TRANSCANADA KEYSTONE XL PIPELINE: ALTERNATIVES – PART 5 | A Book: Nuclear Energy

The US Department of State (the Department) prepared the Final Supplemental Environmental Impact Statement (FSEIS) to assess the potential impacts associated with the proposed Project and its alternatives. The FSEIS takes into consideration over 400,000 comments received during the scoping period and 1.5 million comments received on the Draft Supplemental EIS issued in March 2013. Notable changes since the Draft Supplemental EIS include:

Expanded analysis of potential oil releases;
Expanded climate change analysis;
Updated oil market analysis incorporating new economic modeling; and
Expanded analysis of rail transport as part of the No Action Alternative scenarios.

Several alternatives exist for the transport of WCSB and Bakken crude oil to Gulf Coast refineries, including many that were not carried forward for detailed analysis. The FSEIS provides a detailed description of the categories of alternatives, the alternative screening process, and the detailed alternatives identified for further evaluation.

As a part of this initiative, the Department conducted detailed analysis on three broad categories of alternatives to the proposed Project, consistent with the National Environmental Policy Act (NEPA) and here are those categories:

No Action Alternatives: This category of alternatives addresses potential market responses that could result if the Presidential Permit is denied or the proposed Project is not otherwise implemented;
Major Route Alternatives: This category of alternatives includes other potential pipeline routes for transporting WCSB and Bakken crude oil to Steele City, Nebraska; and
Other Alternatives: This category of alternatives includes minor route variations, alternative pipeline designs, and alternative sites for aboveground facilities.

Consistent with NEPA and the Council on Environmental Quality (CEQ) regulations, the Department compared the proposed Project with the alternatives that met the proposed Project’s purpose and need, and that were carried forward for detailed analysis in the FSEIS. The alternatives carried forward for detailed analysis were:

2011 Steele City Segment Alternative under the category of Major Route Alternatives;
1-90 Corridor Alternative under the category of Major Route Alternatives;
Rail and Pipeline Scenario under the category of No Action Alternatives;
Rail and Tanker Scenario under the category of No Action Alternatives; and
Rail Direct to the Gulf Coast Scenario.

The two pipeline alternatives compare different routes that meet the purpose and need of the proposed Project, and the No Action Alternative scenarios describe the likely potential impacts associated with transport of crude oil from the Western Canadian Sedimentary Basin (WCSB) and the Bakken formations if the Presidential Permit is denied or if the proposed Project is not otherwise implemented.

1. COMPARISON OF ALTERNATIVES:

The two pipeline alternatives compare different routes that meet the purpose and need of the proposed Project, and the No Action Alternative scenarios describe the likely potential impacts associated with transport of crude oil from the WCSB and the Bakken formations if the Presidential Permit is denied or if the proposed Project is not otherwise implemented. The comparison focuses on three categories of impacts: physical disturbance, GHG emissions, and potential releases.

1.1 Physical Disturbance Impacts Alternatives Comparison:

The primary differences between the proposed Project and the alternatives related to physical disturbance are summarized in Table 5-01.

Physical Disturbance Impacts Associated with New Construction and Operations for the Proposed Project and Alternatives

Description

Status

Quo

Proposed Project

Major Pipeline Route Alternatives

No Action Alternatives

Alt 1

Alt 2

Alt 3

Alt 4

Alt 5

New Pipeline Length (Miles)

875

854

927

Number of New Aboveground Facilities

Length Co-located with Existing Keystone Pipeline (miles)

254

NDEQ-Identified Sand Hills Region Crossed (miles)

New Highly Erodible Soil (Wind) Crossed (miles)

116

Perennial Waterbody Crossings

1,216

330

711

Major Water Crossings

Number of Shallow Wells in Proximity

113

New NHPAQ Crossed (miles)

294

247

145

Wetland Affected during Construction (acres)

262

544

223

193

351

Communities within 2 Miles

350

182

669

Construction (Temporary) Land Area Affected (acres)

11,599

11,387

12,360

5,227

6,427

1,500

Operations (Permanent) Land Area Required (acres)

5,309

5,176

4,818

5,103

6,303

1,500

Source: Final Supplemental Environmental Impact Statement Table: 5-01

Alt 1 = 2011 Steele City Segment Alternative;

Alt 2 = 1-90 Corridor Alternatives;

Alt 3 = No Action – Rail/Pipeline Scenario;

Alt 4 = No Action – Rail/Tanker Scenario; and

Alt 5 = No Action – Rail Direct to the Gulf Coast Scenario.

1.2 Greenhouse Gas (GHG) Emissions Alternatives Comparison:

To facilitate comparison of GHG emissions across all alternatives for operational GHG emissions, an assessment was made for all alternatives along the entire route from Hardisty, Alberta, to the Gulf Coast (including pipelines in Canada and from Steele City to the Gulf Coast). GHG emissions from the two pipeline route alternatives would be similar in scale to those of the proposed Project. The direct emissions during the operation phase of the 2011 Steele City Segment Alternative would be essentially the same as those generated by the proposed Project because they would have the same number of pump stations (20). The I-90 Corridor Alternative is expected to have similar but slightly higher GHG emissions because it would have one more pump station than the proposed Project and could generate slightly higher amounts of indirect GHG emissions from electricity consumption.

