DOE/EIS-0034 BOOKSTACKS* Hnal Supplement to Rnal Environmental Impact Statement FEA-FES-76-2 STRATEGIC PETROLEUM RESERVE Expansion of Reserve U.S. DEPARTMENT OF ENERGY January 1979 UNtV. OF ILL. L!3^APV UNIVERSITY OF STACKS Available from: National Technical Information Service (NTIS) U.S. Department of Commerce 5285 Port Royal Road Springfield, Virginia 22161 Price: Printed copy: $13.00 Microfiche: $3.00 DOE/EIS-0034 UC-11, 13, 92 Hnal Supplemeiit to Hnal Environmental Impact Statement FEA-FES-76-2 STRATEGIC PETROLEUM RESERVE Expansion of Reserve Responsible Official Ruth C. Clusen Assistant Secretary for Environment U.S. DEPARTMENT OF ENERGY Washington, D.C, 20545 January 1979 Digitized by the Internet Archive in 2013 http://archive.org/details/strategicpetroleOOunit_0 SUMMARY STATEMENT TYPE: ( ) Draft ( ) Final Environmental Statement (X) Final Supplement to Final Environmental Statement PREPARED BY: The Strategic Petroleum Reserve Office, Federal Energy Administration, Washington, D.C. 20461 1. Type of Action: ( ) Legislative (X) Administrative 2. Brief Description of the Proposed Action; The Department of Energy Administration proposes to implement the Strategic Petroleum Reserve, Title I, Part B of the Energy Policy and Conservation Act of 1975 (P.L. 94-163). The purpose of the Reserve is to mitigate the economic impacts of any future interruptions of petroleum imports. The impacts of storing one hundred fifty million barrels (MMB) of oil by 1978 and five hundred MMB by 1982 were addressed in the final programmatic EIS and the SPR Plan. It is now proposed that the SPR be expanded to store a total of 1,000 MMB. This supplement addresses the environmental impacts of this proposed expansion. 3. Summary of Environmental Impacts and Adverse Environmental Effects; This supplement to the final programmatic EIS has identified which environmental parameters would be particularly sensitive to an increase in the amount of oil stored. The expanded SPR also causes cumulative impacts (those impacts that are additive because of the location of two or more facilities in the same geographical area, and those which result from two or more oper- ations at the same facility) to become more important. The most sensitive parameters appear to be water quality and geology. The adverse impacts that could result from the expanded program include the degradation of surface water quality from construction runoff, increased dredging, and more frequent oil spills. In addition, brine disposal associated with solution mining salt cavities will increase the salinity of the receiving waters, whether under- ground saline aquifers or small portions of the Gulf of Mexico. Changes in water quality will have a short-term impact on aquatic organisms in local areas. Use of large quantities of ground water for developing salt cavities could cause some surface subsidence over water storage areas, slow salt water encroachment, and movement of near-surface geologic faults. The expanded program would also increase hydrocarbon emissions from the use of above ground tanks and fill and withdrawal operations which may cause temporary localized violations of the Federal standard, but no long-term adverse impact on air quality would result. 4. Alternative Considered : The following alternatives were addressed in the final EIS. Non-Structural Alternatives to the Strategic Petroleum Reserve Increase Domestic Energy Supplies Reduce Energy Demand by Conservation No Action Shut-in Capacity Alternative Methods of Acquiring the Oil Naval Petroleum Reserve Oil Royalty Oil Old Oil Open Market Purchase of Oil Imported Oil Implementing the industrial Petroleum Reserve Structural Alternatives Solution-Mined Cavities in Salt Conversion of Salt and Other Mines Aboveground Tanks Laid-Up Tankers 5- Comments on the Supplement have been rece ived from the following; ~ ' ~ Federal Agencies Department of Commerce Department of Interior Environmental Protection Agency State Agencies Arizona Solar Energy Research Kentucky Bureau of Environmental Protection North Dakota Geological Survey Texas Parks and Wildlife Department Texas Department of Agriculture Texas Department of Water Resources Other Organizations National Wildlife Federation 6. Date made available to CEQ and the Publi c; The Final Environmental Impact Statement was made available to Council on Environmental Quality and to the Public on December 17, The draft supplement was made available to the Council on Environmental Quality and the Public in September 1977. This final supplement was made available to the Environmental Protection Agency and the public in January 1979. TABLE OF CONTENTS Page I. INTRODUCTION AND SUMMARY I-l A. Overview of Program Objectives 1-6 B. Major Types of Storage Facilities 1-7 C. Description of the Environment 1-7 D. Environmental Impacts on the Gulf and East Coast 1-8 1. General 1-8 2. Air Quality 1-9 E. Measures to Mitigate Adverse Impacts I-IO F. Irreversible and Irretrievable Commitments of Resources I-IO G. Program Alternatives I-IO 1. Alternatives to the Proposed Action . . I-IO 2. Alternative Methods for Acquiring the Oil I-IO 3. Industrial Petroleum Reserve I-ll H. Environmental Impact Statement Content .... I-ll II. PROGRAM DESCRIPTION II-l A. Need for Strategic Petroleum Reserve II-l B. Authorization for the Strategic Petroleum Reserve II-l C. Requirements for Storage Capacity II-2 1. Strategic Petroleum Reserve II-2 2. Early Storage Program II-3 3. Regional Petroleum Reserve II-3 D. Summary of Major Storage and Distribution Facilities II-4 E. Selection of Candidate Storage Sites II-4 1. Seaway II-5 2. Texoma II-5 3. Capline II-6 4. Other Sites II-6 F. Considerations for System Flexibility II-7 1. Terminal Locations II-7 2. Pipeline Lengths II-8 G. Implementation of the Reserve II-8 1. Environmental Action Reports II-9 2. Environmental Planning for Oil Transport 11-12 3. Spill Prevention Control and Counter- measure Plan 11-12 III. ALTERNATIVES III-l A. Non-Structural Alternatives III-l 1. Industrial Petroleum Reserve III-2 2. Shut-in Storage III-3 3. Noncontiguous Areas III-3 B. Structural Alternatives III-4 ii IV. DESCRIPTION OF THE ENVIRONMENT IV-1 A. Gulf Coast Storage Region [ iv-1 1. Geology IV-2 2. Hydrology IV-3 a. Surface Water Hydrology IV-4 b. Ground Water Hydrology IV-10 3. Meteorology, Climatology and Air Quality IV-12 4. Noise IV-13 5. Biology | * iv-i3 6. Land Use Patterns IV-14 a. Mississippi: State Land Use Planning . IV-15 7. Population and Economic Factors IV-16 B. East Coast Storage Region IV-21 V. ENVIRONMENTAL IMPACTS V-1 A. Gulf Coast Storage Region , ', v-2 1. Coastal Subregion V-2 a. Geology V_2 b. Hydrology and Water Quality v-2 c. Meteorology, Climatology and Air Quality V-4 (1) Onshore Strategic Petroleum Reserve V-6 (2) Offshore Strategic Petroleum Reserve V-11 d. Noise V-16 e. Biology V-22 f. Historical and Archaeological Reserve. V-23 g. Land Use V-23 (1) Effects of Site on Surrounding Land Use V-24 (2) Site Uses V-25 (3) Land Use Planning V-26 (4) Recreation V-27 h. Economic and Social Impacts V-28 (1) Storage in Solution Caverns . . . V-29 2. Inland Subregion V-32 a. Hydrology V-34 (1) Surface Water V-34 (2) Ground Water V-34 (3) Brine Disposal V-36 (4) Other Water Quality Impacts . . . V-37 (5) General Conclusions V-37 b. Air Quality Impact V-38 c. Biology V-39 B. East Coast Storage Region V-43 1. Background V-43 2. Air Quality Impacts V-43 C. Oil Spills V-50 1. Ecological Impacts V-56 a. Relative Vulnerability of Organisms. . V-59 b. Relative Toxicity of Oils and Petroleum Products V-59 iii c. Biological Recovery V-62 d. Effects of Chronic Oil Pollution . . . V-64 e. Summary of Effects on Marine Organisms V-65 2. Ecological Effects of Onshore Spills . . . V-66 3. Ecological Effects of Spills of Refined Products V-68 4. Regional Overviews V-69 a. Texas Gulf Coast V-70 b. Southeastern Coastal Area of Louisiana V-71 c. Atlantic Coast Region V-73 D. Summary of Cumulative Impacts V-74 VI. MITIGATING MEASURES AND UNAVOIDABLE ADVERSE ENVIRONMENTAL IMPACTS VI-1 A. Mitigating Measures VI-1 1. General Measures VI-1 a. Use of Existing Storage Space VI-1 b. Location - VI-5 c. Accident Risk Reduction .VI-3 d. Pipeline VI-4 e. Pipeline Construction Methods VI-5 (1) Conventional Land Lay Construction VI-5 (2) Conventional Push-Ditch Construction VI-6 (3) Flotation Canal Construction. . .VI-9 (4) Pipeline Construction at Crossings VI-10 f. Accident Prevention VI-14 g. Rock Disposal VI-14 2. Geology VI-15 3. Hydrology VI-15 a. Brine Disposal . .VI-15 b. Sediment Production VI-I6 c. Dredging VI-16 d. Water Use VI-I6 e. Aqueous Discharge VI-17 4. Meteorology and Climatology VI-17 a. Air Quality VI-17 b. Pressurized Underground Storage Space VI-18 c. Air Residuals of Aboveground Tankage .VI-18 (1) Construction VI-I8 (2) Filling VI-19 (3) Static Storage VI-19 (4) Withdrawal VI-19 d. Marine Tanker Operations VI-20 (1) Unloading Operations VI-20 (2) Loading VI-21 IV 5. Biology 6. Noise ::;;:•• •vi-22 7. Historical and Archaeological Resources. .*VI-22 ». Land Use and Related Planning VI-22 a. State Land Use Programs vi-' Storage Site .*!.'.* ivi-' b. Storage Site . . //. ..,.'' *vi-24 9. Control and Cleanup of Spilled Oil .* ! .* .'vi-24 a. Spill Prevention Control and Countermeasure Plan VI-25 b. Oil Spill Contingency Plans. ! .* * * *VI-2fi c. Operations Manuals * * *VT 97 d. Salt Marsh Cleanup !.'.'* *VI-28 e. Bacterial Degradation and Other* Biological Processes VI-29 f. Costs of Oil SjDill Cleanup ...*.* [ .'vi-30 g. Summary of Spill Removal Techniques*. . !vi-30 h. Containment and Cleanup at Terminal. .VI-31 1. Containment at Sea VI-32 j. Containment at Coastal Inlets! ! ! .* .*vi-33 k. Beach Cleanup !vi-34 1. Biological Decomposition ... * vi-36 m. Costs of Oil Spill Cleanup ....*! *vi-38 10. Mitigating Effects of FEA Planning . . . .vi-39 11. Floodplains/Wetlands Mitigation. . . vi^O B. Unavoidable Adverse Impacts ... ' 'vi^l 1. Geology .*.*;!.* ivi^l a. Gulf Coast Region VI-41 b. East Coast Region. ... • • • 2. Hydrology .*.'.'.*.' ;vi^2 a. Gulf Coast Region VI-42 (1) Surface Water Impacts ...*.* [ .*vi-42 (2) Ground Water Impacts .*VI-44 b. East Coast Region VI-45 3. Meteorology, Climatology and Air Quality .*VI-46 4. Noise ^ utJ^ I' Biology :;:.*:.*; ivi:^^ 6. Historical and Archaeological Resources. .VI-47 7. Recreational Resources . . . vt-^-7 8. Land Use .*.*.*.*! ivi^s 9. Economic and Social Impacts. .,','.,[ .*VI-49 VII. IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES VII-1 A. Land Resources !!!!!!' VII-1 B. Water Resources !!!!!.*!!! VII-2 C. Ecological Resources ! 1 ! ! ! ! ! VII-3 D. Archaeological and Historical Resources. . . viI-4 E. Human Resources VII-4 F. Materials ',',[['.'' viI-4 G. Energy .'.*.*.*.*.*.*.* .* .* .' viI-5 VIII. RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY VIII-1 A. Geology and Hydrology VIII-1 B. Water Quality VIII-2 C. Air Quality VIII-3 D. Biology VIII-4 E. Archeological and Historical Resources. . . .VIII-5 F. Recreation VIII-5 G. Agriculture VIII-5 H. Socioeconomic Factors VIII-6 IX. CONSULTATION AND COORDINATION WITH OTHERS . . . .IX-1 A. Agencies and Groups Consulted IX-1 B. Parties from Which Comments were Requested. .IX-2 C. Parties from Whom Comments were Received. . .IX-5 X. BIBLIOGRAPHY X-1 APPENDIX A OIL SPILLS APPENDIX B CONSIDERATION OF TANKER LOADING AND UNLOADING EMISSION FACTORS AND THROUGHPUTS APPENDIX C LETTERS OF COMMENT VI Table I-l. Table IV-1 Table IV-2 Table IV-3 Table IV-4 Table IV-5 Table IV-6, Table V-1. Table V-2 . Table V-3. Table V-4. Table V-5. Table V-6. Table V-7. Table V-8. Table V-9. Table V-10. Table V-11. Table V-12. Table V-13. Table V-14. Table V-15. Table V-16. LIST OF TABLES Page Scenarios for an Enlarged Strategic Petroleum Reserve I_4 Flow Data for North Louisiana Streams. '. ! *lv-6 Flow Data for Mississippi Streams IV-9 Projected Percent Increase in Total Population of United States IV-17 Projected Population Percentage Increase . .IV-18 Quality-of-Life Rankings for SMSA's in Salt Dome Region IV-19 Percent of Total Earnings by Industry 1971 lv-21 National Ambient Air Quality Standards (s) v-5 Comparison of Major Fugitive Hydrocarbon Emissions from Two Example Salt Dome Facilities to AQCR Emissions from all Sources Y_9 Throughputs and Scenarios for the Crude Oil Transport and Transfer Operations at Terminal Areas V-13 Estimated Emissions and Air Quality Impacts at Terminal Areas V-15 Sound Levels Required to Protect Public Health and Welfare V-18 Maximum A-Weighted Sound Levels That Will Permit Acceptable Spoken Communication for Voice Levels and Listener Distances Shown . V-19 Sound Pressure Level (dB) at 50 Feet From Drilling V-21 Quality of Telephone Usage in the Presence of Steady-State Masking Noise v-21 General Water Availability Northern Louisiana Salt Domes-For Programmatic EIS Expansion . V-35 Comparison of Fugitive Hydrocarbon Emissions From Example Tank Storage Facility to Total Annual Emissions in AQCR's on East Coast. . V-46 Peak Hourly Hydrocarbon Emissions From Example Tank Storage Facility and Estimated Maximum Concentrations V-47 Combustion Emissions From Steam Boiler for Heating Stored Product V-49 Risk of Oil Spills for Major Geographical Areas V_53 Summary of Effects of Oil on Some Major Ecosystems V-58 Summary of Effects of Oil on Populations and Communities V-60 Cumulative Impacts - Maximum Local Storage of Product (Worst Case) V-75 vii Table V-17. Table V-18. Table V-19. Table V-20. Table V-21. Table V-22. Table V-23. Table V-24. Cumulative Impacts - Maximum Local Storage of Product (Expected) V-76 Cumulative Impacts - Maximum Local Storage of Product (Expected) V-77 Cumulative Impacts - Maximum Substitution of Crude Oil (Expected) V-78 Cumulative Impacts - Maximum Substitution of Crude Oil (Expected) V-79 Cumulative Impacts - Maximum Substitution of Crude Oil (Worst Case) V-80 Cumulative Impacts - Maximum Substitution of Crude Oil (Expected) V-81 Cumulative Impacts - Maximum Substitution of Crude Oil (Expected) : * * V-82 Cumulative Impacts - Maximum Substitution of Crude Oil (Expected) V-83 Vlll LIST OF FIGURES Page Figure Il-l The SPR Environmental Process. . . . ii-in Figure III-l. Feasible Staging Points for Transfe^ if' Crude from Small Tankers or Barge Tows to FianrP TM 1 ^P^P^li^^es of 80 Miles in Length or Less III-6 Figure iv:2 Surf^'' drainage Area-Northern Louisiana. lv-5 figure iv 2. Surface Drainage Pattern in the ^„ , Mississippi Salt Dome Field Area. tv-r Figure IV-3. Geologic Section of Rayburns salt domi * Bienville Parish ' Tv-n Figure V-1. Locations of Salt Domes Relative to' * * Fianr^ VT 1 rp^''^^^.^"^ ^^^^ ^""^ Freshwater Wetlands. . .v-40 Figure VI-1. Typical Cross-Section of Conventional Dry Land Pipeline Construction After Excavation and Several Months After Backfilling „,_^ Figure VI-2. Typical Cross-Section of Conventional' ' Push-Ditch Pipeline Construction After Excavation and Several Years After Backfilling „, o Figure VI-3. Typical Cross-Section of 6oi;v;n;i(;n;i * ' ' Flotation Canal Construction After Excavation and Several Years After Pipeline Installation ... vt n Figure VI-4. Typical Cross-Section of Conventional* * ' Flotation Canal Expansion of Existing Canal After Excavation and Several Years After Pipeline Installation . . . .vi-12 IX I. INTRODUCTION AND SUMMARY All agencies of the Federal Government are required by the National Environmental Policy Act of 1969 (NEPA) , 16 U.S.C. 4321 et seq. , as implemented by Executive Order 11514 of March 5, 1970, the Council on Environmental Quality (CEQ) Guidelines of August 1, 1973, to prepare a detailed environ- mental impact statement (EIS) on proposals for legislation and other major Federal actions significantly affecting the quality of the human environment. The objectives of the NEPA are to (1) build into the agency decision-making processes an appropriate and careful consideration of all environmental aspects of proposed actions, (2) explain potential environmental effects of proposed actions and their alternatives for public understanding, (3) avoid or minimize adverse effects of proposed actions, and (4) restore or enhance environmental quality as much as possible. The Energy Policy and Conservation Act of 1975 (EPCA) , Title I, Part B, Strategic Petroleum Reserve, provided for the creation of necessary strategic reserves. The impact of this action on the environment was investigated and the results published as the Final Environmental Impact Statement, Volume I , Strategic Petroleum Reserve, FES 76-2, December, 1976 by the Strategic Petroleum Reserve Office of the Federal Energy Administration (FEA) . The responsibility for implementing the Strategic Petroleum Reserve (SPR) which was originally vested in FEA by EPCA was assumed by the U.S. Department of Energy (DOE) on October 1, 1977, with the inception of the new department. The schedule for development of the SPR established in the EPCA and addressed in the SPR Plan, which became effective I-l on April 18, 1977, and was assessed in the FEIS, was to store 150 mxllion barrels (MMB) of oil by DecenO^er 1978 and 500 MMB by Dece^er 1982. However, as ^ of the I^tic^i ^r^ ,,^ the President recommended a 1 billion barrel reserve wMcL is the maximum size authorized under the EPCA. This increase provides greater insurance against the effects of a petroleum supply interruption, fin SPR Plan Amendment, which became effective on June 13, 1978, increased the approved reserve size to 1 billion barrels. 1-2 Impacts of the expansion to 1,000 MMB have been assessed in this supplement by using the cumulative impacts and assum- ing worst case scenarios of critical areas. Table I- 1 outlines scenarios for an enlarged reserve. These scenarios are similar to those used in FES 76-2. Three alternative storage systems for satisfying the objectives of the program were identified. These alternatives, which remain valid, were specified in the final environmental impact statement (FES) for SPR. These alternatives were solution-mined cavities in salt, conventional mines and above-ground tankage. Prototype "worst case" facilities were developed to characterize these systems and to provide a basis for determining potential program impacts and resource requirements. These facilities will provide the basis for determining impacts in this supplement with the factors of an accelerated schedule and a proposed larger quantity being integrated into the basic program to establish new "worst case" conditions for examining the environmental impacts. 1-3 TABLE I-l SCENARIO S FOR AN EN LARHph STRAThblC PETROLEUM RF^^wp Facility Typ p Product Conventional tanks New Rock Mines Crude Oil New solution salt dome cavities Existing solution salt dome cavities Existing salt mines Existing rock mines V Total '"'an'SMBr ' ^— -° NO. 2 (Expect, ^ "^ ^ (in MMB) SPR Composition Assuming Maximum ^ocal Storage of Pmriur^^- 95 605 210 90 1,000 15 80 530 235 120 20 1,000 Crude Oil New solution salt dome cavities Existing solution salt dome cavities Existing salt mines Existing rock minesV Total SPR Composition Assuming Maximum Substitution.^ nf r.r,^^ oil 700 210 90 1,000 625 235 120 20 1,000 1-4 Analytic efforts were focused on the impacts expected at the national and regional levels, particularly in the Gulf and East Coast Regions. Although this supplement considers only programmatic level impacts, the names and locations of specific sites under consideration are not identified herein. Site-specific EIS's evaluate each candidate storage location for the sensitivities of each of the proposed sites with respect to the characteristics of a particular storage svstf^m Of the first nine candidate sites for which final EIS's have been prepared five have been selected for development. These sites are: Bayou Choctaw, West Hackberry, Weeks Island, and Sulphur Mines in Louisiana and Bryan Mound in Texas. Additional candidate sites are clustered into groups around the major crude oil pipelines that lead into the interior: Seaway, Texoma, and Capline. Final. EIS's for these three groups of salt dome have been published. 1-5 A. Overview of Program Ob-)ectives The EPCA provided for the creation of four distinct but overlapping reserves: o Strategic Petroleum Reserve (SPR) o Early Storage Reserve (ESR) o Industrial Petroleum Reserve (IPR) o Regional Petroleum Reserve (RPR) When the SPR plan became effective on April 18, 1977 the ESR was no longer a separate reserve but became part of the initial phase of the SPR. m the EPCA, the manner of implementation of the RPR and whether an IPR would be estab- lished were left to the discretion of the FEA administrator. The option of requiring importers and refiners to main- tain Industrial Petroleum Reserves as part of a 500 MMB Reserve was investigated, and it was decided not to implement such a requirement. The SPR Plan Amendment which increased the size of the Reserve to 1,000 MMB proposes the storage of 750 MMB in underground storage facilities. Decisions have not been made regarding the type of storage facilities for the remaining 250 MMB, or the extent of Government and indus- try involvement in such storage. Previous analysis of the RPR and storage in noncontiguous areas of the United States indicated that centralized storage of crude oil would provide adequate protection for all regions It .s planned that all regions of the country will be protected the future. A use plan will be proposed in the sununer of 1979 that wUl address this protection. No in-region product storage 1-6 is contempleted at this time. However, since the storage of product in tanks was addressed in FES 76-2, it is also addressed in this supplement to provide an updated analysis of the air emissions which would occur. The new analysis reflects the more standard use of floating roof tanks, as opposed to the originally assumed fixed roof tanks. The updated analysis also uses more recent emission factor data than was available for the analysis in FES 76-2. B. Major Types of Storage Facilities DOE investigated many types of storage facilities, and limited the final consideration to three. These facilities were described in FES 76-2 on pages 1-5 through 1-8. Prototype storage facilities were devised in an attempt to identify any particularly sensitive environmental parameters These prototypes represented a "worst case" situation, since they were the largest facilities contemplated. These proto- types consisted of: o An existing 90 MMB solution-mined cavity in salt, o A new 200 MMB solution-mined cavity in salt, o An existing 90 MMB conventional salt mine, o An existing 15 MMB rock mine, o A new 30 MMB rock mine, and o A new 10 MMB tankage facility. Because the expansion of the SPR to 1,000 MMB does not mean storing more oil at any single site larger than these prototypes, the prototype facilities remain valid for this supplement. C. Description of The Environment Two major regions of the United States described in FES 76-2 were the Gulf Coast region and the Atlantic or East 1-7 Coast region. The Gulf Coast was chosen because of its extensive natural salt dome formations which provide existing and potential storage capacity, and because of the significant petroleum refinery and distribution facilities located there. In addition increased emphasis has been placed on examination of the possibility of storage in salt domes further inland from those previously addressed for the Gulf Coast Region. This supplement addresses inland dome storage in Louisiana and Mississippi. The East Coast region was included in FES 76-2 because refined products could be stored there under EPCA. Although no in-region product storage is contempleted at this time, this supplement also updates the analysis of predicted emissions which would result if that program alternative were implemented - °- Environmental Impact s of the Gulf and East Coasts 1. General The environmental parameters of geology, hydrology, water quality, meteorology, climatology, air quality, noise, history, archaeology, land use, demography and economics were broadly described in the FES 76-2. These descriptions, with the exception of I.D.4, Air Quality, provided the baseline data against which the impacts were measured in the FES 76-2. This data base is still valid and is used for this supplement. However, additional examination of the impact in the inland salt dome areas of the Gulf Coast Region is indicated and is necessary to determine feasibility, impact, major problem areas, and limitations that may be imposed. There appears to be probable serious problems with brine disposal by injection into deep wells, as well as with economic tradeoffs involved in inland dome storage in Louisiana and Mississippi. These factors as well as other conventional environmental disciplines have been addressed in this Supplement. 1-8 2. Air Quality Increase of the SPR from 500 to 1,000 MMB is not anticipated to significantly alter regional air quality. FES 76-2 indicates that there will be some short-term and localized dust problems during construction of on-site facilities. The expanded SPR will probably intensify the fugitive dust problems as more construction activities will be required. However, the dust emissions can be effectively minimized by taking precautions such as timely watering of construction areas and unpaved roads. The same major air quality problem of hydrocarbon vapor losses during marine tanker unloading and loading, as iden- tified for the original SPR, would be associated with the accelerated and expanded SPR. It is anticipated that some Federal hydrocarbon standards would be exceeded by increased tanker loading/unloadings for the expanded SPR. Any site specific impacts associated with crude oil transfer would be temporary in nature and occur during construction and fill and withdrawal of oil from the site. Once fill is complete, the site would be in a standby situation until the need for drawdown arose during a supply interruption. Because the double-sealed floating roof tanks being used for the SPR will have much less vapor loss than the fixed roof tanks previously assessed in FES 76-2, the predicted on-site and terminal hydrocarbon emissions are significantly lower. Likewise, based on the assumptions used in the analysis, no significant impact on air quality would result from tank storage of residual fuel oil or distillate oil in the East Coast Reaion. 1-9 ^- Me asures to Mitigate Adverse Imp aci-s FES 76-2 noted that for each area of environmental concern, certain policies and measures exist that at least partially attenuate the environmental impacts. Details are contained in Chapters II and VI. ^- Irreversi ble a n d Irretr JPv.hi . r^^^^tments of Re.onr..<= Resource factors were contained in FES 76-2 and remain applicable to this supplement. These are described in more detail in Chapter VII. G. Program Alternatives FES 76-2 addressed possible non-structural program alternatives. These alternatives included: ^' Al t e rnatives to the Proposed Action o Increase Domestic Energy Supplies o Reduce Energy Demand by Conservation o No Action o Shut-in Capacity ^' Alternative Methods for Acquiring th^ nil o Using (or exchanging) Naval Petroleum Reserve oil o Using (or exchanging) royalty oil o Purchasing "old" oil o Purchasing oil on the open market o Importing oil I-IO 3. Industrial Petroleum Rese rve (IPR) FES 76-2 stated that the DOE's conclusion was not to implement an IPR- This conclusion has not changed. H. Environmental Impact S i-^tement Content FES 76-2 was structured to comply with the requirements of NEPA, and to enable the reviewer to examine the various influences and the resulting impacts associated with the program. It was organized into eight major chapters, each having a relationship to the impact of the proposed program. TO simplify cross-referencing and to permit ready comparison I-ll of FES 76-2 with this supplement, the same format and chapter organization has been maintained. The chapters for both FES 76-2 and this supplement are as follows: I. Introduction and Summary II. Program Description III. Alternatives IV. Description of the Environment Environmental Impact of the Proposed Program Unavoidable Environmental Impacts and Mitigating Measures V. VI. """"' of'^Llources '''' ^^^^^-vable Commitments ""'''* of^Man^f p°"^^'^ ^^'^''^^" ^°^^^ Short-Term Uses of Man s Environment and Maintenance and Enhancement of Long-Term Productivity. 1-12 II. PROGRAM DESCRIPTION This chapter describes the changes to the basic Strategic Petroleum Reserve Program, as modified from the description contained in the FES 76-2. The need for a stand-by energy supply was well documented therein, and is reinforced by the current increases in U.S. energy demand and the equally critical increases in imported petroleum to meet those energy requirements. The major types of storage facilities and distribution systems were discussed in detail in FES 76-2, and need little reexamination, except to examine what impact the increases in total Detroleum storage could have on the existing facilities. A. Need for Strategic Petroleum Reserve The need for the SPR program is well documented in the President's National Energy Plan and will not be considered further at this time. B. Authorization for the Strategic Petroleum Reserve The 1973 petroleum embargo highlighted the perceived requirement for a petroleum reserve for the United States in the event of interruption of the flow of petroleum to the United States from any cause. This need was met with legislation in the Energy Policy and Conservation Act of 1975 (PL 94-163) , which created the Strategic Petroleum Reserve, and also provided for the Early Storage Reserve, the Industrial Petroleum Reserve, and the Regional Petroleum Reserve. II-l C. Requirements for Storage Capacity The 500 million barrel Strategic Petroleum Reserve Program provided for petroleum storage reserves based on 1974 and 1975 U.S. petroleum import data. The expansion of the reserve size was the result of a continuing assessment of the program, and will ensure maximum energy supply protection for the United States consistent with the President's National Energy Plan goal of providing one billion barrels of SPR storage of 1985. 1* Strategic Petroleum Reserve The Energy Policy and Conservation Act provided for the amount of the reserve to be equal to the total volume of oil imported over a three consecutive month period in 1974-1975 during which average monthly import levels were highest. Accordingly, 1974 and 1975 crude oil import data were examined Included in these data were imports to the Virgin Islands, Puerto Rico, and Guam. The three consecutive months in which crude oil imports were highest were August through October of 1975. Based on imports in these months, the SPR Plan recom- mended a Reserve size of 500 MMB. The Plan stated that if subsequent estimates of national vulnerability showed a need for a larger or smaller Reserve, this requirement would be presented to the Congress as a Plan Amendment. II-2 Daily average U.S. petroleum imports have increased from approximately 6 MMB per day during 1974, to approximately 9 MMB per day during 1977. Total U.S. petroleum imports (direct and indirect) from the Arab OPEC states have also increased. These Arab OPEC imports have risen from 22 percent of total imports in 1973 to over 40 percent in 1977. The United States is far more dependent on imported oil today than it was prior to the 1973-74 embargo. While disrupting world petroleum markets poses risks for producing countries, nevertheless, based on recent vulnerability assessments, simple prudence dictates that this country prepare to deal with the possibility that another interruption will occur. Therefore, SPR Plan Amendment #2 increased the size of the SPR to 1,000 million barrels. 2 . Early Storage Program As stated in Section I, the Early Storage Reserve is no longer in effect. 3 . Regional Petroleum Reserve (RPR) No product storage within specific regions or in non- contiguous areas is contemplated at th'is time. However, it is planned that all regions of the country will be protected from SPR storage sites, including those sites to be chosen in the future. A use plan will be proposed in the summer of 1979 that will address this protection. II-3 ^' Summary of Major Storage and Distribution Faciliti es As a result of preliminary feasibility studies conducted by DOE, emphasis has been placed on underground storage facilities. The advantages of underground storage include low cost in comparison to surface tankage, large capacity and minimal environmental impact. Aboveground facilities were also considered and continue to offer a practical, if less desirable, alternative. For analysis, prototype facilities have included a facility using existing solution mined cavities in salt with a storage capacity of 90 MMB; an existing salt mine with a storage capacity of 90 MMB, facilities using new solution mined cavities in salt with a storage capacity of 200 MMB; an existing rock mine with a storage capacity of 15 MMB; a new conventional mine with a capacity of 30 MMB; and a 10 MMB tank facility. These prototypes have been continued for analytical purposes. It should be noted that some of the analysis done for specific sites, published separately, offers more precise capacities for specific geographic locations. E. Candidate Storage Sites Candidate storage sites for both underground and above- ground storage were surveyed and identified by DOE. The types Of facilities under consideration included solution cavities in salt domes, conventional mines, and tank farms. sites were considered with respect to existing and potential capacity availability schedules, accessibility to the distribution network, technical feasibility and suitability for storage, the extent of environmental impacts, the feasibility of acquirin the sites, economic impacts, relative costs, security, and safety. m addition DOE is currently soliciting from Tz:Zy7:^V' ^^°"^^ ' -''^'^^ "-°^-^ -— • - II-4 The three market areas most dependent on oil imports that are likely to be interrupted are: the interior of the country served by the major crude oil pipelines fed from the Gulf Coast; the Gulf Coast refinery complexes; and the East Coast and Caribbean refineries. Because locating the bulk of the Reserve storage in the Gulf Coast area will maximize the flexibility of the Reserve, storage sites in this area have been the first to be selected. Candidate sites identified by DOE are clustered into three groups around the major crude oil pipelines that lead into the interior: Seaway, Texoma, and Capline. 1. Seaway Five salt dome sites have been assessed in the Seaway Group EIS. One salt dome site, Bryan Mound, has already been selected because solution cavities that could contain 60 million barrels of oil are available there. If the proposed development plans for all five salt domes were developed to their assessed capacities, 560 million barrels of oil could be stored in this area. However, for purpose of this assessment the capacity of the Seaway area was limited to 200 million barrels. 2. Texoma The Texoma Group EIS includes four salt dome sites. Existing solution cavities at the West Hackberry dome have P^ already been acquired and could hold 51 million barrels of oil. The Sulphur Mines site has also been selected and has II-5 a capacity of 22 million barrels. If all sites were used, 522 million barrels of oil could be stored in the Texoma area However, for purposes of this assessment the capacity of the Texoma area was limited to approximately 350 million barrels of oil. 3 . Capline Five salt dome sites have been assessed in the Capline Group EIS. Two of these sites with existing capacity have already been selected for storage facilities: Bayou Choctaw and Weeks Island. A total of 710 million barrels of oil could be stored in this area if all candidate sites were fully developed. However, for purposes of this assessment the capacity of the Capline area was limited to 500 million barrels of oil. 4. Other Sites In addition to those candidate sites identified by DOE and assessed to date by DOE, it is anticipated that other sites win be identified and offered to the DOE on a turkey basis by industry. Additional site specific environmenta ' co^l:: Llor^^hel:"::,:;!^^^ -.ulrements Of HEP., Will be process. appropriate during the selection II-6 F. Considerations for System Flexibility To be efficient, the SPR Program must be designed and built to insure flexibility that facilitates transportation of oil to the storage site, and distribution of oil during a withdrawal phase. Efficiency also calls for providing storage in locations of anticipated need in amounts that are proportional to the requirements. Facilitating transportation means not only minimizing the length of the route, but also providing for alternate modes of transportation. This consideration suggests that the storage sites be located in coastal areas, that they should be near marine terminals for the offloading or load- ing of tanker ships, near waterways for further transport by barge, and near major crude oil distribution systems that exist, such as major pipelines. Although much of the nation's oil refinery capacity is located near the Gulf Coast (6.2 MMB per day) and near the East Coast (1.6 MMB per day), important capacity exists in the northern Midwest (2.5 MMB per day). Storage facilities located in these areas not only could serve these refineries directly, but could also provide surge capacity at the end of a transportation route, from the Gulf Coast area (whether pipeline, barge, or tankship) . 1. Terminal Locations Flexibility of the system depends in a large part on the flexibility of the oil transportation network. To the extent practicable, marine terminals should have access to the inland waterways that support barge transport, and be near the terminals of major pipeline systems. Thus, Gulf Coast locations appear to be well suited, and adequate or easily II-7 expanded terminal capacity already exists there. East Coast terminal capacity could be used to receive petroleum for the Gulf Storage Region, but because of the distances involved these Eastern terminals would be less desirable than those' located on the Gulf. 2» Pipeline Lengths Because of the anticipated high filling and withdrawal rates, it will be necessary to connect the storage sites and ".arine terminals by pipelines. Wherever possible, the new pipelines would also connect with existing pipelines and be routed to connect as many storage sites as possible with a minimum of new construction. The length of new pipelines is a function of the types of transport selected, and combina- tions Of these modes (e.g. barge/pipeline), as outlined in ±11. • B . ^' Iinplementation of the Strategic P^i-rm eum Reserve Facility acquisition and development has begun Petroleum procurement and actual filling operations began in mid-1977. The expansion of the Strategic Petroleum Reserve (SPR) will require aquisition and development of additional facilities and the procurement of additional crude oil. Actions taken to implement the expanded program will follow the policy and procedures established for the SPR. All actions will be in compliance with the National Environmental Policy Act, other Federal laws and regulations, and to the extent applicable, state and local laws and regula- tions, established to protect the quality of human life and the environment. II-8 i DOE has followed and will continue to follow a two-step environmental process inclusive of Environmental Impact State- ment preparation and environmental planning. Programmatic and site-specific Environmental Impact Statements (EIS) are prepared as required. These statements identify probable impacts associated with development and operation of the SPR. Environ- mental planning follows the preparation of an EIS and is the mechanism for insuring that environmental issues associated with the SPR as well as with each site, are either avoided or minimized to the extent practical, consistent with the Congres- sional directives for the SPR. Environmental planning as shown in Figure II-l, covers all phases of SPR development from the acquisition and opera- tion of storage sites through oil purchase and transport. Individual plans for the SPR Program, the design, construction and operation of storage sites, and the transport of crude oil will be prepared and implemented. Site environmental planning is documented in Environmental Action Reports. Oil transport environmental planning will be documented in procurement con- tracts. Planning for the prevention of, as well as the contain- ment and clean-up of oil spills, is accomplished through the preparation of Spill Prevention Control and Countermeasure (SPCC) plans. A separate plan will be prepared for each storage site. Each contains a Contingency Plan to be implemented in emergency conditions. 1 . Environmental Action Reports Environmental Action Reports translate environmental impacts identified by the Environmental Impact Statements into site development and operational requirements. These require- ments include design criteria, construction practices and oper- ational procedures which, when implemented at each site, will minimize or avoid impacts. These requirements will be implemented by engineering contractors developing and operating each site. II-9 k 1 »H « *i c 41 E *J C u O w Q. •^ « > ce C Cd c o V '^ JJ xi -^ U CO < z < cu < Z u > z aa r- <^ 4J O 10 u — ^ •u c a — ^ "^ O > -U u c u cu u < , 1 c o •*4 ■u c o o 3 -< e u -u 0»AJ 0) c a U M a c o JJ -i U XJ O <0 Q.^ (0 3 e a IB-^ U JJ t< « i ■u u o Q. CO c « u t' c V e c o a e o u c « -*" Revie n a a. CO (0 0) u o u c S c o u •H > c u K (m CO (D x: E-i < OS K a 3. >1 k« (0 c >- — * JJ 91 E — - c -^ ^^ cy ^^ •^ -^ V o o w <0 (U o. u. a D cn •H Cm 11-10 Preparation of environmental requirements is initiated through a review and analysis of each component of SPR design, construction, and operation. This review and analysis includes a detailed environmental assessment of meteorology and air quality, hydrology and water quality, noise, geology and land use, species and ecosystems, socioeconomics and unique features. The result of these assessments is a summary of environmental impacts or concerns which have probability of occurrence. Current facility design and development specifications are then analyzed to determine those aspects of site design, construction, and operation, which, if guided by alternative criteria, will avoid or minimize identified environmental impacts. This analysis includes the assignment of realistic environmental goals to be achieved and an identification of design, construction and operation specifications or alternative development methods that can satisfy these goals. The development of alternative specifications and recommendations includes an analysis of engineering practicality, economic cost, and environmental effectiveness. Environmental requirements are documented for the overall SPR program in the Programmatic Envr ionmental Action Report (PEAR) . Site environmental specifications are documented in individual Site Environmental Action Reports (SEAR) . These documented environmental requirements are made part of all Architect/Engineer and Construction contracts. Compliance is monitured by subjecting their designs and development specifications to a detailed environmental review. Individual site environmental inspectors document actual implementation. 11-11 2. Environmental Planning for Oil Transport Although the oil spill risks associated with the ocean transport of oil are not severe, DOE has taken measures to ensure that these risks are minimized. DOE is requiring that each offeror who submits a proposal for the sale and/or transport of oil to SPR storage sites comply with a set of transport stipulations developed by DOE as a condition of the contract, and that the offeror submit an environmental plan of how he will minimize oil pollution. Transport stipulations may include: specifications for the use of certain oil spill prevention devices; for the use of certain types of tankers; requirements for adequate liability coverage; and the right of DOE to inspect vessels prior to charter and to monitor offloading procedures. Criteria for precharter inspection have been developed by DOE and the Coast Guard. The environmental plan required to be submitted with offers must detail the procedures and equipment, over and above those required by stipulation, which the offeror proposes to use for preventing or mitigating the effects of oil spills. DOE is in the process of developing a procedure whereby, in future oil purchases, each offer will be evaluated, in part, on the basis of the efficacy of the environmental plan. 3- Spill Prevention Control and Countermeasure Plan Spill Prevention Control and Countermeasure (SPCC) Plans are being developed in accordance with Title 40, Part 112 of the Code of Fedeal Regulations (40 CFR 112) for all facilities in the SPR Program. The objective of an SPCC is to prevent discharged oil from reaching both the surface and navigable waters of the United States. The Plan will contain a descrip- tion of the facility and its operation, the control and alarm 11-12 systems for leak detection, the security measures against unauthorized entry into the facility, the spill prevention systems (dikes, retention basins, drip pans) at on-shore and non-production systems, record keeping and inspection proce- dures, and training of operating maintenance personnel. An oil spill contingency plan, developed in accordance with Federal law, is an integral part of an SPCC Plan, Oil Spill Contingency Plans comprise a predetermined sequence of instructions for communication and actions in the event of an oil spill. The objective of such a plan is to prevent an on-land spill from reaching water, or in the case of a water- based spill, to contain, remove and minimize contamination of the water body. The Spill Prevention Control and Countermeasure Plan for each site will be filed with appropriate Federal Agencies within six months after the site begins operating, and will be fully implemented within a year after the start of opera^ tions. The SPCC and included Contingency Plan will be made part of the operational procedures to be implemented at each site. Surveillance for compliance will be performed by 11-13 III. ALTERNATIVES The data in FES 76-2 remains valid, and only minor change is required by the programmatic increase from 500 to 1,000 MMB in the SPR. A. Non-Structural Alternatives Alternatives to the Strategic Petroleum Reserve, such as an increase in domestic energy supplies or reduction in energy demands through conservation are considered nonstructural alter- natives. Nuclear power and synthetic fuels are in this category, as are alternative methods of acquiring petroleum. The methods and impacts of such acquisition have already been examined. The information presented below supplements that in FES 76-2. The acquisition methods examined in the 1976 EIS are still applicable for the SPR Program; however, due to the increased volume of petroleum to be stored, the economic impacts will vary from the original estimates. DOE is using the authority granted by the Emergency Petroleum Allocation Act (EPAA) to allow the Government to obtain the benefit of price controlled crude oils for fill in the SPR, at least until the mandatory allocation authority of EPAA expires. Increased costs will occur in the form of higher prices for crude oil and petroleum products. These higher prices are estimated to be less than 2/10 of a cent per gallon on average over that portion of the acquisition period for the expanded program during which EPAA allocation authority will be effective. Under the new scope for the SPR Program, this price change would be greater than the original estimate, only III-l if the amount of SPR crude oil purchased under the EPAA allocation authority is increased. This would be dependent on the development schedule for the program as a whole. Based on November 1978 prices for imported oil and old domestic crude, the value of an entitlement is approximately $1.35-$1.45 a barrel. Therefore, budget costs should be reduced by this amount per barrel compared with Government procurement at world market prices. This reflects the estimated average differential between imported prices and national average prices until price controls end. As noted in the FES 76-2, there was certainty that oil imports would rise under any of the alternatives for the 500 MMB SPR. The increase to a 1000 MMB program over a slightly longer period of time than was previously planned for storage of 500 MMB, only serves to increase these import requirements. 1* Industrial Petroleum Reserve (IPR) FES 76-2 stated that tne DOE • s conclusion was not to implement an IPR. This conclusion has not changed. III-2 2. Shut-in Storage - Elk Hills The possibility of shutting in the Elk Hills reserve indefinitely as part of the SPR has been studied by DOE and the Office of Naval Petroleum Reserves. There are a number of problems with the use of Elk Hills oil as a stra- tegic reserve. First, the withdrawal rate would be far less than necessary; it is estimated that the maximum sustained production rate for NPR-1 will be approximately 260,000 barrels per day, as contrasted to the rapid withdrawal rates designed for the SPR, which is over six million barrels per day for the one billion barrels to be stored. Second, there would be delays in starting up production from a shut-in field. For example, unless full crews are maintained on a standby basis, there may be difficulty in quickly obtaining adequate numbers of trained personnel to operate the facil- ities. The SPR is being designed to reach its full with- drawal rate within one week of a drawdown decision, whereas it would take an estimated 90 days for the first drop of oil to be available from a shut-in NPR. The limited daily production rate and the slow start-up time is likely to limit Elk Hills production to a total of about 25 million barrels during a six month interruption. This would represent only about 2 1/2 percent of the one billion barrel SPR. 3. Noncontiguous Areas No product storage in non-contiguous areas is contemplated at this time. It is planned that all regions of the country will be protected from SPR storage sites, including those sites to to be chosen in the future. A use plan will be proposed in the summer of 1979 that will address this protection. III-3 B. Structural Alternatives The structural alternatives include solution-mined cavities in salt, mines, tank farms and tankships used for storage. In addition to assessing the impacts of additional storage development in the Gulf Coast this supplement will focus on the feasibility of oil storage in salt domes of the inland Gulf Region, and the impacts associated with the use of these domes. The programmatic increase will result in some additional impact and the introduction of factors not examined in FES 76-2. Fundamentally, the changes reflect a marked increase in thoughput requirements at terminals, and increases in usage of pipeline and barge transport from marine terminals to inland sites. Inherent in consideration of structural alternatives is consideration of the transport modes available or feasible for construction to serve the storage sites. Two pipelines of a greater than 15 inches are located near inland domes, these are the Exxon 22 which runs northwest from Baton Rouge, and the 40 inch Capline line which runs north from St. James, Louisiana through Mississippi. Trunk lines from these pipelines could serve approximately 75 percent of the dome locations if capacity were available. However, many of the domes are very small, and only a limited amount of storage capacity could be developed there. Oil can be feasibly transported in large quantities to the domes in northern Louisiana and southern Mississippi by lightering to smaller tankers or barges in the Gulf or at the ports of New Orleans, Baton Rouge or St. James area, and transporting the crude further on navigable waterways to convenient staging points for constructing pipelines of reasonable lengths to the domes. Tankers having drafts of 20 to 25 feet can make the voyage up the Mississippi to III-4 Natchez; such vessels range from 5,000 to 10,000 DWT. Some- what smaller tankers can even make the voyage up to Vicksburg; seasonal variations of river level limit the tanker size more severely for this alternative, however. It is concluded that small tanker (5000 to 10,000 DWT) transport of crude to Natchez is a feasible alternative, but that transport to Vicksburg lacks the requisite program flexibility. A pipe- line of length 80 miles or less can be constructed from Natchez to 26 of the domes in southern Mississippi. Alterna- tively, a similar pipeline from Vidalia on the Louisiana side of the Mississippi across from Natchez, could be used to fill 19 of the domes in northern Louisiana. The range of such pipelines are shown by dashed areas on Figure III-l. Lightering to barges for transport by barge tow should also be considered. Such lightering can be accomplished at New Orleans, St. James or Baton Rouge for barge tow transport up the Mississippi, up the Old River to the Red River, and thence to the Ouachita Black River. Shipment by barge can feasibly continue up the Ouachita Black all the way to Monroe, Louisiana, at which point a pipeline of length less than 80 miles can be constructed to fill any of the domes located in northern Louisiana. Another dashed area, centered on Monroe, Louisiana on Figure III-l illustrates this. Lightering to barges can also be accomplished at New Orleans for further shipment by barge tow east along the Gulf Intracoastal Waterway to the Pearl River, and up the Pearl River to Bogalusa, Louisiana. A pipeline of 80 miles or less could be constructed from Bogalusa to transport the crude to a large number of the domes in southern Mississippi. The dashed area centered on Bogalusa, Louisiana in Figure III-l shows this. III-5 "*<>*/, ^ ^-?