2.1 Overview of the Proposed Project - Keystone XL pipeline - US ...

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Draft Supplemental Environmental Impact StatementKeystone XL Projectdetect leaks down to approximately 5 percent of pipeline flow rate. Computational PipelineMonitoring or model-based leak detection systems would separate the pipeline system intosmaller segments and would monitor each segment on a mass balance basis. These systemswould detect leaks down to a level of approximately 1.5 to 2 percent of the pipeline flow rate.Computer-based, non-real time, accumulated gain/loss volume trending would assist inidentifying low rate or seepage leaks below the 1.5 to 2 percent by volume detection thresholds.If any of the software-based leak detection methods indicates that a predetermined loss thresholdhas been exceeded, an alarm would be sent through SCADA and the Controller would takecorrective action. The SCADA system would continuously poll all data on the pipeline at aninterval of approximately 5 seconds.If an accidental leak were to occur, the operator would shut down operating pumping units andclose the isolation valves. Once shutdown activities are initiated, it would take approximately 9minutes to complete the emergency shut-down procedure (shut down operating pumping units)and an additional 3 minutes to close the isolation valves.In addition to the SCADA and complementary leak detection systems, direct observationmethods, including aerial patrols, ground patrols and public and landowner awareness programs,would be implemented to encourage and facilitate the reporting of suspected leaks and eventsthat could suggest a threat to the integrity of the pipeline.Keystone has committed to keep abreast of the latest developments in external leak detectiontechnologies (above and beyond those already proposed to be implemented, as described) thatcould be installed along the pipeline at sensitive locations. In Nebraska, Keystone would reportto, and discuss with, the Nebraska Department of Environmental Quality (NDEQ) the status ofinnovation in such pipeline leak detection equipment and the methods on or before January 1,2014, and at such additional times thereafter until 2024 as the NDEQ shall specifically request,but in no case more frequently than once every three years. A similar leak detection requirementexists in the SDPUC certificate. There is no comparable requirement in Montana.Emergency Response ProceduresPHMSA requires that pipeline operators prepare and abide by both the PSRP and the ERP forresponding to emergencies on their systems. 49 CFR 194 requires that pipeline operators haveresponse plans that ensure resources are available to remove, mitigate, or prevent a dischargefrom an oil pipeline that could cause substantial or significant harm to the environment,including a worst case discharge. As stated in 49 CFR 194.7(a), a pipeline operator “may nothandle, store, or transport oil unless the operator has submitted a response plan meetingrequirements of this part,” and as stated in 49 CFR 194.7(b), operators must also operate onshorepipeline facilities in accordance with the approved response plan. In addition, 49 CFR 194.107requires that the response plan include “procedures and a list of resources for responding, to themaximum extent practicable, to a worst case discharge, and to a substantial threat of such adischarge.”Keystone would determine the optimal location of spill response equipment, taking into accountresponse times to sensitive areas and receptors. These spill response locations would be reflectedin the ERP that would be submitted to PHMSA for review and approval.Keystone would submit a PSRP to PHMSA prior to initiation of proposed Project operations inaccordance with the requirements of 49 CFR 194. The PSRP would describe how spills would beProject Description 2.1-68 March 2013
Draft Supplemental Environmental Impact StatementKeystone XL Projectresponded to in the event of a release from the proposed Project resulting from any cause (e.g.,corrosion, third-party damage, natural hazards, materials defects, hydraulic surge). The planwould address the maximum spill scenario and the procedures that would be in place to deal withthe maximum spill. The PSRP requires PHMSA review and approval; however, there is a 2-yeargrace period under which operations can proceed, thus allowing PHMSA time to review thedocument in light of as-built Project conditions and to require incorporation of any neededchanges to ensure system safety prior to PHMSA approval.As required by 49 CFR 195.40, Keystone would also prepare and follow a manual of writtenprocedures for conducting normal operations and maintenance activities and handling abnormaloperations and emergencies. This manual would be reviewed by PHMSA at intervals notexceeding 15 months, but at least once each calendar year, and appropriate changes would bemade as necessary to ensure that the manual is effective. This manual would be prepared beforeinitial operations of the proposed Project and appropriate sections would be kept at locationswhere operations and maintenance activities are conducted. The emergency section of thisoperations and maintenance plan would be prepared by Keystone in a separate document thatKeystone refers to as the ERP.While USEPA has authority under the Clean Water Act and Oil Pollution Act of 1990 withrespect to regulation of onshore non-transportation related facilities and USEPA requires thedevelopment and submittal of a Facility Response Plan for any such facility, it appears that noneof the facilities or activities associated with the proposed Project would be subject to the USEPAregulatory authority, as discussed below. Keystone would therefore be required to develop aPSRP for review and approval by PHMSA and an ERP for review by PHMSA for the proposedProject. PHMSA may request USEPA and U.S. Coast Guard consultation on the responseelements of the PSRP. Keystone would share on its own volition portions of the PSRP withcommunity emergency responders along the proposed pipeline corridor to ensure an appropriatelevel of collaborative emergency response planning. However, based on a PHMSA advisorybulletin issued on November 3, 2010, Keystone would be required to share the ERP with localemergency responders in relevant jurisdictions along the proposed Project corridor. The bulletinnotes that operators of gas and hazardous liquid pipeline facilities must make their pipeline ERPsavailable to local emergency response officials.While the draft PSRP and the draft ERP for the proposed Project are not yet available, Keystoneprepared similar plans for the existing Keystone Pipeline Project. These plans for the proposedProject would have the same general approach as those plans but would have many specificdifferences, such as the names and contact information for responders along the proposed Projectroute.There have been concerns raised about the possibility of a spill comparable to the Kalamazoospill in Marshall, Michigan, on the proposed Project. There are a number of reasons, discussedbelow, that this is not anticipated. Nevertheless, Keystone would be prepared to respond to a spillof a similar magnitude and extent of the Marshall, Michigan, incident. Further, the lessonslearned from the incident would be incorporated into industry recommendations and guidance.Keystone would incorporate lessons learned throughout the life of the project in the followingways:• PHMSA Advisory Bulletins: These items are incorporated in the applicable phase of theProject (e.g., design, construction, or operations) through modification of the Project’sProject Description 2.1-69 March 2013
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2.1 Overview of the Proposed Project - Keystone XL pipeline - US ...

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