In the Matter of Enbridge Northern Gateway Project Joint Review Panel OH-4-2011 Northern Gateway Pipelines Inc. Enbridge Northern Gateway Project Written Evidence of Intervenor David John Shannon 1. Once exiting the western Hoult Portal, the proposed twinned pipelines will be traversing some very active landslide areas of Hoult Creek and the upper Kitimat River (See Figures 1.1 and 1.2 below). The source of these evaluations is from Airphotos at scale 1:15,000 scale shown in Figures 1.3-1.10, following. (Figures 1.3 to 1.10 are best viewed in sequential pairs through a Stereo viewer, i.e. Figs 1.3 and 1.4; 1.5 and 1.6;, etc…) Figure 1.1 Active and Stable Landslide Regions Upper Hoult Creek area (superimposed on Figure A-119 Enbridge Potential Full-Bore Ruptures, etc…). Figure 1.2 Active and Stable Landslide Regions Upper Hoult Creek area (superimposed on Figure A-120 Enbridge Potential Full-Bore Ruptures, etc…). Figure 1.3 Photo 200 Hoult Tunnel (East ½) Figure 1.4 Photo 199 Hoult Tunnel (West ½) Figure 1.5 Photo 198 East of Waypoint #8 (East ½) Figure 1.6 Photo 198 East of Waypoint #8 (West ½) Figure 1.7 Photo 196 Waypoint #8N (East ½) Figure 1.8 Photo 195 Waypoint #8N (West ½) Figure 1.9 Photo 86 Waypoint #8S (East ½) Figure 1.10 Photo 87 Waypoint #8S (West ½) 2. Enbridge has made estimates of full bore ruptures at selected points along the pipeline. A selection of segment A-120 (shown below) will be discussed in more detail: Figure 2.1 Pipeline Route through the Upper Kitimat. The estimated rupture amounts from segment A-120 are shown in Figure 2.2 below: Figure 2.2 Potential Full-bore releases in upper Kitimat (Enbridge NGP information A- 120) In this region the estimates vary from approximately 5,000 to 14,000 barrels of oil. A Google Earth photo shown below puts the last slide into perspective: Figure 2.3 Google Earth photo of Upper Kitimat. Three proposed boom locations are shown on the map above (Fig 2.3) along the pipeline route. My concern, having walked the route, is the inaccessibility of access to this portion of the river especially during winter. The slide below (Fig. 2.4) shows a series of GPS waypoints (Waypoints #8- #18) at which photographs were taken of recent boulder and debris slides which cause me grave concern for the pipeline route. Figure 2.4 Google Earth photo showing GPS waypoints of several photographs of landslide evidence A photograph at waypoint #18 (Hoult “Monolith” photo) is shown below (Fig. 2.5), just about at the location the pipeline would exit Mount Nimbus, between Enbridge KP 1091 and KP 1092. The potential for this kind of geological activity in the region of a pipeline is most concerning. Figure 2.5 Huge boulder at the Hoult Portal location Another sizeable boulder in a region estimated to be ‘Active’ is shown in the next figure (Fig 2.6) at GPS waypoint #8. Waypoint #8 is also identified in Figures 1.8 and 1.9. Figure 2.6 Boulder at waypoint #8 along the pipeline route. A portion of an Information Request from the BC Government is shown in Figure 2.7 below, highlighting the concern that even larger releases than those from full-bore ruptures are possible with slow leaks: Figure 2.7 Leak Detection Systems Capabilities I share the same concerns as the BC Government (Fig. 2.8 below) Figure 2.8 Leak detection was also a problem in the Kalamazoo and Kitimat’s isolation is a further concern In a region known for its valuable salmon habitat, I am very concerned with a crude oil pipeline to Kitimat and the destructive cleanup methods which would be required after a spill. See Fig 2.9: Figure 2.9 Concerns for the Kitimat River guided by Kalamazoo experience In the Matter of Enbridge Northern Gateway Project Joint Review Panel OH-4-2011 Northern Gateway Pipelines Inc. Enbridge Northern Gateway Project Written Evidence of Intervenor David John Shannon 1. The tanker route proposed by Enbridge Northern Gateway Pipelines would be one of the longest most challenging routes for VLCC tankers in the world. Supporting evidence is given in Appendix A (World Tanker Routes). 2. The passage has been compared by some to the Strait of Magellan, in which the Chilean Government experienced a very large spill of crude oil (Metula incident of 1974) in their fourth and final attempt to traverse the Strait with VLCC crude oil tankers. Evidence is given in Metula Grounding Incident USCG Final Report shown in the link: http://www.fas.org/ota/reports/7508.pdf . The location of the grounding is identified in the last figure in attachment 1., above. The route now requires the presence of two “well-rested” pilots for the entire journey through the Straits. 