- MlSSISSlf CULF OF MEXICO Scol* iniUi Figure III-l Feasible Staging Points for Transfer of Crude From Small Tankers or Barge Tows to Pipelines of 80 Miles in Length or Less. Ill - 6 The barge transits mentioned are sufficiently lengthy (at least 90 to 195 miles in length) that the risk of oil spills for these transits is probably greater than for the lesser number of vessel transits that might be required to Natchez. Vessel transport to Natchez or Vidalia, and pipeline shipment to domes within a reasonable distance, may therefore be preferable to the use of barges. As the volume of petroleum handled in a given period of time increases, so does the chance of an accident occurring with resulting emissions into the atmosphere. Thus, while the alternatives remain valid, the impact of the programmatic increase to one billion barrels of storage is examined in this supplement. III-7 IV. DESCRIPTION OF THE ENVIRONMENT The description of the environment contained in FES 76-2 contains the background environmental, cultural, and socioeconomic data for the geographic areas under consideration. This data includes the hydrology, geology, meteorology and climatology, historical and archaelogical, socioeconomic and similar factors against which any analysis of environmental impacts must be conducted. The majority of the data in the FES 76-2 analysis and description remain adequate and was used as a basis for this supplemental study. The Gulf Coast Region has been supplemented with information relevant to potential Northern Louisiana and Mississippi sites. The use of salt domes to store oil in the Gulf Coast Region will require substantial quantities of water and produce equal volumes of brine. For this reason the regional water supply system is a critical factor in the development of storage sites, and the description of the hydrology of the inland region has been emphasized. A. Gulf Coast Storage Region The Gulf Coast Storage Region encompasses southern Mississippi, Louisiana, and portions of southeastern Texas along the coast of the Gulf of Mexico, adjacent to the Louisiana border. The region is located entirely within the Western Gulf Coastal Plains Province. The inner coastal plain, including most of the embayments, is characterized by distinctly belted topography and rolling hills. The subaerial portion IV-1 of the outer coastal plain is chiefly broad, nearly flat prairie, sloping very gradually toward the Gulf at the rate of about five feet per mile. The coastal features include laterally extensive coastal marshes, extending as much as twenty miles inland, bay estuaries and offshore bars near major streams. Some relief elevation is provided by the onshore salt domes which result in increased localized elevations of several tens of feet. From the Gulf coast, the subaerial coastal plain surface extends under the sea for more than a hundred miles, with very even topography resulting from the blanketing by marine sediments. 1. Geology The Gulf Coast salt dome basin of the United States and Mexico is one of the most extensive salt basins in the world. It underlies most of the Gulf of Mexico, Mississippi, Louisianc Texas; Southeastern Veracruz and Western Tabasco, Mexico; and Cuba. The United States portion has five sub-basins. These include the Texas-Louisiana Coastal Basin, the Northern Louisiana Interior Basin, the East-Central Louisiana-Mississipp Interior Basin, the East Texas Interior Basin, and the Rio Grande Basin. The basins and uplifts which separate them predate the period of salt deposition so that the greatest accumulation of salt occurred in these basins. It is postulated that the interior domes were formed before the coastal ones. As the ancient Mississippi River Delta progressed farther south, relatively more sediment was deposited in the coastal dome area than in the interior region. Without continued sedimen- tation, the growth rate of the interior salt domes decreased while the coastal domes continued to rise. IV- 2 The inland salt domes currently being considered for oil storage sites are in the Northern Louisiana Interior Basin and the East-Central Louisiana Mississippi Interior Basin (the Mississippi Basin) . The subsurface ridge that separates the interior salt domes from those along the coast is about 100 miles wide. The surrounding rock is older at the inland domes, and generally more consolidated than at the coastal domes. There are significant differences between the two inland salt dome basins. The Northern Louisiana Basin is small and has only 19 known salt domes, whereas the Mississippi Basin has about 60 domes. Furthermore, the domes in the Northern Louisiana Basin have generally not produced petroleum around the perimeter although petroleum is usually found around the Mississippi Basin domes and the Coastal domes. Because of the lack of oil, relatively little geologic exploration has been conducted, therefore the surface area and vertical configurations of the Northern Louisiana domes are not as well known as the domes in the coastal basins. Unlike some of the coastal domes, there is generally no topographic rise above the inland domes. A number of them are under lakes and low, swampy areas which may have resulted from partial subsidence due to dissolution of the salt. The land over the inland domes is sometimes in pasture, but more often it is woodland. 2. Hydrology The hydrology of the Gulf Coast Region is discussed in general terms in FES 76-2. However, additional consideration must be directed toward the northern Louisiana and Mississippi salt-dome basins. IV- 3 a. Surface-water Hydrology The surface drainage of the area of interest in the northern Louisiana Salt Dome Basin is shown in Figure IV-1, and pertinent hydrologic data on these streams are summarized in Table IV-1 . The largest discharges are by the Mississippi River and the Red River. The smallest discharge is the Dugdemona River. Within the Red River Basin, both the Red and Ouachita River flows are regulated; the Red River by Lake Texoma and the Ouachita River by Lake Hamilton and other upstream lakes as well as a series of locks and dams. High flows usually occur in February to May and low flows in August and September. Development of facilities in Madison, Franklin or Tensas parishes would most probably rely on the Mississippi River or its back waters as a raw water source. Facilities in Webster, Bienville, Jackson, Winn or Natchitoches parishes would most likely rely on the Red and Ouachita Rivers or their tributaries as a source of raw water. These streams have relatively high amounts of suspended materials and as a consequence are usually turbid. Overall, the water quality of streams in Red River Basin is good during the greatest part of the year. Poor water quality has occurred during times of low flow when depression of dissolved oxygen levels, especially near municipal discharges, has been a problem. Streams within the Red River Basin are generally classified as being suitable for all uses except as public drinking water supplies. Smaller tributaries are often classified as unsuitable for primary IV-4 IREYEPORT Figure IV-1 Surface Drainage Area - Northern Louisiana IV- 5 CO s (0 0) u ■u CQ c <0 •H (0 •H 3 o o z u O U-l <0 4J (0 Q o I > to CO u 4-1 0) a o > o O o o o o O o o o o o o r^ e o o o 00 rsi iH o D k V ^ k ^ ^ E o m i-H ^ -^r r- m •H 00 m o "•^ I-H CN X o (N >-l 03 *» S CN CN •H e (0 Q) U < «0 C •H to u a c o •H 4J (0 o o •J c o •H 4J «3 4J w e 4J CO o o 'a* m in c» Q o . o . 2 o a\ o o o ** CN ^ CN o r>- CN m 00 OO cn c v£) 00 CN rH r-{ •^ n (0 k •> ^ *» ^ H s in m 0) OS 0) o u c o u > (0 4J -rH u 03 D o 03 C (U c 03 c 4J 03 Q) jC U u o Q o 03 ca 00 m 03 I-:] O >i (0 DQ 0) C 03 CO CN CN 03 U OJ C -H U C 03 C iH -H u u 03 03 C C u > 03 C o e -4 C 03 U •H C3 03 •H PS o CQ c o •H JJ 03 -H 3 CJi 0) u >i u 03 U O a iH e CN E-t s VO VO IT) 00 D ro m 1^ € ■^ ir» VO r- iH iH H ^ C o> H s D £ ^ » * i» « •. •H CN 00 CN ^ m X 00 r- r~ r»- a\ r« (0 iH i-i s - r^ r- ^ t— 1 cr> C •^ VO 00 in VO (0 VC CN V£) ro ^ r* (U ^ V « k k ^ s r- VO f*i CN •i-l e ^^ in (T> 00 in ^ vo VO ■<* VO (0 ^ » ^ ^ ^ 0) r- VO ir» ■<»• CN u «T < r-t en c •H (U u Q C o ■<-t 4J <0 o o 1-3 c o •1-1 4J nj ■u W u CN 01 U 3 to o u > •H O4 •H to to •H to to T3 O O c (U o (U > •H OS o o N (0 >-• CO to to (0 tfl -H •H X) S £ 3 •. 1—1 rH O •t-l i-l 1.1 U (0 s c > •H to > (tj 3 o en (0 o to oj cc u e to 3 J<: rH (tJ O OJ J sz (0 to 03 •H o 0) 0) •iH XI e o E-" iD tH I CO IV- 9 one of three principal sources, the Pearl River, the Pascagoul River or the Tombigbee River. Water quality data for the Mississippi River, from the discussion under the northern Louisiana area, are applicable to eastern Mississippi as well. The other streams mentioned above and in Table IV-2 are turbid but less so than rivers in Louisiana^ Although the occurrence of chemical pollution is not a particularly serious problem in these Mississippi streams, runoff agricultural pollutants such as nutrients and bacteria is a problem similar to that in Louisiana. This type of pollution is likely to continue. b. Ground Water Hydrology The fresh water-salt water interface in northern Louisiana normally lies 300 to 600 feet beneath the surface. In the vicinity of salt domes, however, the interface may actually reach the surface, as shown in Figure IV-3. Throughout much of the region the interface lies in the Sparta sands. To the extreme northwest it passes through the Wilcox formation while to the northeast it rises up into the Cockfield sand. In northern Louisiana in 1970 approximately 40 million gallons of fresh ground water was pumped per day (DI - 097) . By comparison 356 million gallons of fresh water was pumped from surface water sources. Thus the ground water system represents the secondary source of fresh water in the region of interest. The subsurface strata on the western end of the Mississipp Salt Dome Field is generally similar to that in northern IV-10 i w s }> . c \ o. o o o '•-, ri 2! l 13 04 M OS 0) (U OJ r-» u -H 3 •H cn c > •H c &4 •H ug/m-» (0.5 ppm) irbon lonoxide 8-hour 10 jug/m^ (9 ppm) Same as 1-hour 40 /ug/m^ (35 ppm) Primary lotochemical Dxidants^^) 1-hour 160 Mg/m^ (0.08 ppm) Same as Primary ^drocarbons ^^) lonmethane) 3-hour 160 >ug/m3 (0.24 ppm) Same as Primary Ltrogen Dioxide Annual (Arith- metic mean) 100 A*g/m3 (0.05 ppm) Same as Primary I All standards (other than annual standards) are specified as not to be exceeded more than once per year. The measurement methods are also specified as Federal Reference Methods. The air quality standards and a description of the reference methods were published on April 30, 1971 in 42 CFR 210, recodified to 40 CFR 50 on November 25, 1972. I The secondary annual standard (60 fxq/m^) is a quide to be used in assessing implementation plans to achieve the 24-hour secondary standard. I Expressed as ozone by the Federal Reference Method. I This NAAQS is for use as a guide in devising implementation plans to achieve oxidant standards. V-5 Class I: Any change in air quality would be considered significant. Class II: Deterioration normally accompanying moderate well-controled growth would be considered insignificant. Class III: Deterioration up to the National Standards would be considered insignificant. In August 1977, the Clear Air Act Amendments made pro- visions in the significant deterioration standards. The changes that have significant impacts to the SPR development are: a) that PSD regulations no longer apply only to parti- culate and sulfur dioxide emissions, but to all criteria pollutants, [i.e.. Sulfur Dioxide (SO2) , Total Suspended Particulate (TSP) , Non-Methane Hydrocarbon (NMHC) , Nitrous Oxides (NOx), Carbon Monoxide (CO), and Photochemical Oxidants (O3), and b) that PSD designated source catego- ries have been expanded from 19 to 28 sources, one of which IS petroleum storage and transfer facilities. The effect of these changes will definitely require SPR sources to apply available control technology to ensure the proper emission reduction measures. As the result, the SPR development would employ double seal floating roofs on all storage tanks, in compliance with above regulation. m addition, the applica- tion of hydrocarbon vapor emission collection and control systems to terminal operation will be studied. However, the extent of installing this vapor emission control system is difficult to determine, since this technology is relatively new to the industry and also presents a unique set of safety and design problems. (1) Onshore Strategic PetrolPiiTn Re serve As the majority of the expanded SPR will be stored in salt domes, this supplement assesses the air quality impact V-6 of salt dome storage in the Gulf region for both the con- struction and the operational phases. The assessment is based on the cumulative impacts, and assuming worst case scenarios in critical areas. During the construction/ drilling phase for onshore salt domes, fugitive dust emis- sions will occur from the activity around the site and along the pipeline right-of-way. Construction dust emis- sions cannot be quantified at the programmatic level. In general, construction dust emissions are influenced by a number of factors including soil characteristics, climate, amount of construction activity, and dust suppression measures. An expanded SPR would increase the fugitive dust emissions, since more construction activities will be required. However, most of the dust impacts will be localized and short-term, and can be minimized if adequate dust control measures are employed. An expanded SPR would also increase combustion product emissions from construction vehicles and equipment. This includes primarily particulates, sulfur oxides, carbon monoxide, hydrocarbons, and nitrogen oxides. In addition, particulate and hydrocarbon emissions will result from the sandblasting and painting of surge and storage tanks. Approximately 1 percent of the applied abrasive material used in sandblasting will be emitted as fugitive dust. Tank painting will generate approximately 1,120 pounds of hydrocarbon emissions per ton of paint applied (EN-071) . The air quality impact of these construction-related acti- vities is anticipated to be short-term and minor. Substantial amounts of evaporative hydrocarbon emissions will result from transport and transfer operations of the expanded SPR. Emissions will occur during marine tanker ballasting and loading. These emissions depend upon through- puts, vapor control/disposal systems used and other factors. V-7 An expansion of the SPR from 500 MMB to 1,000 MMB would essen- tially double hydrocarbon emissions from these operations. During tanker loading and unloading, ship and tug engines will generate small amounts of combustion pollutants at terminals. Hydrocarbon vapor loss to the atmosphere is also anticipated to occur from pump seals, connecting joints and valves in the oil pipeline, surge and storage tanks and ballast water separation tanks. The amount of hydrocarbon vapor released from these sources is affected by a number of factors and can only be determined at the site-specific level. The expansion of the SPR would increase emissions from the above-mentioned sources with the highest increase in hydrocarbon emissions occurring in the Capline area. Texoma and Seaway areas would have less of an increase in hydrocarbon emissions. In order to quantify the potential impact of the expanded SPR, two typical salt dome facilities (one with a 200 MMB capacity; another with a 60 MMB capacity) were selected for emissions analysis. These represent the largest proposed facility and a typical small-size storage facility in the Gulf Coast storage region, respectively. Estimated emissions have been computed and are presented in Table V-2. For com- parative purposes this table also presents published estimates of 1973 hydrocarbon emissions from all sources in each of the three Air Quality Control Regions (ACQR) . Considering the Gulf Coast region as a whole, estimated worst-case emissions for a single 200 MMB salt dome facility would be less than 0.3 percent of total emissions in 1973. If both SPR facili- ties are in the AQCR with the lowest ambient level of hydro- carbon emissions, the maximum additional emissions would not exceed 2.4 percent of total 1973 hydrocarbon emissions in that AQCR. During vessel loading of stored oil (withdrawal), V-8 T ABLE V-2 COMPARISON OF MAJOR FUGITIVE HYDROCARBON EMISSIONS FROM TWO EXAMPLE SALT DOME FACILITIES TO AQCR EMISSIONS FROM ALL SOURCES Major Emission Source^^) Tanker Loading Tanker Ballasting Surge Storage Tanks Pump Seals, Pipe- line Valves Example Facilities 60 MMB Facility 693 tons/year 529 tons/year 59 tons/year (2) 19 tons/year 200 MMB Facility 2,310 tons/year 1,763 tons/year 65 tons/year (3) 38 tons/year TOTAL 1,300 tons/year 4,176 tons/year AQCR NAME 106 S. Louisiana, SE Texas 214 Corpus Christi 216 Houston-Galveston GULF COAST REGION TOTAL 1973 ANNUAL HYDROCARBON EMISSIONS* (4) 941,473 tons 225,389 tons 608,376 tons 1,775,238 tons 1 Based on a hypothetical conservative annual cycle, consisting of tanker unloading and filling of the facilities over a 6-month period and loading the stored oil in tankers over a 5-month period. 2 Based on three 200,000 bbl tanks and one 1,000 bbl tank. 3 Based on two 400,000 bbl tanks and one 5,000 bbl tank. ^ Based on an incomplete inventory of hydrocarbon sources. V-9 any emissions that would occur would be in lieu of and traded- off by those emissions which would normally occur as a result of crude oil handling in the area. The air quality impact of an expanded SPR must be deter- mined at the site-specific level. This is because ambient air quality is affected not only by emission strength, but also by geographical distribution of emissions, topographic condi- tion, meteorological factors and chemical characteristics of the pollutants. The impact of an expanded SPR at specific sites and under typical meteorological conditions would be less than this worst case. As indicated in Table V-2, the highest HC emissions would result from tanker loading operations. For the proposed expanded SPR, a peak loading rate of 40,000 barrels per hour was assumed. (The loading rate of 10,000 barrels per hour was used in FES 76-2.) This yields a maximum emission rate of 924 Ibs/hr. The U.S. EPA's air quality model PTMAX was used to estimate the max- imum downwind concentrations and the associated meteorological conditions. Another EPA model, PTDIS, was used to calculate the downwind concentrations at various distances under worst- case dispersion conditions, with these parameters, the areas within 16 kilometers downwind from the tanker will have 3-hour hydrocarbon concentrations exceeding the 160 g/m3 standard. This violation of the Federal standard, under the assumed conditions, would occur only during a tanker loading period. It has been assumed that the emissions from tanker opera- tions are 100 percent reactive hydrocarbons. Additionally, the models used do not consider any chemical reactions occurring during transport of the hydrocarbons. As a result, the models PTMAX and PTDIS could seriously overestimate the hydrocarbon concentrations. it should also be noted that the worst meteor- logical conditions (meteorological stability D and wind speed at 1 meter per second) assumed in the analysis would occur V-10 only during a very small portion of the time. Under typical meteorological conditions, the extent of the temporary viola- tion of the hydrocarbon standard would be less. The air quality impact of other emission sources such as tanker ballasting, pump seal and pipeline valve leaks, etc. would be much less than that of tanker loading. (2) Offshore Strategic Petroleum Reserve One possible scenario of the expanded SPR program includes 200 MMB offshore storage. For offshore salt domes, the onsite production of power will contribute combustion product emissions from the diesel generators used. The hydrocarbon vapor loss from salt dome storage will be minimal. However, major hydrocarbon emissions will result from tanker loading and unloading operations. It is estimated that the total emissions from loading and unloading of 200 MMB will be 2,310 and 1,764 tons, respectively. The air quality impact of offshore storage will be rela- tively insignificant as compared to that of coastal storage, because the emission sources are far from populated areas, and there are better dispersions of pollutants offshore. Under the worst-case dispersion condition (meteorological stability D and wind speed at 1 meter per second) , the areas within 14 kilometers downwind from the site will have 3-hour HC concen- trations exceeding the Federal HC standards, during the tanker loading periods. The extent of this temporary air quality violation would be less during the period of tanker unloading. During more normal dispersion conditions, the ground-level HC concentrations resulting from tanker loading and unloading operations would be much less than those during "worst case" conditions. V-11 It is anticipated that Seaway, St. James and Sun Terminal will be the three major terminals to be used for the expanded SPR in the Gulf Coast region. The potential air quality impact of the expanded SPR at these terminal areas is discussed below. As noted previously, construction of new DOE docks and surge tanks at the terminal will have short-term and localized fugitive dust impact. During the operation phase of the expanded SPR program, minor pollutant emissions from surge tanks, pumps, and tug and ship engines will occur. The major air quality impact will be created by the hydro- carbon emissions from tanker loading and unloading operations. In order to analyze the "worst case" impact, the maximum crude oil transfer rates for each of the three terminals were extracted from the Capline, Seaway, and Texoma draft EIS's (See Table V-3) . Based on these maximum oil transfer rates, the "worst case" emissions were estimated using up- dated emission factors. The updated emission factors for oil transfer operations are less than those used in some of the earlier DOE EIS's. This is because the emission factors previously used were based on the data obtained from gasoline transfer, while the revised emission factors have been based on the more recent testing data on crude oil transfer. Hydro- carbon emissions will also result from VLCC-tanker transfer operations. However, as these emissions will occur off-shore, their air quality impact will not be as significant as those occurring at the docks. The 3-hour hydrocarbon concentrations from the tanker transfer operations were estimated using the U.S. EPA's air quality simulation models PTDIS and PTMAX. Under the "worst case" dispersion conditions ("D" stability and wind speed at 1 meter per second), the tanker transfer operations will generate downwind hydrocarbon concentrations higher V-12 TABLE V-3 THROUGHPUTS AND SCENARIOS FOR THE CRUDE OIL TRANSPORT AND TRANSFER OPERATIONS AT TERMINAL AREAS* Terminal Seaway St. James Sun Throughputs (daily) Filling Phase Withdrawal Phase 175,000 BPD 490,000 BPD 175,000 BPD 1,100,000 BPD 2,000,000 BPD 1,100,000 BPD Maximum Hourly Transfer Rates Filling Operation o VLCC to Tanker o Tanker to Pipeline 100,000 BPH 30,000 BPH 100,000 BPH (55,200 BPH) 100,000 BPH** 30,000 BPH** Withdrawal Operation o Pipeline to Tanker 30,000 BPH (55,200 BPH) 30^000 BPH * Derived from the Seaway, Capline, and Texoma draft EIS's, the Bayou Choctaw, Bryan Mound, West Hackberry, and Weeks Island FES's, and their supplements. ** Assumed rate BPD = Barrels per Day Alternative Dist. System BPH = Barrels per Hour V-13 than the Federal standard of 160 ng/m^ . Table V-4 presents the distance downstream of each source for which a violation of the hydrocarbon standard for each of the three terminals would occur. The downwind hydrocarbon concentration during typical meteorological conditions will be less than that shown in Table V-4. These hydrocarbon impacts can be alle- viated by reducing oil transfer rates, particularly during air stagnation periods. If salt mines are used, construction activities will generate fugitive dust. Hydrocarbon emissions from the mines will either be flared and the vent subsequently sealed, or run through a condensing system and returned to the mine. Thus, no appreciable air quality impact is anticipated. Evaporative hydrocarbon emissions from tanker unloading and loading would be similar to those presented in Table V-2. The possibility of a catastrophic accident, such as a wellhead shear or an accidental break in an aboveground pipeline, would result in air emissions. if during static operation an entire wellhead were sheared off, a significant quantity of oil would escape. Some hydrocarbons from the spill would evaporate to the air. The air quality impact of this occurrence would be short term and minor. As discussed in Chapter 1, various time frames for the proposed expanded SPR program are under consideration. These changes would not appreciably affect the "worst case" impact of the expanded SPR discussed above. However, the air quality impact under typical meteorological conditions will change with a variation in time frame. For instance, the average annual emissions would be increased slightly if the entire 1,000 MMB SPR is to be completed by 1983 instead of 1985. V-14 X t^ M J < CO D < a Oi < M < < ^ Q z 1 Z M > < a CO a J z EH ca O < M Eh EH CO CO < M CO s: b^ Cd < Q CM a s t^ M < s M EH CO ClI Maximum Downwind Distance (Km) In Which 3-Hour HC Concentration Standard Would Be Exceeded c 3 CO CO 1 03 15 (TJ rH (0 (D CO 133 234 133 (1054) (1856) (1054) 174 307 174 (1380) (2434) (1380) Major Hydrocarbon Emission Source at Terminal Areas en c •H I-H rH •H [X4 Tanker to Pipeline^ iH (0 4-> ■H Pipeline to Tanker^ u £ \ (0 JO iH • c CO •H c o • c •H CO fO o •H u •H 01 c o d) -H <-i -(-> C7^ CO c c (0 •H o rH 73 •H rH 01 CO to o CO XI rH •H e u U OJ ] -». 9 [lo ^^ * iO/10) dE where Ld - Leq for daytime (0700 to 2200 hours) dBA eg for nighttime (2200 to 0700 hours) dBA Ln = L and Leg = Equivalent A-weighted sound level over a given time interval This equation essentially states that a 10 dB penalty is applied for nighttime operations. For the purposes of this program, it can be assumed that L^g is the measured V-16 or predicted sound level approximated by a normal distribu- tion having a standard deviation equal to zero, and that these sound levels are those that are exceeded 50% of the time. As such, measured or predicted levels can be con- sidered equal to Lgg. Table V-5 summarizes noise level limits in terms of Ldn ^"^ Lgq considered essential to protect public welfare and safety. Note that L^^ = 55 dB and L^q = 55 dB are values that are representative of outdoor areas that will likely be impacted by development of storage facilities. This table selves as the basis for general assessment of environmental noise as required by this program. Further refinement of these guide- lines can be achieved by considering the factors discussed below. The ability to communicate effectively depends upon the presence and level of ambient or "masking" noise. The values of Table V-6 illustrate the person-to-person separation that will permit 95% speech intelligibility in the presence of different A-weight sound levels (dBA) and vocal efforts. The data are representative of male voices with individuals face-to-face outdoors. The change in ambient sound level is an important factor in assessing the impact from added noise sources. It is possi- ble to just detect a 2-3 dBA change while a 5 dBA is readily apparent. The effects of noise upon wildlife and domestic animals are not well understood. Studies of animals subjected to varying noise exposures in laboratories have demonstrated physiological and behavioral changes, and it may be assumed that these reactions are applicable to wildlife. However, V-17 TABLE V-5 SOUND LE VELS REQUIRED TO PR OTRPT PUBLIC HEALTH AND WELFARE EFFECT Hearing loss LEVEL AREA 'eq(24) < '^^^^ All Areas Outdoor activity interference and annoyance 'dn < 55dB Outdoor and residential areas, farms and other areas where people spend widely varying amounts of time, and other place in which quiet is a basis for us Indoor activity l^ < 45 dR interference and ^ ~ annoyance " ■ eq(24) < ^SdB Outdoor areas where people spend limited amounts of time such as d school playgrounds, etc. J Indoor residential areas. ^eq(24) < ^SdB Other indoor areas with human activities such as schools, etc. Source: EN-108 Note: L eq(24) = Equivalent A-weighted sound level over 2 4 hours V-18 I TABLE V-6 MAXIMUM A- -WEIGHTED SOUND LEVELS THAT WILL PERMIT ACCEPTABLE SPOKEN COMMUNICATION FOR VOICE LEVELS AND LISTENER DISTANCES SHOWN AMBIENT SOUND LEVEL IN dBA DISTANCE Vocal Effort (feet) LOW NORMAL RAISED VERY LOUD 1 60 66 72 78 2 54 60 66 72 3 50 56 62 68 4 48 54 60 66 5 46 52 58 64 6 44 50 56 62 12 38 44 50 56 (Superseded Table V-5 in FES 76-2) V-19 no scientific evidence currently correlates the two. it is known that large aniinals adapt quite readily to high sound levels. Conversely, it has been demonstrated that loud noise disrupts breeding in poultry and consequently can affect egg production. Equipment required to create storage caverns in salt domes consists primarily of drilling rigs, vehicles, pumps, and ancillary support machinery. Operation of these equipment generates noise of sufficient levels to be a source of concern some distance from the rig site. A gross estimation of noise emitted from a single drilling activity was obtained using standard acoustical field equations uniform noise radiation, absence of physcal barriers, and a standard day were assumed in the prediction. Additionally the following sound spectrum level at fifty feet from the drilling operation was used (Table V-7) . V-20 TABLE V-7 SOUND PRESSURE LEVEL (dB) at 50 FEET FROM DRILLING Frequency - Hz 63 125 250 500 1000 2000 4000 8000 Hz 77 77 83 80 77 73 77 72 dB (Supersedes Table V-7 in FES 76-2) Computations revealed the following: Distance from Rig (Feet) 500 1000 1500 2000 2500 Predicted Ldn (dB) 63 58 54 51 48 Additional evaluation may be made by considering the effect of noise upon communication by telephone. The quality of telephone usage in the presence of a steady-state masking noise may be obtained from Table V-8. TABLE V-8 QUALITY OF TELEPHONE USAGE IN THE PRESENCE OF STEADY-STATE MASKING NOISE NOISE LEVEL (dBA) TELEPHONE USAGE 30-50 50-65 65-75 Above 7 5 Satisfactory Slightly Difficult Difficult Unsatisfactory (Supersedes Table V-6 in FES 76-2) V-21 It may be concluded that at distances of 1,000 feet, or less, sporadic complaints about noise may be expected and 25% of the population exposed to the noise level will complain about it. The computations provide only gross approximate answers but do indicate that noise could be a source of environmental concern during the drilling operations. These estimates did not take into account impulsive noises associatec with rig operation. Such noises aggravate the problem when considering human response. e. Biology The Strategic Petroleum Reserve will have various effects on the biota of the Gulf Coast region. Some actions which may be expected to have the most adverse effect will include waste disposal - liquid, gaseous and solid - construction, with special emphasis on dredging operations, excavation and devegetation. In the programmatic sense the biological impacts must be discussed at a hypothetical level because of the wide variations in the actual environments of the salt domes. However, regardless of actual site selection, there will be some biological impact from both construction and operation. The construction period will represent the greatest time of disruption in a biological sense. The operational stage for both types of salt dome storage will be relatively free of biological disturbances, with the exception of increased ship and barge traffic, and the risks of accidental spills of crude oil or brine discharges from the solution cavities . V-22 Increasing the volume of the Strategic Petroleum Reserve from 500 MMB to 1,000 MMB would increase the number of sites, and this would impact proportionally on the biota affected. The impacts from the construction phase would generally be localized in the vicinity of the site and pipeline construction During the operational phase adverse effects would be limited to storage areas, handling points where the mode of transport changes (e.g., barge to pipeline), and to those isolated instances where an accident to the pipeline may result in an oil or brine spill. f . Historical and Archaeological Resources In terms of the historical and archaeological resources of the region where the Strategic Petroleum Reserve would be located, the construction and operation of the SPR would have a minimal impact. However, any new construction required by the increase in the SPR from 500 to 1,000 MMB will increase the geographic bounds that will be affected. Such effects may include construction or excavation for surface buildings or equipment, roads, pipelines or pipeline tie-ins would generally result in physical alteration or damage to any historical or archaeological resources within the construction area. The presence of roads, surface buildings and equipment may also result in degrading the aesthetics of an area by introducing elements which are out of character with the perceived historic or archaeological background. g. Land Use In the event that the full 1,000 MMB oil reserve were stored in the Gulf Coast Region, the land used for V~23 the storage sites would amount to a total of about 2260 acres, or 3.5 square miles distributed throughout the coastal states. Additional land would also be used for pipeline rights-of-way and brine disposal fields for solution cavities in inland areas, but the choice of sites would determine the amount of their additional acreage. (1) Effects of Sites on Surrounding Land Use In the Gulf Coast region, the entire oil reserve could be stored in selected salt dome formations. Oil and gas deposits are frequently found around the periphery of these domes and, at the majority of candidate storage sites, the surrounding lands are dotted with oil and gas wells. Use of the domes would not interfere with continued production from these wells. The candidate sites are in rural areas. Depending on the particular location, the surrounding land may be pasture, crop land, forest, marsh or swamp. The major effects on land use would result from the noise, traffic, and visual impacts. Noise and traffic would be primarily due to construction activities which would last for 1 to 2 years at sites where existing solution cavities and mine space are to be used, and 3 to 4 years where new solution cavities are being developed. Steel tanks that must be built at some sites to provide oil surge capability would constitute the primary visual impact, particularly in pasture, crop, and marsh lands. Typical tanks would be about 60 feet high. The noise, traffic, and placement of tanks, however, would not constitute a conflict with the use of surrounding lands . V-24 The sites would require a network of pipelines and power transmission lines. Oil pipelines are only required at mine storage sites. Solution cavity storage sites require additional pipelines to supply water to the cavities and to dispose of the brine. Where existing rights-of-way can be used, the new pipelines will be laid along those routes. However, it will be necessary to cross farms, forest lands, wetlands, rivers, and highways. The impact would be confined to the construction period except where trees must be cut to prevent their roots from breaking the pipe and where pipeline trenches through wetlands will take time to become silted over and revegetated. The pipeline and transmission line routes will be planned to minimize effects on residential and commercial areas. The storage sites will not employ a sufficiently large number of permanent workers to induce the establishment of commercial industries near these sites, nor will the use of the land for oil storage be an inducement for industries to locate in the vicinity. Therefore, there are no changes in property values anticipated from the use of the sites. (2) Site Uses While oil and gas are often produced around the perimeter of the dome, the ground overlying the dome surface generally does not contain oil and gas deposits. The sites have, in some instances, been used for the production of sulfur, rock salt, and brine which is used in chemical manufacturing. Some existing solution cavities are used for the storage of petroleum products. Use of the sites for oil storage will preclude the production of sulfur from the caprock during the period of V-25 oil storage. Sulfur required for industrial purposes is being produced from stack scrubbing equipment where coal with sulfur content is burned. Efforts to extract sulfur from the caprock of salt domes have been unprofitable. Salt mining operations, brine production, and storage of refined petroleum products may in some instances be relocated to an adjacent portion of the dome. The net effect in these instances would be an increased utilization of the dome surface area. Where salt mines or rock mines are used for storage, an office, warehouse, electrical transformer, and pumphouses would be needed at the site, and the use of surface land could be limited to 30 to 50 acres. Where solution cavities are used, a large brine pond must also be built, requiring additional land. The use of the sites for oil storage would be classified as an "industrial use" by the U.S. Geological Survey and by state planning agencies. Where the site has been previously used for production of sulfur, salt or brine, the land use classification would remain unchanged. i Some candidate sites, however, may alter land use designations of the area. (3) Land Use Planning Since the candidate oil storage sites are located in rural areas, most of which have already been used for extraction of oil and gas, there is no conflict between the use of the sites and existing land use plans. In some cases, the expansion of urban areas may enclose the storage facilities within the next 20 to 25 years if currently projected population growth rates are realized. At sites where this V-2ty is likely to occur, sufficient acreage around the main storage facilities can be obtained and reserved as a buffer zone between the operations of the facility and the future surrounding land use. The pipeline rights-of-way and perhaps the power transmission corridors would cross areas that eventually will become residential. The situation does not present a land use conflict, but would influence the future development of roadways and neighborhoods. These portions of the rights-of-way would have to be maintained in accordance with municipal regulations when they are brought inside city boundaries. (4) Recreation Hunting and fishing are major forms of recreation in the Gulf Region, where there are large areas of wilderness in the forests, swamps and marshes. It will be necessary to route pipelines and transmission lines across portions CQ < Eh o a: CO O M w M s w 2 O CQ a; <: u o Cc: Q >H X > < 2 2 < < O Eh O Eh X Eh O O 2 O CO M < cu o * CO < o CJ CO < 2 o CO u a < CO 2 O M CO CO M s CiJ « CO < u I Eh CO O CO 2 O 2 < EH a 2 M a PQ Eh M CO I 2 O CO Q CO < M O < < CO a CO CO 2 o M a: CO Eh CO M M S s CO CO o u o < o Eh CO CO CT> c •H >H 4J Eh fO M O J rH M Cu - u < 2 < Eh □Q (0 CO iw I 0) f-i D o Q CN \£> • • r-t in ro • • ^ CN LD 00 o o V in CN (U CN (0 U .-H ^ a I) -H fo a; rH •H 4J (0 en •H -H Q J ro o V 1^ (U en CO D •H CO > 0) ac 2 o 03 < u o Q >H a: < Eh o EH O 2 CJ a < 2 O CQ < u o oi a >H K < O EH O 2 Pi CJ O < u (d >i \ c o oooooooooo oooooooooo mooo(y>rHCNnr~-(^ rHiHCNroc:oo>CNr~o^^ iHmt^i^MPO'«4'iHrOCX5 CM iH rH ,-1 VOOrHOCX)OO^in I— li— tr-HCNCNinvOCNCNCN rHrHiHrHrHc— Ic— (CNCNCN U CO CU >i \ CO c o ooroooooooo oooooooooo OOrHCN'^r^LDLnrHCT* ^r^ooocNcN^OLncy* CNcTv^ CNCNOinCN^ >— I O IT) Ol CN 1— icNro^LOv£>r~0'^ OOOOOOOiHiH LD CO cr» «-i c 1 o o • \ rH 4-> CO o CO C CO (U +J c 3 u o H J-i "O 4J U H a cu 0) fO o e O Jitf CO 3 o C CJi CO o fO c C CO ^ 4-> -H O CO o 'O jQ o IM (0 U >i «x> o o m H ^ rH u cu 00 CO o > ■*-> 73 U -H CO C TJ 4J • •H CO >i nj J CO CO s: > < •H c -o M b^ CO O O 4-1 CU p fCJ U -H O CO Eh JD u c 4J OJ >i o Eh rH (CJ a u U CO fN Eh CJ e C H 1 CO c: >i 1 •H -H VO < (0 U X O r- w •H TD u c J-> -H Ol, (0 cu (0 ' cu cu -P TJ rH CU > £ -H £ C CO rH rH •H 4J rH -P O U -H jQ en O -H c C714-> CO a. o o ^a CO Eh CO >i fO E CU M-l -H c x: *4-i 1 CO O T3 CO o cu CO CU •H CO cu > JQ CO CN no CO cn-H CO CU CO c (0 iw CO O CU CO •H O U •H rH TJ U e O fO CO CD (U T3 -t-* rH U U Pj cu CO u CO O CT> D rH CO (U -»-» a CO rH CO <+-i > O (0 14-1 < CQ O O Eh > O * ■ K * * cu * * * 4J * * o * 2 V-46 TABLE V-11 PEAK HOURLY HYDROCARBON EMISSIONS FROM EXAMPLE TANK STORAGE FACILITY AND ESTIMATED MAXIMUM CONCENTRATIONS 10 MMB Tank Farm Stand ing Storage Loss Withdrawal Loss (12 400,000 bbl Peak HC Maximum Peak HC Maximum tanks and 20 emission downwind HC emission downwind HC 200,000 bbl tanks) rate concentration (6:00 a.m.- 9:00 a.m.) rate concentration (6:00 a.m.- 9:00 a.m.) Distillate, double- 3.16 28 /ig/m^ 12.0 109 ^l<3/m■^ sealed floating Ibs/hr Ibs/hr roof tank Residual oil, double- 0.64 5 . 6 Mg/m 0.44 4 ^lg/m sealed floating Ibs/hr Ibs/hr roof tank (Supersedes Table V-20, FES 76-2) V-47 concentration of hydrocarbons and the contributions of any other neighboring sources in order to deternine compliance with the standard. Based on the assumptions used, the maximum hydrocarbon concentrations resulting from the prototype 10 MMB tank farm would be less than the non-methane hydrocarbon standard of 100 «g/m3. Air emissions would occur from tankage modules during emptying operations in conjunction with generating steam for tankage heating. For winter withdrawals, an estimated 2,600 gallons of fuel oil per hour would be required to generate steam. Combustion emissions for a typical on-site boiler are presented in Table V-12. During a total withdrawal of stored fuel on, these emission rates would continue for approximately fifty days. The impact of these emissions on the ambient air quality would be minor. The expanded SPR would increase the probability of pipeline breakage or other accidents. Oil spills resulting from on pipeline breakage would contribute some amount of evaporative hydrocarbon emissions to the air. The impact of these emissions would be short-term. Any catastrophic fire occurring from the upset of one or more tanks would contribute major combustion product emissions to the air. The impact of these would be severe but would be short-term. V-48 TABLE V-12 COMBUSTION EMISSIONS FROM STEAM BOILER FOR HEATING STORED PRODUCT EMISSION FACTORS EMISSION RATES EMISSION (lb/103 gal) (Ibs/hr) Particulates 23 60 Sulfur dioxide 110 286 Sulfur trioxide 2 5 Carbon monoxide 4 10 Hydrocarbons 3 8 Nitrogen oxides 80 208 Aldehydes 1 3 Heating oil rate is 2,600 gallons per hour for a tankage withdrawal rate of 40,000 barrels per hour Source: EN-071 (Supersedes Table V-21, FES 76-2) V-49 C. Oil Spills Probably the most publicized and widely reported actions pertaining to petroleum and the environment occur from oil spills, both at sea and on inland waterways. The effects are dramatic, represent substantial impacts on a variety of environmental disciplines, and are frequently costly. In some cases, such as the oil loss from a well in the North Sea in raid-1977, the coverage of the efforts to halt the flow of oil and contain the spill have become international front-page news. For this reason, as well as the actual substantive issues of environmental damage resulting from oil spills, special emphasis has been placed on this area. A detailed analysis is contained in Appendix A, Oil Spills , dealing with the risks involved in accidental discharges, spills at marine terminals, collisions, and other casualties that might damage the carrier, spills during vessel-to-vessel transfer, and pipeline accidents. An oil spill cause and event tree, and preventive and mitigative measures for reducing oil spillage also are described. Operational discharges of oil, such as those resulting from the disposal of oily bilge waters, tank washings, and ballast waters, were not considered in the analysis of oil spill risks. It has been established that these con- stitute the bulk of oil discharges associated with tank vessel operations. However, recent national regulations and pending international conventions will limit these discharges. Existing and proposed U.S. Coast Guard pollution V-50 prevention regulations in Title 33, Part 157, Code of Federal Regulations (33 CFR 157) , are intended to control the discharge of oily mixtures from tanker operations. These regulations are based on requirements contained in the IMCO* International Convention for the Prevention of Pollution from Ships, 1973, but also include constraints not included in the Convention on the location of segre- gated ballast spaces. Specific requirements of 33 CFR 157 concerning operational discharges from U.S. flag vessels are as follows A tank vessel may discharge oily mixtures from machinery space bilges if the vessel is more than 12 miles from the nearest land, proceeding enroute, has in operation an oil discharge monitoring and control system, and is discharging an effluent with an oil content of less than 100 parts per million. Tank vessels operating on inland waters and sea- going tank vessels under 150 gross tons must either retain on board oily mixtures or transfer them to a reception facility. Seagoing tank vessels of 150 gross tons or more may discharge oily mixtures from cargo tanks and cargo pumproom bilges into the sea, if the vessel is more than 50 nautical miles from the nearest land, and proceeding enroute, the instantaneous rate of dis- charge of oil does not exceed 60 litres per mile, and the total quantity of oil discharged does not exceed, for an existing vessel, 1/15,000 of the cargo carried, and for a new vessel, 1/30,000 of the total quantity of the cargo from which the discharge came. The vessel must have in operation an oil discharge monitoring and control system. *The acronym "IMCO" stands for "Inter-Governmental Maritime Consultative Organization." V-51 Similar regulations have been proposed for foreign flag tankers in U.S. waters. if these regulations are followed pera tional discharges will tend to be widely dispersed over the open ocean. in contrast, accidental spills may occur anywhere, especially in coastal and inland waters, including harbors and harbor entrances. Moreover, accidental spill! „ay result in a large outflow at a single location rather than being Widely dispersed as for operational discharges. More significant adverse environmental effects are expected from accidental discharges of oil and thi= i .w, f„„ ^ , y or oil, and this is the reason for the focus of the analysis. The results of the analysis of accidental oil spill risks IS summarized in Table V-13, which li a. a u a u 3 o <0 4J •W -H -H (9 T3 o a 00 a.u-1 u g a "-I (u g •a o C OJ ^ a s «H •H o C u O >w •" C -H J^ O C -w en a u E *-* a oj o. M u o o a •" c >, >% « OD J= 00 O T3 iJ >« a U3 CI O > J S u a ■< o ■.< u C 3 -i M a o ■H - n 4j a 4j a u a ■H -H a u u a • u a i-t TJ <-> -H u « U li 4J a 01 u rt u u a u x: u M a a > ■H a O 6 1-4 X c o o a o 00 gj c u O o i-t 3 o a ki o.^ a a u C 00 41 O s ^ ■H O 73 -W s C >H O -H •O -H rt ■H 1-t O. 41 4-1 >« a .^ a ^ wi a rH ^ JZ a >, u > B u 3 -^ ■H •« 41 ^ 41 -H ki a c > 41 3 -H -H > -^ iH 13 4) . >^ B • u a 4< a -H a tJ o -H c j= -H a a u j3 s a. B a 3 41 a u a O ^ a w a >H 00 >« c o s C T3 ■w a > -H O •^ E O 41 a 73 a K c >N a a a p^ ki M a a a a e u ^ j= o 3 3 a a 73 o u o -H a B u u r: ■H O. 11 a a o a M o* • uh c a a u u c a o a a a a u B a a 73 -H a > > o o o 00 c -H a u a o .--I •a o s -u a 41 3 •o » O ■ i-l « o 4) ^ « u .a *^ e 73 3 fH 3 1 o o o vM u a a u > o u u a >M b: o a a c a O 00 •H fi XI a a j: ^ y 3 a. a o o a. 3 73 a B 13 - a 00 ^ c r-( .-1 1§ kl k< a a B 3 ^ u 3 a > o >W U1 o o •H a — a -H a X u 73 O •»< C pH 3 T3 a O O u a k> ii o. o a •o •- a >N o a js e u B i-( a o a o e •H O B a o U 73 X C u a . v./ a B u O ki fi 1-4 a a 4-1 a u 3 >, a J3 -H •w H b ■*-« 1-4 4-1 a 73 -H 4-1 -W .a 73 ■H a u 3 B a 4.1 a 00 b a iw o a. >> > 4) •^ <4-( .. c o -o a a a 4j >\ --4 O ki a c a a U 4-1 . 