2015/08/07

Comments on the scope of the WesPac EIR, part 1

August 7th, 2015 - my first email submitting comments, on issues other than climate change. Part two focuses on climate change.

In this document, I am listing all comments on the scope of the WesPac 2015 RDEIR other than those related to climate change.

Pipeline and tank integrity issues


When I refer to "pipelines", I mean both the pipelines fully internal to the site, as well as the external pipelines that connect to the regional refineries and other distribution networks.

Please include detailed information about the age of all tanks and pipelines. Which of these tanks will be refurbished?

What are the limits of vapor pressure that the tanks and pipelines can handle? How does this compare to the known very high vapor pressure of Bakken shale oil?

What other effects does crude type have on pipeline or tank integrity? For example, both tar sands dilbit and Bakken shale are likely to be more corrosive than fuel oil or other crudes, and the more viscous tar sands dilbit is likely to be pumped at higher pressure than other crudes. Tar sands dilbit is also often heated to get it to flow; how does this affect pipeline integrity? It could increase corrosion and it could also increase wear-and-tear from thermal expansion and contraction.

The Mayflower spill in Arkansas was a result of the rupture of Pegasus, a 65-year-old pipeline that was intended for refined products. Exxon 1) reversed the flow and 2) sent more corrosive tar sands dilbit down the pipe 3) at high pressure. All three actions stressed the already quite old pipeline; together, they weakened it enough to rupture it.

To what extent do the plans for external pipelines connected to the WesPac site match the Mayflower situation? As I understand it, they are almost as old as the Pegasus pipeline, and transported fuel oil from the refineries to the storage tanks. WesPac would reverse that flow, and its products could be more corrosive and pumped under higher pressure (as noted above). How does this increase the stress on the pipelines, and to what extent does this increase the chances of a leak or rupture?

How much can double-walled pipelines reduce these risks? Please note that there have been recent spills even with double-walled pipelines; see e.g. http://globalnews.ca/news/2116785/nexen-to-provide-update-on-northern-alberta-pipeline-spill/

Please use total numbers for us to better assess risk. As noted in http://pittsburgdc.org/?p=583 the previous EIR listed leak and rupture probabilities for each pipeline segment. Those numbers are each low, but summing them together they give a return period of less than 30 years; i.e. a rupture or leak of one of the pipelines during the oil terminal’s lifetime is very likely. (I would add that those numbers don't reflect the greater risks of expected crude types as listed above.)

Similarly, leak, spill, and rupture probabilities can be presented per-tank, but should also be summed to give the probability of at least one leak, spill, or rupture occurring on the site.

The possibility of legally binding restrictions


Is it possible for us to get a legally binding restriction against the use of tar sands-based crudes in this project?

Is it possible for us to get a legally binding restriction against ever adding a rail component to this site in the future?

Is it possible for us to get a legally binding restriction against the use of this facility to export crude oil or partially refined crude oil, in the event that the federal restriction against crude oil export be repealed?

Miscellaneous


Why is diesel, a finished product, included as a possible cargo, given that the project need claims a lack of adequate storage for crude oil in the Bay Area?

There appear to be health dangers of tar sands dilbit due to the volatilization of the diluent beyond than that of other crudes. Please include the latest information and research on this point.

In Vancouver, Washington, the EPA has asked for the EIR for a proposed oil-by-rail terminal there to include "a broad, cumulative analysis that considers not just [that] terminal but other regional facilities that handle crude oil" (see http://www.columbian.com/news/2015/aug/03/epa-oil-terminal-plan-doesnt-pass-muster/ ). Similarly, the WesPac project should be considered within a broader regional context of oil facility development, including refinery marine terminal enhancements and crude-by-rail facilities in San Luis Obispo, Benicia, and Richmond.

Please include a consideration of a project alternative of no heating.

Finally, I ask that information about the EIR be distributed quite widely, and not just given to those who live within a relatively short distance of the site. I'd recommend that all those who live within a mile of the site be notified, and that such notification be provided in simple English and in other languages, including Spanish and Tagalog.

Thank you,

Martin MacKerel
1647 McAllister St. #6
San Francisco, CA 94115