3. Difficulty in dealing with the spill and its aftermath are shown in “Metula Oil spill Medeiros and Kjerfve” in the link http://geotest.tamu.edu/userfiles/167/77.pdf and “The Metula Oil Spill 21 Years Later” found in the link http://www.iosc.org/papers_posters/00323.pdf. Dated this 20th day of December, 2011. Dave Shannon, Appendix A: World Tanker Routes Page 1/5 Figure A 1 Sullom Voe, Shetlands (20 miles) Appendix A World Tanker Routes Page 2/5 Figure A 2 Mongstad Norway (20 miles) Appendix A World Tanker Routes Page 3/5 Figure A 3 Brofjorden, Sweden (20 miles) Appendix A World Tanker Routes Page 3/5 Figure A 3 Valdez, Alaska (90 miles) Appendix A World Tanker Routes Page 4/5 Figure A 4 Kitimat Enbridge Northern Gateway Northern Route (190 miles) Appendix A World Tanker Routes Page 5/5 Figure A 5 Strait of Magellan (350 miles) Showing location of Metula Oil Spill In the Matter of Enbridge Northern Gateway Project Joint Review Panel OH-4-2011 Northern Gateway Pipelines Inc. Enbridge Northern Gateway Project Written Evidence of Intervenor David John Shannon 1. This passage was taken from a “History of HSC Tug Escort Guideline and Regulation Development” for the port of Los Angeles/ Long Beach harbor found in this June 30, 2007 link: http://www.mxsocal.org/pdffiles/App%20C3%20History%20HSC%20Tug%20Escort%20Reg.pdf “Analysis of marine casualties for vessels operating in the LA/LB port area revealed that an average of 1 in 100 commercial vessels (1 per week) sustained some type of steering or propulsion failure during the inbound or outbound transit. The mechanical problem rate and the ever-decreasing amount of navigable water inside the breakwaters threaten safe transit of vessels through the “relatively” confined breakwater entrances. If a significant allision or collision causes a major oil or chemical release, the environmental and economic costs could be devastating.” 2. With these figures applied to the combined LNG and Enbridge Northern Gateway crude oil traffic in the Kitimat harbor potentially to exceed 300 major tankers per year, the occurrence of steering or power failures could well exceed three events per year. The same occurrence rate would no doubt also pertain to the tugboats intended to perform escort and towing functions in the harbor and its approaches. The potential for a major crude oil or fuel oil release for the very sensitive north coast waters is alarming. 3. Tug boats are not immune to the combined human error and other risk factors, as the following Figures 1.1 and 1.2 (below) illustrate. Figure 1.1 Sea Voyager and Pathfinder Tugs service the tanker fleet in Prince William Sound Figure 1.2 Pathfinder Tug aground on Bligh Reef in Prince William Sound 4. An earlier incident also involving the Sea Voyager Tug in Prince William Sound is summarized in Figure 1.3, below: Figure 1.3 Incident Involving Sea Voyager Tug and Escort Response Vehicle in prince William Sound Dated this 19th Day of December 2011. David John Shannon, In the Matter of Enbridge Northern Gateway Project Joint Review Panel OH-4-2011 Northern Gateway Pipelines Inc. Enbridge Northern Gateway Project Written Evidence of Intervenor David John Shannon 1. Figure 1.1, below shows TSB Reported Marine Incidents on the Inside Passage for the 6 years ending January 2009. The western boundary of the summary area is the vertical red line: Figure 1.1 TSB Reportable Marine Accidents/ Incidents for the 6 years ending January 2009 The table from which this view was taken is shown in “TSB Marine Incidents Inside Passage.pdf” attached separately. Dated this 19th day of December, 2011 David John Shannon Accidents and Reportable Marine Incidents where Latitutde between 51 00 00 and 54 15 00 N and Longitude between 127 50 00 W and 130 30 00 W (Inner Passage - Prince Rupert to Port Hardy ) Obs OCC_NO OCC_CLAS ACC_TYPE_ID OCC_DATE VESSEL_NAME VESSEL_TYPE_ID INC_TYPE_I REGION_ID OCC_LOC AREA_TYPE_ID OCC_LATIT LAT_IDENTI OCC_LONG LONG_IDEN S_ID D UDE FIER ITUDE TIFIER 1 M03W0007 CLASS 5 CAPSIZING 07-Jan-03 POWELL BARGE - CARGO . WESTERN RODERICK ISLAND, BAY 524010 N 1282200 W CARRIER REGION WATSON BAY, B.C. 2 M03W0008 CLASS 5 FLOODING 08-Jan-03 MANSON TUG - OTHER . WESTERN FOG ROCKS, CHANNEL / 515800 N 1275500 W REGION FITZHUGH SOUND, STRAIT / SOUND B.C. 3 M03W0013 CLASS 5 STRIKING 18-Jan-03 SEA RAKE FISHING - . WESTERN MOORE ISLAND, B.C. BAY 524030 N 1292440 W UNSPECIFIED REGION 4 M03W0019 CLASS 5 GROUNDING 28-Jan-03 NANA BARGE - CARGO . WESTERN DUMAS POINT, CHANNEL / 521200 N 1280600 W PROVIDER REGION SEAFORTH STRAIT / SOUND CHANNEL, B.C. 5 M03W0027 CLASS 5 GROUNDING 28-Jan-03 NORMAN S TUG - OTHER . WESTERN SEAFORTH CHANNEL / 521200 N 1280600 W REGION CHANNEL, DUMAS STRAIT / SOUND POINT, B.C.