3 •• o C >N O ^-^ 4J U1 X 4J 4J 3 ■H .a o -H B ki a 4-1 73 a •H B 73 O ■H -O 4-» B a a fH 3 a a. u O fi ' Q. q ■D B fi ■H 3 -a a a a a a a a a 1-1 ki u o 3 k4 a 00 O B Q. a X a Q. e a o a a 3 a a 73 a a o a k> ki ki 00 Ck 00 j: B 00 <4-i r* *" o B a > a O 4J ^ ■woe 4J 3 kl o 73 a c o > 3 ki a a k4 a o a -a a ^ fi 3 o c fi 3 a a 73 o u3 a a. u X 73 a a B 4j a ^ a a a 4j (41 ki 3 o o o O U 4-1 00 kl o o 4-1 B Q. o a a u ' 00 a > a 4-1 a a o C a a o 73 <41 •Ha. a a JZ •-! r-t 4-1 a a 4) JS 3 tH 4-1 73 a -H O -Q >4 3 73 n a B at a E a ■H 00 73 to B B ■a a a kl 73 O E Ui o. a o a kl k4 kl 14 O § > o o a u> 1-1 .c o c ta iM « •H O M 01 u o O fO e u »< . a Has 73 a >> E 3a. '" a a 4-1 n a a a a i-i 73 a > M • a - " = S 41 o a j^ ti e a e ^ UJ 00 a a a u u B OL kl j: o < u ^55 V-5B initial impacts to detrital food webs and breeding organisms could be heavy, with a high potential for long term effects from oil fractions which persist in the sediments. The magnitude of impact to estuaries, bays, channels and harbors would depend upon numerous physical factors such as size, flushing action, wave exposure and shoreline characteristics. a. Relative Vulnerability of Organisms Hyland and Schneider (1976) , in reviewing the effects of petroleum on the marine environment, summarized the initial impacts of petroleum on various marine populations and communities. Table V-15 contains the author's summary, and points out that birds and the subtidal offshore benthos were estimated to be the most heavily impacted components of the marine fauna. Birds can become oil coated resulting in a loss of buoyancy (drowning) or increased heat loss (pneumonia) . Ingestion of oil can result in direct toxic mortality, or, as Dieter (DI-099) pointed out, an osmotic imbalance leading to dehydration. Dieter also noted that experimental oiling of bird eggs has led to decreased hatching and possibly direct toxicity from the aromatic compounds. The subtidal offshore benthos can be heavily impacted initially due to a generally higher vulnerability than other benthic communities, and the persistence of oil in the substrate. b. Relative Toxicity of Oils and Petroleum Products Weathered crude (crude which has lost the lighter fractions) has been reported to be less toxic than fresh crude. In this regard, the experimental oil spills conducted by Bender et al. (BE-001) are worth noting. Using semi-enclosed sections of a mesohaline salt marsh off the York River (Virginia) , which were dosed with fresh and artificially V-59 CO z D £ S O o > o u Id a o. o e -^ eo o >><« e 4J M -H -rt £ c -o O &I -H "3 u c > «1 o a o a c o u cj u o •3 -H J 3 (8 cr S -rt . O Ji ^^ ■H 3 >s 3 a 3 a. 3 u o "o a ■^ > •H O o "a u u c « -H >, u a a o 1 ^ u u a. o u u t-i u io o a -ri U •H -o ea « 3 e a o •H 4) u ^ (9 a 3 o. :>. o a o. e » e a m o 0) '^ 3 CO u O c V « ■.J B > T3 -H 4 B •T3 3 -H 01 >« 9) ^ o e S •H •a -H >< •rt O TJ .-^ O § 2 •o •H » OJ h 4) U -^ 4) U 41 T3 U > 3 U 4) a ^ •a 01 u -o o T^ O ^ h 01 -H rH O. a. b X ■H Id at 41 O O h u BL4 -U Q Z < CO z o 01 -a OJ o fa S o I s m 1-1 I > W CO < Eh < a o 2 O O CO EH CJ U Cu CE4 U fa O < s s D CO U C 41 U 41 U 01 01 "a O c ■u o c c -w O O • u >M CD o ^ 3 e o 4) Q. > 41 e a. M •H 3 > Q. •H O -u a. u 3 ;« •a c O -H U T3 O. 41 41 fH Ii . fH U O iH (3 41 a -H 41 r-l >M 01 41 U -H \ B a s F^ g- M a U 41 •-I 01 41 a •H U 3 41 U a o B O. SO B eo iH 3 B O B td a a o o< ca ^ a h S -H j= a a O O u B O ^ •o 4 -H ■H a a u JS • § O u W U •H a 41 u 0) u a B u u u o ■H 01 rH a u u O M « 3 .:^ a u >M O B 14 •H B 41 a U JS B u 41 13 a B B a T3 O 41 oo >» a 3 TJ a a a "o ts u a u u a 01 41 -3 00 ts > B 4J a ■>-( 41 -H B 41 v» > > a •H -H a -H s JJ a j: 1-1 g ■H B o i-( a u )-■ 14 a a a o -H u j: U4 > u a u B a a a a Baa O M *J a o B a o a. u a B H-l 3 a a a -H B ^ u ^ B a a a a ^ 'H a >. 00 a -' a a £ ■H o B -H 3 <-l M 3 e X I u 4J a 3 u -a O -H u >s ki 73 a S u a B en M V-60 Z O s z o u Q z < w z o u-i' M I-ll tH 1 < > J o W (Hi hJ O pq 04 < H z o > o u 41 u 41 X O >> I . B iH O -O ^ U C ' •H 3 n t-i O n o u-i o 'U Qx to e 41 O T* ■ B e t 01 o a •»4 -rt f-l C *J 3 « O iH tJ c -• ^ O O oa iH 3 kl o u (U 0) M s -i • o > 3 ^ ^ •H O. 0) 4J O J-i X U O.I-I u 3 3 3 o -rt a V< 00 41 o. eg -a .i^ 4» pH C 0) |4 41 a) u a 4) 4) 41 o. X Ci] 4> u c o >, H •rt o C -H 3 w a v u a. o di 4) Oi ^ ui u j: > ■" « . •H 91 > a u O ti u g 0) m 1-1 c l-l o O <4-l -H ClI u-l O -U 41 C u s C l-l 10 CO O 4) ■H 00 E ao«-i S (fl u c •H O 0) O rH U l-l O .O M-l c to 00 c e at 4) iH U U 4) <« 4) 41 ^ ■a u a ^ ■H B % 0) ^ .a 3 •a OJ 4) . B <» (0 .M 41 > O >W >» O 41 •« B I- T) B g IS i B t3 > SO ■H 41 -H 01 u tj u 41 -H •H 01 41 B U B > -H •H 41 (d rH (0 X SO 0) B 4-J 41 <-> -H S O X -H g g U rH 41 O U M u 41 0) -a 0> 41 -H t4 OOTJ *J (a B 41 -H 41 4) B 01 l-l TJ -H B •rH « u 41 M U O e O. 0) 41 O. 41 M-l JZ 41 3 O 1 s 01 01 ♦ - 1 O B >, 01 >« 01 O O U 41 u B -rt •H u ■H • U •W B •a o - 41 B R) B 01 V4 rH 3 « 3 rH 41 3 O O O •< > O. 41 41 41 O «-l O >w 3 cu 41 • 3 01 3 -O S 41 es O 41 M rH 4) • rH 01 •rt l-l B 0) • U • •• O o — 41 B B B "O B ■H tJ M O 41 O 41 -rt iJ 41 U •rt ■rt > 0) > B 4-1 U-l U T^ U l-l •H -rt U O 3 -H O 3 t-t B rH 1 -H O. 1 ;>N -rt 01 rH 00 > O 00 u U 01 O B 41 o. B 41 X o. O X o > 41 iH rrt 41 41 r-l o rH .a U o U U T^ « e > a 41 fH •H 00 -W •rl 41 § '^ 3 "O 41 01 •a B E •rt 01 e b o B -rt 9 > 41 M OOiH w u S 41 u C o >. •• 01 00 O la 3 B O •rt T3 « t4 41 •u >sja hi •rt J3 U rH rH B •rt -a OJ •rt jQ 41 O -^ •rt Vi O 01 41 rH 01 01 MH >\ o OH o . 01 O 41 ^ 00 •S X rH •o rH 4J 41 U 41 u 41 •rt B 43 U Id u e « rH > aj c 41 B h •rt o 0. 4) • g • rH 3 •a 41 X 41 u 01 kl. S 41 01 ^ -rt (3 01 lH a ■rt 13 01 o j: 3 41 O JS 4J >\ u g u a ■rt ■rt 4J 4i o O 4-1 u 41 o > 4J U <4H 6 rH B rH 41 at 10 ■ >-rt a N CU •rt U <4H u >« 4> O 3 •n rH Jl l-l O O U o ■rH rH > 'rt B 09 •o •H 41 • O. B Ui y O 41 -• X 2:2 01 -H q 41 CU 00 41 •rt o. s CU 00 00<*H 41 *J J= >M 01 3 s 4-1 o B a o rH JJ u <« O o 41 Ed B u rH ■H ■rt o ■o B B 3 B a 41 l4 r-H O O OJ ■ri B kl B O •rt T3 41 B 41 li 00 4) B IH o 41 o a. »T3 41 B U 00 rH CO U rH 00 4J 41 4J ■rt U o • 01 •a j: a B s -rt CU B 0] 41 o o 4J t3 B •rt g Ui 41 B 00 3 41 kl ttl 41 .-\ 41 ooua 4-1 B O U g u g 41 41 B 4J 4J (B O ■o tJ B > 41 01 o 01 ^ B >»T3 o 01 3 41 41 B o w ai j: J3 M 01 rH B o o rH •rt Crt 0] 4J •rl g^ 3 >4H O 01 01 41 41 g rH 4J <4H 4-1 4-1 rH 01 i-t 41 • ^ ! CU s o ■rt 41 41 B Cd • rH o >. >-' •rt 01 b 41 M OkrH rH O 4J 01 ■rt MH OO-O 4J U 41 « M "O ^ >% 1 » 4-1 rH O U u B 01 rH -rt ■U rH 6 rH 4.J a X u 41 U 41 rH 4H u u 01 u g 01 3 -O O r4 l-l « u > .a 9 00 «l ■rt S rJ rH 41 Cd kl -o o ■ri Jl 4-1 (11 J3 UH 3 u-l ui O J3 10 V-61 weathered South Louisiana crude, the authors recorded impacts to the salt marsh from weathered crude which were, on the whole, as great as fresh crude. in both the fresh' and weathered plots (relative to controls), marsh grass production and benthic fauna declined, while periphyton biomass increased. Phytoplankton production suffered a substantial decline immediately after oiling, only to recover fully in seven days. Recent research on the photo-oxidation of Number 2 fuel oil revealed that two groups of toxic compounds (peroxides and carboxylic acids) resulted from irradiation of the fuel oil with artificial light. This is a further indication that weathering may not detoxify at least some types of petroleum and petroleum products. o. Biological Recovery Hyland and Schneider (HY-001) in reviewing the impacts of petroleum on the marine environment, assessed the expected recovery of major populations, communities and ecosystems following oil contamination. The authors' assessments are contained in Tables V-14 and V-15. The open ocean ecosystem was regarded as having the fastest expected recovery due to a rapid dispersion and degradation of the oil combined with a rapid recovery of any affected biota through reproduction and immigration of adults and larvae. Wetlands and estuaries, bays, channels and harbors were estimated as having the slowest recovery rates. Recovery of a wetland could be appreciably hindered by the persistence of oil in the sediments. Estuaries, bays, channels and harbors could be slow to recover if local breeding populations of fish or shellfish were heavily damaged. The populations and communities expected to have the slowest recovery were V-62 the subtidal offshore benthos, birds, and, if heavily impacted, aquatic mamiiials. Persistence of oil in the sub- strate and a possibly slow rate of biological succession in some communities were noted as factors in the slow recovery of subtidal offshore benthic communities. Birds and mammals could be slow to recover due largely to long life spans and low fecundities. G.L. Chan (CH-157) reported no long term effects of a 1971 spill of 840,000 gal. of Bunker C in San Francisco Bay. Assessing recruitment for five years following the spill, Chan noted significant increases in population densities of some species of intertidal mollusks which had been heavily impacted by the spill. Nadeau and Bergguist (NA-009) made follow-up observations of a spill-impacted area in Puerto Rico where 24,000 bbl of Venezuelan crude had washed ashore from the tanker Zoe Colocotronis in 1973. Three years after the spill, red mangrove (Rhizophora mangle) and black mangrove (Avicinnia nitita) had died-off in part of the impact area where sediments still contained high levels of petroleum hydrocarbons. Epibenthic communities in turtle grass (Thalassia) beds, initially impoverished as a result of the spill, had begun to recover three years later, as had the Thalassia infaunal community. Certain fauna in the mangrove prop root community, also heavily impacted, had begun repopulation during the three year span. Krebs and Burns (KR-001) surveying the recovery of salt marshes contaminated by a 1969 spill of number 2 fuel oil, found that recovery of fiddler crab (Uca pugnax) populations was still incomplete seven years later. The authors attributed the long term reduction in the crab population to the persistence of toxic oil components in the sediments of the salt marsh which led to direct mortality of juvenile crabs and impairment of locomotor activity and general behavior in adults. Hershner V-63 and Moore (HE-164) performed a post-cleanup assessment of the 1976 Chesapeake Bay spill of 250,000 gallons of number 6 oil Selecting Vancluse Shores as a monitoring site for eight months following the spill, no significant short term effects could be detected in populations of the intertidal mussel ^^^^^^"^ ^^"'^^^"s o^ the American oyster (Crassostrea ^^il5inica). Snails (Littorina irrorata) , initially heavily reduced in numbers, appeared to be recovering at the end of the study period, while the marsh grass ( Spartina alternif lora ) exhibited an increase in standing crop and density. The authors hypothesized that the impact of the spill was mini- mized by the relatively low toxicity of the spilled oil, the time of year (dormant) , and the wave and tidal action of the shoreline. In summary, the impact and subsequent biological recovery of an area following a petroleum spill will depend upon a complex variety of factors such as the type of material spilled, time of year, energy characteristics of the impacted area (tidal exchange, wave action, etc.), vulnerability of the biological community, and dynamics of the affected populations such as turnover rates and fecundity imposed upon these factors is the cleanup operation itself (response time, techniques, etc.). Biological recovery may require only a few months for some communities, to several years. ^- Effects of Chronic Oil Pollution The original subsection contained in FES 76-2 presents an overview of studies conducted in marine areas subject to chronic low-level oil pollution and the potential effects of chronic exposure on marine populations. As such, this material is not affected by expansion and acceleration of the SPR program. V-64 e. Summary of Effects on Marine Organisms Recent research indicates that weathered crude may not necessarily be less toxic to marine biota than fresh crude. Bender et al. (Be-001) determined that the overall impacts of weathered crude on experimental plots in a mesohaline marsh were as great as fresh crude. It has also been found that photo-oxidation (a weathering process) of Number 2 fuel oil can yield highly toxic compounds such as peroxides and carbo- xylic acids. Expansion of the SPR to 1000 MMB over a slightly longer period of time (1985 versus 1983 for the base case) would result in a higher probability of oil spills in a given portion of the marine transport phase of the project (open ocean. Gulf of Mexico/Caribbean, Gulf Coast, East Coast, and inland waters) . The frequencies of oil spills greater than 1000 barrels over the total marine transport life of the project are given in Appendix A. The frequencies noted are about twice that expected for the base program (500 MMB). As such, expansion of the SPR program increases the risk of ecological damage from the project as a whole. The greatest risk arises from transport operations in the Gulf Coast, East Coast and inland waters since these areas are near or contiguous with the biologically productive wetlands, estuaries, and other fin and shellfish habitats of the coastal zone of the United States. The Caribbean transfer phase (Scenario C, Appendix A) could also have a high risk of ecological damage from a large spill, assuming that the transfer point would be relatively close to shore. The open ocean and Gulf of Mexico transport phases are not considered "worst cases" since it is assumed a spill in these areas would not reach the coastal ecosystems. It should be noted that the frequency of a spill greater than 1000 barrels in V-65 the "worst case" transport phases are very low for each alternative to the original case of 500 MMB . A large spill in these zones could have severe impacts on the affected ecosystem, requiring up to several years for biological recovery. The magnitude of impact would vary with numerous factors, mentioned in earlier subsections, ranging from the type of product involved, time of year, rapidity and effectiveness of containment and cleanup, and the biological characteristics of the impacted environment. As an adjunct to marine transport of oil, there is the possibility that river barge transport could be utilized if an inland salt dome (e.g., northern Louisiana or southern Mississippi) were to be used for storage. The frequency of a spill (larger than 1000 bbl) for this transport mode over the life of the project is quite low. A large spill during barge transport could affect an extensive area along the shoreline of the river due to rapid transport of the spill by currents. Such a spill could have a significant short-term impact to the ecology of the affected area, especially commercial and sport fisheries which are extensive along the Mississippi River. Recovery of the impacted area should be relatively rapid due to the high flushing rate of the river and the broad biological base available for repopulation. 2. Ecological Effects of Onshore Spills An oil spill on shore must always be considered possible, although the probability is relatively low. Mechanical failure such as wellhead shearing off, the rupture of a pipeline from an external impact, the failure of a valve, are all possible. Human failure could also create a spill, and must be weighed for consequences. V-66 Tankage area spills are contained inside safety dikes. Only spills outside of the area, such as a pipeline rupture, would be expected to create an adverse ecological effect. Such a spill could occur as a result of a ruptured pipe or a sheared wellhead, however, a combination of safety devices and the fact that the pressure on the oil in the well would rapidly reach equilibrium would probably limit the volume of such a spill to less than a hundred barrels. Small pipeline leaks can be totally contained in the soil before they move a great distance horizontally or downward if the quantity is small enough. Chronic leaks, if undetected, may travel long distances both horizontally and downward. If porous backfill is used in a trench made in impermeable material, the oil would follow the course of least resistance and migrate along the pipeline within the trench. This usually can be eliminated easily with no environmental consequences. In either the Gulf Coast or East Coast regions small spills on land should present few cleanup problems. However, the vegetation and soil organisms would probably be destroyed locally by either the oil or the cleanup operation, which usually consists of removal of the contaminated soil. The possible exception would be large trees that could survive if the cleanup were rapid. The destruction of the vegetation would temporarily displace whatever animals lived in the area prior to the spill. Most animals would be able to avoid the spill area, and would not be harmed. Revegetation can be assisted by reseeding and replanting after the cleanup is completed. V-67 If an oil spill is not cleaned up promptly, but permitted to continue for several days the effects would be much more extensive, and the following cleanup more difficult. If the spill were carried by surface water the effects would be felt by the aquatic organisms in the streams and throughout the drainage system affected by the spill. ^' Ecological Effects of Spills of Refined Products Spills of refined petroleum products are generally more harmful than those of crude petroleum. To insure "worst case- evaluation, the catastrophic loss of a complete tanker of about 35,000 DWT was considered. Two refined products were selected for this evaluation: Number 2 Fuel Oil and Bunker "C." The worst case area for such a disaster was a U.S. port, where tankers of that tonnage are frequently found. In the port area the loss would have the greatest environmental effect. Carried by tidal currents, the products would be widely distributed throughout the harbor unless cleanup and containment were promptly initiated to protect sensitive areas. The spilled products would be washed ashore, and enter the small bays and wetlands adjoining the harbor. Tides and estuarine circulation would distribute the products in both surface and subsurface waters. Since most refined products are lighter than water they will generally move with the net flow of surface water in a seaward direction, but turbulent mixing can also distribute the oil throughout the water column as an emulsion and through dispersion of tiny oil droplets. The net landward flow would carry these materials back into the harbor, spreading the products widely throughout the system. The oil may enter marine food webs through planktonic or benthic organisms. V-68 The lighter petroleum products contain higher concentrations of the more toxic constituents of petroleum. When washed ashore quickly after a spill, and before loss by evaporation or burial in sediments, these refined products can cause widespread losses of marine organisms in wetlands. If the product should become buried within sediments where anaerobic conditions exist, degradation could take years. In this event, the product would represent a long-term ecological hazard which could significantly impede the speed of biological recovery within the impacted area. Bunker C is a heavy residual fuel oil with a propensity for water-in-oil emulsions. This, combined with its high viscosity causes it to tend to remain at the surface, where mechanical recovery or removal is facilitated. Since it would remain at the surface a spill of Bunker C would endanger the marine birds in the harbor and adjacent wetlands if control and cleanup were not promptly initiated. Other marine fauna, especially benthnic communities, could be heavily impacted by a spill of Bunker C, although biological recovery should be relatively rapid. 4 . Regional Overviews This portion of the chapter briefly summarizes appropriate portions of the final Environmental Impact Statement for the Maritime Administration Tanker Construction Program, which in turn drew from CEQ studies on supertanker port sites. Those elements extracted have some regional significance and are appropriate to the considerations of the SPR. V-69 a. Texas Gulf Coast The biological productivity of the marine environment of the Gulf of Mexico is lowest in open waters, increases toward the coast and is greatest in the estuaries. An oil spill inside a Texas bay would have a greater potential for significant ecological impacts than a similar spill further offshore. The shallow bay waters provide less volume for dilution of toxic oil components, and the slow flushing characteristics of the estuarine systems would result in a longer contact time for marine organisms with the spilled oil. Depending upon the time of year, fin and shellfish, especially larvae and juveniles using the estuary as nursery habitat, could be subjected to long-term impacts through loss of a substantial portion of the year-class. Recovery following an estuarine spill could require years. Winds and currents have been estimated to drive spilled oil toward the Texas coast approximately 60 percent of the time. Barrier islands along approximately 300 miles of the Texas coast protect bays and estuaries from most effects of offshore oil spills. The small tidal openings through the islands would probably inhibit the movement of large volumes of oil into the estuaries. As a result, the major short-term impacts would occur at the barrier beaches where a large portion of an oil spill would most likely be stranded. Intertidal and subtidal benthic communities would probably be the most heavily impacted components of the ecosystem. The impact to waterfowl would probably be minimal since they should be protected by the barrier islands from the major force of a spill. Pelagic organism residing in the offshore area would be affected primarily through loss of the more susceptible larval and juvenile stages which come into contact with the contaminated water strata. V-70 Low-level continuous spills in the Gulf of Mexico are not likely to reach the shore. Soluble fractions from thin oil films should be diluted enough to prevent damage to swimming organisms. Chronic oil contamination of some Gulf Coastal areas has been associated with past offshore drilling operations on the Gulf Coast, but its effects have not been reported. b. Southeastern Coastal Area of Louisiana The areas most vulnerable to oil spills along the Louisiana coast are the estuaries. Oil drift projections (based on regional winds and local currents) indicate that the (supertanker) site most distant from the shore will have the least effect because a potential spill there would probably not reach the estuarine areas. Estuarine areas of Louisiana are flanked by levees and, on the Gulf side, usually by barrier islands. This configu- ration, coupled with a gentle slope, has produced a nutrient- rich environment that now supports over four million acres of estuarine marshlands — one of the world's most extensive coastal wetland areas. The climatic regime provides high solar radiation, abundant rainfall and a wind system that interacts with the physical setting in such a way that primary production supports the largest fishery in the United States. The principal commercial species are menhaden and shrimp. These species depend on the estuaries for habitat and/or nursery area and for detrital food — the product of marsh grass disintegration. Oil drift projections were based on a hydrodynamic numerical model. By using four wind conditions, local tides V-71 and bathymetry, the hypothetical oil spills nearest shore moved either northwest toward Timbalier Bay, Louisiana, or northeast toward Barataria Bay, Louisiana. Oil spills further into the Gulf did not impinge on the shorelines or estuaries, oil spills at both sites usually assumed an east-west orientation and moved somewhat faster than drift projections based solely on winds. Effects resulting from an oil spill would be potentially most severe in the estuaries, if repeated oilings occurred, valuable oyster grounds located in this area could be destroyed. Oil could temporarily damage extensive areas of marsh grass, thereby eliminating or reducing important spawning and nursery grounds. Most of the marsh fauna is located near the boundary between the grass zone and deeper estuarine waters, if oil enters the estuaries, it is believed that it will concentrate in this boundary area and thereby possibly cause high mortalities to these forms and damage the fishery species since they use this area for protection, spawning and nursery grounds, and as a food source. The larval and juvenile stages of the fishery species use the tidal passes into and out of the estuaries as migratory routes. If oil reached these areas during such a movement, juvenile mortalities could have severe effects on later fish harvests. Damage to the Gulf shoreline from spilled oil will probably be minimal unless the oil concentrates in the littoral currents which are used as a migratory aid The most severe effect offshore would probably be damage to the spawning waters or feeding grounds used by the fishery species. V-72 c. Atlantic Coast Region The circulation of coastal water along the Maine coast is generally southward during the cooler months of the year. This circulation is driven primarily by density effects associated with local river discharges and modified by regional winds and is most vigorous in early spring. In autumn, when winds are relatively weak and river discharge is low/ the circulation is sluggish. Tidal currents dominate the circulation of near-coastal waters but the details of the circulation are not well known. The complicated geometry of the coastline makes it difficult to develop simple mathematical simulation models that adequately describe the nearshore circulation that would play a dominant role in moving oil slicks resulting from accidents to ships or at the terminal. Oil would have severe effects on the intertidal organisms living on the rocky shoreline. Oil would also likely enter the small wetland areas and cover the small beaches at the head of small coves in the area. Data on marine communities of intertidal rocky shorelines are adequate to permit qualitative assessments of damage from the stranded oil. Less data is available for wetland areas and information needed for assessment of damages to aquatic organisms in the coastal waters or on the continental shelf is inadequate for reliable assessments. The study concluded that such oil spills could possibly cause localized permanent changes in communities of marine organisms. Oil spills at sea on the lower portions of the Atlantic Coast would probably present increased hazards from pollution of beaches and wetlands due to easier access from open water. Generalizations are necessary because of the V-73 wide variety of possible sites along the coast, and the wide range of variables affecting each as a separate site for consideration. D. Summary o f Cumulative Imp act; !S more Consideration of cumulative impacts becomes I e acceleration important with examination of the increase in the Strategic Petroleum Reserve from 500 to 1,000 MMB, and th in attaining the original storage goals. Cumulative impacts can be considered in two ways- those that are additive because of the location of two or ZZlTT"''^ '" ""' """^ "''' °' ^""^ >">"- ^he impact results from two or more operations at the same facility. Since the sites have not been selected, the methodology for additive impacts because of proximity is not valid in a programmatic evaluation - although it must be a major consideration in site-specific examination of the cumulative effects when two candidate sites are co-located or in close proximity. Estimations on a per-site basis were made in FES 76-2 and have been updated in this supplement. However, the ' amount Of oil stored by facility type has been modified, and this data was contained in Table I-l in Chapter I of this supplement. Using this revised capacity for proto- types the following Tables v-16 through V-24 of cumulative etfects have been derived. V-74 J < ,~. u DQ o CO ij < u s D EH s CO M OH X o <: IS iH 1 1 Eh > a CO D ClI EH Q J U O QQ < tf < 04 04 Eh s M b O U3 > u M o EH < s iJ o D EH S CO D ul CD a « > o « 8.1. a o 8-. 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U 4J B *J 4J B B a 4J -^ a Id -H a 1^ ■H a -g a k4 lo a B B Sh a B S>i a ° -y a a< a U Qt >H Oi ^ h 44 44 Q, •H _ s a X a X Ot 3 "O ig a a 44 a a 44 a a c a a M a 9 a V4 V4 a 4J 4J M -H 1.° a a ^ a o ^ 3 4J a a 4J a Id u rr 0« w m U 4J O l4 ^ 22 S « a -w a -H «N 44 a M 44 Q E4 s ^ 44 44 3 (S U (d u O a M a iS a SOCI ECON a a u a a ^ -o -4 a o "O 3 •o 44 B -H a lO S B o a rH 4J ■H O a a l4 B -H •rt 13 B a ^ ij c » 3 JJ o « k4 -4 14 'Q a f4 (0 f^ a rs •O 3 •-4 -4 O -4 B << M V-83 VI. MITIGATING MEASURES AND UNAVOIDABLE ADVERSE ENVIRONMENTAL IMPACTS In general terms the mitigating measures that were applicable to the Strategic Petroleum Reserve when the volume was established with a goal of 500 MMB remain valid for an expanded 1,000 MMB SPR. Measures having site specific application remain useful and appropriate, since the shift is not to enlarge individual sites, but to increase the number of sites to be used in the program. The acceleration of petroleum deliveries to meet the new goals will increase the volumes of petroleum to be moved, in some cases by as much as four times, through selected marine terminals during a specific time frame. This will increase the statistical probability of accidental spillage and will increase the quantity of emissions. Both factors support greater emphasis on mitigating measures to reduce the adverse environmental impacts to a minimum. A. Mitigating Measures 1. General Measures a. Use of Existing Storage Space The magnitude of the environmental impacts, or potential impacts, is generally more significant with new construction than with the use of existing facilities. The original goal for the SPR was 500 MMB, and the 370 MMB potentially available storage volume in existing facilities provided a substantial mitigating factor in the impact of the program by limiting VI-1 the degree of new construction, with the planned increase to 1,000 „MB the requirements for new construction J L expected to increase by a factor of approximately four This represents a measure of the scope and magnitude of the possible impacts on the environment created by the expansion and acceleration of the SPR. b. Location Since various options as to the actual sites are open, the combinations represent alternatives which, in themselves. Offer a very effective way of mitigating the adverse effects on the environment of the total SPR system. This flexibility exists at both the regional and local levels, m the regional approach, for example, surface facilities may be located only in those areas that do not have any appreciable seismic risk (such a difference exists in the Atlantic Coast region between the northern and southern extremes, as an example,. Within local areas ecological impacts can be mitigated by locating storage site facility components and pipeline routes away from highly productive wetlands, breeding areas, nest- ing areas, tidal inlets and offshore banks and reefs. in addition to flexibility in actual location, considera- tion of time of construction can also reduce adverse impacts. If a pipeline is to be run through wetlands, the construction can be timed to minimize disruption of breeding, nesting or migration in that area. Once the relative impacts on specific sites and rout are determined, programs to weight the environmental ad tages can be derived and translated into engineering speci- fications and timetables for construction. es van- VI-2 c. Accident Risk Reduction The risk of oil spills and attendant fire hazards are an ever-present factor in petroleum handling operations. There are practices which can be employed during the development and operation of the Strategic Petroleum Reserve sites which would reduce the risk of spills and fires. Generally, such risk reduction equipment and techniques are employed as standard practice throughout the petroleum industry. During construction at the storage caverns the risk of blowouts can be greatly reduced in some operations through the use of blowout preventers on drilling rigs. During well-workover operations, depressuring the system with strict control of potential ignition sources could substantially reduce the risk of accidents. Radiographic inspection of all pipeline welds, cathodic protection of buried pipelines and proper identification of pipeline location can greatly reduce the chances of pipeline spills. Redundant high and low pressure detection mechanisms as well as pump vibration and high temperature detection devices integrated into the oil delivery system can greatly reduce the probability of spills resulting from equipment failure. Downhole safety valves can also be employed for certain well designs in order to reduce the volume of oil spilled in the event of major damage to the wellhead during the static storage phase of the program. The use of specific equipment, instrumentation and operational procedures is a function of the detailed system design. As this detailed design is developed, appropriate oil spill risk reduction measures will be incorprated into the system consistent with the goals and operational philosophy of the SPR. Human error is by far the most common cause of oil spills. Proper training and close supervision of both terminal and site operations personnel is the most effective means of reducing the risk of spills caused by human error. VI-3 C rH o <0 O 0) c O tD •H C (0 4J o 0) cn I -H 03 rO c o o u X r-l Cd O M •H i 4J o > -H C 4J > O X a c O u •H iX Eh W I u 3 CD O CJ VI-12 Special measures will be used at points where the pipeline would cross streams and rivers to control potential environmental impacts during the construction phase. Usually it will be necessary to excavate or dredge a trench into which the assembled pipeline would be placed where the line crosses a river. For smaller streams the actual construction techniques would vary, according to the volume of flow and the conditions of the streambed. To minimize interruption of the stream flow and turbidity, the stream may be temporarily diverted or passed along the pipeline trench by means of a flume or conduit. Backfills into these streams would be the original material. Where major streams, those greater than 100 feet in width, are crossed, the installation would normally be open trenching using dragline dredges operated from the banks, or excavating equipment operated from barges. Excess excavated material would be deposited in a spoil area, usually on the stream bank, but selected and approved with consideration of possible environmental impact. Where there are major crossings of streams or canals, it is estimated that an area of about 170 acres would be required for equipment access, pipe storage and temporary spoil storage Where a stream has a silt or clay bottom, there would be no excavation until immediately before the actual pipe-laying operation. After the ditch is open the concrete-coated pipe is pulled into the trench by cable from the opposite bank until it spans the stream. The ends are plugged during this portion of the operation to prevent water from entering the pipe. Where the stream channels are relatively unstable, or where future channel widening is planned, the horizontal run VI-13 Of the pipe is extended well into the banks of both sides Pxpe under the stream would have a mininu™ of five feet of cover below the maxi^u. depth of the river bottom or Lour. Equipment crossings of soft bottomed streams are usually done using causeways constructed of the most suitable locally available materials, and with an elevation equal to or slightly higher than the normal water levll Where the possibility of causeway erosion exists, norma erosion control methods are applied. ^' Accident Prevention The design of all equipment, all buildings and all local st'n"/" ''"" accordance with Federal, state and ocal standards. Monitoring systems and inspections will xnsure operation within safe limits, including pressures in effec'tl'orr" '"""'"' ''"'^■"^"^ ""' '^ ^-^-^^^ ^-^ the effects of temperature, pressure and vibration damage by sensors which have an automatic shut-down capabilitj. Ill Pipelines will be coated, both externally and internally to n-inimize corrosion. Peaking electric generators will provide power in the event of a utility system power failure. 9' Rock Disposal Rock excavated during the construction phase represents a potential degrading influence. To the extent practlcab e this rock Will be sold commercially for use as !ggrega e ^ construction, thus lessening the impact that roc^'deL Of rock debris must reflect efforts to minimize the effects on both surface and subsurface water supplies VI-14 2. Geology Control of the total volume of salt domes excavated insures that the proportion of cavity to remaining structure mitigates against accidental acts or events which might impact on the environment. During operation, oil that would be removed from the cavities would be replaced with water, thus mitigating against collapse or other accident to the cavity. 3. Hydrology a. Brine Disposal Detailed geologic and hydrogeologic reconnaissance, subsequent proper siting and spacing of disposal wells, and specialized injection well design matched to expected aquifer performance will minimize the number of injection wells and the environmental consequences of deep-well disposal of brine. With dynamic pressure monitoring and positive control over injection rates and wellhead pressures, dangerously high pressure gradients may be completely avoided. Properly conducted disposal into saline aquifers is essentially a safe environmental practice. For brine disposal in the Gulf, the primary measure for mitigating impacts is the placement of the outfall diffuser and the resultant orientation of the plume under all reasonable ambient conditions. By avoiding reefs and banks that are known to support abundant, diverse marine biota and by not obstructing tidal inlets with the salinity plume, adverse ecological impact will be restricted to the immediate vicinity of the diffuser. A large distance VI-15 between the shore and the outfall win serve as an additional buffer against environmental damage. The brine diffuser will be sited and designed to provide minimal physical Obstruction to those normal activities that take place in coastal waters. fc>. Sediment Production The amount of sediment produced and the consequences with respect to stream siltation may be minimized with sound, available erosion and sediment control practices. The methods suitable for accomplishing this must be evaluated on a site-by- site basis but generally win include avoidance of potentially difficult areas, diversion of runoff, vegetative buffers and stabilization and sediment trapping by vegetative ' filters and detention (or retention) basins. c. Dredging The adverse impacts of dredging may be mitigated and localized to the removal and disposal sites by good engineering practices, especially by proper disposal site selection to minimize ecological impacts and by prior characterization of the dredged material as to its toxicity to aquatic organisms. d. Water Use The large volumes of water to be used in constructing and operating solution mined-cavities cannot be reduced However, the impact of this water use can be largely mitigated by using water of poor quality, i.e., high salinity. The Gulf Of Mexico represents an essentially unrestricted source of saline water. Large amounts of saline ground water are ■vT-16 available in storage and it is not likely that this water would have competing uses during the course of the program. Storage of saline surface water in brine ponds may also be used to provide the required water supply. e. Aqueous Discharge Aqueous wastes associated with aboveground tankage consist of tankage condensates and rainwater runoff. The impact of aqueous wastes on the environment is minimized by waste water containment and proper disposal. Tankage condensates are stored in a closed vessel and delivered to a waste disposal company. Rain runoff water is retained within the diked areas until absorbed or evaporated. 4. Meteorology and Climatology Tankage and other above-ground appurtenances will be constructed out of or above the hurricane tidal surge zone. Permanent buildings will be constructed to withstand maximum wind loads occurring with a one hundred year frequency. a. Air Quality No significant impact on the air quality in the Gulf Coast region will occur from construction, filling, or operation of subsurface storage facilities for the expanded SPR. The associated tanker loading and unloading, under worst-case meteorological conditions, is predicted to cause local and temporary violations of Federal hydrocarbon standards. VI- 17 ^- pressurized nnderoronn^ ^^ oraae Sp ..o To reduce the explosiveness of the vaoor c,n.. • storage facili>,-oo . • • ^ P^^® ^" "^i^ed rage facilities containing volatile products or crud. .v, vapor would be allowed to build to a Pressure gretelln atmospheric at which point the vapors would be nt d the atmosphere. The elimination of hydrocarbon emiss o ./'^ then be accomplished in one of two ways a. . T niethod, a temporary flare svstJ I alternate ^ ^ system may be used, a second alternative would provide for i-h« .r . . second thro... . conae.saLon":.r:n' Lr: l:"::: :::- T''-^ liquid returned to the stor.n. ^^^^^^ and the condensed i-u cne storage caverns. ""• ^^r Residuals of Abov.^r..,nd Tank... Mitigating measures available in f-h^ ^ ..ouna .an.a,e can .e .U..., .n": L".". .^^es" Ir apPl.caMe to the construction, aUin,, staL t". and the withdrawal phases. ^ ' (1) Construction .round't '!"'"'' '"""'' '^ ''^ construction of above- " a Ip :::i:r":":"^ "°" san..iastin„ a„a aoca..o„. can be grLtlTrea!;ed r?"""'' '' earth-moving operations however .,. '^"9 cP"ations are not readily controllable; i !hlch o '''""""^ ^"""^-9 techniques .ay be available f s :aT:;:„;r'^ ""^ Pa-lculates. „yarocarbon emissions on, spray painting operations can be reduced by using hiah r::;L"::d":h^"/""" -"" -'-- -^ ^ejired l poteitiiu;!:::::::: -^^ ^^— -- — ons, by VI-18 (2) Filling Floating roof tanks are to be used for the expanded SPR. As there is virtually no vapor space between the liquid surface and the roof, little hydrocarbon vapor will be displaced during filling operations. (3) Static Storage During the static storage period there will be small amounts of standing storage loss around roof seals. These standing storage emissions can be reduced by designing the storage tanks with a large height to diameter ratio; by painting the tanks with a heat-reflecting white paint; by using double tight-fitting seals around the roof; and by periodic regular maintenance on the roof seals to insure adequate functioning. (4) Withdrawal As floating roof tanks are to be used for the expanded SPR, hydrocarbon emissions will occur in the withdrawal phase due to wetting losses as the roof level drops, leaving the tank walls coated with a thin film of oil. This withdrawal loss is generally very small for the type of steel tanks intended for use in the SPR. No control measures have been proved to be effective. Other emissions occurring during emptying operations are associated with the combustion products generated by the steam boiler. Steam is required to liquify residual oil. Major combustion emissions are particulates, sulfur oxides, and nitrogen oxides. Under most conditions these emissions Vl-19 can will have negligible impact. Nitrogen oxide emissions be reduced through combustion modifications, and sulfur oxide emissions can be reduced by burning a lower sulfur fuel. '^- Marine Tanker Qperafinnc The hydrocarbon vapor emissions occurring from unloading and loading marine tankers have been shown to have the largest air impact. Several measures for prevention of these impacts are described below. Because of cost limitations, some of these measures may only be feasible for new tankers. (1) Unloading Operation?; Emissions are caused by ballasting subsequent to unloading. One method of reducing in-port emissions from ballasting would be to take on less water in port. Also, tankers which have segregated ballast tanks could be used These tankers use separate tanks for ballast and oil cargo storage. The number of this type of ship available for use in the proposed program is thought to be small. Another emission prevention method would be hydrocarbon vapor control equipment. Hydrocarbon vapors are collected on- board the tanker and piped to on-shore recovery or disposal equipment. Refrigeration, absorption, and incineration are the most likely control devices used on-shore. Incineration, although having an effective control efficiency of over 99 percent, is a potential hazard due to explosion. VI-20 (2) Loading During loading, hydrocarbon emissions from tanker cargo tanks occur by the displacement of vapor-rich air by in-coming crude. Emissions can be prevented by two methods. The first is to purge empty tanks at sea so as to remove hydrocarbon vapors. Two forms of this clean-up operation are heel washing and butterworthing. Heel washing removes puddles of oil left from the previous cargo shipment after unloading. Butterworthing is the washing down of tank walls. It is estimated that these housekeeping activities could reduce in-port filling emissions by over 50 percent. The second means of emission prevention is to employ vapor control equipment as described for unloading operations. 5. Biology Use of the most recent technology during the construction of the facilities can be an important step toward mitigating adverse effects on the biological ecosystem. This is particularly true where dredging in marshes or waterways is required. Proper use of a hydraulic dredge reduces turbidity effects which are detrimental to aquatic biota. Where waterways are used by migratory species such as shrimp, activities such as dredging in the waterways could be scheduled to avoid the migration season as much as possible. Efforts should be made to revegetate areas where the soil has been excavated for the construction of roads, dikes, pipelines and other facilities. Where herbicides might be used to control growth of undesirable plants along pipeline or transmission line rights-of-way, care will be taken to use the minimum amount necessary. VI-21 6. Noise Construction noise levels will be kept as low as practical through proper maintenance of exhaust systems and through adherence to OSHA standards. Personnel will be protected in their work environment according to established OSHA noise level standards. For sites near inhabited areas It may be necessary to institute a noise reduction program ' with installation of noise abatement designs. Historical and Archaeological Rggnnr, ces Mitigation measures could include professional salvage of a site to preserve a meaningful record of its existence or selection of an alternate location for the undertaking, should there be no feasible or prudent alternative, the procedures for the protection of historic and cultural properties contained in Federal laws will be followed. It is the expressed policy of the ESR and SPR Programs to utilize only those sites and rights-of-way that do not affect historical and archaeological resources listed in or eligible for inclusion in the National Register. PEA will conduct a survey of such resources of each site and will request review and concurrence from appropriate Federal and state agencies if utilization is essential 8- Land Use and Related Planni sa Adverse impacts on the use of lands adjacent to the oil storage sites can be largely avoided by careful selection of the sites, underground storage will be built primarily VI-22 1 in rural areas and once constructed, will not significantly affect the surrounding land use. The primary efforts in mitigating adverse effects will be where tanks, transmission lines, and pipelines are to be constructed. Wherever possible, existing rights-of-way can be used for both the proposed pipelines and the necessary power transmission lines. As much as possible, routes will be chosen that will not require the removal of homes or businesses. State and regional planning commissions will be consulted to determine whether the anticipated growth of residential and commercial areas will engulf portions of the right-of-way during the next 20 to 25 years. Where practicable, the rights-of-way will be planned to remain outside of such areas, but where it cannot be avoided, the rights-of-way in urbanized areas will be landscaped and maintained in such a way that they will not degrade the value of adjacent properties. a. State Land Use Programs Each state planning office will be able to review the proposed plans for oil storage facilities in that state prior to the finalization of designs and right-of-way selection. Often there are a number of state agencies that have jurisdictional interests related to land use although land use planning is not specifically a part of their function. Those agencies empowered to protect the fish and wildlife resources of an area will be consulted to that such valuable and fragile environments as shellfish beds, fish and waterfowl breeding and nursery areas, and the habitat of rare or endangered species can remain unaffected by the project. VI-23 construction practices recommended by state agencies to protect the land from unnecessary erosion will be followed Th.s includes such actions as seeding and placing sod on Slopes where natural vegetation has been removed, and placi barriers across channels cut through wetlands for laying pipelines. ^ ^ ng b. Storage Site Disruptions to the use of lands around the storage sites wil be due primarily to noise created by the pumps and and ;."'/''': '"' '""' """^^^ °' "^^^"^ "°"9« tanks, and the deposition of excavated rock from new mines. These Impacts can be mitigated by the purchase of sufficient land around the facilities to act as a buffer between the site llTl'lT '"' =""°""'^"5 i-"^-- Trees and undergrowth in this buffer area can reduce the noise emanating from the site and mitigate the visual impact of the storage tanks. Where excavated rock must be stockpiled near the storage facilities in new mines, the rock can be covered with soil, landscaped, and seeded. This will help stabilize the landfill area, control sediment runoff from the rock that would be deposited as silt in streams near the site, and mitigate the impact of having to stockpile the rock on the existing landscape. 