Trans Mountain’s r
esponse to IR
explanation for claiming IR response to be inadequate
year? How many of these result in the initiation of shutdown? In those instances where there is a shutdown, what is the average length of time it takes a control centre operator to begin the shutdown process from the initial alarm? For this question 1.4 a), please break down your response by TMPL and other Kinder Morgan pipelines. existing Trans Mountain pipeline system unless specifically requested to do so by the National Energy Board. The information request is not relevant to one of more of the
issues identified in the National Energy Board’s L
ist of Issues for the Trans Mountain Expansion Project. However, in recognition of the interests of the Province of British
Columbia, and specifically the provincial government’s
mandate to uphold the interests of all British Columbians, Trans Mountain commits to meet with the provincial government to further discuss the information request and work with them to provide the relevant information.
the project, including emergency response planning”.
Therefore, information regarding leak detection and pump shutdown is squarely within the scope of the issues identified by the Board. Information concerning the effectiveness of leak detection and the promptness of shutdowns on the existing TMPL system and all Kinder Morgan pipelines is directly relevant
to the company’s “track record” with respect to the safe
operation of its pipelines. The Province requires such information in order to assess Trans
Mountain’s ability to
operate the proposed pipeline safely. Further, Trans Mountain itself makes multiple references throughout the Application to
leak detection and spill response:
“The expanded TMPL system, like the
existing TMPL system, will include the implementation of the state-of-the-art, real-time, transient, computational pipeline leak detection system, that is currently in service on the existing TMPL system. KMC has a long and successful history with the implementation of these types of leak detection systems, which are widely viewed as the most effective type of system for liquid petroleum transmission
[emphasis added] (A3S0Q7, Application Volume 1, Summary, Section 2.5: Operations and Maintenance. PDF p. 69 of 113). Trans
reliance on KMC’s history as an
experienced pipeline operator invites scrutiny. It is therefore
not open to Trans Mountain to argue that KMC’s leak
detection and pipeline shutdown history is not relevant to the issues in this proceeding.
Trans Mountain’s offer to meet with the Province to provide the “relevant information” is of no assistance in the context