Dear Mr. Monaco:
We are writing to express great concern about the current condition of Enbridge's Pipeline #5 ("Line 5"), and the accuracy of previous communications we have had with your company regarding this segment that crosses the Straits of Mackinac.
On March 10, 2017, we sent you a letter that inquired about the integrity of several layers of protective coating on Line 5, as well as the inspection and remedial practices your company follows to ensure the integrity of the underlying pipeline. On April 6, we received a response from Enbridge Vice President of U.S. Operations, Bradley Shamla, informing us that the Biota Investigation Work Plan showed "no indication of any anomaly with the outer wrap or other elements of the coating, including the enamel layer that covers the pipeline." Moreover, the letter detailed the company's broad suite of inspection processes and tools -- including the use of Remote Operated Vehicles, In-line Inspections, and around the clock remote monitoring of the cathodic protection system on the dual pipes that cross the Straits.
Despite these assurances and inspection measures, your company recently disclosed extensive loss of enamel coatings on Line 5. This includes eight different areas of the pipeline that are without any protective coating, leaving bare metal exposed to the harsh underwater environment. We understand that all but one of these areas are 7 inches or more in diameter, and perhaps most troubling, that your company was aware of these damages since 2014.
According to your company's public statements, "internal reporting issues" are to blame for the discrepancies between the facts on the ground and the information provided to our offices and to state regulators. This explanation is simply unacceptable. Your company's leadership has repeatedly told us that the segment of Line 5 under the Straits is the most closely monitored pipeline in your network. Enbridge's Vice President of Pipeline Integrity has publically stated that Line 5 "really is as good as new." In addition, your company has repeatedly described to our offices the procedural, cultural, and institutional changes that have been implemented to prevent a pipeline rupture like that which occurred near Marshall in 2010 from ever happening again.
It is apparent to us that further changes are needed in the institutional procedures and culture at Enbridge to ensure accurate reporting, transparency, and communication of pipeline integrity management. Given the critical risk this pipeline poses to public health and safety, please respond to the following questions:
What is being done to correct internal reporting procedures at Enbridge to ensure that damage sustained by pipelines and the coatings that protect these pipelines against corrosion is accurately communicated throughout the company and to our offices and the state regulators?
We are concerned by the increased number of reported locations along Line 5 with damage. Initial reports of two "Band-Aid" sized bare spots and an additional suspected location at the end of August 2017 expanded to eight locations, eight holidays ranging in size from 1.5 square inches to over a square foot, and six features being addressed in the repair work plan dated September 13th, 2017. Are there any additional portions of Line 5 with anomalies of any type to any of the coatings covering the pipeline that have not been reported? Were any additional sites identified needing further inspection or repairs of any sort since September 13th?
Given the internal reporting issues and increasing number of reported sites with damage to protective coatings on the pipeline, we are concerned that additional issues have not been clearly communicated to state regulators and federal agencies providing oversight. How can we be certain that no other damage to either the pipeline or its protective coatings has occurred and that state regulators, federal agencies providing oversight, and our offices are fully informed?
We are dedicated to protecting the Great Lakes, and want to hear your responses to our inquiries so that we can ensure the health and safety of the millions of people who rely on the Great Lakes for drinking water, recreations, and jobs.