During operation of all No Action rail scenarios, the increased number of unit trains along the scenario routes would result in GHG emissions from both diesel fuel combustion and electricity generation to support rail terminal operations (as well as for pump station operations for the Rail/Pipeline Scenario). The total annual GHG emissions (direct and indirect) attributed to the No Action scenarios range from 28 to 42 percent greater than for the proposed Project (see Table 5-02).

The indirect GHG emissions over the lifecycle of oil sands crude oil production, transportation, refining, and product use are compared between the proposed Project and the evaluated alternatives in Section ES.4.1.2, Lifecycle Analysis.

Annual Greenhouse Gas Emissions from Crude Transport (from Hardisty/Lloydminster, Alberta, to the Gulf Coast Area) Associated with the Proposed Project and Alternatives (per 100,000 bpd)

Description	Proposed Project	Major Pipeline Route Alternatives			No Action Alternatives
Description	Proposed Project	R. Alt 1	R. Alt 2		R. Alt 3	R. Alt 4	R. Alt 5
Operation (direct and indirect)—Transportation, Not Extraction
MTCO2e/Year per 830,000 bpd	3,123,859	3,123,844		3,211,946	4,428,902	4,364,611	3,991,472
MTCO2e/Year per 100,000 bpd	376,369	376,367		386,981	533,603	525,857	480,900
% Difference from Proposed Project	NA	0.0%		2.8%	41.8%	39.7%	27.8%

Source: Final Supplemental Environmental Impact Statement Table: 5-02

R. Alt 1 = Overall 2011 Steele City Segment Alternative Route;

R. Alt 2 = Overall 1-90 Corridor Alternative Route;

R. Alt 3 = No Action Rail/Pipeline Scenario;

R. Alt 4 = No Action Rail/Tanker Scenario; and

R. Alt 5 = No Action Rail Direct to the Gulf Coast Scenario.

1.3 Potential Spill Risk Alternatives Comparison:

Similar to the GHG emissions comparison, potential spill risk was evaluated for alternatives along the entire route from Hardisty, Alberta, to the Gulf Coast (including portions of the route in Canada and including existing pipelines from Steele City to the Gulf Coast). Table 5-03 provides a summary of calculated potential release impacts for the various alternatives analyzed in terms of the number of potential releases per year and the potential volume of oil released per year.

Potential Releases Impacts (Full Pathway) Associated with the Proposed Project and Alternatives

Description	Proposed Project	Major Pipeline Route Alternatives					No Action Alternatives
		R. Alt 1	R. Alt 2		R. Alt 3	R. Alt 4		R. Alt 5
								Option 1	Option 2
Miles for Transport (Overall Route)	1,938	1,917		1,990	3,902	14,014		4,624	5,375
Releases per Year	0.46	0.46		0.48	294	276		383	455
Barrels Released per Year	518	513		533	1,227	4,633		1,335	1,606

Source: Final Supplemental Environmental Impact Statement Table: 5-03

R. Alt 1 = Overall 2011 Steele City Segment Alternative Route;

R. Alt 2 = Overall 1-90 Corridor Alternative Route;

R. Alt 3 = No Action Rail/Pipeline Scenario;

R. Alt 4 = No Action Rail/Tanker Scenario; and

R. Alt 5 = No Action Rail Direct to the Gulf Coast Scenario.

Both of the major route alternatives would begin at the same border crossing as the proposed Project (near Morgan, Montana) and end at the same location as the proposed Project (near Steele City, Nebraska); as such, the pipelines in Canada north of the border crossing and the pipelines south of Steele City down to the Gulf Coast would be identical for all three overall pipeline routes. Compared to the proposed Project, the two major pipeline route alternatives would have similar potential spill risks. In addition, both of these major route alternatives would require aboveground facilities that are similar to those for the proposed Project; therefore, potential releases impact areas would be similar. Because the I-90 Corridor Alternative is slightly longer than the proposed Project, it would carry a slightly higher spill risk (with an estimated 533 bbl released per year compared to 518 annual bbl released for the proposed Project).

The three No Action Alternative scenarios differ from the proposed Project in that they would use alternative modes of transportation to deliver crude oil to refinery markets in the Gulf Coast rather than just a pipeline (although one of the three scenarios includes a pipeline as a significant part of its delivery system). Potential spill risks for these alternative modes differ from the proposed Project in terms of both average spill frequency and average spill size.

Volume of crude oil transportation by rail in the No Action Alternative scenarios would generally be limited to the volume contained within individual railcars. This volume constrains the total volume of crude oil that could potentially impact groundwater relative to the proposed Project in the event of a release. This constraint is offset by the increased statistical likelihood of spills associated with these alternative modes of crude oil transport relative to pipelines.