3- Control an d Cleanup of Spilled nil A principal criterion governing storage system operational procedures is the need to prevent chronic or major releases of oil to the environment. Efforts will be VI- 2 4 I made to educate personnel and to supervise, monitor, and improve operations to prevent any accidental releases of oil. An oil spill contingency plan will be developed which outlines response activities and areas of responsibility in the event an oil spill accident or leak should occur. The plan objective is to deploy the proper equipment as quickly as possible for containment of the oil, to recover the oil as efficiently and completely as possible, and to clean up impacted areas to restore the original condition, insofar as practicable. a* Spill Prevention Control and Countermeasure Plan Spill Prevention Control and Countermeasure (SPCC) Plans are being developed in accordance with Federal law for all facilities in the SPR Program, The objective of an SPCC is to prevent discharged oil from reaching both the surface and navigable waters of the United States. The Plan will contain a description of the facility and its operation, control and alarm systems for leak detection, security measures against unauthorized entry into the facility, the spill prevention systems (dikes, retention basins, drip pans) at on-shore and non-production systems, record keeping and inspection procedures, and training of operating and maintenance personnel. The training is particularly important since on-site personnel will be able to significantly limit the quantity and extent of a spill in most cases. In the case of the SPR program, supervisory personnel will be trained prior to facility start-up. Emphasis will be placed on the SPCC Plan, and in the case of operating supervisors, operational procedures, safety and spill prevention is VI-25 stressed. Maintenance supervisors will also concentrate on preventive maintenance. Supervisory personnel will receive monthly refresher courses, and in turn, will instruct remaining facility personnel. b- Oil Spill Contingency Plans An oil spill contingency plan, developed in accordance with Federal law, is an integral part of an SPCC Plan at facilities where an oil spill can reach navigable waters. Oil Spill Contingency Plans are defined as a predetermined sequence for communications and actions in the event of an oil spill. The objective of such a plan is to prevent an on-land spill from reaching water, or in the case of a water- based spill, to contain, remove and minimize contamination of the water body. The plan covers items such as internal alert procedures wherein the personnel discovering a spill notify the "person in charge" at the facility. Procedures are also delineated for notification of regulatory agencies by the "person in charge." The role of the On Scene Coordinator (OSC) is defined. The OSC is responsible for spill countermeasures at the site, and may be from the facility management, industry, or a governmental agency. The OSC directs the deployment of available equipment and personnel for containment, cleanup and restoration, and serves as a focal point for all phases of these operations. The contingency plan contains a list of predesignated On Scene Coordinators, one of whom is always available. Vl-26 Control and cleanup procedures are also addressed. In this regard, the plan stresses identification of the product and quantity spilled, the status of containment, potential hazards to health and the environment, and a description of the spill site. These actions are necessary if the proper response equipment and personnel are to be mobilized. Restoration of the spill site is also delineated. The OSC and the regulatory agency determine the extent of this action which can take the form of replacing sand on contami- nated beaches, to the removal of contaminated debris. The contingency plan also contains information on predetermined disposal sites for contaminants and debris collected during cleanup. A comprehensive inventory of on-site spill resources (equipment and manpower) in addition to the resources of local and regional entities that can be called in. Public relations and information procedures are also stressed in a contingency plan as a vital part of the cleanup process. c. Operations Manuals Operations Manuals, as required by Federal law, will be prepared for "large oil transfer facilities" (onshore and offshore) where oil is transferred in bulk from a vessel of 250 barrel capacity or larger. As such, the SPR terminals will file Operations Manuals with the U.S. Coast Guard. This document contains a detailed description of the facility, its methods of operation, equipment and personnel, emergency shutdown systems, the quantity, location, instructions for use of spill containment equipment, in addition to specific procedures for each phase of a loading/unloading operation. A spill contingency plan is also an integral part of the manual. VI-27 d. Salt Marsh Cleanup Coastal salt marshes are generally highly productive ecosystems supporting breeding populations of fin and shellfish, often serving as nursery areas for the larval and juvenile stages of these forms. The proximity of salt marshes to various phases and elements of the SPR program makes these systems vulnerable to oil spillage. Westree (1977) identified three general types of salt marshes along the coastal United States: (1) spartina marshes; (2) saltbush marshes; and (3) mangrove marshes. The Spartina marsh is characterized by tall grasses in waterlogged soil frequently innundated by tides, containing brackish to saline water. The saltbush marsh contains low-growing or prostrate vegetation growing on an occasionally waterlogged soil occasionally innundated by tides, with highly saline water. The mangrove marsh generally consists of trees or shrubs in a soil that is frequently water logged, or is subject to tidal innundation. it normally will have brackish to saline water, with the exception of mangrove marsh, all three types occur along, the Gulf and East Coasts (mangrove marsh in Florida) . Westree recommended five approaches to oil spill cleanup in these marshes. Low pressure water flushing was recommended for all types of oil spills in all three marsh situations since the technique provides physical transport and dilution of the oil. Depending upon the amount of effort required for recovery and the availability of disposal sites, sorbents were also recommended. A third method is cutting of vegetation, primarily in Spartina marsh, while saltbush marsh was considered as somewhat tolerant of VI-28 cutting, and mangrove marsh was assessed as intolerant of this practice. A fourth alternative discussed was burning off the marsh vegetation, although this was considered applicable to only the Spartina marsh and then only in the dormant season. A final alternative was the "do-nothing" approach which would be feasible when the spilled oil was non-viscous and adhering well to vegetation with no threat of recontamination by tidal flushing, and when waterfowl use was minimal and other wildlife was not endangered. Cutting marsh grass has been successfully applied to oil contaminated salt marshes following the 1976 Chesapeake Bay oil spill (1977), and along the Hackensack River following a spill in 1976 (HE-164; RO-OOl) . Hershner and Moore (1977) found good recovery of Spartina following cutting, which they felt was aided by the fact that the spill occurred during the dormant winter season. Mattson, (1977) recommended cutting if it could be accomplished quickly during the early phases of cleanup, having found less regeneration of grasses cut late in the New Jersey cleanup operation. ^' Bacteria l Degradation and Other Biological Processes Kator and Herwig (1977), following microbial responses to fresh and artifically weathered south Louisiana crude spills in experimental plots of a mesohaline salt marsh off the York River (Virginia), found that within a few days after the spill the levels of petroleum degrading bacteria rose by several orders of magnitude compared to a control plot. The bacteria remained at high levels, relative to controls, for one year following the spills, while the bacterial levels in the weathered crude plots were statistically higher than in the fresh crude plots, (KA-144) . VI-29 Lee (1976) noted that biological degradation of oil in sediments could be attributed to microfauna, ineiofauna, and macrofauna (LE-001). Microbial degradation is apparently more rapid at the soil-water interface than in the subsurface, and the rapidity of degradation depends, to some degree, on the concentration of high molecular weight aromatics in the soil. The Meiofauna, interstitial copepods, nematodes, turbellarians and polychaetes, presumably function in hydrocarbon degradation although the contribution of this group has not been fully explored. Macrofauna (benthic crustaceans, molluses, large polychaetes and spinculid worms) may function in petroleum degradation by reworking the lower sediments exposing the hydrocarbons to water and bacterial action. Lee noted that sediment oil uptake has been demonstrated by brown shrimp ( Craugon craugon ) and by the spinculid worm Phascolosoma agassizi , and also by certain polychaetes. f . Costs of Oil Spill Cleanup Roland (1977) reported the cost of cleanup operation following the 1976 Chesapeake Bay oil spill at about $400,000, with a recovery of 167,000 gallons of oil (RO-OOl) . Extensive beach and marsh cleanup was required following the spill which contributed to the cost. On a recovery basis, the cost associated with this spill amounted to approximately $400 per barrel. g. Summary of Spill Removal Techniques Current guidance in Federal Regulations for removing spilled oil emphasizes the timely and effective use of mechanical/ manual methods and judicious use of sorbents Vl-30 (agents used to absorb oil on a floating mass for subsequent collection and removal) that minimize secondary impacts. A variety of other treating agents have been used effectively in the past to control oil spills. These include: • Burning agents are chemicals or other materials which assist ignition or enhance combustion of spilled oil. • Dispersants are chemicals forming oil-in-water suspensions. • Biodegradants are substances that promote oxidation of oil by bacterial action. • Gelling agents are chemicals that form semi- solid oil agglomerates and facilitate removal. • Herding agents are chemicals that concentrate the spilled oil in a small area. However, the use of these chemical treating agents is now carefully regulated as their secondary effects can also be adverse, and they may be employed only on a site-by-site basis after evaluation and authorization by the Federal response team. h. Containment and Cleanup at Terminal In the past, routine operations in terminal areas caused chronic, low-level oil pollution from small spills. While industry has substantially ameliorated such conditions in recent years, the potential for small oil spills at terminal areas is still relatively high, and containment and removal equipment will be required to be on-site, ready for immediate deployment should oil be spilled. VI-31 In addition to booms and pneumatic barriers, there are other methods of controlling and collecting spilled oil. Skimming devices scrape oil off the water surface or force it along rotating elements (plates, disks, belts, etc.) from which it can be recovered. Vortex generating devices to separate oil and water have been developed. Magnetic liquids can be added to the oil, and recovery by magnetic pick-up devices is then possible. One of the most promising of all these collection devices for use in offshore terminal harbors appears to be a skimmer boat using an inclined plane. As the collection boat moves through the water oil and water-in-oil emulsions are forced along the moving plane. When the oil-water mixture reaches the collection well it is pumped to an auxiliary collection tank. Using known containment and cleanup techniques, it appears that control of small oil spills from ships in a terminal can be effective. Control should be a relatively minor problem if terminal site selection and design incorporates environmental considerations for proper functioning of existing oil spill containment and removal devices, i. Containment at Sea Although it is recognized that containment and recovery of spilled oil at sea is highly desirable, no system is now available that is applicable to the possible range of oil spill sizes. Wave heights of six to eight feet and currents greater than one knot are conditions which commonly occur at sea and which have caused considerable difficulty in containment and removal of spilled oil. VI-32 Current experience and reports indicate that presently available containment barriers (booms) are ineffective in currents greater that one knot, and in six-to-eight foot high waves; large removal devices have yet to be systematically developed and evaluated for efficient designs; and dispersants (although economic and effective in heavy seas) are toxic, and their use must be restricted. Laboratory tests of the toxicity of various dispersants show the newer compounds to be less toxic than those deve- loped some years ago. National environmental authorities maintain, however, that there is a significant difference between data generated in a laboratory and occurrences that result in field situations. The effects of a dispersant on marine life are partly due to its concentration in the water column. Efforts are being directed towards developing appli- cation equipment and techniques that will assure that con- centrations of the dispersant do not exceed acceptable limits. Much research remains to be done to determine toxologically safe dispersant agents, proper application techniques, and conditions under which the use of such dispersants is environ- mentally acceptable. Use of oil dispersants will probably be an option available for cleaning up oil spills, but the primary emphasis is currently on methods of containment and recovery of the oil. Past experience indicates that a spill of 30,000 tons or larger could not be contained in the open sea. Depend- ing on local conditions and proximity to shore, such a spill could conceivably reach shore before it could be contained. j . Containment at Coastal Inlets Bays, lagoons, and many estuarine areas along much of the Atlantic and Gulf Coast are naturally protected by barrier VI-33 beaches. Various inlets penetrate the barrier beaches and provide passages for spilled oil to enter estuaries or lagoons. In the event that oil from a major spill approaches the coast, it would be desirable to seal off the inlet(s) involved with containment booms. Thus, oil would be kept out of the most ecologically important areas with a minimum effort. However, should oil reach a barrier beach area far from an inlet, natural longshore sand transport processes would tend to eventually move the contaminated sand along the shore until an inlet is reached. From there, it could spread to the estuary or adjacent wetland area. k. Beach CI eanup When oil comes ashore, pronounced economic and ecological damages usually result. m many cases of offshore spills, complete removal or dispersal of the oil will be impossible; therefore, methods and procedures for beach restoration must be available. When a spill occurs and oil washes ashore, it accumulates along the shoreline and may contaminate vessels and shore installations. On beaches, the main impact is aesthetic and the immediate remedy is physical removal of the oil-contaminated sands. Oil contamination of beaches usually causes one or both of the following situations. 1. Beach material becomes uniformly contaminated with a thin layer of oil up to the high tide mark and/or deposits of oil dispersed randomly over the beach surface. Oil penetration is usually limited to approximately one inch, unless dispersants have been used . VI-34 I 2. Agglomerated pellets of oil-sand mixture or oil- soaked material such as straw and beach debris are distributed randomly over the surface and/or mixed into the sand. The choice of restoration methods depends upon the economic and recreational value of the area and the urgency of returning the area to "normal" conditions. A highly developed resort complex, where a large proportion of the area's economic activity depends upon retaining the attractiveness of the beach, will require implementation of cleaning methods chosen more for their quickness than for their cost. In other instances, where the shoreline is mainly valued for its view, the presence of contaminants on the beach will not be so critical and restor- ative techniques of a slower, less costly nature will be found adequate. In conclusion, it appears that the most effective beach-cleaning methods available under the current state-of-the-art: o For rocky areas: sandblasting and/or steam cleaning. o For sandy beaches: removal of the top oily layer of sand entirely or screen-separation where the contaminant occurs in lumps or nodules. o Disposal of debris in approved areas. Other methods of cleaning contaminated sand that have been tried include froth flotation cleaning at an estimated cost in pilot operations of 50-70 cents per ton of sand cleaned and hot water f luidization, a method that has not been successful. VI-35 !• Biological Decomposition Another strategy for dealing with an oil spill, often the only feasible one where a relatively small spill has reached shore in a remote area, is to leave the spilled oil to be decomposed by biological processes. Bacteria have an important role in removing oil from the sea, shore and wetland areas. Bacterial oxidation can proceed as much as ten times as fast as auto-oxidation and there is no doubt that bacteria can utilize a variety of hydrocarbons. In general, however, bacteria cannot degrade the heavier aromatics and branched hydrocarbons such as those found in residual oil. Also, bacterial decomposition is slow, permitting an oil slick to spread over a large area. Micro-organisms capable of decomposing petroleum occur in the ocean, especially in near-shore areas subject to frequent oil spills. Under laboratory conditions, normal marine bacteria have been observed to decompose nearly 60 percent of added fuel-oil in 8 weeks. Light oils are oxidized more rapidly than heavier ones and paraffinic (aliphatic) hydrocarbons more rapidly than aromatics. Decomposition proceeds most rapidly at higher temperatures and in the presence of abundant oxygen. On-going work at the Virginia Institute of Marine Science indicates that petroleum-degrading bacteria also become abundant in salt marsh sediments after oiling. Anaerobic degradation occurs at a much slower rate. This process also depends on the availability of nitrates, phosphates or sulfates which are sources of oxygen for anaerobic bacteria. VI-36 The final products of aerobic oxidation are carbon dioxide and water. Many of the intermediate products are water-soluble and almost all are readily susceptible to further attack by micro-organisms commonly present in coastal waters. Some of the intermediate decomposition products may themselves by deleterious to marine organisms. Intermediate products of degradation, as well as the bacteria themselves, provide support for many higher micro- organisms, protozoa, fungi, and lower algae. Many ciliates occur among oil droplets, some with oil in food vacuoles, and an increase has been noted in the numbers of protozoans following that of oil-degrading bactria in polluted waters. The small polychaete Ophrytotrocha burrows into weathered oil, presumably to feed on the bacteria. Larger animals contribute directly to oil removal, although they probably do not actually digest oil. Limpets (Patella), which exist in great numbers along the coasts of the United States, can scrape weathered oil from rocks during their normal browsing. Oil then appears in the feces, mixed with rock fragments and plant debris, while the limpets are apparently unharmed. Some three to four months after a fairly severe oil spill, parts of the Cornish shore were cleared of oil except for a band deposited above the highest level beyond which limpets could not feed. On the worst-affected shores in Cornwall, England, after the Torrey Carrion wreck, all limpets were killed by emulsifier spraying. Chitons, which occupy a similar ecological niche to limpets but are nearly twice as large, removed much of the fuel-oil spilled from the stranded General Colocotronis from limestone beaches in the Bahamas. VI-37 ">• Costs of Oil Spill Cleanup Historically, oil spills have contaminated the environment to varying degrees depending on the quantity of the oil spilled, location, weather conditions, and a variety of other variables. Oil can dissipate quite rapidly through evaporation, wave dispersion, or sinking. However, once the oil comes in contact with the shoreline it tends to stick or be absorbed by grasses, sand, or rock. Data of actual oil spill incidents were reviewed to obtain an approximate estimate of cleanup costs. The cost data are highly specific to the particular incident; therefore, a range of possible cleanup costs was developed rather than a specific value. This range of costs results from selected incidents which represent a wide variation in oil spill variables. Cleanup costs include all attempts or actions to salvage, contain, remove, or cleanse oil on the surface of the water, shore, or private property. Costs also include, where appropriate, removal of oil from a damaged vessel which posed a threat to the environment. There is a wide variation in the cleanup cost per barrel of cargo. In the World Glory mishap, where no shore contamination occurred, the cleanup cost was comparatively low, at about $1.00 per barrel. However, for the Santa Barbara offshore leak, cleanup costs were nearly $50 per barrel due to the heavy oil contamination of beach and harbor areas in Santa Barbara and Ventura, California. Thus, the estimated oil spill cleanup costs range from a minimum of $1.00 to perhaps $50 per barrel, or $7.00 to $350 per tanker DWT. For the complete loss of cargo from a 400,000 DWT tanker the cleanup cost may range from a minimum VI-38 i of $2.8 million to as high as $140 million if all the oil damage was concentrated on valuable beach property areas. Generally, the cleanup cost per barrel is smaller as the amount of oil spilled becomes larger, so the $140 million cost figure would apply only in a particularly unfortunate set of circumstances. The above comparison pertains to actual data from relatively large unintentional oil spills. There is some indication that smaller spills (less than 5,000 gallons) in waterways and harbors are more expensive to clean up on a per-barrel basis. A recent study indicates an average cleanup cost of about $4 per gallon or $168 per barrel on spills between 500 and 5,000 gallons (US-124) . other sources indicate small spills can cost as high as $1,000 per barrel for cleanup. These smaller spills are generally related to tanker operational discharges and cargo transfer accidents. ^°* Mitigating Effects of doe Planning As described in Section II. G., DOE environmental planning spans site development and operation as well as oil procurement and transport. Environmental specifications for site design, construction and operation are documented in the Programmatic and Site Environmental Action Reports. Environmental operational procedures for the prevention, containment and clean-up for oil spills are documented in the Spill Prevention Control and Countermeasures Plan, and the contingency plan developed for each site. The previous sub-section describes these plans. Environmental criteria for the transport of crude oil will be contained in carrier- contracted stipulations. VI-39 These environmental specifications, procedures and criteria have been promulgated in response to identified environmental impacts or concerns. When implemented, these requirements will mitigate or avoid environmental impacts consistent with the environmental policy of DOE Strategic Petroleum Reserve Office. The details of promulgation, including analysis of engineering practicality, economic cost and environmental effectiveness, are contained in the above cited planning documents. To effectively mitigate impacts, these developmental and operational requirements must be implemented. Implementation is by contractural stipulation, environmental review and surveillance. The design criteria, construction practice and operational procedures, as documented in the Environmental Action Reports, are part of the contracts between DOE and the design and construction engineering contractors. In turn, their site dsigns and construction specifications are reviewed for compliance by DOE. Complaince during actual site construction and operation is monitored by environmental inspectors stationed at each storage site. The cumulative effect of the DOE environmental planning process is to force adherence to standards, procedures and techniques which will insure that adverse effects of the SPR will be mitigated to the extent feasible. 11. Floodplains/Wetlands Mitigation Executive Order 11988, Floodplain Management, and Exec- utive Order 11990, Protection of Wetlands, require Federal agencies to reduce the risk of flood loss and take action to minimize impacts of floods, and to minimize the destruc- tion, loss, or degradation of wetlands. DOE has proposed I VI-40 regulations to implement these Executive Orders. Because the wetlands order (and hence its regulations) provide that It IS inapplicable to wetlands projects under construction prior to October 1, 1977, or to those projects for which a draft or final EIS was filed prior to that date, a large percentage of candidate sites are exempted. Regarding DOE activities within floodplains, the regulations are applicable to all proposed actions where practicable modifications or alter- natives are still available, with respect to projects for which the appropriate environmental review has been com- pleted or a final EIS filed prior to the effective date Of the regulations, DOE will, in lieu of plenary floodplain procedures, review the alternatives identified in the envi- ronmental review or the final EIS for potential floodplain impacts. If project implementation has progressed to the point where review of alternatives is no longer practicable, or If DOE determines after a review of alternatives to take action in a floodplain, the selected alternative will be designed or modified to minimize potential harm to or within the floodplain and to restore and preserve floodplain values. ^- Unavoidable Adverse Impacts 1. Geology 3- Gulf Coast Region There are no certain unavoidable impacts related to the geological characteristics of the region. Probably a very snail change in the geothermal gradient within the salt domes in which new cavities are constructed will occur; also, the geomechanical stability of the portion of the salt dome covering the mined cavities will be decreased. The magnitude Of the environmental impact of any kind, if any, engendered VI-41 by these changes is not known with certainty, but is believed to be insignificant. The historical precedence of petroleum storage, albeit, at a smaller local scale, indicates negligible impact under conditions of sound engineering design and construction practices. b. East Coast Region Any storage facility or other structure, existing or new, in the New England area is subject to higher risks of damage due to earthquakes than in most other areas of the country. This is based on historic records of earthquake intensities, and is true only if one occurs. There is no implication of frequency of occurrence. Ground motion resulting from an earthquake could, depending on magnitude, result in damage to oil storage tanks and pipelines. This in turn could result in oil spills. Although an earthquake would be unavoidable, any oil spill on site that might result would be contained by the dike sys- tem, and the impact of any oil spill due to off-site pipeline damage would be minimized by system shutdown and mobilization of cleanup crews. 2. Hydrology a. Gulf Coast Region (1) Surface Water Impacts Runoff from construction sites will introduce higher con- centrations of suspended solids into proximal water bodies during the construction phase and for a short time thereafter. VI-42 The likely impact of this will be short-term increases in the naturally higher turbidity during storm/runoff events. The program will require a continuation or an increase in the dredging activity for channel deepening or maintenance at several Gulf Coast ports or docking locations. Short- term, direct water quality degradation by increased suspended and dissolved solids will accompany this dredging, and the dredged bottom material generally represents a long-term potential source of various pollutants that requires attentive maintenance for confinement to the disposal site. The direct effects on water quality will be limited to the project area and may include: increased turbidity and its effects; reduc- tion in photo-synthetic activity, flocculation of planktonic algae, and a decrease in available food supply; sediment buildup that may smother benthos; oxygen depletion; and removal of substrate materials and associated benthos. The more long- term effects are less well-known but may include the slow release to toxic dissolved heavy metals, hazardous organic compounds, and anaerobic gases (methane and hydrogen sulfide). Increased traffic of vessels carrying petroleum and petroleum products in the coastal region will result in higher potential for oil spills during the initial filling phase of the program and probably also during cycling. Water supply intakes and brine diffuser pipelines, if any, consti- tute an additional navigation hazard that would not otherwise exist. The increased probability of catastrophic degradation in water quality due to spillage of oil or other hazardous substances and ensuing water quality problems from disposal of oil spill cleanup debris cannot be avoided, although conse- quent impacts are site-specific and also may be mitigated. If brine is discharged into the Gulf of Mexico as a result of either solution mining or fluid displacement, the VI-43 salinity of Gulf waters near the diffuser will be increased. Owing to dispersion and advection, the plume of excess salin- ity will reach a steady-state condition. Under reasonable worst-case conditions of highest brine rates (from a 200 MMB facility) , very little solute advection, and low dispersion, the approximate area over which the increased salinity may be detected by aquatic organisms is 3000 acres; this water quality change would primarily affect the bottom waters rather than surface layers. Behavioral changes (including avoidance) for mobile species or possibly death for sessile species may be encountered in an area of several hundred acres. In addition, about seven acres of marine bottom would be severely disrupted by construction activities for each mile along each of the diffuser pipelines' rights-of-way. Up to five widely separated areas such as those described above may be affected by implementation of the proposed program. No interactions of water quality-related effects among the various areas are predicted, however. (2) Ground-Water Impacts Although usage of ground water and any consequent impacts may be avoided by using surface water, especially Gulf water, at any location, it is a viable alternative water-supply at some locations. Owing to the projected fresh surface water shortages in the western Gulf Coast over the next few decades, ground water is attractive for use at other inland locations; during the long term, where operation of the storage facility during a crude shortfall may require an instantaneously available, reliable water supply. If ground water were used to displace stored crude from a 200 MMB facility during a five-month period, an equivalent water inflow crude outflow of 39,000 gallons per VI-44 minute (or 56 million gallons per day) would be required. The production of this ground water from a properly designed well field will lower the potentiometric surface in the aquifer being pumped as much as 150 feet. Such large drops in hydrostatic pressure within the aquifer system may be accompanied by a few feet of surface subsidence, slow salt- water encroachment up-dip within coastal aquifers, and "activation" of near-surface faulting with differential compaction. Within the area of ground-water pressure declines, foundation damage due to differential settlement and increased flooding potential, particularly in more coastal settings, are possible results. The effects are site-specific in that they depend on the aggregate amount and thickness of the clay beds in the lithologic sequence as well as the actual pressure decline. While most compaction takes place in the clay beds, some compaction of the aquifer material may also occur, which results in long-term loss of storage capacity and thereby may affect the local water-yielding properties of the aqui- fer. Recovery of water levels will occur fairly rapidly after pumping ceases, but some of these physical changes may be irreversible. Brine disposal by deep-well injection will nearly always degrade the quality of the existing formation fluid. Effects on the biosphere are not a necessary consequence, however, if prior, adequate evaluation and design are conducted. b. East Coast Region A minor degree of water quality degradation within sur- face water bodies near construction sites is unavoidable. The principal pollutant of concern is suspended sediment from eroded areas. Dredging will also cause short-term deterioration in water quality in marine and estuarine locations. VI-45 3. Meteorology^ Climatology and Air Quality Catastrophic meteorological events could conceivably destroy surface facilities at a salt dome storage system, but impact from the facility will be minimal. Some oil spillage will occur from fractured pipelines and flow from the storage cavern. Additionally, some oil spillage and uncontrolled hydrocarbon vapor release could occur as a result of conventionally mined storage areas. These impacts will be negligible when compared to that caused by the storm. No significant permanent impact on the air quality in the Gulf Coast region will occur from construction, filling, or operation of subsurface storage facilities for an expanded SPR. The associated tanker loading and unloading, under "worst case" meteorological conditions, is predicted to cause local and temporary violations of the Federal hydrocarbon standard. Storage of residual oil and/or distillate fuel oil in tanks and the required tanker operations will increase local hydrocarbon emissions levels. 4 . Noise Noise from acoustically untreated equipment used during construction of tank farm storage facilities will have an adverse impact on human and wildlife populations within approximately one-half mile of the activity. Radiated noise from filling and operation will be of sufficiently low levels to be of no environmental consequence. Noise from drilling activities in developing salt dome storage will cause an unavoidable adverse impact up to about VI-46 1500 feet from the drilling site. Operation of the facility will impact the area within 3500 feet of the center of the pumping station. 5. Biology Unavoidable biological impacts will be the temporary loss of habitat from development activities and long-term loss of habitat from physical existence of storage facilities, roads, pipelines, dredged channels, etc. Aquatic organisms will be damaged or killed by entrainment and impingement on intake structures if used for water withdrawal in the solution mining of salt caverns. Aquatic organisms will be temporarily disturbed in the area of brine disposal into the Gulf. Streams, rivers, and estuaries will have temporarily increased siltation caused by dredging, drilling, and construction of roads and pipelines. In the Gulf Coast region, endangered species of animals could be disturbed. Odor from storage in tanks could disturb organisms. 6» Historical and Archaeological Resources Impacts to historical and archaeological resources listed in or eligible for inclusion in the National Register will be avoided by the selection of sites and rights-of-way away from such resources. Should there be no prudent or feasible alternative to the use of sites and rights-of-way that affect such resources, the requirements of Federal law will be met. 7. Recreational Resources The project's impact on recreational resources will be related to its use of wilderness areas that are local hunting and fishing areas. The noise and activity associated with constructing the storage facilities will force wildlife VI-47 away from the sites. Furthermore, the sites will be fenced. Where the lands were privately owned and used for production of brine, sulfur, salt, limestone and other industries, the restriction to hunters and fishermen will not constitute a change, where new solution cavities, mines, or tank farms are built in wilderness areas, there will be a net loss of recreational land. The most severe impact of this kind would occur if oil is stored in new mines and the excavated rock must be stockpiled over a few hundred acres. The solution cavities in salt domes and the new mines require pumping water into the storage space when the oil is removed. There will be some loss to sport fisheries due to entrainment of fish eggs and larvae, but this loss will not be a major one. Where pipelines cross beaches to dispose of the brine from salt solution cavities via its diffusion in ocean waters, there will be an avoidable but short-term interference with other uses of the beach. The major impact on recreational resources would occur in the event of an accidental spill of oil or brine. A spill occurring in a waterway would spread, and depending on the quantity of oil or brine lost, vegetation, fish and waterfowl would be injured or destroyed. 8 . Land Use The project will either use sites that are already being used for industrial purposes or build new facilities in sparcely populated areas. The construction of rights-of-way through farms, forests, wetlands and lands that will eventually become residential, is unavoidable. If the reserve is to include storage in new mines, the piling of excavated rock on adjacent land is also unavoidable. VI-48 sites used for petroleum storage will become designated as industrial sites, where there are sites located near urban areas, they may affect zoning regulations that will tend to reserve surrounding lands for industrial use also. 9 . Economic and Social Impacts Adverse impacts that are unavoidable and would be common to both the Gulf Coast region and the East Coast Region include: (1) traffic congestion, (2) accommodation of a migratory pipeline construction crew, (3) a local shortage of plate steel if the maximum amount of petroleum product is stored in steel tanks. Traffic congestion will occur during the construction period at practically every site. It will be due to workers travelling to and from the site and large trucks bringing equipment and materials. Pipeline construction requires workers with specialized skills and experience. While some of the right-of-way preparation and restoration may be done with local labor, it is very likely the pipeline contractor will be from outside the area, and 60 to 100 workers will move temporarily into the communities near where the pipelines are to be laid. The extent to which this may affect the host communities will depend on the size of their current population and the degree to which they can accommodate the pipeline crew. If as much as 95 MMB of petroleum product is stored in steel tanks, it will consume about 360 thousand tons of steel plate. While this constitutes only about 3 percent of the projected capacity for steel plate production in 1978, it could cause delays in delivery of steel to other users, and some local shortages. VI-49 VII. IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES Implementation of the Strategic Petroleum Reserve plan will require some irreversible and irretrievable commitments of resources. With an increase of the total volume of the SPR from 500 to 1,000 MMB , these commitments of resources would increase, although not in direct proportion to the volumetric increase. Some of the terminals and transmission facilities will only have increased use, and new construction on the same scale as the initial 500 MMB plan will not be required. A. Land Resources The land used for surface facilities and pipeline or transmission line corridors is not a permanent commitment. The buildings, equipment, pipelines and other fixtures could be removed and the land used for other purposes. Land that has been used as a site for the disposal of dredge spoil or of excess rock from new mines will be irreversibly altered, but could also be used for other purposes or allowed to revert to a wilderness condition. Some mineral resources will be irretrievably committed. Where solution cavities in salt domes are used to store oil, salt will be removed to create the cavities and more salt lost each time the oil is withdrawn and replaced. The quantity of salt that would be unrecoverable; however, it would be less than one percent of the rock salt reserves in the Gulf Coast States alone. Where oil is stored in rock mines, there will be a loss of this material. Rock, such as limestone, is VII-1 somewhat permeable and would be contaminated with oil along the edge of the storage area. Technically, the stone could be recovered, but it would not be economical to do so. Assuming that there is not an established market for the stone excavated from a new mine and that the stone is crushed and removed, there would be an irretrievable loss of stone that may have been used as dimension blocks. Crushed stone deposited in a land fill could be retrieved. National reserves of stone for construction materials are adequate to provide for the expected demand indefinitely. High-purity limestone and dolomite suitable for use in the manufacture of chemicals and metals is restricted in extent, but selection of mine sites for oil storage could avoid use of these reserves. In the construction of new mines as storage facilities some rock material may be rendered useless and discarded, even though most is potentially marketable and therefore not irretrievably committed. The geological and hydrological aspects of the developed mine area will be permanently altered, but the change will not be significant. Whether land required by any storage facility or its appurtenances could be restored to its original state and/or use after the life of the facility is unknown. it seems likely that some irreversible damage could possibly occur to the present land composition. Rock disposal (or long-term storage) areas and dredged spoil disposal areas are essentially irreversibly committed to that use and realistically generally irretrievable. B. Water Resources When subsurface injection is the method chosen for brine disposal, the injection well will be sufficiently deep VII-2 so that fresh water sources are not contaminated. Proper use and installation of well casings will prevent the contamination of fresh water sands that are pierced by the wells. In the event of an accidental break in the well tubing (i.e. seam failure, improper weld, or corrosion) the well could be plugged to prevent saline water from rising up the well. Normal groundwater movement would then gradually dissipate the brine. Should large quantities of nearly fresh ground water be used, permanent changes in head relationships and flow patterns in aquifers could occur. Changes in the hydraulic regime of aquifers could slightly affect the quality and quantity of discharge into springs and streams. Large quantities of water, ranging from 426,000 to 562,000 acre-feet, will be irreversibly committed to this project for developing new solution-mined cavities. The high salinity after its use makes this water irretrieveble from a practical standpoint. Operation of the facility during a period of interrupted supply may require up to 124,000 acre-feet per complete cycling event on demand at any time; this water is also an irreversible and irretrievable commitment to the storage program. C. Ecological Resources The loss of any endangered species constitutes an irreversible and irretrievable resource commitment. In particular, the Southern bald eagle could be sufficiently disturbed by activity at several sites under consideration to seek other nesting areas more remote from developed sites. This change may be tantamount to a resource commitment. VII-3 D. Archaeological and Historical Resources Any disturbance of archaeological and historical resources would be an irretrievable loss. While it is as yet unknown how many historic and cultural resources may be affected by this program, it is DOE policy to survey each project area to locate such resources and to avoid them whenever possible. Where avoidance is not possible, DOE will consult the appro- priate SHPO and, if appropriate, the ACHP, to develop a plan to mitigate the adverse impact of the project on such resources, E. Human Resources The major sociological resources to be committed are people's work hours and personal time spent on the project. An approximate amount of manpower required to implement the program is difficult to establish with certainty, owing to inadequate information on program components. In the ESR, about 500 man-years of direct labor will be required, and in the SPR, up to 5400 man-years may be expended depending on the type of facilities constructed. Statistical predictions are that fatal accidents will occur in construction of the storage facilities as in construction of any large facility. Other loss of life will result from increased population in traffic accidents and other increased human interactions. F. Materials Some materials used in the storage facilities will be committed and therefore represent an irretrievable resource. Besides materials such as paint, asphalt, lumber, and glass VII-4 that will deteriorate or be discarded in lieu of reuse, a significant amount of steel may be irretrievably lost for other uses. Most of this steel loss is represented by several hundred thousand feet of down-hole casing and pipe that will eventually corrode; some pipeline materials, especially water and brine piping, may also be irretrievable. Most oil pipeline material is anticipated to be salvageable, owing to measures designed to prevent erosion, corrosion, and subsequent rupture. G. Energy The energy consumed in constructing and operating the reserve is a commitment of electric power, and therefore equivalent amounts of solid and liquid fuels that will be irretrievably lost to other uses. The amount of energy to construct the reserve is estimated to be no more than about 4 million megawatt-hours, and to cycle the total system will consume less than 10.5 million megawatt-hours of energy. The system will store up to 1.7 billion megawatt-hours of energy, In a broader context, the crude petroleum itself acquired for filling the reserve is a resource that is destined for irretrievable, although no irreversible, consumption that could not otherwise take place. In this sense, it is a resource commitment, but it is also the rationale for the storage program. The quantity of petroleum ultimately required will depend upon the ultimate capacity of the reserve and the number of times that it will serve as an emergency supply. VII-5 VIII. RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY Virtually any use of the environment, both long- and short-term, will cause some eventual changes in the productivity of the development areas. The overall program for the Strategic Petroleum Reserve, as expanded and accelerated, will insure that longer term national productivity will not suffer a discontinuity through interruption of imported oil to the United States. The impact of such a disruption in imported oil cannot be overemphasized in terms of the gross impact on the national socio-economic growth, and the directed degradation of human living standards, primarily in the economic area, which would result for millions of Americans throughout the nation. This overall national impact, were there no Strategic Petroleum Reserve to insure economic stability, is the overall balance against which localized short-term and longer term uses of the environment for the SPR must be measured. A. Geology and Hydrology For the expanded Gulf Coast Region, the geological relationship between short- and long-term results will depend greatly upon the methods chosen for developing salt caverns and the susceptibility of the geological regime to a particular method. Should ground water be used for leaching of salt dome caverns, a risk of subsidence by proportional compaction of affected strata is present. However, surface water sources are adequate to meet the needs of the project, so the use of groundwater would not be necessary. VIII-1 Some of the sites will require land fill in order to provide a firm base for well pads, roads, and building foundations. Dikes will be raised around tanks, and berms may have to be built to elevate brine ponds. This will cause local changes in soil composition, but not to the extent that it would significantly change the productivity of the surrounding land. The greatest concern in terms of impacts on soil is that of prolonged seepage of brine into the ground from an undetected leak in the brine handling equipment. If such an accident did occur, the soil would become less able to support vegetation. The length of time this effect would last would depend upon the extent of seepage and local conditions that would wash away the salt deposit; but generally, brine seepage from an undetected leak would have a long-term effect. For the East Coast region, development of new tank farms will have negligible impact on the short- and long-term relationships. Construction of new mines will alter the local geology and in some cases hydrology in the mine vicinity. Use of existing mines, salt caverns and tankage for the Early Storage Reserve will require an insignificant change in existing hydrological and geological conditions. Long-term productivity should remain essentially the same as for pre-storage periods. B. Water Quality The solution cavities in salt domes would require approxi- mately 183 billion gallons of water from the area during VIII-2 construction of the cavities, and up to 25 billion gallons during the displacement operation. Comparison of this level of consumption with the available water supplies in major surface water bodies alone indicates that the use of the water would not limit the development of industry in the area or the growth of cities that need to share these water resources. Where subsurface injection is the preferred method of of brine disposal, measures will be taken to protect fresh water sources, including those which are not presently used for drinking water purposes but which may be used in the future. For development of new facilities, short-term water quality impacts arise primarily from dredging and ditching required to emplace pipelines. Near the dredging operations, increased siltation causing increased turbidity will occur. Resuspension of waterway bottom deposits may raise the pollutant levels of heavy metals, pesticides, and organics. Modification of existing capacity to convert it to storage systems will cause less severe degradation of water quality except where new roads or pipelines require development. Increased oil transportation will increase oil spillage about one percent during the fill period, and result in some water quality degradation. In the long-term, water quality as related to activities of the storage system will stabilize to prestorage conditions C. Air Quality There will be a short-term degradation of air quality caused by the development of either new or existing storage VIII-3 capacity. Some fugitive dust emissions will result near storage sites, and will be present only during the construction phases. The increase in the Strategic Petroleum Reserve from 500 to 1,000 MMB, and the acceleration in the filling process will increase the fugitive dust emissions as more construction activities will be required. The expanded SPR will cause temporary and localized increases in hydrocarbons and photochemical oxidant levels during marine tanker unloading and loading of crude oil. This short-term air quality problem will not occur in the East Coast storage region because storage will probably be limited to low volatile oils (residual oil and distillate fuel oil). Hydrocarbon emissions from subsurface storage cavities in the Gulf Coast region will be minimal. The employment of double-sealed floating roof tanks in the East Coast region will reduce the standing storage hydrocarbon emissions to a great extent. No long-term degradation of air quality is anticipated to result from the expanded SPR. D. Biology Short- and long-term biological productivity of certain limited areas will be lowered by implementing the program, primarily from construction of new storage facilities and increased oil spills. Short-term productivity will be affected by the reduction of available habitat by the occupying facility and destruction of organisms during construction activities. Increased noise levels will disturb and displace some wildlife. The effect on long-term productivity will be negative but local to the storage site. Increased population will have a very small effect on biological production in the long term because the percentage of increase in a local area is small. VIII-4 For modification and development of existing mines, tanks, and salt caverns, a small to moderate biological disturbance of each site will occur. Development of existing facilities will have appreciably fewer short-term effects than will development of new storage facilities. Long-term productivity will be about the same. E . Archaeological and Historical Resources During surveys in preparation of new site development, those archaeological and historical resources that are discovered will provide important gains to scientific knowledge regarding the history and prehistory of the site. F. Recreation For development of new facilities, three types of recreation will