The Calgary-based company was responding to the National Energy Board's decision to delay a restart of the pipeline because it's "not persuaded" that Enbridge has met one of the the conditions attached to the NEB's approval of the project.
Line 9 had been targeted to begin shipping western crude eastward through southern Ontario to Montreal in early November but the NEB said in a Oct. 6 letter that approval would be withheld until its concerns over shut-off valves were addressed.
In an Oct. 23 response, Enbridge told the NEB that the company has met or exceeded the safety standards but may have failed to explain its highly technical approach adequately to the regulator.
Most of the eight-page letter is devoted to explaining how Enbridge took the best approach by considering a combination of factors such as the elevation of the pipeline's route when deciding where to place shut-off valves.
“It has become evident to us that key aspects of our valve placement methodology were not clearly conveyed,” said the letter from Guy Jarvis, Enbridge's president for liquids pipelin, to the Calgary-based National Energy Board.
"Enbridge's conservative approach to risk management and valve placement is designed to ensure we not only meet, but exceed, regulatory standards. Our IVP (Intelligent Valve Placement) methodology applies competent engineering judgment and sound engineering practices to reduce potential release volumes to the lowest level reasonably practical along the entire pipeline. In doing so, it helps protect the public and the environment in the unlikely event of a pipeline release."
Line 9 is a 40-year-old pipeline that's part of a larger Enbridge plan to transport more crude from Western Canada to refineries in Eastern Canada and potentially to export markets. The Line originally flowed in a west-to-east direction in the 1970s, but that was reversed in the late 1990s in response to changing market conditions and is being reversed again.
Although the company insists Line 9 has operated safely throughout its history, there's been local opposition to Enbridge's plans to ship more oil eastward due to concern about the risk of a major spill into water supplies.
In its Oct. 6 letter, the NEB said it appeared that Enbridge hadn't complied with some of the conditions imposed by the regulator and said the company had to address the board's concerns before applying for final permission.