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

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Draft Supplemental Environmental Impact StatementKeystone XL Projectspecific design requirements or construction scope of work, or incorporation into Keystone’sIntegrity Management Plan or Operations Manual.• NTSB Accident Reports: Keystone reviews these draft and final reports for pertinent findingsand incorporates them into design basis or procedures, if applicable.• Industry Publications: Keystone has representation on all major Standards and AssociationCommittees and incorporates the appropriate feedback into specification revisions for itspipeline assets, including Keystone, as appropriate through the Company’s EngineeringStandards group.• PHMSA Special Conditions 25c and 43 are examples of where NTSB accident reports andPHMSA advisory bulletins are incorporated into the Project.Environmentally, the lessons learned from the Marshall, Michigan, dilbit spill behavior andrelated response implications include:• The total volume of dilbit released to a river will not float on water indefinitely and dilbitcharacteristics, water temperature, and particulate load in the water could result in much ofthe oil being submerged in the water column.• Submerged oil can be suspended in the water column, suspended just above the river bed, orintermixed with sediment and trapped in the river bed and shoreline.• Submerged oil in a flowing water environment introduces additional recovery challenges forresponders.• Response action planning and response equipment to contain and recover submerged oilshould be considered.• Dilbit intermixed with sediment and trapped in the river bed and shoreline may result in apersistent source of oil and dissolved components such as benzene, polycyclic aromatichydrocarbons, and heavy metals that could be slowly released back to the water column andtransported down current.• Dilbit intermixed with sediment can persist for years.The pipeline involved in the Marshall, Michigan, incident was constructed in the 1950s. Pipelinestandards have evolved and new technologies have resulted in improvements in pipeline safetyperformance. Pipelines are now constructed with higher quality steel that is stronger and hasbetter fracture resistant properties, helps reduce the impacts of external forces, such as floodingand excavation damage. Improvements in external pipeline coatings, the use of cathodicprotection, and mandatory in-line inspection tools have resulted in significant reductions incorrosion-related incidents. TransCanada has not experienced a corrosion-related failure on anyof its pipelines that utilize modern FBE coatings. Federal pipeline regulations have evolved overtime and pipeline operators are now required to actively manage their pipelines to reduce thepossibility of incidents. Operating procedures and leak detection capabilities have improved tomore quickly detect leaks, thereby minimizing the amount of crude oil released and reducingsubsequent impacts.Project Description 2.1-70 March 2013
Draft Supplemental Environmental Impact StatementKeystone XL ProjectKeystone has reviewed the NTSB 2012 Marshall, Michigan Accident Report including theconditions that led to operational failures on the pipeline that resulted in the spill. Keystonewould include lessons learned from this spill, including:• Get big quick: timeliness of a tactical response to an oil spill into water is imperative. WhileKeystone has stated that it already uses this philosophy, the Kalamazoo spill reinforced thisneed to respond with as many resources as possible as quickly as possible. To that end,Keystone would strategically store equipment and employ personnel and contractors alongthe length of the pipeline to ensure a maximum of a 6-hour response time.• Pre-qualify a large contractor network: Contractors would be used to supplement anyresponse Keystone would make to an oil spill. By ensuring a large pool of trained/skilledcontractors along the length of the pipeline have been pre-qualified and contracted withKeystone, the response time would be minimized and resources (equipment and personnel)available are maximized.• Emergency response planning details need to include source containment: sourcecontainment plans including strategies and tactics would be included in the overarching ERP.• Equipment resources required for sunken and submerged oil: Keystone would furtheridentify equipment resources required to respond to sunken and submerged oil and ensurepersonnel are appropriately trained on its use. A primary strategy for oil spill response wouldstill be to contain and recover as much oil as possible as quickly as possible to prevent oilfrom weathering and therefore potentially becoming submerged and sinking. In addition,Keystone already owns and practices the use of containment devices that will preventdownstream migration of submerged and sunken oil such as dams. This type of equipmentwould be further identified and procured for the proposed Project.In addition, Keystone would implement its own company standards and the 57 SpecialConditions, which include operational requirements. The proposed Project would be constructedto standards that exceed current federal regulatory requirements. In addition to company-specificstandards that exceed current federal pipeline safety standards (e.g., typical burial depth of 4 feetof cover rather than the standard 3 feet depth of cover), Keystone has agreed to implement anadditional 57 Special Conditions identified in the Final EIS. The Final EIS stated that theimplementation of these additional conditions would result in a level of safety equal to orexceeding the current levels as required by federal regulations.Pipeline conditions along the proposed Project would be continuously monitored 24 hours a day,7 days a week. The proposed Project would have over 16,000 sensors along its length andmultiple, overlapping state-of-the-art leak detection systems.While flood conditions are not a leading cause of pipeline failures, they can be a threat topipeline integrity in certain locations. Under federal regulations (49 CFR Part 195), Keystone’sIntegrity Management Program is required to monitor and reduce risks from various threats, suchas outside forces due to flooding. Keystone has evaluated stream crossings to identify thoselocations where stream scour could affect pipeline integrity. Where there is potential forsignificant stream scour, Keystone has increased burial depth so stream scour does not pose athreat to pipeline integrity. Additionally, under Special Condition 19, Keystone is required tomaintain depth of cover for the life of the Project.Project Description 2.1-71 March 2013
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2.1 Overview of the Proposed Project - Keystone XL pipeline - US ...

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