be principally affected on the short-term basis: hunting, fishing, and water-contact sports. Game birds and animals will be displaced from the area occupied by the site. Game fish will avoid stream and estuarine waters in areas of excess siltation, and such water-contact sports as swimming will be limited in these areas. The potential for increased oil spills during the fill period could increase pollution on bathing beaches. In the long-term, wildlife may return to the affected areas both on water and land. G. Agriculture If the developed site were previously used for agriculture, some short-term loss of agricultural productivity will occur. Usage of existing storage capacity will have little effect VIII-5 upon agriculture; some right-of-way for pipelines may remove land previously under cultivation. Fencing of facilities may impede grazing of livestock and will lessen available pasturage Implementation of the program could result in both short- term and long-term benefits to agricultural productivity. In the event of another severe supply interruption, all industries, including agriculture, will be affected, with the storage reserve in place, the severity of the associated impact will be lessened. H. Socioeconomic Factors Development activities associated with the program will provide new jobs on both short- and long-term bases. The short-term effects will be significant at a local level, particularly in rural areas. Long-term job productivity is not appreciable but is present. Local inhabitants will benefit by having increased job opportunities and additional revenue. On a regional basis, the increase in jobs and capital will be insignificant. The overriding objective of the program is enhancement of socioeconomic conditions during and after a severe interruption of imported supplies. This can best be measured in terms of impact without the program. Some estimates indicate that an impact in terms of job losses could reach an additional two million persons unemployed if a storage buffer is not available. Such loss of jobs carries with it the attendant human suffering, anxiety, and personal hardships for those affected. with the project, the effects will be significantly lessened. VIII-6 IX. CONSULTATION AND COORDINATION WITH OTHERS Various agencies, governmental units, and local groups contributed information and assistance for the preparation of this Supplement to the Final Environmental Impact Statement. A list of these agencies is given in Section A. Further advice and coordination will be sought from agencies having regula- tory jurisdiction over those segments of the environment which will or could potentially be affected by the proposed project. The Draft Supplement to the Final Environmental Impact Statement was released for public review and comment in September 1977. A list of those agencies and organizations from which comments were requested is given in Section B. Those comments which were received within the time allotted, are included in Section C. Minor changes to the text of the statement have been made in response to these comments. The comments from various agencies are included in their entirety in Appendix C. A. Agencies and Groups Consulted In preparation for the Environmental Impact Report, numer- ous agencies, governmental units and groups were consulted for information and technical expertise pertaining to the proposed project. These groups are listed alphabetically below. Federal Agencies Army Corps of Engineers Bureau of Land Management Coast Guard Environmental Protection Agency Fish and Wildlife Commission Geological Survey Maritime Administration National Oceanic and Atmospheric Administration Smithsonian Institute IX-1 state Agencies Georgia University Institute of Natural Resources Louisiana Department of Conservation Louisiana State University Louisiana State Wildlife and Fisheries Commission Mississippi Bureau of Environmental Health "^llilltl^ llTJoTrol^lr'"' '"' ■^-lop.ent District Texas A&M University, Marine Station Texas Parks and Wildlife Department Texas Water Development Board Local Government Agencies Houston-Galveston Area Council Other Groups C.R. Gushing and Company, inc. Exxon Corporation Gulf Marine Management Corporation Gulf Trading and Transportation Company Tanker Advisory Center ^- Par ties From Which Comments Were Requested As a part of the review process for the Environmental Impact Statement, comments have been requested from th( departments, agencies, and organizations listed below: Federal Agencies Appalachian Regional Commission Council on Environmental Quality Department of Agriculture le IX-2 (Federal Agencies continued) Department of the Array, U.S. Corps of Engineers Department of Commerce Department of Defense Department of Health, Education, and Welfare Department of Housing and Urban Development Department of Interior Department of Labor Department of State Department of Transportation Department of Treasury Energy Research and Development Administration Environmental Protection Agency Federal Power Commission Interstate Commerce Commission Nuclear Regulatory Commission Tennessee Valley Authority Water Resources Council State Agencies All State Clearinghouses including Puerto Rico and the Virgin Islands Regional and Local Agencies Assumption Parish Police Jury Brazoria County Commissioner Gulf States Marine Fisheries Commission Iberia Parish Police Jury Iberville Parish Police Jury Louisiana Offshore Terminal Authority South Central Planning and Development Commission St. Mary Parish Police Jury Other Organizations Acadiana Planning and Development District American Fisheries Society American Littoral Society American Petroleum Institute Baton Rouge Audubon Society Calcasieu Rod & Gun Club IX-3 (Other Organizations continued) Canoe & Trail Shop, Inc. Center for Law and Social Policy Council on the Environment Domtar Chemicals, Inc. Ecology Center of Louisiana, Inc. Edison Electric Institute Electric Power Research Institute Environmental Defense Fund, Inc. Environmental Policy Center Environmental Resources and Energy Group Florida Audubon Society Friends of the Earth Funds for Animals, Inc. Institute of Gas Technology Interstate Natural Gas Association Izaak Walton League of America League of Women Voters LOOP, Inc. Louisiana Power and Light Louisiana Wildlife Federation Louisiana Department of Justice Morton Salt Company National Association of Counties National Audubon Society National League of Cities National Parks and Conservation Association National Resource Defense Council, Inc. National Science Foundation National Wildlife Federation New Orleans Audubon Society RESTORE, Inc. Seadock, Inc. Sierra Club-Delta Chapter Sierra Club-Gulf Coastal Regional Conservation Committee Sierra Club-New Orleans Group Sierra-Southern Plans Regional Conservation Committee The Courier The States-Item The Times-Picayune U.S. Conference of Mayors U.S. Louisiana Department of Justice IX-4 C. Parties From Whom Comments Were Received The comments on the Draft Environmental Impact Statement addressed herein are those received by the Department of Energy within the allotted comment period. Copies of those letters of comment are contained in Appendix C. Comments received by DOE after the expiration of the time period also have been considered in the preparation of this Supplement to the Final Environmental Impact Statement to the degree practicable within such time limits, but are not addressed individually within Chapter IX. Comments Received from Federal Agencies 1. Department of Commerce, Maritime Administration Comment a ; The discussions on page V-50 and in Appendix A of operational discharges of oil from tankers should be rewritten and expanded. Response ; The discussions on page V-50 and in Appendix A have been expanded by the inclusion of detailed information provided by the Maritime Administration. Comment b ; The last sentence of the first paragraph on page V-54 should be corrected to indicate that 2,380 barrels of oil is about equivalent to 100,000 gallons. Response ; This correction has been made on page V-54. Comment c ; "The first paragraph [on page VI-32] states among other things that "dispersants (although economic and effec- tive in heavy seas) are toxic, and their use must be IX-5 restricted." it is suggested that more discussion be devoted to the recent development of dispersants with lower levels of toxicity. The use of these dispersants would require prior approval by national authorities but they could prove useful in mitigating the effects of large oil spills in open ocean areas where containment IS impossible". Response ; The text on this page has been expanded to include a discussion of dispersants. Recent developments in producing dispersants with lower levels of toxicity ar( recognized along with the need for further research in their use. 2. Department of the Interior Comment a: The supplement points out that a capacity now exists for 370 million barrels (MMB) of oil storage previously proposed. This means that the previous proposal would require 130 MMB of new storage capacity while the new proposal to store 1,000 MMB would require 630 MMB of new storage capacity, which is approximately a fourfold increase m new capacity. This same type of relation- ship for oil storage capacity requirements could occur for other phases as well. Impacts that previously were projected to be minor, local, and insignificant could possibly now become major, regional, and significant. Consequently, we question the rationale that doubling a program will double the impacts without noticeably altering their direction or significance. There may be a fourfold increase in some impacts, and the timing should also be considered". Response ; The extent of increase in environmental impacts is not expected to be in a linear relationship with the increase in the number of barrels of oil to be stored. Furthermore, some types of impacts will be dispropor- tionately increased relative to other types of impacts That construction impacts would not be merely doubled by the expansion of the reserve is acknowledged in the opening paragraphs of Chapter VI. The significance of individual kinds of impacts brought about by expanding IX-6 the reserve will depend upon the storage methods and oil transport methods to be used, and the environmental characteristics of the sites chosen. While it is true that most or all of the second 500 million barrels will require new leached storage capacity, as compared to about one-half of the first 500 million barrels (thus resulting in a tripling of the amount of brine to be disposed) , it does not necessarily follow that the cumulative impacts will become more significant, merely because of the increased volume. The question turns rather on the environmental acceptability of the selected disposal method for each storage site. Since the sites are sufficiently separated geographically so that the effects of disposal from any two cannot interact, no synergistic impacts will occur to cause significant results where none would have been produced otherwise. In general terms, it may be said that doubling the amount of oil to be stored means that more sites will be used and affected by the program, but it does not necessarily mean that individual sites will be more severely impacted, Comment b "It is noted that violations of carbon monoxide and photochemical oxidant standards are frequent on the East Coast (p. IV-22) . It should also be mentioned that hydrocarbons are a major contributor to the reaction with sunlight which creates photochemical oxidants. We suggest that the environmental statement should identify the increment of pollutants that may be added as a result of the proposed project". Response ; The increment of hydrocarbon emissions resulting from the proposed project has been identified and assessed in the Sections V.A.l.C, V.A.2.6. and V.B.2. However, the impact of the increased hydrocarbon emissions on ambient levels of photochemical oxidant was not quantified. This is because photochemical oxidant is primarily a regional air pollution problem, while the SPR will generate emissions from one or two specific sites. The state-of-the-art is not sufficiently advanced to quantify the regional photochemical oxidant level resulting from a couple of single polluting sources. Comment c: "The discussion of wetlands [on pages V-27 and V-28] should take into account Executive Order 11990, signed by President Carter on May 24, 1977. The Order directs Federal agencies to avoid wherever possible the long- IX-7 and short-term adverse impacts associated with the destruction or modification of wetlands and to avoid direct or indirect support of new construction in wetlands wherever there is a practicable alternative We are especially concerned about possible impacts to wetlands because of their value as a recreational resource and the uniqueness of their habitat. Careful consideration should be given to the implementation of any part of the Strategic Petroleum Reserve program which would involve the modification of wetlands". Response Although Executive Order 11990, by virtue of the exemp- tion contained in Section 8, does not apply to those^ bPR Sites assessed in environmental impact statements ^h^^'•.'°•'''^^°^^? "■'• ^^^^' nevertheless DOE believes that It IS developing the SPR in consonance with the DrarM.^h/^^ ^'^^^ ^^ ^^^^"^ ^^^ mitigative measures practicable to minimize adverse impacts to wetlands. The discussion on pages V-27 and V-28 is focused ^he^Gulf^^o^L^?''^ ^°' recreational purposes. Along the Gulf coastal area, most of the land used for drvl^n^'?JJ hunting and fishing is wetland, although dryland forests are also used for hunting, hiking, camping, and other forms of recreation. The discussion of the project's potential effects on recreational land, and measures that are to be taken to mitigate adverse impacts is in accordance with Section 5(c) of Executive Order 11990 which directs each agency to consider public use of wetlands for recreation as a oTsuch^:^tIands!° ^ P^P-al's effect on the quality Comment d: . We are also concerned about possible infringement by man-made canals upon recreational lands funded under tne Land and Water Conservation Fund Act of 1965 as amended Section 6(f) of the Act states, 'No property acquired or developed with assistance under this section shall, without the approval of the Secretary, user^'Tv.l^t '° ?'^^' '^^" P^^^i^ ^'^tdoor recreation if h; flnL ^^'!^^K^ ^^^^^ approve such conversion only If he finds It to be m accord with the then existinq comprehensive statewide outdoor recreation plan and only upon such conditions as he deems necessary to o^a^^^^^t.^"^^^'^^^'°" °^ ^^^^^^ recreation properties of at least equal fair market value and of reasonably equivalent usefulness and location'". IX-8 Response ; The construction of canals is not a feature of the design for SPR development. Dredging associated with the project will be confined to the deepening of existing waterways at oil ports, excavation needed to construct and maintain water intake structures, and the laying of pipelines under water. Where the burying of pipelines under wetlands would normally result in the formation of small canals, these will be blocked at appropriate intervals to prevent the alteration of natural drainage patterns and to enable the channels to become silted in. Comment e: "As pointed out [on page V-55,] the doubling of the proposed capacity for the Strategic Petroleum Reserve program will result in a doubling of the risk of a major oil spill sometime during the life of the project. We remain concerned about the possibility of spills in wetlands areas which are utilized for local recreational activities and urge that the latest available technologies be implemented in order to minimize this possibility". Response ; The potential seriousness of oil spills is recognized and stringent measures are being taken to obviate such risks. In addition to preparing Spill Prevention Control and Countermeasure Plans as required by the U.S. Environmental Protection Agency, and complying with the U.S. Department of Transportation regulations on standards for equipment, testing procedures, and operation activities, efforts are being directed toward further reducing the dangers of oil spills. Prospective oil shippers are being required to submit an environmental plan specifying the equipment they have on board for preventing oil spills and the extent of training of the crew in its use. Studies are being conducted to identify the best available technologies for reducing the danger of oil spill at each site. 3. Environmental Protection Agency Comment a ; "The Draft Supplement states that the proposed SPR expansion will require large quantities of surface water for construction and operation of the expanded facilities. If intake structures will be required, the Final Supplement should provide adequate information to IX-9 allow EPA to determine that the best technology to minimize environmental impacts will be implemented in the design of these structures". Response : Intake structures will be required. Their designs will take into consideration the water elevation sediment load, the characteristics of fish or fish larvae that may migrate through the waterway, and various other factors. it has not been assumed that any single type of intake structure would best minimize environmental impacts at all sites. The intake velocity however, is not to exceed 0.5 feet per second. This generic standard has been set to enable most fish to swim away from the intake. Bars, screens, and other components will be selected on a site-specific basis. Comment b ; EPA is developing the Underground Injection Control program which will regulate such operations as the pumping of oil into salt domes, solution mining to create cavities in these domes, and deep well injection Auan^J^t; ?S?f^ regulations for this program, published August 31, 1976, require certain data and analyses to be provided before such actions are permitted. The Department of Energy should now provide data and analyses consistent with the requirements of the proposed regulations and of the State agencies which will enforce the Underground Injection Control Program. Selected technical data should also be made available to the public by request. Response ; The purpose of the programmatic EIS is to identify the cumulative impacts of the program on the envi- ronments of various regions that would be suitable for oil storage. Site specific EISs are a more appropriate place for the detailed data and analyses that are being gathered prior to underground injection at individual sites. The data and analyses of each site vary according to the geology and geohydrology of the area, the depth of the surface of the salt dome, the location of wells, the capacity of the cavities, the characteristics of the water used for displacement of oil and for solution mining, and similar factors. The Department of Energy is providing to State agencies governing injection programs the data and analyses they request, and such data IS also available to the public. IX-10 Comment c: "The discussions of operational discharges of oil from tankers [on pages V-50 and A-1] , while correct, do not fully describe the status of control measures being developed. These discussions refer to pending U.S. Coast Guard regulations and the 1973 Marine Pollution Convention of IMCO (Intergovernmental Maritime Consulta- tive Organization) . The 1969 amendments to the 1954 International Conven- tion for the Prevention of Pollution of the Sea by Oil have been adopted, but the 1973 Convention has not... The Convention may not be adopted in time to affect the SPR, but if it is, it could affect the statistical analysis in Appendix A of the EIS " Response; The discussions on pages V-50 and A-1 have been expanded to include requirements of the pending 1973 Convention which have been incorporated into the U.S. Coast Guard pollution prevention regulations in Title 33, Part 157, Code of Federal Regulations (33 CFR 157) . The statistical analysis in Appendix A addresses the issue of accidental oil spill and remains unaffected by conventions and regulations pertaining to operational oil discharges. Comment d: "EPA strongly recommends that the method of brine disposal involving use of the displaced brine as a chemical feed stock be used wherever practicable. Discussion on this recommendation should be addressed in the Final Supplement". Response : Where brine production cavities are being converted to oil storage facilities, as much brine as will be accepted by the chemical plant is being provided to it via the existing brine feed stock pipelines. These plants use raw water that has been tested and treated so that it does not contain impurities that would con- taminate facilities or the substances for which the brine is used. The water used by SPR facilities for solution mining and oil displacement will not be treated prior to injection. The resulting brine is generally not acceptable as feed stock. Additionally, because IX-11 chemical companies use caverns created by brining for their own storage purposes, they are reluctant to accept SPR brine which would limit their own rate of cavern development. Furthermore, the rate of brine used locally as chemical feed stock is very small compared to the rate generated by the solution mining which will be done to create storage space or to displace the oil. if the problem of trace impurities in the brine were overcome, vast quantities of brine would have to be stored at the site in artificial reservoirs that would cover several hun- dred acres. The environmental risks of storing such a great volume of brine over several years makes this alter- native unacceptable. Comment e: The Draft Supplement indicates that pipelines serving the SPR salt domes sites will be coated externally with an asphalt-sand mixture or coal tar enamel for corrosion protection. The pipelines will also contain sacrificial zinc anodes to lessen internal corrosion. The Final Supplement should discuss whether these corrosion preven- tive measures could cause any adverse impacts to ground- water quality in the project areas". Response ; Pipelines are usually coated with a relatively inert asphaultic material which provides oxidation protection and insulation properties. in addition cathodic protection is achieved by having a small DC current on the pipeline or by having a sacrificial metal such as magnesium nesium alloy (e.g., 6% Al , 3% Zn, and 91% Mg) as the anode and the pipeline as the cathode. The technique of utilizing a small DC current to inhibit electrochemical reactions introduces no foreign materials into the environment. The sacrificial anode scheme utilizes the oxidation of the magnesium anode to provide the current flow to inhibit oxidation of the pipeline and consequently forms ionic materials over the lifetime of the anode. It is generally assumed that for a large pipeline of 30 inches in diameter or more, a 17 to 32 pound anode rod will be utilized with a coating of plaster, which IS composed of gypsum, bentenite clay, and sodium sul- fate to provide protection for a section of pipe several hundred feet long (e.g., 500 ft) for approximately 12 to IX-12 14 years. The plaster will also deteriorate as the anode is oxidized. One would expect to obtain sulfates, silicates, oxides, and carbonates of the aluminum, magnesium, zinc, and calcium materials from the anode and its coating. The proposed pipelines in the Gulf Coast Region will be buried primarily in prairie-type soils which are composed of pleistocene clays. Smaller segments of the pipeline may potentially be buried in marshy soils. These soils represent the upper layer of an impermeable clay aquitard from 100 to 400 feet thick. Where the water table is within one or two feet of the surface, the soil will be generally water-saturated. Thus, due to the presence of ground water some dissolution of the cathodic system will occur. The carbonates, which are formed from the ground water are relatively insoluble, and contribute to the hardness of water. The sulfates are relatively soluble in water. All of these materials are relatively common constituents of ground water. The insoluble materials will no doubt aggregate onto clay particles present in the soil and present no problem. Comment f: "The Draft Supplement needs to be strengthened in its address of the Spill Prevention Control and Counter- measure (SPCC) Plan required under 40 CFR 112 (Oil Pollution Prevention, Non-Transportation Related Onshore and Offshore Facilities) . The Final Supplement should acknowledge DOE's intention toward developing a SPCC Plan which meets the requirements of 40 CFR 112 within six months after a storage facility begins operations. DOE should provide that the SPCC plan shall be fully implemented no later than one year after facility operation begins". Response ; The text on page 11-13, which discusses SPCC Plans for the oil storage facilities, has been expanded to acknowledge DOE's intention of complying with the 40 CFR 112 regulations regarding the filing and implemen- tation of SPCC Plans. Comment g ; "The Draft Supplement does not address any discharges or treatment of domestic wastewater for the proposed SPR expansion. If such discharges will exist, the point of discharge, the type of treatment and possible IX-13 impacts to the receiving stream should be identified and addressed in the Final Supplement. In addition, DOE should indicate if application for a National Pollutant Discharge Elimination System (NPDES) permit has been made. Discussion on this matter should also be included in the Final Supplement". Response : The additional oil stored in expanding the SPR will not all be placed at a single site. The methods used for disposing of domestic wastewater will depend upon the environmental characteristics of the sites chosen. Several methods of sanitary waste disposal are being con- sidered, including (a) connection into existing munici- pal sewage treatment systems, (b) holding tanks which can be pumped out and wastes carried to local treatment centers, (c) septic tanks designed to comply with state and local health ordinances, and (d) incineration. NPDES permits will be obtained for the various kinds of wastewater discharges from these sites. These include discharges from settling ponds which collect rainwater runoff from the site, discharges from the oil-water separator, and similar releases. Comment h: The expansion of the SPR program from 500 million barrels of oil to 1 billion barrels will increase hydrocarbon emissions from the use of above ground tanks as well as from fill and withdrawal operations. This may cause localized violations of the Federal air quality standard for hydrocarbons in areas that are already experiencing violations of this standard. The compatibility of the program's storage with State Implementation Plans for attaining and maintaining air quality standards' will require specific site-detailed analysis. Response ; The impact of hydrocarbon emissions from SPR tanks and from fill and withdrawal operations on local air quality is being addressed in the site-specific EISs. Consultations are being held with State agencies regarding the design of emission control systems so that SPR facilities will be compatible with State programs for attaining and maintaining air quality standards . IX-14 Comment i: "In addressing ambient air quality standards, the Final Supplement should recognize that the Clean Air Act, amended on August 1 , 1977, has changed past Prevention of Significant Deterioration (PSD) Regu- lations. The changes significant to this project are: a) that PSD regulations no longer apply only to parti- culate and sulfur dioxide emissions, but to all cri- teria pollutants, (i.e.. Sulfur Dioxide (SOo) , Total Suspended Particulate (TSP) , Non-Methane Hyudrocarbon (NMHC) , Nitrous Oxides (No^) , Carbon Monoxide (CO) , and Photochemical Oxidants (O3) , and b) that PSD designated source categories have been expanded from 19 to 28 sources, one of which is petroleum storage and transfer facilities. The effect of these changes upon the project should be addressed in the Final Supplement" Response ; Appropriate modifications have been made to the text of the discussion of air quality on page V-4 to include the recently enacted changes in National Ambient Air Quality Standards. Comment j ; "In addressing Federal Clean Air Regulations, the Draft Supplement states that EPA's emission offset policy excludes new sources with "actual" emissions, totaling less than 100 tons per year. However, this amount will be based upon "potential" emissions and not "actual" emissions. Clarifications of this matter and its possible effect upon SPR projects should be included in the Final Supplement". Response ; The USEPA has set New Source Performance Standards (NSPS) limiting allowable emissions for certain indus- trial facilities. These include standards for petroleum refineries and storage vessels for petroleum liquids. The NSPS for storage vessels would normally impact the SPR project as it applies to vessels with a capacity greater than 40,000 gallons (950 barrels). This regulation does not apply to pressure vessels, sub- surface caverns, porous rock reservoirs, or underground tanks under some conditions. IX-15 In December 1976, USEPA adopted an "emission offset- policy under which construction permits for new indus- trial sources in non-attainment areas could be issued if any increase in air pollution from the new source was more than offset by additional emission reductions by existing sources beyond those levels required by the applicable state implementation plan. The newly enacted Clean Air Act Amendment of 1977 (42 U.S.C. 7401 et. seq.) accepts this offset process and extends the date by which states must attain the primary standards to July 1, 1979 in these currently non-attainment areas. During the initial implementation of the SPR, the EPA determined that the offset policy did not apply to SPR facilities due to the temporary and intermittent nature of its associated emissions. DOE is aware that the EPA policy regarding emission offsets, and its applicability to the SPR program, is currently undergoing review, and that a clari- fication will be issued in the near future. DOE will take any steps necessary as a result of this clarification. Comment k: "In discussing possible mitigative measures in elimi- nating hydrocarbon emission venting from the underground storage caverns, we suggest that condensation units in lieu of a flare system be used. The condensation unit would not only provide less potential for explosion of the volatile gases within storage but would also provide fuel conservation by allowing the condensed emissions to be returned to storage". Response ; Condensation units are being considered as a means of controling hydrocarbon emissions from underground storage . Comment 1: The statement [on page V-12] that hydrocarbon emissions which result from VLCC-tanker operation will not be as significant as those occurring at dock may be correct; however, the emission may add to already intolerable air quality conditions which exist in the Gulf Coast near the three terminal areas of Capline, Seaway, and Texoma. DOE should address this issue in particular light of the accelerated filling schedule proposed". IX-16 i Response : The VLCC tankers will be operating 50 to 100 miles offshore, and their hydrocarbon emissions will be dispersed over a wide area. In general, the hydro- carbon vapor concentration diminishes with increased distance from the source. For this reason, the impact on the air quality in the coastal region is not anti- cipated to be significant. Comment m: In Appendix B, page 5, the last line should read as follows: "Hydrocarbon vapor loss is generally increased as the molecular weight of the crude oil decreases (emphasis added)". Response ; It is not the modecular weight of liquid crude oil that is being referred to, but rather the molecular weight of crude oil vapor. Given the same vapor rate, hydrocarbon vapor loss is generally increased as the molecular weight of the crude oil vapor increases. The text of Appendix B, page 5 has been modified to clarify this issue. Comment n: Address more fully in the Final Supplement, proposed and alternative storage sites with respect to their potential for wetlands impact. For future SPR projects DOE IS urged to contact EPA for consultation and recommendations in the selection of any future SPR sites. DOE should announce its intentions in this respect within the Final Supplement. Response ; A section of text addressing the potential for wetlands impact has been inserted into this Supplement starting on page V-39. However, the issue of potential impact to wetlands can be fully addressed only in the study of a particular site. The appropriate site-specific EIS should be consulted for a discussion of this issue as it pertains to that site. EPA is one of several agencies that is routinely requested to review proposals for the use of various sites for oil storage facilities. IX-17 Comment o: "Inland salt domes for storage sites located in the Northern Louisiana Interior Basin and the East-Central Louisiana Mississippi Interior Basin are being considered With this information, EPA questions why these inland sites were not addressed as possible sites for the currently proposed SPR expansion in the alternative section of this Draft Supplement". Response : The second section in Chapter III is "B: Structural Alternatives" which includes a discussion of solution- mined cavities in salt, mines, tank farms and tankships. The feasibility of using inland salt domes as possible sites for the SPR expansion is addressed in this section Comment p ; "As possible alternate salt dome crude oil storage sites for future storage reserves and expansion, the Final Supplement should consider the possibility and practicability of using off-shore salt domes lying within the Gulf of Mexico. Feasibility and potential impacts should be discussed in the Final Supplement". Response ; The development of offshore salt domes is discussed in the programmatic Environmental Impact Statement in Chapter III under the section entitled "Development of Salt Dome Storage Facilities." Their use remains as an alternative to onshore sites. Studies of potential candidate offshore domes are currently underway. Comment q ; "In discussing land use of the proposed SPR expansion, the Draft Supplement states that approximately 2260 acres or 3.5 square miles of land distributed throughout the Gulf coastal states will be used. To assist in effectively evaluating overall environmental impacts, the statement would be strengthened if this total amount of land was identified and categorized into segmented amounts according to existing land use, and state location. This would assist EPA in evaluating the overall impact of the proposed expansion". IX-18 Response ; The estimate of total land that would be used was based upon expected average sizes of the various kinds of sites. Since the storage sites have not been chosen, it is not possible to know yet the specific locations of the sites or the amount of land currently in various categories of usage. Where candidate sites have been identified, the site-specific EIS quantifies the existing use of the land at the site and surrounding It, and also discusses projected future uses of adjacent lands. Comments Received from State Agencies 1. Arizona, Solar Energy Research Comment ; "Have Arizona's salt deposits been considered as possible sites for petroleum storage"? Response Yes, they have been considered. However, the lack of abundant water resources for solution mining to create storage space and the distance from oil ports and major oil refineries makes other salt formations more suitable as candidate storage sites. 2. Kentucky Bureau of Environmental Protection Comment a ; "The statement does not identify the specific site where these additional 500 MM barrels of crude petro- leum will be stored. We will certainly be interested to know if storage capacity at Central Rock Mine (Fayette County) will be increased from 14 MM barrels. Also, we would like to know if the terminal capacity at Tates Creek will be increased". Response ; The additional 500 MM barrels of oil will not all be stored at one site. The potential exists for storing part of this additional reserve in areas of the Midwest. Specific sites have not yet been selected so It IS not yet possible to state whether Central Rock Mine or the terminal at Tates Creek will be used for SPR expansion. IX-19 Comment b: "In spite of good objectives associated with the SPR, the amount of hydrocarbon emissions throughout SE U.S. A, will delay attainment of the photochemical oxidant standards" . Response The release of hydrocarbon emissions will be almost entirely due to unloading and loading tankers. These emissions will be intermittent and temporary. They are generally considered to be unavoidable, but DOE is undertaking special efforts to reduce such emissions. During the period of storage, there will be practically no release of hydrocarbons from the reserve. Surface tanks will be equipped with appropriate roofs and seals to prevent vapor losses, and will be coated with a heat-reflecting paint. Underground storage facilities will not be subject to the temperature fluctuations that cause vapor releases from surface tanks. Mines used for storage will be equipped with vapor control systems, and solution cavities in salt will be kept full of brine and oil in a way that prevents the formation of air spaces where vapors may accumulate. 3. North Dakota Geological Survey Comment ; "The massive salt beds of the Williston Basin should be considered as alternative sites for solution salt cavity storage of the SPR. This would help to insure crude availability to the northern tier refineries". Response ; In the initial stages of SPR development, all salt formations were considered. The lack of abundant water resources to use in leaching the solution cavities and displacing the oil was a primary drawback to the use of the Williston Basin. Use of the basin would also have required the construction of hundreds of miles of pipeline to carry the oil from ports or existing oil pipelines into the storage facility. 4. Texas Parks and Wildlife Department Comment a ; "Future preparation of "Environmental Action Reports" on specific sites is mentioned on page VI-38. Since it is IX-20 anticipated that these reports will contain detailed information, and proposed procedures for construction and operation of each site, review and comment upon the reports would be desirable". Response ; Site-specific environmental impact statements will be made available for review and comment before they are made final. The Environmental Action Reports are internal documents which are largely based on the site- specific EISs and which serve as technical specifications for the design and construction of the facilities. Comment b ; "In regard to alternative brine disposal techniques for use in the Texas coastal area, it is recommended that injection of the brine into subsurface aquifers be utilized to the maximum possible extent in order to minimize discharges to surface waters or the Gulf of Mexico" . Response ; The selection of any brine disposal method must take into consideration numerous factors, among which are: the volume and rate of brine produced, the receiving capacity of subsurface aquifers available to the site, the engineering feasibility of various alternatives, and environmental impacts. For this reason, the selection of brine disposal methods is being made on a site-specific basis. 5. Texas Department of Agriculture Comment ; "With regards to the selection of future SPR sites, we support the idea that a careful review should be made to avoid taking of unique or prime agricultural land. In general, however, we believe the benefits from the SPR will outweigh the costs; we therefore, offer no objections to the proposed expansion". Response ; In the site selection process, considerable attention is focused on existing and possible future use of the land. Whether the site on unique or prime agricultural land is one of the issues that is addressed. Where pipelines must be constructed across agricultural lands, steps will be taken to restore the topsoil. IX-21 6. Texas Department of Water Resources Comment a ; "One of the major water quality policies of the State has been to disallow any direct discharge of brine into the State's waters. This policy is particularly applicable to any proposed brine discharges within the State's three-league seaward boundary and especially to estuaries having fish and shellfish nursery areas. Therefore, we support the Federal Energy Administration's rigorous efforts to explore all viable methods of brine disposal including usage by local industry, deepwell injection, and disposal to the Gulf of Mexico. And, we concur that final site-specific brine disposal method determinations should be based on the geographical location of the site with respect to the Gulf of Mexico, the proximity of saline aquifers, estuarine productivity, and relative costs of alternative brine disposal methods". Response ; Various methods of brine disposal are being considered. Where it appears that brine diffusion in the Gulf of Mexico is the most acceptable alternative, great care is being given to selecting the dispersion area and the design of the diffuser to minimize adverse impacts on the marine ecology. Studies performed to date indicate that the zone of adverse impact can be limited to a few acres in the immediate vicinity of the diffuser. Comment b ; "The report duly notes that the large quantities of surface water (i.e., approximately 183 billion gallons of water from the area during construction of the cavities and up to 25 billion gallons during displacement operations) required for the construction and operation of storage caverns in salt domes is a significant concern. Further, the report notes that there are ...few undedicated fresh surface water supplies in the Gulf Coast region...' In view of the foregoing findings, we reiterate one of our early comments. .. that a special analysis of project impacts on vested surface water rights be prepared". IX-22 Response ; The impact of the project on vested surface water rights is an issue that is best addressed in site- specific EISs. Before commitments are made to use a specific site, the impact of its water use is analyzed and is one of the determining factors in site selection The scope of this analysis includes not just water rights but also existing and future needs for water resources for urban areas, industrial growth, and agriculture. Comments Received from the Public 1. National Wildlife Federation Comment a; The statement makes no attempt to assess the hazard potential associated with various spill locations, or to contrast the hazard potential of inland versus coastal sites. in terms of estimating the frequency of oil spills in various "impact areas," the statement is misleading because, for instance, it assumes that all oil spills in wetlands will be associated with pipelines This obscures the fact that transport in harbors and channels connecting the harbors with the sea and the storage site, also has potential for spilling oil in wetlands. Response ; The five categories of areas affected by oil spills (listed on page A-19 and A-20) , are grouped according to the type of data available on spills. The fifth cate- gory IS pipeline spills. The historical data, based on reports of pipeline spills, does not distinguish between pipelines in wetlands and pipelines on dry land. Similarly, the category of oil spills in harbors and inland waters was chosen because records of oil spills do indicate their being in harbors and inland waters, but do not indicate whether these harbors or inland waters were surrounded by wetlands or not, or whether the spill floated downstream to a wetland area. The statistical units in which the data are compiled are (a) spills per vessel per year, and (b) spills per mile of pipeline per year. Thus, there is a direct IX-23 relationship between the distance and time the oil must be transported and the expected number of spills. The use of inland storage sites would increase the distance and time for delivering oil to storage sites, and greater incidence of spills would be expected. While the use of inland domes would reduce the number of pipeline oil spills in wetlands, it would not appreciably reduce the number of oil spills from ships affecting wetlands. Except in the early stages of facility construction, oil is not being brought to coastal storage sites via waterways. Oil for both coastal and inland sites will have to be brought by ocean vessels into coastal harbors and ship channels, where there is a risk of oil spill contaminating adjacent wetlands. Oil destined for coastal wetlands IS then transferred from the harbor to the site via pipelines. Oil destined for inland must be trans- ferred either into much longer pipelines or into smaller ships or barges that can navigate the shallower inland waterways. Transport of oil to inland sites via the major rivers, would present a serious risk of oil spill to freshwater wetlands along their banks. Comment b: "The estimated incidence of a major spill for pipe- line accidents in inland areas of the Gulf Coast is incorrectly stated [on page V-54] to be 0.1 gallo ns per 1,000 MMB transported; the correct figure (from Table V-13) would be either 0.1 MMB per 1,000 MMB transported, or 0.1 gallons per 1,000 gallons transported." Response ; This discussion has been revised. In Table V-13, on page V-53 it is stated that the estimated frequency of a major spill (greater than 238 bbls.) from pipeline accidents in inland areas of the Gulf Coast is 0.70 spills during the transport of 1,000 MMB of oil. Commment c: While this supplement discusses numerous potential problems related to the use of inland salt domes, it fails to emphasize environmental advantages of using inland rather than coastal salt domes. IX-24 Response ; The function of the programmatic environmental impact statement is to identify environmental impacts, partic- ularly the adverse impacts which must be taken into consideration, prior to the selection of sites for the proposed facilities. However, DOE believes that either inland or coastal sites can be developed in an acceptable manner, provided that appropriate mitigative measures are employed to protect the environment. Comment d: This supplement "should take pains to contrast in some detail, the nature, number, and distribution of wetlands in association with inland versus coastal Gulf Coast salt domes." This would be aided by a map "which shows the location of each of the following, in addition to the other information found in Figure III-l: The Exxon pipe- line, Capline, the port of St. James, Vicksburg, Vidalia, Old River, Red River, Ouachita Black River, Gulf Intracoastal Waterway. Each of these items is mentioned on pp. III-4 to III-5, but is nowhere to be found on the accompanying map." Response ; This supplement focuses on the expansion of the oil reserve and discusses the various means of implement- ing this expansion. The value of using inland sites because there are fewer wetlands associated with them IS recognized. Figure V-1 has been added to the chap- ter on environmental impacts to show the locations of the salt domes in the Louisiana and Mississippi salt basins in relation to the wetlands of the area. In addition. Figure III-l has been improved to include Items noted in the text. Comment e; "The discussion of 'Mitigating Measures' (beginning at p. VI-1) would. . .greatly benefit from a discussion of reduced wetland losses associated with increased reliance on inland salt dome storage site. As the Draft states (p. VI-2) , ecological impacts can be mitigated by selecting sites... away from highly productive wetlands " IX-25 Response ; The referenced sentence has been clarified to indi- cate that, on a localized basis, the application of appropriate mitigative measures and design techniques can significantly reduce the potential for wetland impacts. Comment f: "We firmly believe that the potential for seriously damaging the vital coastal wetlands of Louisiana and Texas (as an unintended side-effect of the SPR Program) is sufficiently great as to justify slowing the program's pace to the extent necessary to permit maximum possible use of inland salt domes for as much as possible of the proposed storage reserve. Major resource commitments have already been made to several coastal salt dome sites. We strenuously urge (and we believe NEPA requires) that commitments to additional coastal sites be withheld until the evaluation of inland salt dome alternatives has been completed." Response ; SPR oil is being stored at West Hackberry, Bryan Mound, and Bayou Choctaw. Work is under way to con- vert Sulphur Mines and the Weeks Island salt mine to storage facilities. All of these sites have been used for industrial operations for many years. They are on dry ground and only the Bayou Choctaw site requires a modified building design because of the risk of seasonal floods. Portions of their oil and brine pipelines will cross wetlands, but efforts are being taken to avoid damaging these wetlands during pipeline construction. Studies are being undertaken to identify candidate inland salt domes which may be used for the oil storage program and to find solutions to some of the critical problems that are associated with the use of the inland domes. Although the stringent congressionally mandated schedules for implementation of the SPR dictate that the program must move forward, inland domes are being studied to determine what part they might play in the expanded program, given their locations and the technical problems discussed in the text. IX-26 'X. BIBLIOGRAPHY AD-029 Advisory Council on Historic Preservation, "Procedures for the Protection of Historic and Cultural Properties," Federal Register 39 (18), Part 2 (1974). Al-OOl American Petroleum Inst., Div. of Refining, Recommended Rules fo r Design and Construction of Large , Welded Low-Press ure Storage Tanks , API Standard fi?n ■ ' Washington, D.C. (1970). AM-087 American Petroleum Inst., Evaporation Loss Committee, Evapora tion Loss from Fixed Room Tan ks. Bull. 2518 Washington, D.C. (1962). ' ' AM-166 American Petroleum Inst., Basic Petroleum Data Book. Petroleum Industry Statistics , Washinatnn. n r (October 1975) . 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NA-261 National Petroleum Council, Committee on Emergency Preparedness, Petroleum Storage f or National Security (August 1975) ."" "-" ^ NA-273 National Climatic Center, Local Climatologic al Data, Asheville, N.C. (1973-75). NA-274 National Climatic Center, Wind Distribution by Pasquii: Stability Classes, Star Program for Selected U. S. Cities, Ashville, N.C. (1970-1975). X-13 NE-079 NA-080 NA-295 National Oceanic and Atmospheric Administration, Texas h^M^T^^^^: ^'''' ^^^^^"' Fisheries statistics^ff^ 6394, Washington, D.C. (Febuary 1974). Nelson-Smith, A., Coastal Pollution. ProcePdinn . of th !"■ f"""^ """ Environme ntal Research, Wales, C ?FdTTf-- ■'•^ '^ ' Bangor, Nature Conservancy (1972) . Nelson-Smith, A., Oil Pollution and Marine Rrnln ny, N.Y., Plenum (1973K ■ ^^ -^ NE-116 New York, State of. Division for Historic Preservation n'y (1974^°""''^^ ^""""^^ '^''""''^ ^ '^''' ^^•' ^^^^^^y' NI-031 Nichols, D R. and J. M. Buchanan-Banks, Seismic Hazards and Land-Use Planning . Circular 690 Washington, D.C, USGS (1974). OD-012 OP-018 Odum, H. T., B. J. Copeland, and E. A. McMahan, Ifs., Coastal E cological Systems of the Onif^^H St|^^^wasnington, D.C, Conservation Foundation Oppenheimer, C H. and K. Gordon, Biotypes- An a972K^^ ' ^"""^ Aransas, Texas Marine Science Inst. OP-019 Oppenheimer, Carl H., et al.. Establishment of Operational Guideli nes for Texas Coasta l Znnp Management, Biological U ses Criteria . fin;.l rop^.