversal of the flow is really not at issue; it’s more just making sure that with the increased flows that there is a site-specific risk assessment and emergency protocols in place,” Ross said. “We understand that is happening and we will be meeting with Enbridge around that kind of thing.”

Toronto spokesperson Wynna Brown said the city can’t discuss the details of its submission until upcoming hearings.

“But I can advise that staff at the city, and a number of other municipalities, have put significant time and effort into this review to ensure that the Enbridge application meets the highest standards for pipeline integrity and spill response preparedness, the issues raised by Council,” she wrote in an email. “If there are any outstanding concerns, we will be recommending conditions to ensure they are appropriately addressed.”

Intervenors, such as Toronto, and commentators have made final submissions. The last step in the process will be summary arguments, made in writing by Oct. 3 or at hearings scheduled for Montreal from Oct. 8 to 11 and Toronto from Oct. 16 to 19.