Historical rail incident data were analyzed to evaluate potential releases associated with rail transport in the United States. The results help provide insight into what could potentially occur with respect to spill volume, incident cause, and incident frequency for the No Action Alternative scenarios that involve rail transport. In addition, rail incident frequencies were compared to frequencies for other modes of transport (i.e., pipeline, marine tanker). Although the product to be transported by the proposed Project is crude oil, incidents for petroleum products were also analyzed to provide a comparison to a larger dataset. In order to make comparisons between the modes of transportation, the statistics regarding releases are expressed in terms of ton-miles (1 ton-mile is transporting 1 ton of product 1 mile; to calculate total ton-miles in a given year, one multiplies the total tons transported by the total number of miles transported).

The rates of releases and average size of releases vary between modes of transportation. For instance, rail transport has more reported releases of crude oil per ton-mile than pipeline or marine transport but, overall, pipeline transport has the highest number of barrels released per ton-mile. Comprehensive data from 2010 to 2013 are not yet available and therefore this analysis does not include incidents subsequent to 2009 such as the 2013 Lac-Mégantic rail tragedy or the Tesoro Logistics pipeline incident. The number of barrels released per year for the No Action scenarios is higher than what is projected for the proposed Project or the other pipeline alternatives because of the alternate modes of transport in the No Action scenarios.

There is also a greater potential for injuries and fatalities associated with rail transport relative to pipelines. Adding 830,000 bpd to the yearly transport mode volume would result in an estimated 49 additional injuries and six additional fatalities for the No Action rail scenarios compared to one additional injury and no fatalities for the proposed Project on an annual basis.

2. RECOMMENDATIONS:

As described briefly above, alternatives were developed and assessed based on information provided in the Presidential Permit application and supplemental submittals related to the application, information provided by the cooperating agencies, public comments received in the scoping process and on the Draft Supplemental EIS, and information obtained from research of relevant available information conducted by the Department and its third-party contractor.

Consistent with CEQ regulations, and the Department’s regulations and authority, the FSEIS identified alternatives before the decision maker for determination of whether or not the application serves the National Interest pursuant to the President’s Executive Order 13337. The FSEIS does not specify a Departmental preference between these two alternatives because no final United States position has been established on the application before the Department. These alternatives are:

The No Action Alternative; and
The Proposed Project.

3. OTHER PERSPECTIVES:

Pipelines have been used to transport Canadian natural gas and oil, both across Canada and into the United States, for over a century. Canada’s first pipeline began in 1853, with the development of a 25 kilometre cast-iron pipeline that moved natural gas to Trois-Rivières, QC, for street lights (Natural Resources Canada, 2013). Canada is home to an estimated 825,000 kilometres of transmission, gathering, and distribution pipelines. The National Energy Board, which has regulated inter-provincial and international pipelines since 1959, is currently responsible for 71,000 kilometres of oil and natural gas pipelines.

In June of 2013, the National Academy of Sciences released a study entitled Effects of Diluted Bitumen on Crude Oil Transmission Pipelines that was required as part of the Pipeline Safety, Regulatory Certainty and Jobs Creation Act of 2011. The report found no evidence that diluted bitumen, the type of crude oil that would flow through the proposed Keystone XL pipeline, would contribute to pipeline failures or corrosion.

Pipelines are the primary mode of transportation for crude oil, petroleum products, and natural gas in both Canada and the United States. Although North America is home to 825,000 kilometres of pipeline in Canada and 4.2 million kilometres in the US, US government authorities still insist on blocking additional pipeline construction.

It is true that in the face of expanding production and pipeline bottlenecks, more oil is moving by rail in both Canada and the United States, but transport of oil by rail (or other non-pipeline transportation modes) carries its own set of risks. While pipelines may leak, trains and trucks can crash, hurting individuals, as it was seen in case of Lac-Mégantic in July 2013, and barges can sink. There is no perfectly risk-free way to transport oil, or anything else for that matter.

US data on incident, injury, and fatality rates for pipelines, road, and rail for the 2005 to 2009 period (the latest data available) show that road and rail have higher rates of serious incidents, injuries, and fatalities than pipelines, even though more road and rail incidents go unreported. Americans are 75 percent more likely to get killed by lightning than to be killed in a pipeline accident.

A Global News analysis found that train spills in transit are larger than those from pipelines. And trucks, though they have a higher rate of accidents, tend to spill much less. Between January 1, 2006 and June 30, 2013, almost one third of all dangerous goods accidents on rail or road involved crude oil – much more than any other substance. But most of the 1,556 accidents in this time period happened while the vehicle was being loaded or unloaded; 645, or 41 percent, happened in transit.

After reviewing available data on the safety of different oil-transport modes, we conclude that the evidence is clear: transporting oil by pipeline is safe and environmentally friendly. Furthermore, pipeline transportation is safer than transportation by road, rail, or barge, as measured by incidents, injuries, and fatalities. Here is the link to Part 5 – Alternatives …

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