^ Port Aransas, Tx., Univ. of Texas Marine Science Inst, (no date, circa 1974) . OP-023 Oppenheimer, Carl, Computer Data Bank-Environmpn^.^ Life History Data Bank. Port Ar.nc:><. rp^^^^^ ^^^.^ ot Texas, Marine Science Institute (1975) . OR-021 Orton, Robert, Climatograohy of Texas . Austin, Texas National Weather Service. ^exas, OT-022 Ottaway, S "The Comparative Toxicities of Crude r^i ' ^? The Ecological Effects of Oil Pollut ion on Tno^°''^ . T""^^^^^ ^ ^'^' Co^ell^ ed., London, Inst. Petroleum (1971), pp. 172-80. ^'^-^^^ Pipe Line Ind. 1975 (January). X-14 PO-110 Pomeroy, L., "Algal Productivity in Georgia Salt Marshes," Limnol. Oceanogr. 4 , 386-397 (1959). RA-151 Radian Corporation, Advance Review of Various Engineering, Socioeconomic, and Environmental Factors Related to Development and Operation of a Strategic Storage System. 3 vnl.g.^ A^c-n.-r. t-YcII (February 1975) . RA-157 Radian Corporation, Fuel Usage Assessment for E PA Energy End Use Study , Interim rppori-^ Ano^-.^r^ Tcfnz (December 1974) . RA-218 Ray, C, private communication. Division of Marine Mammals, Smithsonian Institution, Washington, D.C. RA-223 Radian Corporation, Background Reference Ma terial and Worki ng Papers for the Strategic Petroleu m Reserve Environmental Impact Statem ent, Austin. Texas (1976). RE-172 Research Institute of the Gulf of Maine, A Socio- Econom ic and Environmental Inventory of the N orth Reaion, « vols.. 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X-15 SA-218 Sadow, Ronald D., "Pretreatment of Industrial Waste Waters for Subsurface Injection", in Underground Waste M anagement and Environmental Implication s. Procee dings of Symposium, Houston, Dec.. 1971 ." Tulsa, Ok., Amer. Assn. Petroleum Geologists (1972). SA-219 Saffir, Herbert S., Report of the Nature and E xtPnf of Structural Damage Caused by Hurric ane CamiTT^ — COM-73-10229, Coral Gables, Fla. (S eptember 1972 ). SC-305 Schoner, R.w. , Characteristic and Generaliz ed Isohyetal Patterns for Gulf and East Coast Hur ricanes. Washington, D.C., U.S. Weather Bureau (October 16, X -? ZJ / j • SEOOl Science Applications, Inc., and C. R. Gushing Co., Inc System Safety Analy sis Report, Deepwater Po rt Inspecti ^r^''?o4?'^ Procedures, draft report tor U.S. Coast Gi (May J. y 77 ) . SI-110 Simpson, R.H. and Miles B. Lawrence, Atlantic Hurrican e Frequencies Along the U.S. Coastli ne, Technical Memorandum NWS SR-58, Ft. Worth, Texas Southern Region Hdqts., National Weather Service' (June 1971) . SE-111 Simmons, J. A., A. J. Houghton, and W. E. Gonso, A Fails afe Transfer Line for Hazardous Fluids . Science Applications, Inc., McLean, Virginia (1976) . SK-034 Skanska-Sentab, Co., "Rock Caverns for Oil Storage" Brochure. ^ ' SM-1 Personal Communication, Charles Smith Consulting Geologist, LSU, August 22, 1977. SO-108 South Carolina Department of Archives and History, South C arolina Historic Preservation Plan, Vol. 3 , Annual Preservation Program for Fi scal Year iq7fi Columbia, S.C. (1975) . ~ " — ' SP-043 Spears, R.w. , "An Evaluation of the Effects of Oil, Oil Field Brine, and Oil Removing Compounds," in Proceedi ngs AIME Environmental Quality Confe rence Washingto n, D.C., June 1971 , Washington, n.r., Amer. Inst, of Mining, Metallurgical, and Petroleum Engineers. (1971), pp. 199-216. X-16 SPP-066 Spangler, Walter B. and Jahn J. Peterson, "Geology of Atlantic Coastal Plain in New Jersey, Delaware, Maryland, and Virginia," Bull. Amer . Assn. Petrol. Geol. 34 (1), 1 (1950). ST-210 Stebbings, R.E., Torrey Canyon Oil Pollution on Salt Marshes and at Shingle Beach in Brittany Sixteen Months After , Furzebrook Research Station, Nature Conservancy (1968) . ST-211 Stebbings, R.E., "Recovery of Salt Marsh in Brittany Sixteen Months After Heavy Pollution by Oil," Env. Pollut. 1, 163-167 (1970). ST-212 Straughan, D., ed. , Biological and Oceanographical Survey of the Santa Barbara Channel Oil Spill, 1969-1970 , Sea Grant Publ. No. 2., Los Angeles, Univ. Southern California (1971) . TE-231 Texas Water Development Board, The Texas Water Plan , Austin, Texas (1968). TE-267 Texas Parks and Wildlife Department, "Regulations for Taking Possession, Transportation, Exportation, Processing, Sale or Offer of Sale, or Shipment of Endangered Fish or Wildlife Threatened with Extinction in Texas," as amended April 1975. TH-067 Thomann, Robert V., Systems Analysis and Water Quality Managment , N.Y., Environmental Research & Applications, Inc. (1971) . TH-079 Thom, H.C.S., "New Distributions of Extreme Winds in the United States," Proc. ASCE, J. Structural Div. 1968 (ST 7), 1787. TH-105 Thom, H. C. S. and R. D. Marshall, "Wind and Surge Damage Due to Hurricane Camille," Proc. ASCE, J. Waterways Harbors Coastal Engineering Division 97 (WW2) , 355-363 (1971) . TO-028 Todd, David Keith, ed.. The Water Encyclopedia , Port Washington, N. Y., Water Information Center (1970) . TR-063 Tracer, Inc., Guidelines on Noise , Medical Research Rept. EA7301, Washington, D.C., API (1973). X-17 TR-075 Trewarsha, G. T., An Introduction to Climat-P. New York: McGraw-Hill (1957). ' TU-OOl Turner, D. Bruce. Workbook of Atmospheric Dis^n ^r.^nn Estimates, revised, AP-26, Air Resources Field Research Office, Environmental Science Services Admm. (1969) . US-118 us Army, Corps of Engineers, WaterborneCommerce, Washington, D.C. (1974 and 197Tn " ~ US-119 U.S. Geological Survey, Saline Ground Water in Louisiana, Hydrologic Investigations Atlas, HA JIO, 1968. US-120 U.S. Geological Survey, Water Data Report Louisiana, 1976 Report MS-76-1. US-121 U.S. Geological Survey, Water Data Report Louisiana, 1976 Report LA-76-1. US-122 U.S. Dept. of Commerce, Social and Economic Statistics Admin., Regional Economic Analysis °^^-' 1972 OBERS Projections. Economic Activii-v in the U.S. 1929^:2020, 7 Vols., Washington, D.cl, J.S. Water Resources Council (1972). US-148 \ US-124 U.S. Dept. of Commerce, Maritime Administration, Maritime Administrati on Tanker Construction ProQr;.ni. Final Environment al Impact Statement , EIS-AA-7l-n79R-.p Washington, D.C. ~ ' US-144 U.S. Bureau of Mines, Minerals Yearbook 1972. V ol i Metals, Minerals, and Fuels , Washington, D.C. (1974). US-145 U.S. Geographical Survey, Mississippi , G.P.O., Washington, D.C. (1976). ^ US-146 U.S. Geological Survey, Water Resources Data for Tex;. .c.. . ! ' .. ^'^ ^^^^ ^' Surface Water Records. PbFTT. — - Water Qua lity Records . Washi nai-nn ^ n r (IQ?^)'; I US-147 U.S. Geological Survey, Water Resources Data for Tex as. 1^/0, 2 Pts., Part 1, Surface Water Records . P^77~? Water Qu ality Records . Washi ngi-nn ^ n r (IQ71). Vq?; ^5°i°gical Survey, Water Resources Data for Tex as. , > ' , .^'^ ^^^^ ^' Surface Water Recor ds. P^FTT. — Water Qu ality Records . Washingi-nn^ n r (1070) X-18 i US-149 U.S. Geological Survey, Water Resources Data for Texas , 1972, 2 Pts., Part 1, Surface Water Records, Part 2, Water Quality Records , Washington, D.C. (1973) . US-150 U.S. Geological Survey, Water Resources Data for Texas , 1973, 2 Pts., Part 1, Surface Water Records, Part 2, Water Quality Records , Washington, D.C. (1974) . US-155 U.S. Geological Survey, The National Atlas of the United States of America , Washington, D.C. (1970). US-159 U.S. Coast Guard, Polluting Incidents In and Around U.S. Waters, Calendar Year 1972 , Washington, D.C. 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US-320 U.S. Army Corps of Engineers, Army Engineer Div. , Lower Mississippi Valley, Vicksburg, Miss., Waterborne Commerce of the United States, Calendar Year 1973, Pts. 1-5, New Orleans, U.S. Army Engineer District, New Orleans. US-325 U.S. Dept. of the Interior, Office of Endangered Species, Threatened, Rare, and Endangered Fish and Wildlife of the U.S. , Washington, D.C. (1970). ,X-19 US-326 U.S. Dept of the Interior, Office of Endangered Species, Threatened Wildlife of the n,.q, . Revised Washington, D.C. (1973). US-328 U.S. Bureau of Reclamation, Design of Small n.n,. , 2nd ed., Washington, D.C, GPO (1973) . ~ US-329 U.S. Interstate Oil Compact Commission, Subsurface ?ju^n96Bf.'"^"'^''^' ""^^'^" ^ Oklahoma City, Ok. US-343 US-344 US-370 US-394 US-395 US-396 US-397 US-398 US-540 A^L- ?^\°^ Commerce, Social and Economic Statistics Administration, County and City Data Book. 1972 Washington, D.C, GPO (1973) . U.S. Fish and Wildlife Services, Flyways. a^™- °^?^\?^ Commerce, Social and Economic Statistics Administration, "The Input/Output Structure of the 24-56 a974[: ^^^^'" ^^^^^^ Curren t Business 54 (2), ?Q?^ Geological Survey, Water Resources Dat a for Texas 1966, 2 Pts., Part 1. Sur face Water RerorH., p^' . o -- Water guaiity Records. W;..<.hi nr^^nn , n r (ing^^; '- 1967 ^rD^^^'^^n S^^Y^y' water Resources Data for tpv;.. , 1967, 2 Pts., Part 1. Surface Wat er Records . P;.ri- 9. " Water quality Records. W;.5.hinr^i-..n , n r (lo^e)': 196^ ^TllV'^'^l Survey, Water Resources Data for Tpv;.. . 1968, 2 Pts., Part 1. Surface Water Records . P;.ri- ?, — Water Quality Records. W;.shinqi-..n , n n (i969). U.S. Geological Survey, Surface Water Suo nlv of the U S ^^;Z^' ^^Lt_A. western c.ult ot Mexico bLL -^4^^;^-^ U.S. Geological Survey, Surface Water Supply of the U S |||lz|l: |Mt^. western c.ult ot Mexico lUin . y gg^ Til i^^lT, "" ^° ^^^ GrandJ— wJ^hTn^?7;Tr-nT^^ Nitnr^^r^c e^^i;:^^ Water Use in the Petroleum ;.n^ Natural Gas Industries . I.C 8284 (1966) . — " ~~ X-20 VA-117 Van Houten Associates, Inc., Investigation of Feasibility and Practicality of Using Above Ground Steel Tanks to Store a Strategic Reserve of Finished Petroleum Products , Washington, D.C., Federal Energy Administration. WA-243 Walton, William C, Groundwater Resource Evaluation , N.Y., McGraw-Hill (1970) . WE-101 Webster, B., 1977. Researchers Find that Sunlight Intensifies Toxic Effects of Oil Spills . New York Times, June 8, 1977. WE-102 Wermund, E. G., ed.. Approaches to Environmental Geology , Report Investigations No. 81, Austin, Texas, Bureau of Economic Geology, Univ. of Texas (1974) . WE-103 Westree, B., 1977. Biological Criteria for the Selection of Cleanup Techniques in Salt Marshes . In: Proceedings: 1977 Oil Spill Conference, March 8-10, 1977, New Orleans, American Petroleum Institute, Washington, D.C. (p. 231-235). WE-215 Weaver, Lewis, Private Communication , FEA Region VI, Dallas, Texas (15-16 January 1976). WO-044 Wood, Leonard A., R. K. Gabrysch and Richard Marvin, Reconnaissance Investigation of the Ground- Water Resources of the Gulf Coast Region , Texas, Bull. 6305, Texas Water Commission & USGS (1963). YO-039 Young, Addison and J. E. Galley, eds., A Symposium Fluids in Subsurface Environments , Transactions of the 6th Annual Meeting of the Southwestern Federation of Geological Societies , Midland, Texas, 1964, Tulsa, Ok., The American Association of Petroleum Geologists (1965) . X-21 I 4 APPENDIX A OIL SPILLS The transport of crude oil involves environmental risks as a result of accidents and spills. This section presents an analysis of these risks and the frequency and size of spills that may occur during transport of oil from a foreign port to the SPR storage sites. Oil Spill Analysis Background In this analysis only accidental discharges of crude oil were considered. These include spills from vessel casualties, such as collisions with other vessels, rammings of fixed objects and groundings, spills at marine terminals during the offloading and loading of tank vessels, spills during vessel-to-vessel transfers (lightering) and pipeline accidents. Not considered in this analysis were operational discharges of oil, such as those resulting from the disposal of oily bilge and ballast waters. It has been established that these constitute the bulk of all oil discharges associated with marine operations, as shown in Table A-1. However, recent and pending conventions and regulations will limit these discharges. Pending U.S. Coast Guard regulations and the 1973 IMCO (International Marine Consultative Organization) would prohibit operational discharges in coastal waters and limit discharges in the open sea (>50 miles from shore) to of the carqo 30,000 A-1 based on requirements contained in the IMCO* International Convention for the Prevention of Pollution from Ships, 1973, but also include constraints not included in the Convention on the location of segregated ballast spaces. Specific requirements of 33 CFR 157 concerning operational discharges from U.S. flag vessels are as follows; • A tank vessel may discharge oily mixtures from machinery space bilges if the vessel is more than 12 miles from the nearest land, proceeding enroute, has m operation an oil discharge monitoring and control system, and is discharging an effluent with an oil content of less than 100 parts per million. • Tank vessels operating on inland waters and sea- going tank vessels under 150 gross tons, must either retain on board oily mixtures or transfer them to a reception facility. • Seagoing tank vessels of 150 gross tons or more, may discharge oily mixtures from cargo tanks and cargo pumproom bilges into the sea, if the vessel IS more than 50 nautical miles from the nearest land and proceeding enroute, the instantaneous rate of discharge of oil does not exceed 60 litres per mile, and the total quantity of oil discharged does not exceed, for an existing vessel, 1/15,000 of the cargo carried, and for a new vessel, 1/30,000 of the total quantity of the cargo from which the discharge came. The vessel must have in operation, an oil discharge monitoring and control system. Similar regulations have been proposed for foreign flag tankers in U.S. waters. If these regulations are followed, operational discharges will tend to be widely dispersed over the open ocean. 7oLf?f°!?^"' "IMCO" stands for "Inter-Governmental Maritime Consultative Organization." A- 2 In contrast, accidental spills may occur anywhere, especially in coastal and inland waters, including harbors and harbor entrances. This is borne out by Table A-1, which shows the world-wide distribution of accidental oil spills from vessel casualties during the five-year period of 1969-1973. Moreover, accidental spills may result in a large outflow at a single location rather than being widely dispersed over a great distance as for operational discharges Hence, more significant adverse environmental effects are expected from accidental spills of oil, and this is the reason for the focus of this analysis. Oil Spill Statistical Data The oil spill analysis was based on three types of historical data on accidental oil spills collected from several sources: o The number of spill incidents during a certain time period; o The exposure to spills; o The size distribution for spills of the several types considered. The quotient of the first two factors above give the frequency of accidental spill and the data of the third was used to estimate the size of an average spill. Also, the accident frequency data were combined with spill size distributions to estimate the frequency of spills exceeding a given volume. The frequencies of the several types of accidental spills derived from these data are presented in Table A-2. The size distribution of these spills are presented in Figures A-1, A-2, and A-3 for tank vessel casualties; Figure A-4 for vessel loaded-offloading acci- dents; and in Figure A-5, pipeline accidents. A-3 Table A-1. Location of 452 Tankship Involvements with Oil Outflow, Tankships over 10,000 DWT INVOLVEMENT TYPE Breakdown Collision Explosion Fire Grounding Ramming Structural Failure Other PIER 5 5 10 1 18 8 1 HARBOR 1 41 4 2 27 15 9 Total Coastal and Harbor: 345 Total at Sea: 98 ENTRANCE 1 25 40 5 4 COASTAL 5 45 6 1 53 4 7 2 SEA 3 9 15 4 2 64 •1 Source: (CA-294) A- 4 Table A-2 . Frequency of Accidental Oil Spills. A) Vessel Casualty Frequency (Polluting Casualty Only) Transits in Sea and Coastal Waters 200,000 DWT Ballasted Voyage 1.24 x IQ-^/mile Loaded Voyage 6.24 x 10~S/mile 50,000 DWT Ballasted Voyage 3.65 x 10-8/mile Loaded Voyage 1.54 x 10~7/mile 25,000 DWT Ballasted Voyage 3.12 x lO-^/mile Loaded Voyage 2.30 x 10"'7/mile Transits in Mississippi/Ohio Rivers Barge Loaded Voyage* 3.816 x IQ-^/mile Transits in Harbors and Ports Tanker 4.4 x lO'^/trip into port Barge 5.4 x lO-5/trip into port Vessel Casualty Frequency During Lightering = .012/year. B) Accidents Loading-Offloading Operation Loading-Offloading = 13.5 x 10"3/operation Other Operation = 6.9 x 10~3/port call Total = 20.4 x lO'^/operation Lightering Operation Loading-Offloading = 13.5 x 10~3/operation Other Operation = 13.8 x 10"3/operation Total = 27.3 X 10-3/operation Pipelines Greater than 12 inches in diameter 5.3 X 10-2 per 100 miles per year A-5 H a • a — a — fc to 'H 5 S3 5^:5 IT"^ • JQ O C i3 O 0) i3 O D« t7>J3 CTja O « O O « o « O U9y O V4 O O l-l V£> ^ ^) « . > fN » > VO O < (N O «S ' «n < . fM -' .-1 U-l — CTv rs -^ 00 o o o o o I o CO El o in o m o O (siqq) aziS IlldS A- 6 O u ^ m 3 4-1 Q c 0) in o •o J 00 •H •J .— 1 u M 1 o cx o < w CO Eb o a; O w Eh •H o S a < Q w Eh • z O .H 03 U O •H (U U o O C7^ a ^ 10 w o u-l >i 0. CO 1 0- > u o >1 > in JJ ^3 M • •H 0) Eh -P TJ < C (0 J « D Eh 3 J S S O D Q D^ U u-i C o 0-H o M o C 3 « Q o •H in 1 -P W 3 a o jQ -H m •H X ■ U (0 ■p JkJ w c •H »0 ^ Q in o 1 o < o ^ (U o k-i m 3 1 O^ o •H iH b • « • M N N •^ •^ •r* 10 in m .-< .-• rH f-l .-1 .H -H •H -H E- a-- a^ a — X V) m H w to E-i w m O -I s -^ 2 ^ 9! X} Q Q) XI O 01 X} O CrXl O^X> tT>Xl O (0 O (0 o (0 O l-i u-1 O Ui in O U 03 » 0) -w o 0) ty> O (D <^ O > r- - > in » > n O < > O < ' in < •• rM — tn in >— ^ , « k o P a o > cu 00 1 Ti u o 0) > LO >i+J M • JJ w E-i •H fO < 4J .H hJ C .H 3 Eh fO "3 s: S D CQ D Q O u Cn O ^ C o 0-H o >-l ^ C 3 o Q in 1 •H 4-> W o 3 CL m X! -H ■ CO c El •H n3 S a Eh o o fSJ o 1 o < o d) 1 3 O tJi (siqq) aziS TlldS A- 7 n jQ — i3 -- i3 O nH O .H O iH O o rH in O -H O O -H (N ■* Djt- " ai>-i cH 03 - IT) CO »• CN CS rH C>J ^ Q) ^ (U tj> II O^ II Q) <0 -H (0 > -H CQ <: cn OQ < Ol o in o o en o CN O (siqq) azis nids A- 8 (0 •P c i O^ o w UH > o Du -o O >i •H EH D U < JH to J •H OQ D U S 4J e D (0 o CJ •H U Q MH 1 < (U u 3 Di i 10 l-t N M CO •J •-3 M CU CO \J , w w w- > / / r — 1 OOQ- / r— / / / J / 100- / / J / / 10- / f / / / f / / 1- a / / / 30 40 50 60 70 80 90 95 98 99 99.8 99.9 99.99 PERCENTAGE OF SPILLS OF SIZE LESS THAN ORDINATE VALUE Figure A-4 Distribution of Quantity of Oil Spilled in Accidents During Loading and Offloading Tankships and Tankbarges. A- 9 A-10 The sources of the data used are presented in Table A-3. This includes all but the spill frequency for barges in the Mississippi and Ohio Rivers, and the spill frequency associ- ated with a lightering operation. The fact that the spill frequencies and size distribu- tions were based on extensive historical data gives credence to their general reliability. This is because many of the methods and vessels that will be used to transport SPR oil are much the same as those used in the recent past. On the other hand, as will be discussed subsequently, the FEA may require more stringent procedures and methods which would insure a lower accidental spill rate relative to the histor- ical rate. It should be noted that the risk of oil spills in the Caribbean deepwater port was estimated using the same frequency values and distribution of size of spills for the U.S. Gulf Coast ports. Also, the estimation of the risk of oil spills during the actual ship-to-ship transfer of oil (in Scenario B) was made using the spill frequency and the distribution of the size of spills for loading and offloading at conventional docks. This application probably resulted in an overestima- tion of this risk. The probability of accident during lightering operations is believed to be less than that for loading and offloading operations at conventional docks. Industry representatives indicate that oil spills during lightering are rare. This operation is unregulated, and since the operation is performed 50 miles or more off the U.S. coast, there are no requirements for reporting oil spills. The mooring and un-mooring of the two ships at A-11 Table A-3. Sources of Data vessel Accidents and Spill Sizes U.S.C.G., 1 Exposure Casualties Data At Sea 2 Gulf Coast Harbors and Ports 3 4 Rivers 3 4 Loading-Offloading Operations Lightering Estimated Estimated Fixed, Inland Ber th PIRS, 5 Estimated, 4 Deepwater Port 6 6 Pipelines OPS, 7 Bu Mines, 8 1. Card, J.C., P.V. Ponce and W.D. Snider, "Tankship Accidents and Resulting Oil Outflows, 1969-1973", 1975 Conference on Prevention and Control of Oil Pollution, March, 1975, San Franciso, California. 2. J.J. Henry Co., Inc. "An Analysis of Oil Outflows Due to Tanker Accidents, 1971-1972", Report CG-D-81-74, U.S. Coast Guard, 1973. 3. Commercial Vessel Casualty Data, U.S. Coast Guard. 4. Waterborne Commerce, for the years 1974 and 1975, published annually by the U.S. Army Corps of Engineers. 5. Pollution Incident Reporting system, data file maintained by the U.SA. Coast Guard. 6. Science Applications, Inc. and C.R. Gushing, Co., Inc., "System Safety Analysis Report, Deepwater Port Inspection Methods and Procedures," Draft Report Prepared for U.S. Coast Guard, May 1977. 7. Data obtained from liquid pipeline accident reports on DOT Form 700-1, 1970-1975. Crude-Oil and Refined-Produced Pipeline Mileage in the United States, January 1, 1974, Mineral Industry Surveys, Bureau of Mines, Department of Interior. A-12 8 the beginning and at the end of the lightering operation provide opportunities for a collision between the vessels and a spill of oil. However, no such casualties have been reported in the Lloyds List or the U.S. Coast Guard Commercial Vessel Casualty Data, and consequently the risk of spills during those phases of the lightering operation must be low. Industry statements with respect to oil spills is corroborated by U.S. Coast Guard observations. At the invitation of the companies involved, the Coast Guard does overfly lightering operations in the Gulf of Mexico once or twice a day. Also, a Coast Guard observer may be placed oboard the ship to be lightered (usually a VLCC) . The impressions gained from these activities are that the current lightering operations are well planned and executed. No significant spills of oil have been observed. Finally, it may be noted that the uncertainties in the frequencies of spills from the various types of accidents may be as high as a factor of 2. These arise, in part, from the historical data themselves and in part from assumptions that must be made to apply the data. The uncertainties in the spill size distributions arise primarily in the projection of the fraction of large spills which are at the extreme end or outside the range of the data. This is especially true of pipeline spills. It is estimated that the fraction of spills projected in the upper 2 percentile in Figures A-1 through A-5 could be in error by as a factor of 2. However, this would cause a corresponding uncertainty of no more than 50 percent in the estimates of the average spill sizes. The uncertainty in the fraction of very large spills arises because of the A-13 relative infrequency of large-spill accidents and the relative shortness of the time span of the data base. Also, it may be noted that log normal distributions of spill size, which seem to fit the data, have been used in this analysis. In a recent statistical analysis, Devanney and Stewart prefer a gamma distribution for spill size. This distribution is similar to a log normal distribution, but the gamma distribution projects a smaller fraction of large spills, using the same data. Hence, the log normal distribution appears to be conservative in the sense of overestimating the fraction of large spills. Scenario Analysis The foregoing accidental spill statistics were applied to estimate the worst case environmental impacts to several geographical areas along the routes over which the SPR crude oil could be transported. Three transport scenarios were considered: A. Transoceanic shipment of the oil from the Middle East directly into U.S. ports via a mix of 25,000 DWT and 50,000 DWT tankships; B. Transoceanic shipment via VLCC ' s to U.S. coastal waters, lightering onto 50,000 DWT tankship and shipment into U.S. ports; C. Transoceanic shipment via VLCC's to a DWP* in the Caribbean, and transhipment to U.S. ports in 50,000 DWT tankships. These scenarios are summarized in Table A-4, which also lists the number of shipments, offloadings and loadings involved. Table A-5 lists the mileages of selected shipping routes and pipeline lengths for SPR oil transport. Also, loadings onto barges and shipment by barges in inland waters are included, corresponding to plans to commence an interim fill phase during which pipelines between the storage site and the marine terminal would not have been completed. * Deepwater Port A-14 I < ■J OQ < — * o> 4J c oo E-i » c c • ^ UH 10 Ul (N u ■o 3 CO —1 3 (0 (0 01 l-H 0> 01 ^ 01 0) 01 C 01 Q a<'D 3 u 0) c 3 13 .X a -x a> (0 CT> CO C m 3 01 13 (0 a O i3 C -D -w c c « c Qt 3 U -I O » JC £ u O .p^ 10 C u 10 -^ tn 01 -^ en •-« 3 CJ "D J 3 C — < •O Eh J= — H Ul Eh <0 H Eh -D CM CTi-O 3 ■-: u 3 •J O 00 H "0 <0 - a C7^ P» r- CJi'O •— < % 3 O 3 3 «H r> AJ H a, rn u ■o r- -., Ul r~ >4H •D u fO U-t ■1 ^ £ JN O (N ^^ UH « C S -U 3 » JC UH c » Ul (0 -U C 10 O >ui £ ^ > ~- ve O -H £h O 10 (N Eh ffl CN O "0 ffi J o o _ (0 01 4J c 00 u a g - c c — ^ lUI <0 U CN Ul "O U CO --H 3 CD (0 01 ^^ 0) 0) vO 01 01 01 c 01 o Oi'O 3 iM 0> c 3 ^ ■X a ■X a> 10 CT> (0 C 10 3 01 ^ <0 CJ O i3 C T5 -I c c « c U a 3 O -1 O » j<: 13 u O .■4 (0 C u (0 — in 01 -H O 01 — < 3 U "O J 3 C •-( TJ £h £ u H m H Eh "a CN 0>'D ij U 3 ij (0 in 10 111 c CT> X <0 (0 » C 10 3 OQ Eh > o :^ Eh (0 o U 10 <4-l £ «»■ J fN ^ t«-i • c 3 *J 3 ^ x: lUI c « u (0 «>ui C fO n Uij CO CO £ ro > ^ f^ O^ O Q <0 Q CM EH O 10 ^ H ffi rH O 10 ffi J b £ ^^ 0) 30 £ g oo r- CO o (0 l-H 0> U (N 0) vA 01 Ul o< 0} C CO o o Q r»- CT>3 u 0) ■X a Ji« CT> •0 C7< Ul » c 3 a> CO 01 c "a -H C C v0 c o Qi 3 Cj fN — » j«: r^ UH V 10 C u (0 •« in 0} -H -H CO 3 J •-^ 3 U 3 U k- 3 c r» kj •> o; in (0 > O > EH <0 Eh £h -D (0 4J 6h fN m 0) 00 01 OJ 00 0-^ 0( — • o 3 OQ U 3 a^ o Q. 0] r«- a CJ^ r>- ^ CTi*U »-H * 3 U 3 3 -"^ Cn -tJ El "O •«^ 01 r^ — u r»- MH "o Ul 10 u-i < -H £ ff\ J CM a> u — c 2 c Ul £ « Ul (0 « UH C ffl n lui CO £ sO > ^ vOEh>J OQ iOEhEh CM Eh ffi CM o CO c S 00 CO 3 CO V 01 vO 01 0) 01 C CO Q O CT13 lij 01 ■X a JX tJl O* 01 C "D — • C C VO c y a 3 U ^ ••* » ^ flo >w 0) 10 C u 10 -w m 01 -•* o o ■r^ 3 U O CJ 1- 3 C ro •J •> 01 in <0 « O > EH <0 Eh H -D fM (0 ^ c «0 0) -n o in 3 ffi H > (0 4J H ^ 0) 01 9\ 01 0) ■JN O M O CO O 3 0<£ O a 0) 00 Q, CT 00 ^ 0**0 l-H O ID in cj 3 >n -.^ O^ 4J Eh "O ^ I- — C S C 0) m •« Ul ro UH "D U fO *4H £ ^ J — <^EhJ OQ iDEhH 'H Eh ffl -H o <0 ffi J O "O "O 00 Ul (N Ul T3 c CO 04 n c (0 CO CO] 0) v0 CO 0> 01 X .S*!? '°.2'g aEH 10 an ■X a C C v0 <0 CTi c U Q « u Q Ul Q i> u Q 10 C Ul 10 "• in CO -w as CO H 01 H 3 u O (0 Eh 0} Eh CO O IM O U £h 10 Eh Eh -o "^ o o O ffi CM 3 a> *« 3 0) (N 3 0) « 3 a> 00 01 o> oo O l-H tn 3 ffi (N O ^ v« O J£ CN 3 ^ kO O ^ 00 Qi 0> 00 -^ 0^*0 ^H "^^ * (N - Q •> CuQ wi Q » ao 10 C Ul 10 -^ in 01 ■•« X (0 -3 H CO -^ 3 u ki 3 CO £h CO -h CO O U U 8 U £h (0 Eh Eh TJ CN O ffi ^ O 0) H 3 0) ^3 0> Eh 3 01 ^ 01 o» O ffi >-• O ^ 3 ^ •-13^ 3 ^ ^ a CT> ^ r-l ^ *© '■H in ■H » C ro » c ^ »| C ro » C On -w u 9S I4H 73 U (0 UH u Q £ « in ID ro O UH C (0 O "Ul ffi .J O £ —( , •0 c ■'H U 4J •O •'- X 10 IW U (0 JJ (0 C Gb (0 C 01 V o O 2 0> 10 C 10 rQ « CO £ ^ XI u c CD o 01 4-1 Ed CO Ul ia CO Ul 0) ■^ 01 •'^ U C *> j: o> <*■( -^ 4J 10 4J •O CT" <0 ^ O 01 U •H C7>>4H O Ul — I <0 <0 C -o c flj (0 E 1— t CO 3 0} <0 CO 3 O -w c ■ H CO l-l c a-o C O C iM CJ c • ^ 'O <0 E je 01 a (0 "H "O 10 Ul 10 r-l <0 CO "D UH 10 ^ Ul CJ kri .C -w Ul J= Ul 3 Ul Ul • C •H 4-> (D C Ul 01 4J O o 1—1 CN 00 in CN o 00 'a' m o in CM O in CM rH O in CN in 00 00 1—* in 00 00 1— t n i-i 00 o v£) CM 1—1 o 1— < o in CN 1— ( CN CN 00 00 in m CN on CM in CM f— t CM 1— t CN 00 w o •f-t 4J «4-( W r-« CD 3 O o u ^3 W C ui C 03 CO CO QJ to O CO) -H •r-* •!-( 1— 1 U 1— 1 i-< I— t (0 CD Ch< C Qj Oi 0) •r-( < O U a< ^ -p CO A-97 versus frequency are shown in Figures A-6 through A-10. These curves were obtained as follows: Number of Frequency Frequency of Fraction Spill Per of SpillL ...^^ ^, Trip or 100 x Exceeding x One Mile Miles or a Given Segments Operation size Operation °^ ^Pjl^l Spill Per of Spills Trips or Exceeding = Trip or 100 x Exceeding x One Mile ^^^''^^ Miles or a Given Segments or •size ODf^rafinn ci^^ /-v .^ _• Data for the first factor are given in Table A-2. Data for the second factor are shown in Figures A-1, A-2, A-3, A-4, and A-5. Finally, data for the third factor were obtained from Tables A-4 and A-5. Each of the Figures A-6 through A-10 show both the total frequency of spills exceeding a given size and the contribution to the total of the various transport operations which occur in the geographical area. For the open ocean, the worst case results from the transport of 1,000 MMB of oil via a mix pf 25,000 and 50,000 DWT tankers. The greater number of trips of smaller tankers required to transport the oil, accounts for the prediction of a greater amount of spilled oil. in coastal waters and the open sea, a major spill is defined as 2,380 bbls (100,000 gallons); the frequency of a major spill during transport of 1,000 MMB from Figure A-6, is 1.8. With respect to spills affecting the U.S. Gulf Coast, and the waters of the Gulf of Mexico and the Caribbean Sea, an arbitrary distinction was made. Spills from all operations occuring within 50 miles of the U.S. Gulf Coast were assumed to impact the Gulf Coast and not the open waters of the Gulf. All operations beyond 50 miles, including lightering operations, were assumed to impact only open waters, with A-23 10- ^^ M CO > H U 2: H Q U X CO H PU CO o u H D O H 0^ 10 10 -1 10 -2 10-3 -t- 50,000 50,000 25,000 25,000 10 -4 DWT Vessel Casualties (loaded voyages) DWT Vessel Casualties (ballasted voyages) DWT Vessel Casualties (loaded voyages) DWT Vessel Casualties (ballasted voyages) O Total for All Operations a^ ^--H -I i ^l}l^l^}^~ ^ -W IQ- 10' 10 10 10- 10 SPILL SIZE (bbl-) Figure A-6 Worst Case Frequency of Oil Spills in the Open Ocean During Transport of 1,000 MMB (Alternative 1, 3, 4, 5 and Scenario A). A-24 10' H CO O H Q » U X M CO H CO o u z D o 10" 10 10 -1 10 -2 10 -3 10 lo-- 10-^ 10- SPILL SIZE (bbls) 10 10 Figure A-7. Worst Case Frequency of Oil Spills in the Gulf ? nnn'^if ° ^""^ Caribbean Sea During Transport of 1,000 MMB (Scenario C, Alternatives 1, 3, 4) A-25 10- 10 H H (0 H M o H U X CO 1^ H^ H 0^ w b O u z H D O 10 -1 10 -2 10 -3 - 10 -4 < lo'- lO-' 10" SPILL SIZE (bbls) Figure A-8. Worst Case Frequency of Oil Spills Impacting the Gulf Coast During Transport of 1,000 MMB (Scenario A, Alternatives 4 and 5) . A-26 H CO o s M Q W w u X w w H w Cm O >H U D a 10- 10' 10- SPILL SIZE (bbls) Figure A-9. Worst Case Frequency of Oil Spills at Inland Harbors, Waterways and Docks (Scenario A, Alternatives 1 and 3) . A-27 CS3 M W 2 > H H Q W u X K W M CO O X U 2 D O 10' 10" SPILL SIZE (bbls: 10- Figure A-10. Frequency of Oil Spills From Pipeline Accidents Near the Gulf Coast During Transport of 1,000 MMB. A-28 d this distinction, the worst case impact to Gulf and Caribbean waters results from Scenario C for the transport of 1,000 MMB of oil (alternatives 1, 3, 4). The worst case risk of oil spills for the Gulf Coast results from Scenario A for the transport of 1,000 MMB of oil (alternatives 4 and 5). The corresponding spill frequency curves are shown in Figures A-7 and A-8, respectively. The frequency of major spills (>2,380 bbls) in the Gulf and Caribbean during transport of 1,000 MMB is 0.38, and the major contributor to this is a vessel casualty. For the Gulf Coast, the frequency of a major spill is 0.018, and the contributors are vessel casualties and accidents during offloading at the offshore storage site. The worst case risk of oil spills to Gulf Coast inland waters is expected from Scenario A, alternatives 1 and 3. The frequency of spills in these waters is shown in Figure A-9. For inland waters, a major spill is that which exceeds 238 barrels (10,000 gal.). According to the figure the frequency of a major spill during transport of 1,000 MMB is 1.0, for which spills during loading and offloading tankvessels are expected to be the major contributor. Accidental spills from pipelines impacts Gulf Coast land areas and the frequency of these spills is shown in Figure A-10 The frequency of a major spill (>238 bbls) during transport of 1,000 MMB is 0.70. The oil spill risk for the three secondary areas is presented in Table A-7, which lists the predicted average total oil spilled in each area for certain storage and transportation alternatives. The import of 20 MMB of oil through East Coast ports is predicted to pose a negligible risk of accidental spills to the East Coast. A more significant risk is posed by utilizing rock caverns at great A-29 CO H Z DQ Q l-l U CJ < z o CO l-H w E-i > < HH &H H « < o z o^ Qi CO Cl] z H 2 < H u Z ^ o s r* Ct, O < •J CO u M z •J (^ M CQ CO < < H Eh ij a M DQ O u U ac < Eh £-• M O s H Q U W CJ H < < a M Ci] CJ > o < CO CO a < u H u M Q U o: a« 4J 4J Ul M O o Q. 04 CO -^ to ^ C CO C CO fO J <0 J IH CQ Ui CQ Eh CQ Eh CQ 0) Z O £ 4-l (0 a. cc; CN ^-^ O 'ij' *-' CQ ^^ -o 0) l-H l-H •1^ a CO Ou i-H a "H •H o CO JJ 4J (0 Vj — « V-l ^-N f-H fc.-H O CO CO <0 CO CO Oil.:! a,>^ 4J Wl (0 CO CQ CO CQ o OJ -H 1 C CQ C CQ Eh > s 1 fO «0 -iH ^ s u S (U OS 73 EH S H s cn c <-\ ^ oj o ro 0) k-i c CN O^O V£> CT>0 1— 1 -rl * OJ in (Tj < C JC O CQ iw •. CQ <4-l M O rH — O «* ^— t: (U j-> u •r-t -o 0) East Coast Area 4 Scenario A 4 Scenario B 4 Scenario C 1 1 I 1 _ Q) Q) . — . > > in 4-> 4J Q> to «0 0) > C CO c 4J •H CO C > JJ CO -H Ul — » (JJ Ul i-H tt— > iJ u •1^ to J 4J Q) >,oQ a; m Q4 (0 CQ 0) 4J fO CQ (0 > a: CQ 4J CO •r^ C CQ 4J c CJ i~> CJ D z: < TJ to -ri S < ra k^ T. 0) ^ s c CO -H CO s: u 0) 4-1 Z J-» JkC c >, ro Q) CO •-* >, O 4-> CO -H U -• > «0 a; i c > c a (0 to -H CO Q) Q4 a a Dj •H •H •H U »+-l i-i a JJ JJ M-l OJ to OJ CJ1 q; a> Ui I-H Ui CO CO •H <0 Q) J2 e XI <-{ •H r^ vo r^ E vo vo CN 1^ in ^ ». «. rH ^ I-H V£) (N c c C C TD 73 TJ TJ 1000 miles) from Gulf Coast ports. The risk of spills from tank-barge casualties is especially large, mainly because of the long distance and, consequently, the greater exposure to accidents. The oil spill risks associated with utillizing salt domes in northern Louisiana and Mississippi are less because these domes are closer to Gulf Coast ports (<350 miles). Although the risk of oil spills in the Ohio and Mississippi Rivers or overland (pipeline route) is significant, the risk would have to be taken eventually even if all of the SPR oil were to be stored in Gulf Coast salt domes. During a withdrawal phase, more than 100 MMB of SPR oil or products refined from it would have to be transported to the northern midwestern states. In this eventuality, transport by pipelines obviously entails a lower risk of accidental spills. Risk of Oil Spills - Withdrawal and Refill The risk of oil spills in the several geographical areas for withdrawal and distribution of SPR oil, and for refill of the storage sites was not analyzed in detail. However, because of the similarity between the initial fill and refill operations, the worst case risk of spills during refills should be approximately the same. Oil Spill Cause and Event Tree Event and/or fault trees are most useful methods for logically analyzing failures and accidents, both in qualitative and quantitative terms. Such diagrams provide a visual display of the logic and interrelationships of causes, conditional events, and contributing factors. Such visual displays enable identification of critical causative A-31 and contributory factors where the more efficacious preventive and mitigative measures can be applied. Figure A-11 presents a cause and event tree for oil spills into the sea and/or restricted waters. This particular logic diagram has been tailored to be most useful for this case, and is not in the strictest sense either an event tree or a fault tree. The logic diagram proceeds from left to right in a time ordered sequence. Possible causative factors occurring in the design, construction/fabrication/installation, as well as during the operation of oil transport are identified in columns. Contributory conditions are also shown. The level of detail indicated hereon is not intended to be comprehensive, but to provide an indication of the type of analysis needed in the Development of Environmental Evaluation Criteria and Guidelines for assessment of the Environmental Plans (FEA No. 70174) . Such cause and event trees can be developed in sufficient detail, in conjunction with functional staging diagrams as required, to identify the principal causative factors, and to assess the potential of individual preventive and mitigative measures for reducing the risk of oil spillage. The two principal branches of this cause and event tree of Figure A-11 are those spills resulting from a vessel casualty involving the rupture of tanks and hull, as distinct from those resulting from an accidental discharge through an overflow or piping. For vessel casualties, there are two sub-branches. These are: (1) collision, ramming, grounding and structural failure accidents, and (2) fires and explosions. For accidental discharges, there are three branches. These are: (1) accidental pumping overboard, (2) accidental overflow incidents, and (3) equipment failures. It should be noted that the cause and event tree is constructed so that in tracing an accident event sequence from left to right, one or more causative events/factors may be involved, but each sequence does not necessarily contain an event from all or many of the columns. A-32 1 St t: t. ^l 7f ±: n Z m Uz ti te W « V^ rr jr- w . (U (0 (0 c Q> TS •H O O < O M-l (U Qi U Eh •U C > u T3 C (0 0) (0 D (0 u 3 A-33 Human error is most frequently the cause for accidental oil spills, during the marine transport and transfer operations Estimates of the fraction of spills resulting from human error range from 65% up to 90%. Using Figure A-11, tracing spill causes backward from right to left, one can easily see that even material/equipment failures can most frequently be traced back to a human error, although the error may have been during the design or construction of the vessel or equipment. Figure A-12 provides a similar cause and event tree for the eventual consequences of a spill, which may range from a prompt and effective cleanup operation preventing contamination of shoreline, to a surprise contamination of shoreline without notification or detection. This diagram enables identifcation of mitigative measures subsequent to the spill event. Measures for Preventing, Mitigating and Reducing Oil Spillage The desired objective is to prevent, mitigate and reduce oil spillage and consequences of spills within the constraints of available equipment, techniques and procedures, and costs. Historical data are available concerning oil spills resulting from the many causative events shown in the cause and event tree of Figure A-12. Quantitative analysis of such data has been presented and discussed earlier in this Appendix. Such analyses provide useful appraisals of the principal "failure modes" for accidental spills, since techniques for spill reduction should be designed to apply in order of priority to these. The analysis indicated that the frequencies of major oil spills are significant for marine transport at sea in coastal zones and restricted waterways, as well as for A-34 i e 1 X it • 1 si u. ^ 11 si ^ UJ -^ O s (-) 1 i: K w o £ — K K 6 & S o Ul u ■■««»* fcrt ^■ ^O l/l w tA ^ eo 8" W _l u m u • s i 10 ^ rH s s < c oc ^ tH S % 1^ ■H a CO «/» $5 iH ^ *md •H U O o 1 1 tw 1 O m *# i h CO 0) 1 So 5 " oc « o c 1 0) 3 m %E cr s 5- si a; CO «rf Urf u (^ c • (^ o 1 o» 1 U e •< u s. O «* £ h M4 » 0) Ss */* K v^ ac 1 J u 1 K •D C O 10 s 0) CO 3 51 (0 UJ «l ^ — « e 3 1 * ^ I 1 •-! ^^ ^^ 1 *$ S^ < wn ^ 1^ « w Uri ^ ^ »~ 0) ac_j oc z tf « « s <^ M 1 (/I UJ 3 «s .-J -J ^ oc Z X « « 4/> W 4/> ►- X > o o ^ ^ ^ w ^ hfc ^ oo So o A-35 transfer operations, including lightering and transfers to an onshore marine facility. The cause and event tree shown in Figures A-11 and A-12 has been drawn to show the causative factors for these spill risk cases. Considering first marine transportation by vessel, it is straightforward to identify the importance of design and construction requirements for hull, cargo and ballast tanks, propulsion and steering systems, for example. The U.S. has long been recognized for being the leader in implementing stringent standards for the design and construction of hull and tanks. Conformance to such stringent standards is one technique for reducing spill risk and mitigating consequences. Another important item easily identifiable is the training and licensing of both officers and crews of vessels. In this regard, both the U.S. and British are recognized leaders for establishing high standards for vessels registered by their flag. Lloyd's statistics concerning percentage of vessel tonnage lost, by flag of registry, demonstrate this leadership. Such statistics enable quantitative determination of the spill reduction to be expected by choosing vessels manned by licensed crews of a particular flag. The quality of licensing procedures, and required experience, have a pronounced effect on the error rates of vessels in maneuvering and navigational situations, as well as the effectiveness in the implementation of procedures such as "Load-On-Top" for tank cleaning, which considerably reduce pollution. The availability of operating navigational aids, radars, and collision avoidance systems aboard vessels can provide prompt and complete information for navigation and maneuvering. Such information can favorably affect the error rate for such decisions by both masters and pilots. A-36 A Spillage of oil from barge tows is also a significant concern. Such spillage arises from overflows during transfer operations, from chronic leakage caused by corrosion of the hull and from vessel casualties. These latter occur principally in areas of high barge tow traffic density (since the risk is proportional to the square of the traffic density) , and tortuous bends in channels, especially where there are also fast currents to contend with. Barging over long distances in the Mississippi River, for example, presents the potential for high risk of oil spillage. Such transits should be avoided, if at all possible. The most frequent type of oil spillage during transfer operations is overflow of cargo tanks, which is caused by human errors, such as failing to shut down pump or valves, inadequate sounding procedures, pumping too rapidly while topping off, etc. Oil monitors and alarm systems can be installed to prevent or reduce this type of spillage. Spillage also may occur during transfer operations because of hose ruptures, leaky flanges or gasket failures. Fail- safe probes, such as those used in U.S. Navy tankers, and fail-safe transfer hoses, such as the one developed by SAI,1 can be employed to effectively prevent or reduce this type of spill. Since human error is the largest cause of oil spills, the training of personnel in state-of-the-art procedures for reduction of oil spill risks, as well as for fire prevention, during the handling of petroleum and other hazardous materials, is an essential ingredient for a balanceed effort to reduce oil spillage. Such training should be carried out, not only for tankerman (U.S. Coast Guard Publication CG-174, A Manual 1. J. A. Simmons, A. J. Houghton, W. E. Gonso, "A Fail- safe Transfer Line for Hazardous Fluids," Science Applications, Inc. (1976). A-37 for the Safe Handling of Inflammable and Combustible Liquids and Other Hazardous Products, is an excellent training manual for this purpose), but for personnel at the marine terminals and at storage sites. In view of the high potential for spill risk reduction, such training programs should be given high priority at all locations. The risk of subsequent fire and/or explosion because of oil spillage cannot be overlooked. Careful analysis of the equipment required to contain such possible fires, and the training of personnel for such contingencies should also be carried out. The matter of mitigation once a spill occurs also must be addressed. Equipment is required for cleanup. Trained personnel are required in order that the containment and cleanup operations be successful and timely. Well thought out contingency planning is necessary to provide the procedures and organization to ensure efficiency of the operation. A-38 J APPENDIX B CONSIDERATION OF TANKER LOADING AND UNLOADING EMISSION FACTORS AND THROUGHPUTS In the entire SPR operation, tanker loading and unloading are the two major sources of hydrocarbon emissions. Loading emissions are attributable to the displacement of the atmosphere of hydrocarbon vapors residing in empty vessel tanks by volatile hydrocarbon liquids being loaded into the vessel tanks. Loading emissions can be separated into (1) the arrival component and (2) the generated component. The arrival component of loading emissions consists of hydrocarbon vapors left in the empty vessel tanks from previous cargos. The generated component of loading emissions consists of hydrocarbon vapors evaporated in the vessel tanks as hydro- carbon liquids are being loaded. The arrival component of loading emissions is directly dependent on the true vapor pressure of the previous cargo, the unloading rate of the previous cargo, and the cruise history of the cargo tank on the return voyage. The cruise history of a cargo tank may include heel washing, ballasting, butterworthing, vapor freeing, or no action at all. The generated component of loading emissions is produced by the evaporation of hydrocarbon liquid being loaded into the vessel tank. The quantity of hydrocarbons evaporated is dependent on both the true vapor pressure of the hydrocarbons and the loading rate. Unloading emissions are hydrocarbon emissions displaced during ballasting operations at the dock subsequent to B-1 unloading a volatile hydrocarbon liquid such as gasoline or crude oil. During the unloading of a volatile hydrocarbon liquid, air drawn into the emptying tank absorbs hydrocarbons evaporating from the liquid surface. The greater part of the hydrocarbon vapors normally lies along the liquid surface in a vapor blanket. However, throughout the unloading operation, hydrocarbon liquid clinging to the vessel walls will continue to evaporate and to contribute to the hydrocarbor concentration in the upper levels of the emptying vessel tank. Before sailing, an empty ship must take on ballast water to maintain trim and stability. Normally, on vessels that are not fitted with segregated ballast tanks, this water is pumped into the empty vessel tanks. As ballast water enters tanks, it displaces the residual hydrocarbon vapors to the atmosphere generating the so termed "unloading emissions". The tanker loading and unloading emission factors (grams of hydrocarbon vapor per unit throughput) are generally affected by a number of factors, including loading and unloading practice, true vapor pressure, cruise history, previous cargo and chemical and physical properties. These are briefly discussed below. !• Loading and Unloading Practice During the loading operation, the initial loading and unloading rate has a significant effect on hydrocarbon emissions due to the splashing and turbulence caused by higher initial loading or withdrawing rates. This splashing and turbulence results in rapid hydrocarbon evaporation and the formation of a vapor blanket. By reducing the initial B-2 M velocity of entering or withdrawing rates, it is possible to reduce the turbulence and consequently, to reduce the size and concentration of the vapor blanket. Slow final loading rate can also lower the quantity of emissions. This is because when the hydrocarbon level in a marine vessel tank approaches the tank roof, the action of vapors flowing towards the ullage cap vent begins to disrupt the quiescent vapor blanket. Disruption of the vapor blanket results in noticeably higher hydrocarbon concentrations in the vented vapor. 2. True Vapor Pressure The true vapor pressure (TVP) of a hydrocarbon liquid has a marked impact on the hydrocarbon content of its loading and unloading emissions. TVP is an indicator of a liquid's volatility and is a function of the liquid's Reid Vapor Pressure (RVP) and temperature. Compounds with high TVP exhibit high evaporation rates and consequently, contain high hydrocarbon concentrations in their loading and ballasting vapors. The true vapor pressure of crude oil generally increases as the temperature of crude oil increases. 3. Cruise History The cruise history of a ship includes all of the activities which a cargo tank experiences during the voyage prior to a loading or unloading operation. Examples of significant cruise history activities are ballasting, heel washing, butterworthing, and gas freeing. Cruise history impacts marine transfer emissions by directly affecting the arrival vapor component. Barges normally do not have significant cruise histories because they rarely B-3 take on ballast and do not usually have the manpower to clean cargo tanks. Ballasting is the act of partially filling empty cargo tanks with water to maintain a ship's stability and trim. Recent testing results indicate that prior to ballastin. empty cargo tanks normally contain an almost homogeneous concentration of residual hydrocarbon vapors. When ballast water is taken into the empty tank, hydrocarbon vapors are vented, but the remaining vapors not displaced retain their original hydrocarbon concentration. Upon arrival at a loading dock, a ship discharges its ballast water and draws fresh air into the tank. The fresh air dilutes the arrival vapor concentration by an amount proportional to the volume of ballast used. Although ballasting practices vary from vessel to vessel, the average vessel is ballasted approximately 40%. The heel of a tank is the residual puddle of hydrocarbon liquids remaining in a tank after emptying. These residual liquids will eventually evaporate and contribute to the arrival component of subsequent vessel-filling vapors. By washing out this heel with water, AMOCO Oil Company found that they were able to reduce the hydrocarbon emissions from subsequent filling operations from 5.7 volume percent to 2.7 volume percent hydrocarbons. Butterworthing is the washing down of tank walls in addition to washing out tank heels. Butterworthing also reduces loading emissions by reducing the arrival component concentration. The hydrocarbon liquids washed from the tanks are stored in a slops tank for disposal onshore. B-4 In addition to heel washing and butterworthing , marine vessels can purge the hydrocarbon vapors from empty and ballasted tanks during the voyage by several gas freeing techniques which include air blowing and removal of ullage dome covers. A combination of tank washing and gas freeing will effectively remove the arrival component of loading emissions. 4 . Previous Cargo The previous cargo conveyed by a tanker also has a direct impact on the arrival component of loading emissions. Cargo ships which carried nonvolatile liquids on the previous voyage normally return with low arrival vapor concentration. EXXON Oil Company tests conducted in Baytown, Texas indicated that the arrival component of empty uncleaned cargo tanks which had previously conveyed fuel oil ranged from volume percent to 1 volume percent hydrocarbons. Cargo tanks with the same cruise history which had previously conveyed gasoline, exhibited hydrocarbon concentrations in the arrival vapors which ranged from 4 percent (by volume basis) to 30 percent and averaged 7 percent. 