For a backgrounder on the proposed Keystone XL tar sands pipeline supplemental draft environmental impact statement: http://switchboard.nrdc.org/blogs/sclefkowitz/Keystone%20XL%20SEIS%20Backgrounder%20FINAL%20April%2026%202011.pdf
By Anthony Swift and Susan Casey-Lefkowitz
The supplemental draft environmental impact statement (SDEIS) for TransCanada’s proposed Keystone XL pipeline that would bring tar sands oil from Canada to the Gulf coast was released by the State Department on April 15. It is inadequate as already introduced in an earlier blog. For this blog, we’ll focus in on the pipeline safety aspects. This is an area of great public concern – especially for local communities and farmers along the proposed pipeline route. The environmental review has around 80 pages on pipeline safety - all of which manage to avoid serious assessment of the very real problems associated with diluted bitumen in a pipe.
The SDEIS gives a superficial and inaccurate assessment of the pipeline safety risks of transporting diluted bitumen or raw tar sands. The State Department needs to go back to the drawing board for this section – and it should wait until it has a thorough analysis of pipeline safety issues from the Pipeline Safety Administration, as well as new pipeline safety regulations, before moving ahead with the environmental review of the proposed Keystone XL tar sands pipeline. The haste with which the supplemental draft environmental impact statement was prepared (one month) and the haste with which the public is expected to review it (45 days) is incomprehensible given the substantive new information the State Department was legally required to assess and given that there is no need for this tar sands pipeline. America can do better with clean energy alternatives that do not put local communities and farmers at risk.
One reason it is strange that the environmental review does such a poor job at assessing pipeline safety is that the State Department provides a stark picture of what this pipeline could do to the Ogallala Aquifer. The review tells us that a single small leak could go undetected for weeks, spilling as much 21,000 gallons of toxic diluted bitumen in the process. According to the review, numerous small leaks on the Keystone XL pipeline system could amount to five percent of the pipeline’s capacity, or 1.7 million gallons a day, without triggering the real-time leak detection system. Given that small leaks in Keystone XL can spill so much without anyone noticing, this pipeline is too risky to put in our nation’s water supply. In fact, we are already experiencing how faulty a TransCanada tar sands pipeline can be with ten leaks already reported in the National Response Center database for the first Keystone pipeline that was built less than one year ago.
Landowners will not be pleased to know that as the frontlines, the State Department says in the SDEIS that it expects them to be an integral part of the detection system for such leaks. Of course, their efforts will be augmented by “visual or olfactory identification” during aerial inspections. The question on everyone’s mind should be - how big does a spill have to be for an inspector to smell it from a plane?
In a recent report released by NRDC, the Pipeline Safety Trust and others, we raised questions about the safety of moving bitumen through pipelines that are regulated for conventional oil transport. In that study, we cited concerns due to the corrosive characteristics of raw tar sands oil, the fact that the Alberta pipeline system had a pipeline failure rate due to internal corrosion that was sixteen times higher than the U.S. system, and the dangers presented by tar sands pipeline spills.
The State Department said it would not compare the Alberta and U.S. pipeline systems, claiming that direct comparisons are complicated by differences in spill reporting requirements in the two jurisdictions because in Canada, spills of any size are reported while “in the U.S., spills of 5 barrels or more are reported at this time.” Whoever wrote this page obviously didn’t read page 3-87 of the SDEIS, where it correctly states about the U.S. Pipeline Hazardous Materials Safety Administration (PHMSA) reporting: “As of 2002, PHMSA required reports of hazardous liquid releases of greater than or equal to 5 gallons.” The NRDC pipeline safety report compared internal corrosion related spills of 26.3 gallons between both systems between 2002-2010 and found that Alberta’s system had 16 times as many spills per pipeline mile as the U.S. system – a clear indication that additional rigorous analysis of pipeline safety of diluted bitumen is warranted.
The State Department pipeline safety analysis includes a number of technical red herrings and inaccuracies which show a lack of understanding of the environmental impact of raw tar sands oil:
- The SDEIS glossed over concerns of diluted bitumen’s impacts on pipelines by comparing raw tar sands crude to heavy crudes from Mexico and Venezuela which typically do not enter the United States by pipeline instead of comparing it to the lighter crudes that are typically within the U.S. pipeline system.
- The SDEIS argues that because certain heavy crudes from Alberta are also corrosive, raw tar sands shouldn’t be a problem. That doesn’t cut it – State must assess the corrosively of these crudes and the spill history of the pipelines they travel on. After all, the majority of these crudes are exported into the United States on the Enbridge pipeline system – a system that, while accounting for only a few percent of the entire U.S. crude transmission pipeline system, was responsible for over half of the crude oil spilled in the United States in 2010.
- The SDEIS assumes that Keystone XL could be shut down in twelve minutes. That is based on the time needed for the mechanical components to shut the pipeline down. It does not take the time needed for a human operator to identify a spill and initiate the correct response. With spills like the almost 1 million gallons of tar sands oil into Michigan’s Kalamazoo River, it took more than twelve hours for the pipeline to be shut down, not twelve minutes.
- The SDEIS claims that the natural gas condensate used to dilute the heavy bitumen will not separate from bitumen when it is spilled in a river. The State Department makes this claim to say that clean up will be easy because the bitumen will float. It then contradicts this claim later in the SDEIS by saying that the diluent and the bitumen will separate when spilled in the Ogallala Aquifer. The benefit of separation in the aquifer seems to be so that they can argue that the thick, clumping bitumen will be easier to clean from the underground water. This blatant attempt to make it seem as though there is no clean up problem with diluted bitumen at best shows the lack of expertise that the State Department brought to this hasty and minimal pipeline safety review. At worst, it shows a complete lack of concern for what are very real pipeline safety issues. In the real world, during a spill as the natural gas condensate will separate and evaporate fairly rapidly leaving heavy bitumen behind. The bitumen, which is heavier than water, will then begin to sink into the water column, whether in a river or an aquifer.
- The SDEIS acknowledges that tar sand crudes tend to have high sediment content. However, after citing industry research finding that a significant portion of this is made up of hard quartz and pyrite, it stops its analysis because it cannot find “readily available information to compare conventional crude oil with.” That simply won’t cut it - we need to have our pipeline regulators study this issue to determine what the risks are of having hard particles flowing in oil pipes and how this adds to the potential for leaks.
- The SDEIS ignores the explosion risk of diluted bitumen pipeline spills through tortured analysis which goes something like this: First, the State Department admits that Keystone XL will move a mixture of natural gas condensate and bitumen called diluted bitumen. However, because the State Department considers this mixture to be crude oil, and the SDEIS actually goes on to say that because crude oil “contains a relatively small proportion of volatile hydrocarbons” there is little risk of explosion. It then notes that almost all pipeline explosions are caused by volatile substances like natural gas condensate. This ridiculous analysis might be amusing if it wasn’t ignoring a very real risk of explosion from escaping natural gas in the case of a leak. Local communities, landowners and emergency responders deserve a better and more thorough analysis.