5. Chemical and Physical Properties The chemical compositions and molecular weight of crude oil vapors will vary over a wide range. The typical vapor consists predominantly of C4 and C5 compounds. The molecular weight ranges from 45 to 100 pound per pound mole with an average of approximately 70. Hydro- carbon vapor loss is a function of both molecular weight of crude oil vapor and vaporization rate of crude oil. Given the same vapor rate, hydrocarbon vapor loss is generally increased as the molecular weight of crude oil vapor increases. B-5 At the same throughputs, the above-mentioned factors could affect tanker loading and unloading emission factors to a certain extent. it was estimated that the loading emission factors could range from 0.55 to 0.58 lb per 1000 gallons of throughput, and the unloading factors from 0.17 to 0.66 lb per 1000 gallons of throughput. Under normal operational conditions, the throughputs will be the most important factor influencing the total emissions from loading and unloading operations. The total emissions of the expanded SPR will be increased. It should be pointed out that reduction in throughputs is the most effective way to control short-term tanker loading and unloading emissions, particularly during air stagnation periods. I B-6 APPENDIX C LETTERS OF COMMENT I I ***ntff* . w.». y .ui ^uiciiue ana lecnnoiogy Washington. D.C. 20230 (P02) 377-3111 November 17, 1977 Executive Communications Room 3309 Federal Energy Administration Washington, D.C. 20461 Gentlemen: This is in reference to your draft supplement to the final environmental impact statement concerning the Strategic Petroleum Reserve (FEA/S-77/329) . The enclosed comments from the Maritime Administration are forv;arded for your consideration. Thank you for giving us an opportunity to provide these .comments, which we hope will be of assistance to you. We would appreciate receiving ten (10) copies of the final statement. Sincerely, (JlQj^ .dney R. Galler Deputy Assistant Secretary for Environmental Affairs Enclosure- -Memo from: Maritime Administration C-1 \ •W.o''^ fVlaritime Administration Washington, DC. 20230 October 13, 1977 MEMORANDUM FOR: Subject: Dr. Sidney R. Galler Deputy Assistant Secretary for Environmental Affairs Department of Commerce Federal Energy Administration - Draft Supplement to the Final Environmental Impact Statement concerning the Strategic Petroleum Reserve (FEA/S-77/329) The subject document dated September 1977 has been reviewed for comments. This supplement addresses the proposed expansion of the Strategic Petroleum Reserve from 500 million barrels to one billion barrels and assesses the environmental impacts of this proposed expansion. Comments are as follows: !• Operational Discharges of Oil, page V-AA (a) It is suggested that the second complete paragraph be rewritten as follows: "Operational discharges of oil, such as those resulting from the disposal of oily bilge waters, tank washings, and ballast waters, were not considered in the analysis of oil spill risks. It has been established that these constitute the bulk of oil discharges associated with tank vessel operations. However, recent national regulations and pending international conventions will limit these discharges. U.S. Coast Guard pollution prevention regulations in Title 33, Part 157, Code of Federal Regulations (33 CFR 157) are intended to control the discharge of oily mixtures from tanker operations and to incorporate construction requirements for new vessels which will reduce spill size in future casualties and improve the survivability of tankers after damage. These regulations are based on requirements contained in the IMCO International Convention for the Prevention of Pollution from Ships, 1973, but also include constraints C-2 not included in the Convention on the location of segregated ballast spaces." "Specific requirements of 33 CFR 157 concerning operational discharges are as follows: o A tank vessel may discharge oily mixtures from machinery space bilges if the vessel is more than 12 miles from the nearest land, proceeding enroute, has in operation an oil discharge monitoring and control system, and is discharging an effluent with an oil content of less than 100 parts per million. o Tank vessels operating on inland waters and seagoing tank vessels under 150 gross tons must either retain on board oily mixtures or transfer them to a reception facility. o Seagoing tank vessels of 150 gross tons or more may discharge oily mixtures from cargo tanks and cargo pumproom bilges into the sea if the vessel is more than 50 nautical miles from the nearest land and proceeding enroute, the instantaneous rate of discharge of oil does not exceed 60 litres per mile, and the total quantity of oil discharged does not exceed, for an existing vessel, 1/15,000 of the cargo carried, and for a new vessel, 1/30,000 of the total quantity of the cargo from which the discharge came. The vessel must have in operation an oil discharge monitoring and control system. Operational discharges, therefore, tend to be widely dispersed over the open ocean." (b) The acronym "IMCO" stands for "Inter-Governmental Maritime Consultative Organization." 2, Risk of a Major Spill, page V-47 The last sentence of the first paragraph should read as follows : C-3 3. The 2^Rn k""^' ^^ ""^^^ ""^ ^ "^^^°^ ^Pill f"^°^e than I'oon MMu^'^J^ °f 100,000 gallons) is about 0.12 per b^^weeH ? and'l'n'?'^""'"^ '°" "^^^^^^ ^^^^^ ^nd cetween u.5 and 1.0 for open waters." Containment at Sea, page VI- 32 The first paragraph states among other thinas i-h^^ "^,-^^ ind'th^f """""""'^ ^"<^ effectivl in heavy slasf^re toxC"'' and their use must be restricted." It is suggested that dSLrsants'ii^h''? ''""T' ?° '^'^^ ^"^"^ devl?:p^:'t of uibpersants with lower levels of -t-OYi r-i -t-ir mu ^ , ^^ifth-.;^^rd°i-- OU spxlls in open ocean areas where' con?ain:ent"\'r impossible, *■ Oil Spill Analysis Ba ckground, pages fl-1 and A-^ Icnl ^^rht^^K""^ ^""^ changes noted in Item 1 herein are ^ applicable here as well. »^ GEORGE C. STEINMAN Chief, Environmental Activities Group Office of Shipbuilding Costs I I C-4 United States Department of the Interior OFFICE OF THE SECRETARY WASHINGTON, D.C. 20240 ER-77/915 f^Qy ^Q ^g^^ Mr. Michael E. Carosella Associate Assistant Administrator Federal Energy Administration Washington, D. C. 20461 Dear Mr. Carosella: This is in response to your letter of September 26 requesting review of the draft supplement to the final environment statement for the Strategic Petroleum Reserve program. The supplement points out that a capacity now exists for 370 million barrels (MMB) of oil storage previously proposed. This means that the previous proposal would require 130 MMB of new storage capacity while the new proposal to store 1,000 MMB would require 630 MMB of new storage capacity, which is approximately a fourfold increase in new capacity. This same type of relationship for oil storage capacity requirements could occur for other phases as well. Impacts that previously were projected to be minor, local, and insignificant could possibly now become major, regional, and significant. Consequently, we question the rationale that doubling a program will double the impacts without noticeably altering their direction or significance. There may be a fourfold increase in some impacts, and the timing should also be considered. It is noted that violations of carbon monoxide and photochemical oxidant standards are frequent on the East Coast (p. IV-22). It should also be mentioned that hydrocarbons are a major contributor to the reaction with sunlight which creates photochemical oxidants. We suggest that the environmental statement should identify the increment of pollutants that may be added as a result of the proposed project. The discussion of wetlands on pages V-25 and V-26 should take into account Executive Order 11990, signed by President Carter on May 24, 1977. The Order directs Federal agencies to avoid wherever possible CONSERVE ^AMERICA'S ENERGY C-5 Save Energy and You Serve America! ^]!.t l°"^\^1'! short-term adverse Impacts associated with the destruc- lon or modification of wetlands and to avoid direct or indirect suoDnrt .l?Jl ""^truction in wetlands wherever there U a prac?icabU lite? b" : e of'thelr'valui']!','^"^"?' ^'?"' """^"^^ 1. acu'ti'w^if s thep^a ;a\^^^^cr?l?^^^3^d^e^:??i:s^iou7r^eiij^^Tthr?;yi^„"^ We are also concerned about possible infringement by man-made canaU e J c;i?«i II S-, ^^-^^- i:de^\?s"s1^tirshal, a:rde^:!dtrV^c"rea^^■in" ^^^^a^n: if u^^^,---:^^ deems necessary to assure the substitution of other recrelt on pJooerties and1oca?ion!3"'^ '''' ""'''' ^''^^ '"' °' --easonably'e^^^Jl^^nrSs'lfJ^^ess Jh/^t"*?'' •''\°? P?5^ ^-'^^' ^'^^ <'oubling of the proposed capacity for r sk'ofm-o 'o-?\^"if"^"rP^°r^^ "^'^ ^^="lt in a doubl g^of the nsK OT a major oil spill sometime during the life of the oroiprt Uo re™>;t"il?zed™: ?o?al recrL"?"'^']^'^"'.^?^^^^ In wetUnSr^rea^ wh ch art utinzea tor local recreational activities and urop that the ia+^c + available technologies be implemented in ord" to minimize thUpissiMlity. We hope these comments will be helpful. | Sincerely, I QFrlMnt^^' Acting^^puty Assistant btLKhTARY for Policy, Budget and Administration C-6 ji(i° sr^. 1522^1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY '^\ p^o■^^^''^ WASHINGTON. D.C. 20460 DEC 8 1977 OTFICE or THE ADMINISTRATOR Department of Energy Executive Secretariat Box QH Room 3317 12th & Pennsylvania Avenue, N.W. Washington, D.C. 20461 Dear Sir or Madam: In accordance with our responsibilities under section 309 of the Clean Air Act, as amended, the Environmental Protection Agency has completed its review of the Department of Energy's draft supplement to the programmatic final environmental impact statement (EIS) for the strategic petroleum reserve (SPR) program. Our detailed comments are enclosed. EPA has previously reviewed the SPR programmatic draft and final EIS's as well as all of the site-specific petroleum reserve EIS's issued to date. An acceleration in the timetable for petroleum reserve site selection, preparation and filling has made necessary a supplemental DOE environmental analysis of the entire SPR program. EPA's review of the accelerated program has identified several environmental concerns not anticipated at the time of our review of the more phased SPR implementation schedule. These concerns are as follows: a) Data presented by DOE need to be strengthened to support a more effective evaluation of the impacts of disposing produced or displaced brines by deep well injection. Deep well injection activities associated with the SPR program will be regulated in accordance with the Underground Injection Control (UIC) program of the Safe Drinking Water Act (P.L. 93-523) as detailed in EPA's draft regulations issued August 31, 1976. DOE should provide in the Final Supplement sufficient data from its current testing and analysis program before initiating speoific emplacement, mining or disposal operations. C-7 b) An^n^? ? ^o?5 ^^^ ^^^^^ ^^^ Act amendments of August 7 1977 establish new requirements under the program for the prevention of significant deterioration (PSD) of air qualify. These new requirements widen the applicability of PsS to all criteria pollutants. In addition, petroleum storage and transfer facilities are now "desiana^^ source categories" under PSD. Each o^these new aspects of the PSD program as they relate to ?he ruLV.:Zr ^^°^^^ ^^ ^^^— ^ in the pLal d) J Supplement. ""^ sectfnn''^^/''''^^^^^^^ ^^^ ^^"^^ Supplement fnH r° f^^^^ss^ng the Spill Prevention Control and Countermeasure (SPCC) Plan. We urge DOE to ?lan°:M^r i\th\^i"-l supplement that a SPC? fn^ n^? ""^^^^ ^^^ requirements of 40 CFR Part 112 Ret^.!^^n'''';°" Prevention, Non-Transportation 1 Related Onshore and Offshore Facilities) will be ^ sto^aaf /'^n ':? "i" "°"^^^ ^^^^^ ^^^h petroleu^ Ihou?d hfT^t""^-^^?^"" operations. Each plan no lat.^%K'' ^ implemented by DOE or its contractors ODeratfnn! k"" ""^^ ^^^^ ^^^^^ petroleum storage operations begin. EPA wishes to express its strong environmental concern for the impacts which the expanded and accelerated SPR program may have on wetland areas ?hat^ho% ^""^^ ^;?? Louisiana coasts. We recognize of WPf^! President's Executive Order 11990 (Protection of Wetlands) does not apply to this program because Of the exemptions provided in section 8 of the Order However, EPA urges DOE to more fully address, in the* Final Supplement, proposed and alternative storage sites with respect to their potential for adverse wetlands impact. Selected project sites should be the most practicable among alternatives and DOE, through Its contractors, should provide for those mitigating measures necessary to minimize impact on the wetlands environment, particularly in the selection of any pipeline rights-of-way. Wherever possible, wetland areas should be avoided. Mitigative measures for construction in wetlands are available and EPA staff is willing to help C-8 define and oversee their implementation. For future SPR projects not covered by the Executive Order exemption, EPA will implement this order to the fullest extent to preserve and protect the wetlands. We urge DOE to contact EPA for consultation and recommendations in the selection of any future SPR sites not already identified or covered by the Draft Supplement programmatic EIS. DOE should announce its intentions in this respect within the Final Supplement. Finally, EPA notes that inland salt domes are under consideration by DOE for inclusion in an Industrial Petroleum Reserve. We question why these inland -sites were not addressed «as possible sites for the proposed -SPR expansion as discussed in the "alternatives" section of the Draft Supplement EIS. Utilization of inland sites would necessitate only minimal use of wetland areas and would particularly avoid the potential for wetlands degradation as a result of oil spills. This issue should be addressed in the Final Supplement. As a result of our review, and in accordance with EPA procedure we have rated the modified Strategic Petroleum Reserve Program ER (Environmental Reservations) and have categorized the Draft Supplement EIS category 2_ (Insufficient Information) . We request additional information in the Final Supplement on air quality impacts, wetlands mitigating measures and underground brine injection plans as well as on those issues identified in our enclosed comments. We have appreciated the opportunity to review and comment on this draft supplement. If you have any questions regarding our comments, we would be pleased to discuss them with you. Sincerely yours, ^^i- Peter L. Cook Acting Director Office of Federal Activities (A-104) Enclosure C-9 THE ENVIRONMENTAL PROTECTION AGENCY'S COMI^ENTS ON THE DRAFT SUPPLEMENT TO THE FINAL ENVIRONMENTAL IMPACT STATEMENT ON THE STRATEGIC PETROLEUM RESERVE PROGRAM Water Quality 1. The Draft Supplement states that the proposed SPR exn;5nc;-ion wxll require large quantities of surface water lor construction tfllTeTeoTirta 'the -^'^fl facilities. If inta.e^'structur^s Will ce required, the .- mal Supplement should provide adeouate information to allow EPA to determine that the best technoloqy ZsTan"T/LtZ""°.'^T^^ ^"P^=^= "^^^ ^^ implemented in ^he^"^ aesign or these structures . 2. The proposed Strategic Petroleum Reserve projects involve hydrocarbon storage by emplacement of crude oil into salt domes, solution mining of the salt domes to create or enlarae ^^if ^""I '^°J^^^ capacity, and, in some cases, disposafof ?he produced or displaced brines by deep well injection? These nn^^' operations will be regulated in accordance with the Underground Infection Control (UIC) program of the Safe Drinking Water Act (Public Law 93-523) , as detailed in EPA's Draft regulations dated August 31, 1976. Under these Draft regulations, the data presented in the Draft evaluation nTL^^ be _ strengthened to support an effective evaluation of the environmental impact of the injection operations. DOE should provide sufficient data to EPA from Its current testing and analysis program before initiating any of the emplacement, mining, or disposal operations. Since Louisiana and Texas are expected to assume primary enforcement authority of the Underground Injection Control Program, the data and analyses provided should be consistent both with those requirements proposed in EPA Administrator's Decision Statement #5 (39 CFR:69) (or those required under the superseding UIC regulations, when they become applicable), and those required for permit application under Statewide order 29-B of the Louisiana Department -of Conservation, Oil and Gas Division as well as the requirements of the Texas Railroad Commission, Oil and Gas Division. In addition, DOE should afford EPA and both State regulatory agencies close coordination m all phases of data requirements, collection and presentations. Also, selected technical data should be C-10 provided to the public in a form of a "by request" appendix to the Final Supplement. We request DOE to note its intentions to accommodate the above recommendations in the text of the Final Supplement. 3. The discussions of operational discharges of oil from tankers on pages v-44 and A-1, while correct, do not fully describe the status of control measures being developed. These discussions refer to pending U.S. Coast Guard regulations and the 1973 Marine Pollution Convention of IMCO (Intergovernmental Maritime Consultative Organization) . The 1969 amendments to the 1954 International Convention for the Prevention of Pollution of the Sea by Oil have been adopted, but the 19 73 Convention has not. This limits the total quantity of discharge oil to 1/15,000 of the total cargo-carrying capacity at an instantaneous rate of discharae of 60 litres per mile and a distance of greater than 50 miles from shore. The 1973 Convention would place additional restrictions on oil tankers that v;ould further reduce the quantities of both operational and accidental damages. This includes reception facilities, retention of oil on'board, segregated ballast and requirements minimizing outflov; from side and bottom damage. The Convention may not be adopted in time to affect the SPR, but if it is, it could affect the statistical analysis in Appendix A of the EIS. Thus, the discussion of these items should be expanded in the Final Supplement. 4. EPA strongly recommends that the method of brine disposal involving use of the displaced brine as a chemical feed stock be used wherever practicable. Discussion on this recommendation should be addressed in the Final Supplement. 5. The Draft Supplement indicates that pipelines serving the SPR salt domes sites will be coated externally with an asphalt-san mixture or coal tar enamel for corrosion protection. The pipelines will also contain sacrificial zinc anodes to lessen internal corrosion. The Final Supplement should discuss whether these corrosion preventive measures could cause any adverse impacts to groundwater quality in the project areas. 6. The Draft Supplement needs to be strengthened in its address of the Spill Prevention Control and Countermeasure (SPCC) Plan required under 40 CFR 112 (Oil Pollution Prevention, C-11 ?hr?[n^?^r*^?'°" Related Onshore and Offshore Facilities) l^ i^ Supplement should acknowledge DOE's intention oHfcFRl f i5:?hin's'= ^^- "-^i? "-ts the requirements hlrrl 112 withm SIX months after a storage facilitv f^n^^.-^ fiilly implemented no later than one year after facility operation begins. ^ ^-t^er 7. The Draft Supplement does not address any discharoe^; or treatment of domestic wastewater for the proposed -Ip expansion. If such discharges will exist, the point Sf discharge, the type of treatment and possible impacts to the receiving stream should be identified and addressed i? annlTi^f' ^T'^""^^*- '" ^^^^^ion, DOE should indicate If application for a National Pollutant Discharge Elimination System (NPDES) permit has been made! Discussion on this matter should also be included in the lina? ISpplement. Air Quality 1. The accelerated SPR program expands the storage of oil from 500 I-H-IB to 1 billion barrels of oil. The expanded wni'^.o'-^""""""""'/^ ^^" ^^^^^ supplement to ?heE?s will also increase hydrocarbon emissions from the use of above ground tanks as well as fill and withdrawa! operations ^t^n/^^ T""^^ localized violations of the Federal air qiaU^y standard for nydrocarbons in areas that are already experiencLa violations of this standard. The Supplement does portray these^ occurrences m general; however, the compatibility of the program' an^^r r^^^^^ existing State Implementation Plans for a?tainS^g and maintaining air quality standards will require specific !oo^;?r^''f fr'X^'"- '^^^ specific EIS's for Ipl'^l^orage locations should address this question in detail. 2. In addressing ambient air quality standards, the Final Supplement should recognize that the Clean Air Act, amended on August 7, 1977, has changed past Prevention of Significant Deterioration (PSD) Regulations. The changes significant to this project are: a) that PSD regulations no longer apply only to particulate and sulfur dioxide emissions, but to all criteria pollutants, (i.e.. Sulfur Dioxide (SO2) , Total Suspended Particulate (TSP) , Non-Methane Hydrocarbon (Nmc) Ov^d^n^c'^^n'^ff (NO.^) , Carbon Monoxide (CO), and Photochemical Oxidants (O3)), and b) that PSD designated source categories have been expanded from 19 to 28 sources, one of which is C-I2 petroleum storage and transfer facilities. The effect of these changes upon the project should be addressed in the Final Supplement. 3. In addressing Federal Clean Air Regulations, the Draft Supplement states that EPA's emission offset policy excludes new sources with "actual" emissions totaling less than 100 tons per year. Hov/ever, this amount will be based upon "potential" emissions and not "actual" emissions. Clarification of this matter and its possible effect upon SPR projects should be included in the Final Supplement. 4. In discussing possible mitigative measures in eliminating hydrocarbon emission venting from the underground storage caverns, we suggest that condensation units in lieu of a flare system be used. The condensation unit would not only provide less potential for explosion of the volatile gases within storage but would also provide fuel conservation by allowing the condensed emissions to be returned to storage. 5. The statement on page V-10 that hydrocarbon emissions which result from VLCC-tanker operation will not be as significant as those occurring at dock may be correct; however, the emissions may add to already intolerable air quality conditions which exist in the Gulf Coast near the three terminal areas of Capline, Seaway and Texoma, DOE should address this issue in particular light of the accelerated filling schedule proposed. 6. In Appendix B, page 5, the last line should read as follows: "Hydrocarbon vapor loss is generally increased as the molecular weight of the crude oil d ecreases " (emphasis added) . Wetlands EPA expresses its strong environmental concern for the impacts which the expanded and accelerated SPR program may have on wetland areas along the Texas and Louisiana coasts. We recognize that the President's Executive Order 11990 (Protection of Wetlands) does not apply to this program because of the exemptions provided in section 8 of the Order. However, EPA urges DOE to more fully address, in the Final Supplement, proposed and alternative storage sites with respect to their potential for wetlands impact. C-13 Selected project sites should be the most practicable among alternatives and DOE, through its contractors, should provide tor those mitigating measures necessary to minimize project impact on the wetlands environment, particularly in the selection of any pipeline rights-of-way. Wherever possible, wetland areas should be avoided. Mitigative measures for construction m wetlands are available, and EPA staff is willing to help define and oversee their implementation. For future SPR projects not covered by the Executive Order exemption, EPA will implement this order to the fullest extent to preserve and protect the wetlands. We urge DOE to contact EPA for consultation and recommendations in the selection of any future SPR sites not already identified or covered by the Draft Supplement programmatic EIS. DOE should announce its intentions in this respect within the Final Supplement. Alternatives 1. In the discussion of alternative actions to the SPR expansion, the statement is made that current studies by DOE could influence a decision regarding the need for an Industrial Petroleum Reserve as an alternate part of the SPR. Inland salt domes for storage sites located in the Northern Louisiana Interior Basin and the East-Central Louisiana Mississippi Interior Basin are being considered. With this information, EPA questions why these inland sites were not addressed as possible sites for the currently proposed SPR expansion in the alternative section of this Draft Supplement. The utilization of inland sites would necessitate minimal use of wetland areas and would provide for less probability of destruction of wetlands through oil spills. This question should be addressed by DOE in the Final Supplement. 2. As possible alternate salt dome crude oil storage sites for future storage reserves and expansion, the Final Supplement should consider the possibility and practicability of using off-shore salt domes lying within the Gulf of Mexico. Feasibility and potential impacts should be discussed in the Final Supplement. C-14 other Considerations In discussing land use for the proposed SPR expansion, the Draft Supplement states that approximately 2260 acres or 3.5 square miles of land distributed throughout the Gulf coastal states will be used. To assist in effectively evaluating overall environmental impacts, the statement would be strengthened if this total amount of land v;as identified and categorized into segmented amounts according to existing land use, and state location. This v;ould assist EPA in evaluating the overall impact of the proposed expansion. C-15 Arizona Solar Energy Research Commission 1700 W. Washington Room 502 Phoenix, Arizona 85007 / »tua A^pu it: i»Ai.) icf i2-|ni Sutc AZ No . 77-80-00/ Rco= 50S / Phoenix;^ 'ArizoaaTtS 35007.'' Economic Sec . Mineral Res. Indian Affairs Game S Fish Ag. fi Hort, AiUS Power "Health Land Water- Paries AORCC Bureau of Mines Az. Mining Ass 'n ;Arid Lands Studies ■Environmental Studies Archaeological Research SW Minerals Exploration Traiisp^rta±ron - =u _^_- Museum of Nortnexn Arxzona Renewable Natural Resources ^•^^^^Z^y^^?f^J^.'^'^^^:^=^7:p^rissi^ ^l.^^:^ A C-16 ^S-. r^^..Up/jJ^Jl Dr. R- Gwinn Vivian Arizona State Archaeologist Arizona State Museum Tucson, AZ 85721 Arircr.a State Clearinghouse 1700 vresz '."ashir.gtcr. Street, Phcsnix, Arizona 85C07 icf i2_|nn Stitc A2 No . 77-80-0047 Rccr. 505 Economic Sec . Mineral Res. Indian Affairs Game & Fish Ag. & Hort. APJS Power ■Health Land Water Parks AORCC Bureau of Mines Az. Mining Ass'n Arid Lands Studies Environmental Studies Archaeological Research SW Minerals Exploration Transnorta^roH - Museum" of Nortnein Arizona Renewable Natural Resources iiimi :o ycu for :e-/-;rw zra coirur.ir.t. Plsise eviiuats li :o: Atty Gen Admin. Solar Energy Energy Prog Oil & Gas Co Revenue Education Emergency Si Center for Fv Affai OEP.AX)- R. Kinge: : rTO-rsn : if.nr. uron :h^ ;j.-j ;.-il prc^nna of you: ;si.-.c/ I LT.por-jccs of :-j »r.:.':buuoa to 5:^:5 ir.d.'or i.~3 --idr joals arid 3c;t~ves iccord \vi-Ji lay 2ppi;ccb!- liw, ordi: o; rrsuiaucn w,::- which you z.^. lir^ilh: imorji consulsrsiorj mTHis fcr;'1 a:id cr'E xerox copy to ths cisir-'^ghouie r.o h:?.- -Jr-zs. 77 V/Ork"( HO d2V£ f.~rr. ir: the c!iar_-2>.o lm 1; you nsed fiirthtr b/onration or additiorjj vsr.i for .•tv:*'*. anment on this project losal ii i-jppor?i IS -TJtrm mtr.ii 15 ;r.clica'.i^^^r^ ification No. 6. Program (From Federal Catalog) a. Number 8 • 1 t) Title St. Eners Conservation Prog ■Fr< FEA, C)ffice of Energy Cons. And Environment 7. Title and description of applicant's projact Strategic Petroleum Reserve The Fed Btrategic Energf Po_. ., ___ . 94-163). The purpose of the reserve is to mitigate the economic impacts of any future interruptions of petroleum imports. 8. Type of applicant/racioiant A-Sme G-Sp*ciii Purpoa Oinna 6-lntcrttate H— Communrrv Aciton J^ptncy C- Subtitle Diitrici I- Higher Educational D— County Inflitution E-City J- InSian Trib« F- School Dtltrici K-Oth«r iSpedfyj:. Federal Enter appropriate letter QcJ 9. Type of assistance A— Basic Grant D— Insurance B-Supplemental Grant E — Other i— i— i C-Loan Enter appropriate letter(s) \ 1 I 10. Area of project impact (Names of cities, counties, states, etc.) Statewide, Arizona 11. Estimated number of persons benefiting 12. Type of application A— New C— Revision E— Augmentation B— Renewal D— Continuation ^_^ Enter appropriate letter \_J 13 Proposed Funding 14. Congressional Districts Of: 15. Type of change For 12c or 12e a Federal C AnJont c State a. Applicant Multi. d Local I CX) 16. Project Start Date Year month day .00 Other Total 19 b. Proiect Multi. 17. Project Duration A— Increase Dollars B— Decrease Dollars C— Increase Duration D — Decrease Duration E — Cancellation F-Other Specify Months Enter appro- priate letter(s) 1 .00 18. Estimated date -— -1 to be submitted .00 to federal agency Year month date 19. Existing federal identification numbar 19 20. Federal agency to receive request (Name, cit) , state, zip code) 21. Remarks added CVes QNo 22 The Applicant Certifies That a To the oesi o< my iinowledge and belie*, data m this preapplication/ aDDi'cation are true and correct, the document has been duly authorized by the governing body of the appli- cant and the applicant will comply with the attached assurances if the asvstance is approved If required by OMB Circular A-95 this application was submitted, pursuant to instruct ions therein, to appropriate clearinghouses and all responses are attached No Response response attached (1) (2) (31 D D D D D D 23 Certifying repreien tative a Typed name and title b. Signature c. Date signed Year month day 19 24 Agency rtamc 25. Year month day Application received 19 26. Organizalior\al Unit 27. Administrative office 28. Federal application identification u ; 29 Addratt t[ • 31. Action taken _ ria Awarded • I LJb Reiected LJt Returned for amendment Qd Deferred □e Withdrawn 30. Federal grant identification *\ Federal agency A-9S action 32. Funding a Federal b Applicant e. Other f. Toul .00 .00 .00 .00 .00 .00 Year month day 19 33. Action date 35. Contact for additional information (Nome and teleptioitc number) 34. Starting data 19 Year month day 36. Endir>g date Year month day 19 37. Remarks added DVes QNo a In taking above ection, any comments received from clearing- house! were considered H agency response is due under provisions of Part 1 , OMB Circular A 95. it has been or is being made b. Federal Agency A-95 Official (Name and telephone number) 424 101 Standard Form 424 Page 1 (10-75) C-18 Mr. Ralph Kingery OEPAD 1700 W, Washington, to. 505 Phoenix, Arizona 85007 Scau A?7>ic=uon Ilt:-:>cr (SAI) SliLe Azr No . 77-8Q-004 St=-ts;_| CIe2.riiighouse ;-:170O.Ci"ss-t/^7;ashi-g1ran.' Street., Rco= 505 f-EhoeniXr-. Arizona ■tl^aSOaT. ^ AHIS Power "Health Land Water- ParJcs AORCC Bureau of Mines Economic Sec . Mineral Res . Indian Affairs Game & Fish Ag. fi Hort. Az. Mining Ass'n Arxd Lands Studies Environmental Studies Archaeological Research SW Minerals Exploration T ran s-po rtairon Museum of Noztnezn Arizona Renewable Natxiral Resources : -,' V'=>"lti^-'^ '-^i ^?^> -^r; [scr ts-iKicrsd U> yjtt for CCTww ind catnmaal. ?!=!« ey=Ju3te ai tc- hajTXj^M^i e^aifapoCT cits piimr ial pTos^^ ^ io^ortaitt of I^'caittaatiaa; to Slire i^f/ar ira wids joali and 3bj*civ« S3c=otii jifl'Ji any ippCcaaisisB.atniitoi r^stilataa witawhic-tyottZTS [zzsilhz Attjr Gen. Admin. Solar Energ Energy Proj Oil «c Ga.sC Revenue Education Emergency ; Center for J Affs OEPAJD — -" R.King* = THIS^F€Rf'|:A'40:3E'X£ROX COPY ,,.. <^1_. "■ ', ^ r addiho.-ai rine for rsvii». T7 workino days &oni tie daa Mti. ^ saov I cannasivr on this ?{oi«c£:r^^^^^-3^F*r-^i: . rr>5raiurs. ^5 -'3«*irs2--.- •9-?/-'OVl>^ ;|| Mp. Aadrew L. Bettwy if.. CoTTjn., Department of Land :;g 1624 W. Adams St '3 Phoenix, Arizona 4th Floo: 85007 ${«« AZ No . 77-80-0 ^"^~;Ari-crnar Sta-ts ' Clearinghcusa^ ^ ^--i7?^^-^,'^ssrhij:^orK Street, Hcoz: 5QS Economic Sec. Mineral Res. Indian Affairs Game £ Fish Ag-. & Hort- ARLS Power "Health Land Wateir ParJcs AORCC Btureau of Mines Az. Mining Ass'n Arid Lands Studies Environmental Studies Archaeological Research SW Minerals Exploration T r an s p o rta-tro i3. Museum of Nortnern Arizona Renewable Natural Resources Atty Geji Admin. Solar En( Energy I Oil & Ga.) Revenue EducatiQi Emergenj Center fo J OEPAD- -■ R.Ki *-"^^ r=>5:3a> sn»=. :^tv:ii ^jasiai aras=3ua» of rour jj^nc-/ (ff e«£^ icn ro Che cJttrrtihouM: =o Ukt ±2=. TJ working dsys "froci the fee 2^^ :»'^ ■;- .- — r- : -T : "^ Gttmihouse. 20 larst '?->- Ty WC 'J?°P'TrJ^ fi2icp53ccs*^^ 7^'nssd furtbsr LtfocMdcn ot idiihoial tise for srirv. ' ^ -*.•• t ■^}^^i«i^ ^VSi-.-r lass^ts: CUse liMirioftal si}s=!3if ji^ccssary} .'■ ' LO£h^v« ^^^i?v^ t/ri^;::^ ■ Dat C-20 ILLIAM C. WADE (ECUTIVE DIRECTOR Northern Arizona Council of Governments P.O. BOX 57 • FLAGSTAFF. A2 - 86001 • (602) 774-1 895 Regional A-95 Review TO: Ms. Jo Youngblood Arizona State Clearinghouse 1700 W. Washington, Room 505 Phoenix, AZ 85007 RE: Project: FEA, Strategic Petroleum Reserve Office Strategic Petroleum Reserve S.A.I. #: 77-80-0047 The Northern Arizona Council of Governments (NACOG) has completed Us A-95 Review and Comment upon the above project. Action taken on this project notification is as follows: I I Proposal supported as described on the SF-424 and any attachments, [ I Proposal is supported with certain recommendations, provisions, etc. No comment. I I Proposal is not supported. Please be aware that NACOG reserves the prerogative of making additional comments should new information become available to the Agency. The Northern Arizona Council of Governments has appreciated this opportunity to review and comment on this project. Thank you^ William C. Wade Executive Director ^~'^^ Date: Nov. 1, 1977 C-21 THIS A.9S REVIEW IS SUPPORTED IK PART SY A MUO 701 PUNNING SRAFfT. 3 Dept. of Education I 1535 W. Jefferson i Phoenix, A2 85007 V lofi2-[n-i Srue A2 NO. 77-80-00^ ^'ArLzcc »■■ S t'-te -.CleaLringhocse •V 1700- .tfes-C- VTashiict^on' Street, Rcon 303 Economic Sec. Mineral Res. Indian Affairs Game & Fish Ag. 5 Hort. AiUS Power "Health Iiand Water- Parks AORCC Bureau of Mines jrzjzaca.. -.85007 Az, Mining Ass'n Arid LcLnds Studies Environmental Studies Archaeological Research SW Minerals Exploration T ran spx) rtalTo n Museum of Nortnezn Arxzona Renewable Natiiral Resources f tSipiogrsia'i'ir: ar: apoo :is yiiaj n-d jcajn::^ of /oar igt.-.cy f >^*}.'c?ortmcs of hsosDtnbutinn to SlususU'^r irs3-v\^ »cili and aejecives ^ its -rr-a nt wiA zny applicabl-'Iasa, or~s_str VTasHig^n S Rcc3 505 Pncenix,-- iriioaa -^:" 35007-,:? 1'^ ''- 5«. Az NO. 77-8 0-004 Power- Land Parks iv'.T? .-*&...,.. -* . "^ V. -_-> v<.>,.c,- .J^r.- Economic Sec. aIUS Mineral Res. "Health Indian Affairs Water- Game & Fish AORCC Ag. s_H9rt. Bureau of Mines A2 . Minin g As s n Arid Lands Studies Environmental Studies Archaeological Research SW Minerals Exploration T r an spo rtalron Museum of Nortnern Arizona Renewable Natural Resources ^rHIS-FC-y4 "AND ONE-XEROX' COPY to Atty Gcji Admin. Solar Energ ■EInerg7 Pro, Oil &c Gas C Revenue Educatioii Emergency , Center for I Affc OEPAD- •■^R. King' 6? ^o^Kor\S acfet cfiscc^hocse rr^an.ared ^^uthsr L3/cr:r:adaa or 3d.e deir--:shou« no laj-r du=. T7 WOrk-fna G5V; fcjra -Jre dar^ aotsd 'Jav •-. - ■ wj ■: y-,- .- 1 ...-rt^,-,:^r-i.-af-.c^>i^--'-'. "- s: fUie'idditooaT iii«;a ITafcrosaryj^ C-23 10l(^jn_ Tele?hc.Ts Dr. Hermann k. dicxuc^^-, -- Museum of Northern Arizona P. 0. Box 1389 Fort Valley Road Flagstaff, A2 86001 jcrizcaa. Strswe Cleajri^ichouse 1700 5ies^ Washi^gtoa Street, Rccn 5G5 Phoenix, Arizcaa.. 25007 '■^. X: --^.?it: AcJu. ^:^|n-i State TT^o. 77-80-00 Economic Sec . Mineral Res. Indian Affairs Game & Fish Ag. & Hort. ARIS Power ■Health Land Water Parks AORCC Bureau of Mines Az. Mining Ass'n Arid Lands Studies Environmental Studies Archaeological Reseaxch SW Minerals Exploration T r an s pro rtaii-o n Museum of Nortnein Arxzona Renewable Natural Resources prajecr is. :«"2:tt*1 -^ yon for rsrisw ind camracat. Plsase enluata ji la: Atty Gen Admin. Solar Ene Energy- Pj Oil Sr Gas Revenue Education Emergenc Center foi A OEPAD- R.Kii r/ou-is^ricviliir- i of its cantobocon. to SLits aad,'ai irsrwids^oaisand abj-crves • i;niT:-:is FGR;'rA:-,'cr'"d?-?E-'xERo:c copy jcse-Tyoa 2=a£ farti h X. ■ . '. No caLj. - j sflton Lhis projec: 1 Prsposai h ax-p^r^ 2i»=nttsa~.!^T_ ;^ ■' ' f . - •ii^raa: (Use srldJcicnai siisra If orcsasaryj to the cie=.— ihous* no h:>r iiii T7 WO rkj HO dgys &cra tJie dare notsi'a isformtion or liidiric.-aJ rirr.e for rrrirw. .- -•„ ■r'^;.t^^ DO'NOT WISH TO COMMENT. -O t^- "-^■' J». - . ; > ■.• &>s&.^LaM^ -:: — ^ -L-S-AotljrpjpQiogy C-24 Dale Tr^-rr.c-t. Oct. 25, 1977 . Mr. Wesley E. Steiner, ■ State Water Commission i 222 N. Central Ave., Suite 800 Phoenix, Arizona 85004 Arizona Stata Cleajrip.ghouse 1700 West Washington Street, Rcon. 5Q3 Phoenix, Arizona 85007 MinaraX=.Res^:3:f5S^v 2S?i::::^:^«^:<^^^ Game,, ST Fish-^.:>v5rRevenue;-*2^-^- SW Minerals- ExploratioG^V^^^^^^MgP-^^^^^^ - Museum of :NortaeTL:ji Arxzona^^'^'^-^^^-"-^^*'''-'~''^-^-'*'"-~ . - Renewable^.RattiraJL cr-.r-^IS FCrJ'i AND CME XEROX CGFY t, ^.^ <-!£^'^%^%;T^S^^^3^f^^ n:;ct -J: rjrjioiive If you r.sed liirtisr Lnibnration or »ddI:5o=aI cfsisj' ) comrcsnt on uiia projec; oposal la iupporsd ii wn'^sa •.aTztr.ii IS iwiicnid below -".a; r-Jie idijticnal sJissa L: r.tcsasary) , -.will ijyacn, cnief I Energy Programs j -Room 50 7 j 1700 W. Washington I Phoenix, Arizona 85007 :;^..\r±rciia.^.dta-ta^;CIe2riiigbause »^'I70d_;*est'.s:asaij2gt;an: Street, Roo: >^;'^"5hoeni3C jT ■^Xr£iona.'"*C^850O7' ,-, . 1-] Stuc AZ No. 77-80-004 ARIS Power "Healti] Land Water- Parks AORCC Biireaa of Mines Eifonomic Sec. neraJ. Res. diam Affairs Game & Fish Ag. fi Hort. Az. Mining Aas'n Arid Lands Studies Environmental Studies Archaeological Research SW Minerals Exploration TranspxjrtairoA -■ — --__r Museum of Nortnein Arizona Renewable Natural Resources rojscr is- re:zzTsA.,ta yott foe sna^ iad oommtst ?!ssj« eriiuate a to: i.^-?-r .^v-wi- ^'vV- ■?-*!? ^-->---V'^'. -•■'■• JS^iarparcancsar.hs'casnCEiiotioa taSti:t3jid,'ar irMwide laaliand ocj*cdv« artf. witii aay i^otkable .'ii», onfer or rsyihaoa ^sith ;^.^^^- Atty Gen Admin. Solar Enerj Energy Pro Oil Ic Gas C Revenue .,•., Education Emergency Center for '. ■ A£f OEPAD- - • . E.Kini ^^ThlS' FeSi-f . AiNU ONE XEROX -XCFY. to Zhi :aancT.'J:«L'cisacn^c5a Xroo •■^H*^-*^*^^^ oraddicor^al i-s for dsa.-~£h3u« 33 loisr '-has. T7 V/Or'c=atioa oraddldc.-^ tiir.e for rrriiw ,~ .. . — eoo»i ^(o comaieat; on t5u ?ti:^«i?:^?37t^'^i^- - • Cbinnreaa'iinrflcataafceloWj^.^*, V^"^ ! rv-^ .-j-» - t'i-r* rt-^, ^"i* — ^j *^ ^ij^' J"-* ir^'' —...■< I - . . ^4>>a. ^ C-29 ^Q i>^—i±:l±i2x J nr. jonn iiannister f^ Oil & Gas Conservation Cotnm. ■Jj 1645 W. Jefferson, Suite 420 :^| Phoenix, Arizona 85007 ■3 Ut ■e iSAi) 2-ln-i Suf AZ No . 77-80-004 jEconomic Sec . Mineral Res. :^';-Ari^oti5. St^-ta Clea^£iighause ;'-?haeiiix7J-Arizaa^>vaSC07 _■. Srtreat./ Hcoz: SC3 ARIS Power "Heaj-th Land Indian Affetirs Water' ParJts Game & Fish AORCC Ag. & Hort. Bureau of Mines Az. Mining Aas'n Arid Lands Studies Environmental Studies Archa.eological Resesurch SW Minerals Exploration TransptJrtairoja. -■ = -^■.■~ Museum of Nortiiein Arizona Renewable Natural Resources raiecr :i. ;sVr?d la yoo: foe zsrisv znd coma»=t. ?!ssa* rrsiuats is to: '--.-T?" i^'l^ RECEIVED OCT 131977 & & CONS. COMM. Atty Gen Admin. Solar Energ Energy Pro; Oil &t Gas C Revenue Education Emergency ; Center for t Affc OEPAD- •" R.Kingt csaizz XEROX CCP^ ■33ci» iTyca iTsesf Esciiar infocradoa or addico.iii rime fat rrwa*. to *e ciKir^shouM so totsr ±Z3. 17 WOrk'inq dayS Jroci the dare notal abov C<» mc,ie.:a - as mnjafM below ^•»-Tu.-<-.r"-^.^ >- -^ ■ •*-^ Beai Ci-'« 'ffit" rr/taJ ih^islT.-.rc^ssaryl,^--;.^ C-30 iS^Z^M Datr. l2llA:JU^ uiv. ox Emergency Services 5636 East McDowell Road Phoenix, Arizona 85008 I ^^cfi^lnn Sole A2 no. 77-80-0047 Arizcr.i State Cleiiringhcuja 1700 V.'est '.vashi-ctor. Street, Rcon 50; Phoeni;-:, Arizcr.a 85C07 , Economic Sec. Mineral Res. Indian Affairs Game & Fish Ag. £ Hort APJS Power Health Land Water Parks AORCC Bureau of Mines Az. Mining Ass 'n Arid Lands Studios Environmental Studies Archaeolooical Research SW Minerals Exploration TransportsJrori Museum of Nortne^ji Arizona Renewable Natural Resources Atty Gen Admin. Solar Energy Energy Prog Oil &: Gas Cor. Revenue Education Emergency Se Center for Ful Affaii OEPAD- R. Kinger (£> '^qJoAS r. IS :s:s-ii :o you for :v/irw ir.a comr: jr.t. ?!; Li< f/iiujij u io: I LTrort^c: ofi-j ccr:::buLcn to Suti :coord \vi:h say sppLJKbl- !;w, o:d;: or !i::orjil consider: lions ir.d.'or irt2-^ti jcali and objtrives :JSi!h:;c.-i -.-ith which /cj ire f^r-.i: rrTHis fgr;'1 and cne xerox ccfy in ihj oiiinrshoiiie IT you r.ttd farths: L-jonraticn or =dii::or^l •."_—£ for rsvii to th- dii.-L-.2hoiis< -0 litif thsr 17 V/Or'<''nC! d£yS L-cr: the date note aoove. amtnent en this project losil is jupporKl is -TJt'sn i.tier.tj ij i-dicited below s: fuis ;Jd!::!>n2l ih^ts a r.eccisao) :-iturr yC^C-*?-^;^?^^ ...^.<.... Daue. 7 f<>Wjv»^<. C-31 ■x.w,n.<^12r.l.?y.P....„ Mr, Les Ormsby, Admin. Arizona Power Authority . 1810 West Adams Street Phoenix, Arizona 85005 Arizona State Clearinghouse 1700 V'ss- Viashingtcn Street, Phoenix, Arizona 85007 Suu A77:ic:uon Ittzuzt: iSAl) ic(i2.|nn Sdte AZ No . 77-80-004 Rcorr 505 Economic Sec . Mineral Res. Indian Affairs Game & Fish Ag. & Hort APJS Power "Health Land Water- Parks AORCC Bureau of Mines Az. Mining Ass'n Arid Lands Studies Environmental Studies Archaeological Research SW Minerals Exploration Transt>orta±rofl - - .^_- Museum" of Nortnein Arizona Renewe±»le Natural Resources Atty Gen Admin. Solar Energ Energy Proj Oil & Gas C Revenue Education Emergency i Center for I Affj OEPAD-- ■■. R.King ijtct :irs:s7 zo you for rffirv i.-ui comsiesL ?Iszm sidaats is :o: :>.« rro^zn'i efrsct uTon the p'aru zrA prcgnris oi ;'ou: izir.cy w^« Lxpomrcs of its conLnbuion to Slut ir.d/sr irta wicis joals ani objscdves Its accori \vi:h aay appliabls law, oidzz or rsfularion wiih which yo;; zrs faniiiiar iddisor^I considsraaons Kr:: THIS FORj'l A^ID CM£ XEROX CCFY j^ j^. ri-i~,2hou« no laur 'Jjaz 17 WOrkina days iror-. the dsts notai ab intact L^t c;iar>2ho liM if you nted fu.-J:=r L'JorTr.aUon or iidlv.orsd time for rr-.ii'a/. o comment on this project rapoiaJ Is i'jpportsd as wTJt'.m •> omrr.enis as inciicned below :a'-s; (c'se axiditional shsc'j if r.eciisar/) ?r t S j-atufs ..^^^ '^^f^Sg:.... C-32 Dat£.. Mr. Roland H. Sharer State Liaison Officer, AORCC 4433 N. 19th Ave., Suite 203 Phoenix, Arizona 85015 - ^a ^if?-.U Economc Secr^s- ■ aRIS *:*• Power " a^^^ "> • -^ 4^s;.- Mineral- Res. ■:::-. ■Health i- Land .' . ^5^-^-^? r- --i 1700 '^«ast.i,Washi=gt:on Siiiree t /^.RsonvSOS ' Mineral- Res ...:-^. Health i. Land . . . , . ^,,v.%;.- Indian Affairs ■ Water- - Vscrks '. Admin.. • *v " r Game £ TLsh. :,]{<>. r XOUCC. •. " ---•■^,»'- Solar Tn •*«,-,. Ag. fi Hort. ^ • Bureau of Mines Z? ^ -Energy: Az. ^Mining Ass ^n ^.-"^ • • • "---.' ^ Energy Prog • iCoi Mr. David i^andrith. Exec. Director, SEAGO 118 Arizona Street •Bisbee, Arizona 85603 Arirora State Cleajrinrhcuse 1700 Wes- VJashir.gtcr. Street, Phoenix, Arizona 85C07 Stat* ,\.-^\ic:.uen litzu ic'i^lnn iSAi) 77-2(^1 Siite AZ no. 77-80-0047 Rccn 505 Economic Sec . Mineral Res. Indian Affairs Gaine & Fish Ag. & Hort. APJS Power Tiealth Land Water Parks AORCC Bureau of Mines Az. Mining Ass'n Arid Lands Studies Environmental Studies Archaeological Research SW Minerals Exploration Transportairon - . - Museum of Nortne^n Arizona Renewable Natural Resources ajsct la rsfjrrtd to you for :e-/irw ino comsier.:. Pltiie eraJ-oate is to: :>.« rrc^r^n'i ef fsc: jpoa :hi pbru aril prosraras o(' /ou: jxsr.cy ihj imporjT.cs ot' iij contribution to S;jts a.id/or arsawSdr ^aaJi ar.u os;sctiv»j its icsord wiih any aoplicabls law, order or rsgulaticn with which /ou zzt fj.-nilar addiconal consulsr^dou Atty Gen Admin. Solar Energy Energy Prog Oil & Gas Co Revenue Education Emergency S Center for F\ Affai OEPAD- • R.Kinge :tiar: T:-.IS FGUM ^\\2 CME XEROX COPY jntat: ih* cliar-ijhoiii* '1 you nteci fuithsr irJonraiion or addi:;orjl fj-ns for :;v;i'w. to the cieir.-.ihoiis* r.o latir 'i.xz. 17 WOrkJnO dgyS &ara the ti-.i notid aaov« o comment on this project ropcsa! ii iupporsd is .iTJtten otn.Tienij as intiicatsd below ;nLs; (u'sc iiiditionai shreis Lf neccAsar/) C-34 - ^ ■'•-'• Cll r.'.cr . K. Taltea T.>:erutive Secretary jndiar. Affairs Con-jnission 164 5 We- t Jefferson St. Phoenix, A2 85007 -.rircr.i Stst2 CleBjri.r.-hcu3 2 1700 v:ss- '.:£.£;-. ir.c- or. Street, Phcer.i:-:, Arizcr.a c5CC7 i.zis Arr ""Sn '.ztz'-z': iSajj icfi^Hn Stitc ?.Z No. 77-80-004 / ?xct! 505 AH.IS Power "Health Land Water Parks AORCC Bureau of Mines Economic Sec. Mineral Res. Indian Affairs Game & Fish Ag. & Hort. ■hz. Mining Ass'n 'Arid Lands Studies Environmental Studies Archaeoloaical Research SW Minerals Exploration TransportaJrori - - _.- Museum of Nortnein Arizona Renewable Natural Resources Atty Gen Admin. Solar Energy Energy Prog Oil &: Gas Co; Revenue Education Emergency S< Center for Pu Affai R. Kingei St ii :s;'r— ?<; :o ysu for :r/;rw irjd coms-.ir.t. ?! it: Li to: ,t LT.ro.-tiTCs of iis cor.tributioD to St:i".s ;r.c,''or zr:3-i^.i: gcais jr.d objsrtvts i iccorc '.\iih zry jpplicbli ;;•», oidtr or rifjlatics fith whiih ya: zr: Jjrr.iiii: ;-- i.-i::; ■ u.vj-l .-.M^ t..w JA Uo. , .J, ,1,. ritirJ-.ihouM r.o h:i: '-^2:: 17 WOrklHO C2VE ^~ the da:« notad itir: ihi ciiirlrihocie j you r. r.isi f'.:.-ih;r L-Jorr^atisn or additior.^ tirr.s for ;tv;j'-i. i CO— msn' o.T l.'Ui project :pcsij is j-jppor.td zs v.T]:tsn r-,.-r.er::5 li irdictsc beiow ,:s: (Ui5 additional sh^ts ii r.ecess5j->) C-35 -s Ss-it^re. <::7.^[z:^ D.../-^_.tZf.-..2_22. Dr. '..'illi^n H. Dre^l-er, Tiroctor Arizon= ""ureau of Heolc'" 5/ >!ir.-2ral 7e enrol f"?y Vnivorsitv o' Arizc-nn Tijc.=;.in, Ari^r^r.?. P-S721 Arij:ona State Cisajringhcuse 1700 vresw vrashir.gto- Street, Keen 50 = Phoenix, Arizona 85C07 aim A77Mc^uon iitsiLZt: '.SAi) St>i« AZ no. 77-80-004; Economic Sec . Mineral Res. Indian Affairs Game & Fish Ag. & Hort ARIS Power Health Land Water Parks AORCC Bureau of Mines Az . Mining Ass'n Arid Lands Studies Environmental Studies Archaeological Research SW Minerals Exploration TransportaJron - . - Museum of Nortnei.n Arizona Renewaisle Natural Resources Atty Gen Admin. Solar Energy Energy Prog Oil & Gas Cc Revenue Education Emergency S Center for P Affa: OEPAD- R. Kinge (£> '^C|, ens ec: iarefirTsd :o you for rr/irw i.-j comcient. P'.siis evsiujts li to: ^e un?ort2r« of :is conthbuiion to Sute ar.d/or arsawii; »oals and osjecives 3 icsort wiL"! any ippiicsbie hw, ordei or rsguLi:ion with which you its f;.— .ilLsr ddi::or^ consdenaou .r. 7HIS FCR;^ AMD CriE XEROX COPY ,, ,,, c;,^,,,^ ,, :,:,, :,,, 17 work- nc' days fro. the date „.^ abo. ntar: -^.t clsahrsho i:i* If you r.sed furthtr L'uonr.ation or addiiioral time for :sv;i-v. > commsnt on thu project sposal is i-rporsd li wTJttm ■mrr.er.ia li jr.dicatsi below aa: (U« aJditioTjl ihssa d r.ecei$a.->) C-36 William H. Dresher Director ^" . r .._•■. fift/._1 o/. ■> Dr. James Becker Center for Public Affairs Arizona State University Tempe, Arizona 85281 S(su ATT'ie^iion lltstiixT iSAl) icf 12-ln-i Sl4te A2 NO. 77-80-0047 rirona State Clearinghouse 700 West '.vashir.gton Street, Rcon 505 hoenix, Arizona 85C07 lEconomic Sec . Mineral Res. Indian Affairs Game & Fish Ag. & Hort. APwIS Power •Health Land Water Parks AORCC Bureau of Mines A2. Mining Ass'n Arid Lands Studies Environmental Studies Archaeological Research SW Minerals Exploration Transporta±roia - ..- Museum of Nortnern Arizona Renewable Natural Resources : ia ziiimi :o you for :r/isw zM comr-.er.t. Plane srsluats li to: progrini'i ef 'sc: uroo :hi jlaaa 3tA p:opa.-aj o{ :'our igsr.cy imporuac! of :ls contribution to Sim ir.d/or artaw^d: joalsand objscdvei •ccord wi'Ji ary applicable !aw, ordtr or rsf ub:;on with which you ir? firr.iliar iuorai considiTiSons Atty Gen Admin. Solar Energy- Energy Prog Oil & Gas Com Revenue Education Emergency Sei Center for Pub Affair/ OEPAD- R. Kingery r. Tr!IS FORI-l A'-!D CME XEROX COPY ,o t^,. dsa.-L-i|houM r.o lats- 'Jiai 17 working days from the daze notad ai zz -^s cliarlT'-.oiiie J you nteil forthsr Lnforrration or additio.-ol time for rrviiw. afiovtf. arnmsnt on this project Bsal is iupportsd as vtxittm isents as indicated below : (Us* additic-nal shifts U. r.ecissai-/) C-37 r^.-'.z:ur-.(K^^.^.J..'^^ Transpor-.ation PlnnnLnr, Division Ari.von.-i DopL. of Ti ..r^spor tnL 1 on 20n South I7tli Avon".-, Tnorr. 310 riic^MiLX, Arii-.onii 6j(.'07 icf.^! nn Sir ;.2 No , 77-80-0047 17CD vrssz V.-r.shir.g-rr. £rr£-et, P.-cer.i:;, Arizcr.a c5C07 ccr. 50: Economic Sec . M'nerai Res. Indian Affairs G?jT\e & Fish Ac. & Hort. APJS Power Health Land Water Parks AOP.CC Bureau of Mines iA2. Mining Ass'n Arid Lands Studies Environnental Studies Archaeoloq: cal Research SW Minerals Exploration Transportairori Museu-Ti'of Mcrtnei.n Arizona Renewable Natural Resources Atty Gen Admin. Solar Energy Energy Prog Oil &: Gas Co Revenue Education Emergency S Center for ?\ Affai OZPAD- R. Kinge tviluiJ* li ;o: i ur.poniECi zi :--5 cs.-.:.-:bi:tc- to Si^: j Cj.t-joi .'ou: '-gjr.cy r;Si:b-^3= rvuh which ycj i.-? ."■^.-.dur cs— rr.ifit on ihis prcjec: ?o:;: i: ij-pr-i-i i; v.ti:',: -'J;:;c-n2i ihsrts :ao) C-38 r A S :;-;;iufr...i.y^ ..«•:>' ^i-^.i^:.. ..'f^./../.:f.,.(-.k-<-r'';U.*r.'*^r. ^ Tei.pncr..?.kJ.::t25;. Mr. Roger Root, Acting Chief Office of Planning \ Dept. of Econ. Seciirity '. 1717 W. Jefferson i Pljoenix, Ariz. 85007 \rircr.2. Sta"ts Cle=Lrir.gh.oiisa L700 Wesr Washington Street, Rco= 505 Phoenix, Arizona. 35007 Scats ATp-ic^iion Ilt:*.:^;.- (SAj} icfi 2-1 -in jEconomic Sec Mineral Res. 7^ OCT 1 3 1977 XT. A2 NO. 77-80-004 Power Land Parks ARIS ■Health Indian Affairs Water" Game & Fish AORCC Ag. & Hort. Bxireau of Mines Az. Mining Aas'n Arid Lands Studies 'Environmental Studies Archaeological Research SW Minerals Exploration Transp-'ortairon - • •=. _^-^ Museum of Northern Arizona Renewadsle Natural Resources Atty Gen Admin. Solar Energ Energy Pro{ Oil & Gas C Revenue Education Emergency^"! Center for J Aifs OEPAD- •■ R.King< Iff (Unions et a. refined io you for rrrisw irji comsjsEt. Pissie sraiuats u to: t prolan'* effsct a?po :h.» pbai asd pra^ras of your igsr.cy > jnporancs of its contribution to Suteiad/or area w^d; goals and abjecives ac aon i wiih aayippil cablg law, order or rsjulaiioa with whicJi you zrs faniliar iinoral C9nsd«n.aac3 T= T?.I$ FORi'1 AND ONE XEROX COPY ^^ ^j,^ dear-nshou« r.o latir -Jiaa T7 WOrkinO days &oni the date notad tact :h* cI-arj:5Jouse if you nsed furisr infonration or addirionai rjne for rtT.iw. camment on thii project . . - posai Jiiupporrsd'U vr-nttsn nraents as indicated below aaov ts: (Use additional shsrts Lf necessary)' C-39 ■^ SigratufE. Hnllis Choue' Dr .. S\v. .n'-ui .^ Dan-loy, 'Oil Owi.or ]). :i"iVvJ ont: of IL:-U ■■>. 5'?:^' 'CO 17 iO '.:■. ■n l: :, .\-i:ir,c"r'. o -J */ '• / Ar ircr. =_ C rate Cle= -rir ChCU3 l" OG V. es- '•'ashir.c-; .=r. Szree ?h cer.i -'• r ^i2cr-£. £5 GC7 ic'i^lnn ;.z No. 77-80-0047 Rccn 505 APJS Power "Health Land Wate^ Parks AORCC Bureau of Mines .Economic Sec . Mineral Res. Indian Affairs Game & Fish Ag . & Hort. Az. Mining Ass _ Arid Lands Studies Environmental Studies Archaeological Research SW Minerals Exoloration TransportaJ^roh - . . . Museum of Nortne^n Arizona Renewable Natural Resources Atty Gen Admin. Solar Energy Energy Prog Oil Sc Gas Co Revenue Education Emergency S- Center for Pv Affai OEPAD- R. Kinge .i rs:irrti J you r.tsi fu.-t.';t: i.'-ionT:a:ion or addiiioroJ •.ime for .-iv;i-v. to tht dsi.->.2hou« -0 !i:-r -J-.iz 17 WO'^kinO c'gyS Iron the date notiJ :u}ove No csiTiTient o.t ;>J5 project Propcsil ii j-jopors-i 2; ■.'.T;::;r. ["■Jii i.:cit:ori3l ibr:'.; d r.soris^-/) C-40 "^.•^C vWr- Da'.£.. OCT 2 7 1977 ASSISTANT DIRfCTOR AHIZONA DrPT or H^IALT!! SERVICES niv cif rrjv" nv — ,i,.i ;i"aiih crr-virr*: Tc.'i or.c-.r. «-entral Az. Ass'n of Gov'ts. 512 E. Butte Avenue Florence, Arizona 85232 eLsW IJ>N^> i2-i-in Sti-.c No. 77-80-0047 Ariscna State" Clearinghciisa""' ' 1700 West Washington Street, Rccn 503 Phoenix, Arizona 85007 lEconomic Sec. ARIS Power Mineral Res. "Health Land Indian Affairs Water Parks Game & Fish AORCC Ag. & Hort. Bureau of Mines Az. Mining Ass'n Arid Lands Studies ■Environmental Studies Archaeological Research SW Minerals Exploration Transportairon - - ....- Museum of Nortnein Arizona Renewaible Natural Resources Atty Gen Admin. Solar Energy Energy Prog Oil & Gas Cor Revenue Education Emergency Se Center for Pul Affaii OEPAD- R. Kinger 6? f^C^^OTiS «i i» rafjrrsd to you for rr/jrw irjj coma-.ent. PIsaie rrsiua Js li to: e ?TO-ra.'3*J effsc: uron :.h« plaaa arjl zzojnrzi of /our igsacy s LT.porucce of iu contribution to Sw.s and/or arsa'in'i; ^aali and ob;t< sccord with lay aoplicable law, ordsr or rsjuh^on irith which you irs ditional caiusdsiaaona :r-, T:-^.IS F0R;>1 and CNE xerox copy ,, ,,, ,,,™,^,^ ,, ,,,,, e,, n working days ^^ th.da:. no; tart the cliarJrsioLie If you nsed furthrr Ln/ormation or addiriorji tvr.s for rrvitv. otsi s^jove. commsnt on this project poial Is iucportsd is v-rittm Timenu u indicated below ts: (Use additional shssis Lf r.scsisary) :--\^ C-41 D,-.:/t6i. ' V ^ir^ V- 6^6 -^76 OFFICE OF THE GOVERNOR Office of Economic planning and Developmen iTTW—^m WW II 'n ■ ■■!■ ^ ^HW^-TJ.....^ y . 1700 West Washington • Executive Tower • Room 505 • Phoenix, Arizona 85007 December 12, 1977 Mr. Michael E. Carosella, Associate Assistant Administrator Federal Energy Administration Strategic Petroleum Reserve Office Washington, D. C. 20A61 Re; Strategic Petroleum Reserve S.A.I. /'77-80-00A7 Dear: ^^- Carosella, Enclosed is a copy of a response concerning the above project which was received by us after our Signoff to you. Sincerely, ^ ^fC-iu^ liluJ/-^ Mrs, Jo Youngblood, Supervisor Arizona State Clearinghouse JY: ss End. C-42 FEDERAL ASSISTANCE 1. Type Of GPfeaPPlication Action Q Application (Mark rn.i •, apijropnate U Notification Of Intent (Opt.) box! D Report Of Federal Action Applicant'! application OMB Approval No. 29-R0218 a. Numbei b. Date 19 Year Month Da v 3. Suta application idantifiar a. Numbei Az 77-Rn-nnzi7 b. Date Awgned Year month day 19 Lesve Blank 4. L«9al Applicant/Racipiant a. Applicant Name b. Organization Unit c. Strtet/P.O. Box d. City f. Sate h. Contact Perton (Name i telephone no J Federal Energy Administration Strategic Petroleum Reserve Office Washington D. C. Michael E. Carosella, Associate Assistant Administrator 1. County g. Zip Code : 20461 7. Title and description of applicant's project Strategic Petroleum Reserve 5. Federal Employer Identification No. 6. Program (From federal Catalog} a. Number 8 0*0 01 b. Title St. Energy Conservation Frog FEA, C)ffice of Energy Cons, And En vironment 8. Type of applicant/recipient The Fed Energy Adrmn propose? to imnlement the strateeic PerSleurri Reserve^ Title I, Pa:: t B .of the EnergV Policy anc Conservation Act of 1975 (P. L. | 94-163). The purpose of the reserve is to nnitigate \iSpeafyj the economic impacts of any future interruptions of petroleum imports. A— Sl«Ti C-So*Cill PuroOM Otnr'CT • ~ Intertttn H—Co'^montr/ Action A^ne> C-Subnftt DiBtncT I— Mig«»r Eouciuonai 0— Coonty IftRiTution E-Citv J- Inaian Trib» f-Scnool OmncT K-Otft(r Federal 10. Area of project impact (,\ameio/ cities. counties. states, etc / Statewide, Arizona n. Estimated numbei of persons benefiting 13. Proposed Funding 14 Congressional Districts Of: a. Federal b Aixxant State .00 *■ Applicant .001 Multi. d. Local I .00| 16. Protect Start — rr; Date Year month day .00 ig b. Projea Multi. ■". Proiect Duration Months e Other Total 1 .00(18. Estimated date -— T to be submitted P'-' to federal agency Year inonth date 19 20. Federal agency to receive request (!\ame, city, state, zip code) Enter appropriate letter fkl 9. Type of assistance A— Basic Grant D— Insurance B— Supplemental Grant E — Other i— i— i C- Loan Enter appropriate lerrerfs) \ I I 12. Type of application A-New C- Revision E- Augmentation B— Renewal D— Continuation Enter appropriate letter Q 15. Type of change For 12c or 12e A — Increase Dollars F-Other 5pfci/>- B— Decrease Dollars C— Increase Duration D-Decrease Duration E— Cancellation Enter appro- priate tetierfs/ 19. Existing federal identification number 22. The Applicant Certifies That a. To me best o' my Knowledge anc i t belief, data in this preaDPiication' | application are true ana correct, the docunrient nas oeen auiy authorized by the coverning oocy of the appli- cant ana the aoDlicart will comply with the artacheo assurances if the ass. stance :s aoorovea 21. Remarks addad Cves Dno If 'SQuirea by OMB C.rcuiar A-95 tn.s acDiicanon was suomittea. Pursuant to instructions therein, to appropriate clearinghouses and all responses are attached- A'o Response response attached D D D D D D Typea name and title b. Signature c. Date signea Year month day 19 24. Agency name 26. Organizational Unit 27. Administrative office 29. Address 25. Year Application received 19 rruinth day 28. Federal application identification 30. Federal grant identification 31. Action taken Ma. Awarded Rejected Returned for amendment Deferred Withdrawn Db. 38. Federal agency A-95 action 32. Funding Year month da\ a. Federal b. Applicant c. State d. Locsi e Other Total .00 I 33. Action date 19 .00 .00 I 35. Contact for additional information 1 (Name and leleplioue number) .00 .00 .00 a. In taking above action, any comments received from clearing- houses were considered. If agency response IS due under provisions of Part 1 , OMB Circular A-95, it has oeen or is being made. 424-101 34. Startir>g date Year month dav 19 36. Endirtg date Year month day 19 37. Remarks added b. Federal Agency A-95 Official (Nome and telephone number) C-43 Standard Form 424 Page 1 (10-75) Slau Ay?Mr':;f)n i:tc:^tr i3Ai/ Mr. Frank Servin, Exec. Dir. Dist-.-i(. . IV Council of Gov't:, 377 South Main St., Room 202 Yuma, Arizona 85364 Arizcr.a Stats Ciearirigftouse 1700 Wes- '.vashir.gtrr. Street, ?u:cr. 5C5 Phoenix, Arizona S5CC7 1:^1-11 Sti-.t A2 No. 77-80-004 .Economic Sec . Mineral Res. Indian Affairs Game & Fish Ag. & Kort APvIS Power Health Land Water Parks AORCC Bureau of Mines Az. Mining Ass'n Aria Lands Studies Environmental Studies Archaeolocical Research SW Minerals Excloration Transportalrcri - . - Museum of Nortne^n Arizona Renewable Natural Resources ojtei lirtfizz^ :o you for :r/irw i,-jj comr:sr.L ?!sue svjiuite zi to: ■••"•« — os::.-3': -r'sr. .ro-i :.--: -.azs a.-xl z:zjr^r:ii ci ;ou: -.it-c-y :>.« LT.?orac« ot ;"j ca.-tr:buLon to Sli:s ir.d/cr arsawics -^ili mi ob-sctves its icoori wi-'i lay 25cLic==:s "iw, ordii or .-tfuiadon srith which you irt fi.-iiiar Atty Gen Admin. Solar Energ Energy Proi Oil t Gas C Revenue Education Ennergency J Center for t Affa OEPAD- ■ R. Kingi 6? ^C|-.0\S ;n: to :..t c^tir-s.'-.ouii r.o latir tha:: 17 V/Ork-JnO dsyS iroTT. the da:- notsd a or.:;— -J-.t c;jirL"z~ciis ^<^^oriS eet a.;s;j— -d ;o you for rr/irw ir-a coma-.ir.L ?!: svU'iats ij to: i-.e TTopi.-a'i ii'x-. uron :hj ;brj zrji jrcjrarni oi ;ou.- ijs.-.cy ^.e L-nporjccs of iis co.-.:.-:b jtioQ to SLits ir.d/cr anaw^:;; ^oali ar.i objscivej 3 icconl wiih asy aoplicrcls law, ordii or .-^-jlaticn --ith which /cu its fi.T.ill; iiiticrj] consiisridara ^~ THIS FCrJ'l A:!D CME XEROX COPY .^ .v. d.^-i,sh3i« -^ in,, .jun 17 WOrkIno dgyS &orr. the dat- notad 1 nizz: 'J-.i z'.i^dr.zr.cmi 'J you r.ted forihi: LrJonna'-icn or adiirioroi '.irr.e for rtvii-v. loovr. ) corr.meat o.-: this project sposal is j-pportii is wTJttm irr.rTier.tj as ::5dicati!i b«low '.is: ('C« a;idii:onai s'r.tt'^ Lf r.ecMsao) C-45 )aU:. /:.;r:i ;:. c : ARIZONA A - "",..;, OFFICE OP "^^^ ^por\fOM/c PLAm/^fG and developmeni 1700 V.'est Washington • Executive Tower • Room 505 • Phoenix, Arizona 85007 OFFICE O F TH E ^— '^- - — 1- •.- --. - r n- .- j -t .^-^ _. - GOVERNOR December 13, 1977 Mr. Michael E. Carosella Associate Assistant Administrator Federal Energy Administration Strategic Petroleum Reserve Office V.'ashington, n. C. 20461 Re: Strategic Petroleum Reserve S.A.I, y'77-80-0047 Dear: '^r. Carosella, Enclosed is a copy of a response concerning the above project which was received by us after our Signoff to you. Sincerely, Mrs. Jo Youngblood, Supervisor Arizona State Clearinghouse JY: ss End. C-46 Deor.. ot Kevenue .State Capitol Bldg. Phoenix, AZ 85007 .-.ri-cr.2. Sts.'ts Cl62_ri.ri-hou3S 170G tres- '-^ashir.ctcn Street, I IC ■\ ' ( ;5C07 RECEIVED ^T ^ o ^^-77 / 0'J2 APJS Power "Health Land Water Parks AORCC Bureau of Mines Economic Sec . iMineral Res. ilndian Affairs Game & Fish Ag. & Hort. ;A2. Mining Ass'n Arid Lands Stu_ies Environnental Studies Archaeolooical Research SW Minerals Exploration Transoortairon - . _ - Museum' of Nortnein Arizona Renewable Natural Resources Atty Gen Admin. Solar Energy- Energy Prog Oil & Gas Cons Revenue Education Emergency Sert Center for Pub Affairs OEPAB- R. Kingery vr.i'^ —a zoT?^.ir.\. ?:izii ;vij-^;> zs ro: 3a rh^ r-:-3 -.r-_l p:cirj-_s of .•;ii: ;;;r.cy ■JMzy izz--- -cn '.D 5l:;".e ;rj,'rr ;.-;2 rais -.r.i zz-^cz :'i 'z-^, o:de: a: :^ula::ca -i:h whi;h /: -'HIS fcr:i AMD c:;e x:=ox copy '0 the deirlr.EhoLij ec :'_.•„.:: L-J^orrr:3::cn or 3-ii::o.-^J :_— e fo li:;: '^.zz 17 WOrkJnO C'cys irorr. the ds: 5 noi^ above. ;c :-.n: r. :-^ project csci ii i'_rpcr:j-d li -Ti::; .' ^\/l..<1 C-47 D-'. Tc'r — cr;. MEMORANDUM TO: Lynn Ford, Executive Assistant FROM: Sam Cohen, Tax Analyst DATE: December 7, 1977 SUBJECT: Strategic Petroleurr: Reserve, Title I, Part B, of the Energy Policy and Conservation Act of 1975 (P.L. 94- 163) AZ 77-80-0047 The Federal Energy Administration, Strategic Petroleum Reserve Office, V.'ashington, D.C. proposes to implement Title I, Part B, of the Energy Policy and Conservation Act of 1975 (Public Law 94-163. The purpose of the reserve is to mitigate the economic impacts of any future interruptions of petroleum imports. A study of the impact of envi; onmental aspect was made an^ the storage of 150 million barrels of oil by December 1978 and 500 million barrels of oil by Dc^cember 1982 is scheduled. The pro- gram under the lav; is essential for tlie energy problems that V7e are facing todcy and in the future. ITie Department of Revenue should have -Tio objections to tliis proposal and should be inclined to approve it. I^o Fcdcval funding approval has been requested. SC/ts C-48 State OF Florida Pl'^^:5;a ^Jf f^if^'' Srpartmpnt of AbmtntBtratiDn ocTi 01977 Division of State Planning 3 WhitUe. Jr Ri-upr-'ii) !SA!N(\. 660 ApalachM Parkway - IBM Builclin9 Tallahassee 32304 (904) 488-2371 TO: Harmons Shields' Dept. of Natural Resources Crown Bldg. Tallahassee, Fla. 32304 FROM: Bureau of Intergovernmental Relations SUBJECT : SAI : Ll. Gov. J. H. 'Jim- Wllllami ttCltTUT 0» WnikrlTIATIOH DATE: / ■c 'C^ - ' —7 --7 // DUE DATE: 'C C Please review and comment to us on the above draft Environmental Impact Statement, copy attached. In reviewing the statement, you should consider possible effects that actions contemplated could have on matters of concern to your agency. If you feel that a conference is needed for discussion of the project or resolution of conflicts, or if you have questions concerning the statement, please call Mr. Walt Kolb at (904) 488-2401. Please check the appropriate box below, attach any comments on your agency's stationery and return to this office or telephone "no adverse comments" by the above due date. On that date, we intend to consider all review comments received and develop a state position on the project. In both telephone conversation and written correspondence, please refer to the above SAI number. Sincerely. -^ Loring Lovell, Chief Bureau of Intergovernmental Relations Enclosure '^' Bureau of Intergoverimental Relations PROM: Department of Natural Resources SUBJECT: DEIS Review and Comments I x j No Comments r:ign.t -re: I4^,^^^,_^_^^ Title: _Arir-. ; lU r:t.rnt j vc Acsintant I j Coinments Attached Date; Oct. 19, 1977 C-49 Page 2 November 9, 1977 We request that you forward us copies of the final environmental impact statement prepared on this project. Sincerely, i Director R. G. Whittle, Jr. /.^^ RGWjr/WOK/ba Enclosure cc: Mr. Joseph W. Landers, Jr. Mr. Harmon Shields Mr. Loring Lovell Mr. Walter 0. Kolb C-50 LG WTiittle. Jr m PUI»MMC0MEC1OR State of Florida Srparlmrttt nf AbmtittBtratinn Division of State Planning 660 ApatachM Parkwray - IBM Building Tallahassee 32304 (904) 488-1115 Reubln O'D. Askew covc»NO< Lt. Gov. J. H. 'Jim* Williams MUtTMT or WHlMI(Tt«TIOM November 9, 1977 Strategic Petroleum Reserve Office Federal Energy Administration Washington, D. C. 20461 Dear Sir: Functioning as the state planning and development clearinghouse contemplated in U. S. Office of Management and Budget Circular A-95, we have reviewed the draft Supplement to the Final Environmental Impact Statement: Strategic Petroleum Reserve SAI 78-0658E During our review we referred the environmental impact statement to the following agencies, which we identified as interested: The Depart- ment of Environmental Regulation, the Department of Natural Resources, and the State Energy Office. Agencies were requested to review the state- ment and comment on possible effects that actions contemplated could have on matters of their concern. A letter of comment on the statement is enclosed from the Department of Natural Resources and the State Energy Office has indicated no comments on this document. Based upon our review of this document we have no comments at this time. However, we may wish to submit comments regarding this program at a future date. In accordance with the Council on Environmental Quality guidelines concerning statement on proposed federal actions affecting the environment, as required by the National Environmental Policy Act of 1969, and U. S. Office of Management and Budget Circular A-95, this letter, with attach- ments, should be appended to the final environmental impact statement on this project. C-51 STATE OF ILUNOtS EXECUTIVE OmCE OF THE GOVERNOR BUREAU OF THE BUDGET SPRINGFIELD S2706 November 28, 1977 Mr. Michael E. Carosella Associate Assistant Administrator Executive Communications Room 3309 Federal Energy Administration Washington, D. C. 20461 Dear Mr. Carosella: RE: Draft Supplement to the Final Environmental Impact Statement for the Strategic Petroleum Reserve (SPR) (FES 76-2), DEIS //77-09-301 Pursuant to the National Environmental Policy Act (NEPA) , 0MB Circular A-95 (revised) and the administrative policy of the State, the referenced subject has been reviewed by the appropriate State agencies. No comments were made on the referenced subject. Thank you for your assistance. Respectfully yours, T. E. Hornbacker, Director Illinois State Clearinghouse TEH:mc C-52 STATE OF IOWA Office for Planning and Programming 523 East 12th Street, Des Moines, Iowa 50319 Telephone 515/281-3711 3ERT D. RAY Governor ERT F. TYSON Director STATE CLEARINGHOUSE PROJECT NOTIFICATION AND REVIEW SIGNOFF ite Received: October 4, 1977 State Application Identifier: 770010 Review Completed: October 25, 1977 PLICANT PROJECT TITLE: "~~ — -aft Supplement to Final Environmental Impact Statement, Strategic Petroleum Reserve PLICANT AGENCY: Federal Energy Administration ~~ Address Washington, D. C. 20461 Attention: Michael E. Carosella DERAL PROGRAM TITLE, AGENCY Federal Energy Administration D CATALOG NUMBER: OUNT OF FUNDS REQUESTED; NA OJECT DESCRIPTION: ~ ~~ ■aft Supplement to the Final Environmental Impact Statement for Strategic Petroleum source, FES 76-2. e State Clearinghouse makes the following disposition concerning this application / X / No Comment Necessary. The application must be submitted as received by the Clearinghouse with this form attached as evidence that the required review has been performed. / / Comments are Attached. The application must be submitted with this form plus the attached comments as evidence that the required review has been performed. \TE CLEARINGHOUSE COMMENTS C-53 14 Rev. 9-75 Federal Funds Coord ina Robert D- Bell Secbetar» Julian M Carrol GOVCRMQO Commonwealth of Kentucky Department for Natural Resources and Environmental Protection Office of the Secretary Frankfort, Kentucky ^060i TtLEPMONE I502' BS^OaSO November 14, 1977 Executive Conmiunications Room 3309 Federal Energy Administration Washington, D.C. 20461 RE : Late Comments on the Draft Supplement to the Final Environmental Impact Statement on the Strategic Petro- leum Reserve (77-32) Dear Sirs: The enclosed comments were received by our office on the above mentioned Environmental Impact Statement. Even though these comments have arrived late, hopefully, they will be considered in the preparation of the Final Supplement on the Strategic Petroleum Reserve. Sincerely, Robert D. Be' Secretary dm Enclosure C-B4 RoBEBT D Bell SCC»CTA»T pr:OT:cT;D!-; 2iD?H*]7 C."'X£Or THE il'Ii'.LTARY Julian m Carboll Commonwealth of Kentucky Department for Natural Resources and Environmental Protection Bureau of Environmental Protection JOHN A. ROTH Commissioner Frankfort, Kentucky *o6oi MEMORANDUM October 18, 1977 TO: Environmental Review Office of Planning and Research THROUGH: John A. Roth, Commissioner Bureau of Environmental Pro'te^tion f^ROM; John T. Smither, Director Division of Air Pollution SUBJECT: 77-32, Draft Supplement to the Strategic Petroleum Reserve rnnf.nl n^ ^^ 5 "^IV ^"^ ^^^ ^^^"^ ^^"^^ ^^ ^^^ Kentucky Division of Air Pollution Control of the draft supplement to the FEIS for this Strategic Petroli Reserve. leum adrlit.-nn.i ^nn S K ^""^"^ "^^^l "°^ Identify the specific site where these add tonal 500 MM barrels of crude petroleum will be stored. We will certainly wfi hf- to know If storage capacity at Central Rock Mine (Fayette County) will be increased from 14 mm barrels. Also, we would like to know if the terfiiinal capacity at Tates Creek will be increased. ^, . . ^ In spite of good objectives associated with the SPR, the amount of hydrocarbon emissions throughout SE U.S.A. will delay attainment of the photochemical oxidant standards. statement. OTS:PD:kl We thank you for giving us the opportunity to review this n 7 o -. - 1^ yjj 'u !1, ■ C-55 State of Missouri Jojeph P. Tuidale OFFICE OF ADMINISTRATION Cry 0. Piamor., Director Governor Jefferson City 65101 Drvision of Budget ar>d Planning November 8, 1977 Mr. Michael E. Carosella Associate Assistant Administrator Special Programs Strategic Petroleum Reserve Executive Communications Room 330 9 Federal Energy Administration Washington, D. C. 20461 Dear Mr. Carolsella: Subject: 77100026 The Division of Budget and Planning, as the designated State Clearinghouse, has coordinated a review of the above referred draft environmental impact statement with various concerned or affected state agencies pursuant to Section 102(2) (c) of the National Environmental Policy Act. None of the state agencies involved in the review had comments or recommendations to offer at this time. We appreciate the opportunity to review the statement and anti- cipate receiving the final environmental impact statement when prepared. Sincerely, George Lineberry Chief, Grants Coordination ^1^ C-56 .-^''■><^- €'lqtf of Npui dlrrspy DEPARTMENT OF COMMUNITY AFFAIRS PATRICIA Q. SHEEHAN 363 WEST STATE STREET COMMISSIONER POST OFFICE BOX 2768 October 27, 1977 trenton. n.j. 08625 Mr. Michael E. Carosella Associate Assistant Administrator Special Programs Strategic Petroleum Reserve Federal Energy Administration Washington, D,C. 20461 RE: OSRC-FY-78-333 Dear Mr. Carosella: In accordance with the U.S. Office of Management and Budget Circular A-95 Revised, your Environmental Impact Statement for Strategic Petroleum Reserve designated application OSRC-FY-78-333, has met the State of New Jersey's Clearinghouse requirements. We have circulated this Project Notification to the appropriate State agencies, none of which have voiced any objections. Very truly yours, /ilicTiard k.^i/cSLaxi ^ State 'K&vi.&lfjtooTdf^ij&T RAG:br ^ C-57 •TATE or NCVADA GOVERNORS OFFICE OF PLANNING COORDINATION Capitol Building, Room 4B C/kPiTOL Complex Carson City. Nevada 89710 (702) eaB-4ees November 15, 197 7 Executive Coininunications Room 3309 Federal Energy Administration Washington, D.C. 20461 RE: SAX NV #78800020 - Draft Supplement to the Final EIS Strategic Petroleum Reserve Gentlemen: Thank you for the opportunity to review the above mentioned project. The State Clearinghouse has processed the Environmental Im- pact Statement and has no comment. Based on the information contained therein and the responses of interested parties, the proposal, as of this date, is found not to be in conflict with the State's plans, goals, or objectives. Sincerely, Bruce D. Arkell State Planning Coordinator BDA/pf C-58 STATE OF NEW MEXICO STATE PLANNING OFFICE LEILA ANDREWS STATE PLANNING OFICER GREER BUILDING 505 DON GASPAR AVE. SANTA FE 87503 (505) 827-2073 JERRY APODACA GOVERNOR November 18, 1977 Executive Communications Room 3309 Federal Energy Administration Washington, D. C. 20461 Gentlemen: Thank you for the opportunity to comment on the Strategic Petroleum Reserve draft environmental impact statement. We have sent copies of the statement to the following State agencies: Environmental Improvement Agency, Energy Resources Board, and Public Service Com- mission. Comments are enclosed from the Environmental Improvement Agency. Since the reserve would not be stored in New Mexico, and at this point, would not be transported through New Mexico, we have no comment Sincerely, Kate Wickes Resources Planning KW:JEH Enclosure C-59 eia: wauei ^UMUtiuti •'dridyemerit dnu cvatuaiion aeutiun State of New Mexico 'U HEALTH and SOCIAL SERVICES DEPARTMENT To: . Kate Wickes, S.P.O. From: Charles A. Marque z^^i^^vw^-^ MEMORANDU Date: 11-07-: RE: Draft Supplement to the FES Strategic Petroleum Reserve Subject: This proposed action will not, in its present form, affect New Mexico directly. None of the oil would be stored any closer tc New Mexico than Texas (Gulf Coast) or Louisiana (East Coast). Therefore, we have no comments at this time. r-fin North Carolina Department of Administration ^ 1 16 West Jones Street Raleigh 27603 lames B. Hunt, Jr., Governor loseph W. Grimsley, Secretary Division of Policy Development Elmer Johnson, Administrator (919) 7334131 November 4, 1977 Mr. Michael E. Carosella Associate Assistant Administrator Special Programs Strategic Petroleum Reserve Executive Communication, Room 3309 Federal Energy Administration Washington, 5. C. 20461 Dear Mr. Carosella: Re: SCH Fi le No. 167-77; Draft Supple- ment to the Final EIS Strategic Petroleum Reserve The State Clearinghouse has received and reviewed the above referenced projrct. As a result of this review, the State Clearinghouse finds that no comment is necessary on this project at this time. Sincerely, Chrys Baggett (Mrs) Clearinghouse Supervisor CBtmw C-61 NOriH DAKOTA STATE PLANNING DIVISION ST/.'l CAf- 1C;. — NIMH FLOOR — BISMARCK, NORTH OAKOTA66SC5 701-224-2818 November A, 1977 STATE INTERGOVERNIIENTAL CLEARINGHOUSE "LETTER OF COMMENT" ON PROJECT REVIEW IN CONFORMANCE WITH OMB CIRCULAR NO. A-95 To: Federal Energy Administration STATE APPLICATION IDENTIFIER: 7710069836 Mr. Barton R. House Deputy Assistant Administrator for Operations Federal Energy Administration 2000 M Street, mi Washington, D.C. 20461 Dear Mr. House: Subject: Draft Supplement to the Final Environmental Impact Statement by the Federal Energy Administration for Strategic Petroleum Reserve. This Draft EIS was received in our office October 6, 1977. In the process of the A-95 review, the attached comments were received from the Attorney General's Office and OT Geological Survey. This document and attachment constitute the comment of the State Inter- governmental Clearinghouse, made in compliance with OMB Circular No. A- 95. The ND State Intergovernmental Clearinghouse requests the opportu- nity for complete re-review of applications for renewal or continuation grants or applications not submitted to or acted on by the funding agency within one year after the date of this letter. Sincerely yours, !lrs. Leonard E. Banks Associate Plaimer LEB/niTn Attachment C-62 NDSiC ^ORM B (9/71) PROM: STATE INTERGOVERNMENTAL CLEARINGHOUSE STATE PLANNING DIVISION STATE CAPITOL BISMARCK, NORTH DAKOTA 58501 TO: ENVIRONMENTAL IMPACT STATEMENT TO BE REVIEW^ED Mr. Gary Helgeson Attorney General's Office State Capitol ISSUED gy. Federal Energy Administration PNRS NO. Date Recei- /O- /* DATE: October 11, 1977 NAME OF PROJECT: Draft Su pplement to the Final ETS for Strategic Petroleum Kpsf^ry^ The attached Environmental Impact Statement is referred to your agency for review and possible comments. If you consider it satisfactory, please check the box labeled, "no comment." Otherwise, please check one of the other appropriate boxes. Your cooperation is asked in completing this memo and returning it to the State Intergovern- mental Clearinghouse within 10 days from date of receipt. If no response is received within 15 days of date of notification it will be assumed you have no comment. comment LsS^o comm \ I Comments submitted herewith I I Meeting desired with applicant 1. Specific comments which are to be attached to the review statement which will be submitted by the State Intergovernmental Clearinghouse: ( Use r everse side or separate sheets if necessaryJVV^^^ (.^p^^^^^^^f^^^ ^^ . 2. Reasons why meeting is desired with applicant: C-63 Reviewer's Signature: Title: Date Tele; FROM: STATE INTERGOVERNMENTAL CLEARINGHOUSE STATE PLANNING DIVISION STATE CAPITOL BISMARCK, NORTH DAKOTA 58501 TO: ENVIRONMENTAL IMPACT STATEMENT TO BE REVIEWED Mr. Erling Brostuen iNU t»eoiogicai survey UND Grand Torkj. ?ID 50201 ISSUED BY: Federal Energy Administration Date Rece 'Oo ^ATE: Orfnhpr IT, 1Q7_7_ NAME OF PROJECT: Draft Supplement to the Final EIS for Strategic Petroleum Reserve The attached Environmental Impact Statement is referred to your agency for reviev^ an< possible comments. If you consider it satisfactory, please check the box labeled, "no comment." Otherwise, please check one of the other appropriate boxes. Your cooperation is asked in completing this memo and returning it to the State Intergoverr mental Clearinghouse within 10 days from date of receipt. If no response is receivec within 15 days of date of notification it will be assumed you have no comment. D No comment L_J Comments submitted herewith I — I Meeting desired with applican . Specific comments which are to be attached to the review statement which will be submitted by the State Intergovernmental Clearinghouse: (Use reverse side or separate sheets if necessary) The masoive s?lt beds of the -iiliiston Basin sho^old be considrred as alternative sites for solution salt cavity storage of the SPR. This would help to insure crude availabiUty to the northern tier refineries 2. Reasons why meeting is desired with applicant: Reviewer's Signature: Title: Geoloplst/ ■u^ Date: Q.^/ Z^^/ Tele: C-64 ;.V ST STATE OF OKLAHOMA State Grant-ln-Aid Clearinghouse 5500 N WESTERN OKLAHOMA CITY, OKLAHOMA 73118 November 4, 1977 (405) 840-2811 Executive Communications Room 3309 Federal Energy Administration Washington, D. C. 20461 RE: 05J704- -Draft Supplement to the final environmental impact statement for the Strategic Petroleum Reserve Dear Sir: The environmental information for the above referenced project has been reviewed in accordance with 0MB Circular A- 95 and Section 102 (2) (C) of the National Environmental Policy Act by the state agencies charged with enforcing environmental standards in the State of Oklahoma. The state agencies, comprising the Pollution Control Coordinating Board, have reviewed the proposed project and agree that no adverse environmental impact is anticipated. Therefore, the state clearinghouse requires no further review. ■incerely , Don N. Strain Director DNS:mt C-65 eOBEPT ^ STBAUB Executive Department INTERGOVERNMENTAL RELATIONS DIVISION ROOM 306, STATE LIBRARY BLDG.. SALEM, OREGON 97310 December 5, 1977 Michael E. Carosella Associate Assistant AcMinistrator Special Programs Strategic Petroleum Reserve Federal Energy Administration Washington, D.C. 20461 Dear Mr. Carosella: RE: Strategic Petroleum Reserv PNRS 7710 4 140 Thank you for submitting your draft Environmental Impact Statement for State of Oregon review and comment. Your draft was referred to the appropriate state agencies. The consensus among reviewing agencies was that the draft adequately described the environmental impact of your proposal. We will expect to receive copies of the final statement as required by Council of Environmental Quality Guidelines . Sincerely, ^ Donald L. Jones Administrator DLJ : cb C-66 STATE PLANNING BUREAU State Capitol Pierre, South Dakota 57501 605/224-3661 '7f^% •LV Office of Executive monogement November 14, 1977 The Strategic Petroleum Reserve Office Federal Energy Administration Washington, DC 20461 RE: Draft Supplement to the Final Environmental Impact Statement (EIS 040278); Strategic Petroleum Reserve Dear Sir: The State Clearinghouse has distributed for review the above stated draft EIS. The attached comments were received from the Department of Health. Please supply any information you might have relating to his request to: Mr. Ed DeAntoni, Secretary South Dakota Department of Health Foss Building Pierre, SD 57501 (605) 224-3361 Thank you for the opportunity to review and comment on the statement . Sincerely , \ i > ^.,. Steve Merrick Commissioner STATE PLANNING BUREAU jrv Enclosure cc: Ed DeAntoni C-67 Tennessee Valley Authority CHATTANOOGA. TENNESSEE 37401 268 401 Building December 6, 1977 Mr. Michael E. Carosella Associate Assistant Administrator Special Programs Federal Energy Administration Washington, DC 20461 Dear Mr. Carosella: We have reviewed several specific draft and final environmental Impact statements on this subject and rather than addressing each, we will make a generic comment as follows: Our interests in the Strategic Petroleum Reserve Program stems from the possibility of eventual materials storage in salt domes. As we stated in comments on the generic final environmental statement, the salt domes under construction are generally not favorably located for radioactive material storage sites. The Department of Energy (formerly ERDA) has selected sites for investi- gation and has initiated test drilling for radioactive material storage sites. We expect that DOE has chosen the most suitable sites in the Gulf Coast area. Provided that sites are selected from the area covered by the generic and site specific examinations, we anticipate no conflict with national goals. Sincerely, i i ^/Jiarry G. Moore, Jr., Ph.D Acting Director of Environmental Planning C-68 An Equal Opportunity Employer ?# OFFICE OF THE GOVERNOR DOLPH BRISCOE GOVERNOR November 2, 1977 Mr. Michael E. Carosella Associate Assistant Administrator Special Programs Executive Communications Room 3309 Federal Energy Administration Washington, D.C. 20A61 Dear Mr. Carosella: The Draft Supplement to the Final Environmental Impact Statement - Strategic Petroleum Reserve has been reviewed by the Budget and Planning Office and interested State agencies. The comments of the reviewing agencies are enclosed for your use in the preparation of the final supplement to the environmental impact statement. If this office can be of further assistance, please contact us. Sincerely, Afff^ Arcryt Roy Hogan, Assistant Director Budget and Planning Office Enclosures C-69 FYPn ITIVP rtFPirp Rl III niMn • ^11 IA/CCT IITU CTOCCT • akctim -rcvAClo->n< TEXAS DEPARTMENT OF AGRICULTURE REAGAN V. BROWN. COMMISSIONER / P. O. BOX 12847 / AUSTIN. TEXAS 78711 AN EQUAL OPPORTLTMITY EMPLOYER MEMORANDUM DATE: October 21, 1977 TO: Ward C. Goessling^ Jr. FROM: Ray Prewett KtCtlvtt OCT U 1977 Budget/Pianninp RLl Draft Supplement to the Final Environmental Impact Statement- Strategic Petroleum Reserve We have reviewed the Draft Supplement to the Final Environmental Impact Statement: Strategic Petroleum Reserve. With regards to the selection of future SPR sites, we support the Idea that a careful review should be made to ^void taking of unique or prime agricultural land. In general, however, we believe the benefits from the SPR will outweigh the costs; we therefore, offer no objections to the proposed expansion. C-70 COMMISSkONf HS pfiARCE JOHNSON Ch»"m»r\, Austin JOE X. FULTON Vicc-Chairrrxn Lubbock JOHN M. GREEN Beaumont Texas Parks and Wildlife Department October 28, 1977 HENRY B BURKETT EXECUTIVE DIRECTOR 4?00 Smith School Road Austin. Texas 78744 BECEfVtt m Si Budge!/,,. . ,' COMMISSIONERS LOUIS H, STUMBERG San Antonio JAMES R. PAXTON Palestine PERRY R BASS Foft Worth Mr. Ward C. Goessling, Jr., Coordinator Natural Resources Section Governor's Budget and Planning Office Executive Office Building All West 13th Street Austin, Texas 78701 Re: Draft Supplement Environmental Impact Statement - Strategic Petroleum Reserve Dear Mr. Goessling: This agency has reviewed the document cited above, and offers the following comments for consideration by the Federal Energy Administration. Because of the large scope of operations under the program, the draft supplement addresses impacts in a necessarily general manner. Future preparation of "Environmental Action Reports" on specific sites is mentioned on page VI-38, however. Since it is anticipated that these reports will contain detailed information, and proposed procedures for construction and operation of each site, review and comment upon the reports would be desirable. In regard to alternative brine disposal techniques for use In the Texas coastal area, It is reconmended that injection of the brine Into sub- surface aquifers be utilized to the maximum possible extent in order to minimize discharges to surface waters or the Gulf of Mexico. The opportunity to review and comment upon this document is appreciated. Sincerely, ■MRY B/*URKETT Executive Director HBB:BDK:lmw /fjU^''' C-71 nAn> ni.l',\KI.MIM Ol WATLR Kl SOI K( I S 17(11) N ( ..ii.i.ss Amiiiu- TKXAS WAIKR l)i:\ r.l.OI'MI M IIOAKI) . A. L. r.Ijck.fi, . :•....,. Robert 13. Gilino!r.\ i,. ( •, r .. Millor T. I'.i'i. John H. ('.:i'Tci< (.corn U . M.(:K-..ki ) Clrn I., ktiiu \ V(^; f'li.irli-^ I \'i nut I v.- :l.v. Ml.. . • ■ A t October 20, 1977 Mr. Charles D. Travis, Director Governor's Budget & Planning Office Executive Office Building 411 West 13th Street Austin, Texas 78701 II XASWAII H (()M\t|SS|()\ I.T M (.,.!,.. ,,., D'UNCN l>. H.irJiiii.,11 J.x K. Cm, .11 RECEIVE! OH" 26 197? Re: Federal Energy Administration -- Draft Supplement to the Final Environ' mental Impact Statement -- Strategic Petroleum Reserve (FES 76-2), September 1977. Dear Mr. Travis: In response to your October 6th memorandum, the Texas Depart- ment of Water Resources staff has reviewed the referenced draft document on the potential incremental environmental impacts of the proposed expansion of the Federal Strategic Petroleum Reserve Project storage capacity from 500 million barrels (MMB) to 1,000 MMB by 1982. The federal Energy Policy and Conservation Act of 1975 (EPCA). Title I, Part B, Strategic Petroleum Reserve (SPR), provided for the creation of strategic reserves. The SPR development schedule established in the EPCA and addressed in both the SPR Plan which was effective on April 18, 1977, and in the related Final Environ- mental Impact Statement of December 1976, provided for the storage of 150 MMB of oil by December 1978 and 500 MMB by December 1982. However, under SPR Plan Amendment #1, which became effective on June 21. 1977, ' the development schedule was accelerated to store 500 MMB of oil by the' end of 1980. To date, the major areas considered for the Federal storage project are the Gulf Coast Region (for storage of crude oil in salt dome formations and, the East Coast Region (for storage of refined petroleum and petroleum products). C-72 I' < ) II. iv I i(IK,' ( ..|,ii..l Si AllMIH I . V , /K ' I I \.. . ' ■■.I. '.| >jA /s uh; m^ii^f^^J^SS^ff^^^JSS^-.^^ Mr. Charles D. Travis October 20, 1977 Page 2 Our review of the -referenced document is restricted to the portions which pertain to the storage sites located in the State of Texas, and to matters within the purview of our agency statutory responsibilities involving State water. The followmg technical staff review comments are offered: 1, The 65th Legislature of the State of Texas consolidated the Texas Water Quality Board, the Texas Water Development Board, and the Texas Water Rights Commission, creating the Texas Department of Water Resources, effective September 1, 1977. Based on our current analysis, we confirm the review comments made by the three pre-merger agencies relative to the Federal Energy Administration's Draft Environmental Impact Statement, Strategic Petroleum Reserve DES76-2, dated June 1976. These comments were transmitted by letter of September 20, 1976 from the Office of the Governor to the Federal Energy Administration. Indications are that the Federal Energy Administration has given and will continue to give consideration to earlier review comments. Specifically, statement is made in Section V. A. 1. a. (Gulf Coast Region, Coastal Subregion, Geology), page V-2 of the referenced document that important generic geological concerns, including subsidence, seismic stability, and engineering stability were discussed in detail in the Final Environmental Impact Statement (FES 76-2) of December 1976. In addition, statement is made in Section V. A. 1. b (Gulf Coast Storage Region, Coastal Sub- region, Hydrology and Water Quality), page V-2, -3 that a discussion of the analyses performed to determine the impacts of brine disposal in the Gulf of Mexico was included in FES 76-2, and that this work recently was supplemented with modelling efforts performed by the National Oceanic and Atmospheric Agency for the Federal Energy Administration. And, the results of these supplemental, additional study efforts are said to support the results reported in FES 76-2. The sub- sequent two comments are to provide necessary emphasis and elaboration on previous review comments submitted by the pre- merger water agencies of Texas. C-73 Mr. Charles D. Travis October 20, 1977 Page 3 2. (Reference Section V. A. 1. b. . pages V-2. -3. ) --We wish to emphasize that -one of the major water quality policies of the State has been to disallow any direct discharge of brine into the State's waters. This policy is particularly applicable to any proposed brine discharges within the State's three -league seaward boundary and especially to estuaries having fish and shellfish nursery areas. Therefore, we support the Federal Energy Administration's rigorous efforts to explore all viable methods of brine disposal including usage by local industry, deepwell injection, and disposal to the Gulf of Mexico. And, we concur that final site-specific brine disposal method determinations should be based on the geographical location of the site with respect to the Gulf of Mexico, the proximity of saline aquifers, estuarine productivity, and relative costs of alternative brine disposal methods. 3. (Reference: Section V. A. 1. b. , page V-3, and Section VIII. B. . pages VIII-2, and -3. ) -- The report duly notes that the large quantities of surface water (i.e. , approximately 183 billion gallons of water from the area during construction of the c&vities and up to 25 billion gallons during displacement operations) required for the construction and operation of storage caverns in salt domes is a significant concern. Further, the report notes that there are ". . .few undedicated fresh surface water supplies in the Gulf Coast region. ... In view of the foregoing findings, we reiterate one of our early comments made relative to DES 76-2, June 1976 that a -special analysis of project impacts on vested surface water rights be prepared. We appreciated the opportunity to review and comment on the referenced document. Please let me know if you believe we can be of further assistance. rely. Charles E. Actin:T Executive rector C-74 COMMONWEALTH of VIRQINIA 903 NINTH S R November 1, 1977 804786^500 SUSAN T. WILBURN rrtlinril nn thp Fnvirnnmpnt 903 ninth street OFFICE BUILDING ACTING ADMINISTRATOR ^^vuntii UH ifit: E^nvirunrricni Richmond 23219 Mr. Michael E. Carosella Associate Assistant Administrator Special Programs Stretegic Petroleum Reserve Federal Energy Administration Washington, D. C. 20461 SUBJECT: Strategic Petroleum Reserve Dear Mr. Carosella: The Virginia Council on the Environment has completed its review of the subject Supplement to the Draft Environmental Impact Statement. The following State agencies participated in that review: State Water Control Board State Department of Health Soil and Water Conservation Commission Department of Conservation and Economic Development Virginia Energy Office Based upon our review of the document and the comments that we received, we have no objections to the proposal at this time. With respect to the environmental impact of such implementation, the poten- tial problems in this area do not seem to be of such gravity as to outweigh the considerable advantages to be gained by establishing a strategic petroleum reserve. Although the establishment of a strate- gic petroleum reserve would not be a panacea for the present poten- tially very serious situation, it would help to lessen considerably the effects of future interruptions of petroleum imports. We would recommend that reasonable steps be taken to mitigate any adverse im- pacts that might occur. Thank you for the opportunity to review this document. If you have any questions, please do not hesitate to contact me. Sincerely, Susan T. Wilburn STW:RFW:dja C-75 cc: Honorable Earl J. Shiflet, Secretary of Commerce and Resources Mr. J. Boyd Spencer, Virginia Energy Office JOHN D. ROCKEFELLER IV GOVERNOR STATE OF WEST VIRGINIA GOVERNORS OFFICE OF ECONOMIC AND COMMUNITY DEVELOPMENT CHARLESTON 2530^ DONALD D MOVER DtRECTOR DANIEL S GREEN MANAGER PROGRAM SUPPORT SERVICES October 19. 1977 File: PNRS-F Mr. Michael E, Carosella Associate Assistant Administrator Special Programs Strategic Petroleum Reserve Executive Communications Room 3309 Federal Energy Administration Washington, DC 20461 Re: Federal Energy Administration - Strategic Petroleum Reserve - Draft Supplement to the Final Environmental Impact Statement Dear Mr. Carosella: Receipt is acknowledged of the Draft Supplement for the above referenced project. The State Clearinghouse has reviewed this document in accordance with provisions of the National Enviromental Policy Act of 1969 (Public Law 91-190) and Guidelines of the Council on Environmental Quality, and has no comments. Sincerely, I 1 icereiy, /'^ Daniel S; Green Manager Program Support Services DSG:am cc: Donald D. Moyer C-76 ^0 National Wildlife Federation 1412 16TH ST., N W., WASHINGTON, DC 2CX)36 Pnonp 202—797-6800 November 14, 1977 Executive Communications Room 33 09 Federal Energy Administration VJashington, D.C. 20461 Re: Comments of the National Wildlife Federation on "Draft Supplement to the Final Environmental Impact Statement" on Strategic Petroleum Reserve, FES 76-2 (Sept. 1977) To Whom It May Concern: The comments of the National Wildlife Federation ("NWF") on the Draft Supplement to FES 76-2 fall into the following areas of concern: 1) That the Draft understates the risks of oil spill damage to sensitive wetlands in connection with use of Gulf Coast salt domes; 2) That the Draft understates the advantages of inland sal.t domes as a means of minimizing such risks; and 3) That the Draft reflects no willingness to consider deferring further commitment of resources to not-yet-developed coastal salt domes, pending fuller consideration of inland alternatives. 1. Wetland Damage Associated With Coastal Salt Domes The Draft considers oil spill risks at pp. V-42 - V-76 (as well as in Appendix A) . Although implicitly recognizing that oil spill risks and impacts may depend more upon the location of the spill than upon either the frequency or magnitude of spillage, the Draft makes no attempt to assess the overall hazard potential associated with various spill locations, or to coir.pare ard contrast these potentials in connection with inland versus coastal SPR storage sites. Indeed, even in terms of estimating the frequency (incorrectly equated with "risk" in Table V-12) of oil spills in various "impact areas," the Draft is very misleading. For exam.ple, the analysis at pp. V-4 5 - V-48 assumes that oil spills affecting Gulf Coast wetlands will all be associated with "pipelines connecting a storage site with a marine terminal." Since the spill frequency for pipeline transport is the lowest of all transport modes, this assumption permits transport-associated oil spillage in wetlands to be C-77 National Wildlife Federation Executive Comnittee .November 14, 1977 Page Two shrugged off as "small" (i.e., "0.1 gallons spilled per 1,000 MMB transporter'"). What is obscured by the analysis, however, is the fact that -transport in *'Ihlarbors and inland waters of the U.S. Gulf Coast including the Channels connecting the harbors v;ith the sea and the storage site" elso has major potential for wetland-impacting oil spillage (depending upon the ease of water exchange between the spill' site and adjacent wetlands). The Final Supplement should, therefore, attempt an overall assessment (preferably employing worst-case assumptions) of the oil spill hazard potential (with special emphasis on wetland and estuarine impacts ) associated with coastal and inland SPR storage sites. Incidentally, the estimated incidence of a major spill for pipeline accidents in inland areas of the Gulf Coast is incorrectly stated (at V-47) to be ''0.1 gallons spilled per 1,000 MMB transported"; the correct figure (from Table V-12) would be either "0.1 MMB per 1,000 MMB transported," or "0.1 gallons per 1,000 gallons transported." 2. Advantages of Inland Versus Coastal Salt Domes The Draft discusses the feasibility of oil storage in salt domes of the inland Gulf Region (i.e. , northern Louisiana and southern Mississippi) at pp. III-3 - III-7, V-31 - V-37, and V-59. However, while the Draft notes numerous potential problems with such inland sites (e.g., III-5 : increased risk of oil spills for certain barge transits; V-31: increased construction and inaintenance costs associated with construction of additional pipelines, and increased potential for ship casualties; V-32: brine disposal would be a serious problem in northern Louisiana; V-34 - V-35: deep well injection of brine in northern Louisiana would probably require the use of slower injection rates, more injection wells, and a larger injection field) , it inappropriately fails to emphasize the considerable environmental advantages attendant upon use of inland versus coastal salt domes in the Gulf Region. Thus, the Draft notes (at V-35) that ''[t]he only differences [between inland and coastal salt domes] involve the type of habitat where the activities would occur" (emphasis added) and that " [d]redging impacts [at inland domes] would be somewhat lessened as less wetlands habitat would be disturbed than in coastal regions." In fact, the potential for adversely impacting sensitive and ecologically critical wetland areas may be drastically less with use of inland rather than coastal salt dome storage sites. Not only would construction activities associated with wetland-poor inland sites involve far less disturbance of wetlands than for wetland-rich coastal areas, but one might expect oil spillage associated with handling and transport to result in less contact with and impact on wetlands for inland as opposed to coastal salt dome locations. Accord- ingly, the Final Supplement should take pains to contrast in some detail the nature, number, and distribution of wetlands in association with C-78 itional Wildiife Federation xebutive Comirdttee Dv ember 14, 1977 age Three iland versus coastal Gulf Coast salt domes. It should also examine Losely the opportunities for impacting wetlands associated with irious inland and coastal alternatives. (This analysis should seek, 5r example, to distinguish risks to wetlands associated with water- )rne transport of oil in a waterway such as the Mississippi River, which ; largely isolated from adjacent wetlands by dikes, from those presented 1 other inland waterways where the opportunity for exchange with wet- mds may be much greater) . This analysis, and the remaining discussion of the inland salt )me alternatives, would be greatly aided by a better map than that mnd in the Draft at p. III-6. In particular, a map should be •ovidec which shows the location of each of the following, in addition » the other information found in Figure III-l: the Exxon pipeline, ipline, the port of St. James, Vicksburg, Vidalia, Old River, Red ver, Ouachita Black River, Gulf Intracoastal Waterv/ay. Each of these ;em£ is mentioned on pp. III-4 - III-5, but is nowhere to be found on le accompanying map. The discussion of ^'Mitigating Measures" (beginning at p. VI-1) 'Uld, similarly, greatly benefit from a discussion of reduced wetland sses associated v.rith increased reliance on inland salt dome storage tes. As the Draft states (p. VI-2), "ecological impacts can be tigated by selecting sites ... away from highly productive wetlands .. Irreversible and Irretrievable Commitment of Resources to Coastal Salt Do me Sites Although NWF is pleased that the Draft Supplement addresses inland It dome sites in Northern Louisiana and southern Mississippi, we are stressed that such consideration has come so late in the game. Of en greater concern is the prospect that work at coastal salt domes is oceeding so rapidiy that the opportunity for minimizing the use of ch domes in favor of more inland sites will be correspondingly limited foreclosed. We appreciate the strategic desirability of implementing large SFR at the earliest possible time. However, we firmly believe at the potential for seriously damaging the vital coastal wetlands Louisiana and Texas (as an unintended side-effect of the SPR program) sufficiently great as to justify slowing the program's pace to the tent necessary to permit maximum possible use of inland salt domes for much as possible of the proposed storage reserve. Major resource nimitments have already been made to several coastal salt dome sites. C-79 National Wildlife Federation Executive Corrjr.ittee November 14, 1977 Page Four We strenuously urge (and we believe NEFA requires) that conunitments to additional coastal sites be withheld until the evaluation of inland salt dome alternatives has been completed. The opportunity to present these views is appreciated. Sincerely, l(:L^jM.lkiJL^ Kenneth S. Kamlet Counsel cc: Mr. Michael F. Carosella (By Hand Deliver 11/14/77) Associate Assistant Administrator Special Programs Strategic Petroleum Reserve Federal Energy Administration Washington, D.C. 20461 Clinton Spotts EPA Region VI Al Aim Dept. of Fnergy Sandra Rennie Dept. of Energy C-80 UNIVEHSrrv of ILUNOiS-URBANA 3 0112 075681160 c ^9 3 S3 CO O 9 C = 3 S Do » O -* £31 • 3D a o CO 0) S > DC 3> g ^