By: Yardena Mansoor and Carolyn Osborne, Office of NEPA Policy and Compliance
The Department of Energy (DOE) accommodated new information and changed circumstances throughout preparation of its environmental impact statement (EIS) for expansion of the Strategic Petroleum Reserve. This allowed Secretary of Energy Samuel W. Bodman recently to select a new site for development – at Richton, Mississippi – and two existing sites for expansion – at Bayou Choctaw, Louisiana, and Big Hill, Texas.
As unforeseen situations presented themselves, DOE adapted its process and analysis. A new site was proposed at the end of a scoping period already protracted by the hurricanes of 2005. In the course of EIS preparation, geotechnical studies indicated that one of the candidate new sites was unreasonable, one expansion site was slated for commercial use, and new combinations for expansion of existing sites were identified to better serve the Reserve’s mission. Also, DOE made design changes related to the Richton site to protect endangered species and critical habitat.
The EIS process allowed us to adapt efficiently and effectively to changes affecting the alternatives, and it facilitated our decisionmaking. – David Johnson, Director, Planning and Engineering Strategic Petroleum Reserve, Office of Fossil Energy
Energy Policy Act of 2005 Directed Strategic Petroleum Reserve Expansion
The Strategic Petroleum Reserve, a national stockpile of crude oil, was established following the 1973–74 oil embargo to protect the United States from interruption in petroleum supplies that would be detrimental to our energy security, national security, and economy. The current storage capacity is 727 million barrels in underground caverns in rock salt formations at Bayou Choctaw and West Hackberry, Louisiana, and Big Hill and Bryan Mound, Texas.
The Energy Policy Act of 2005 directed DOE to select sites necessary to enable acquisition of the full authorized volume of the Reserve (1 billion barrels). DOE was to select from among sites previously studied, with preference given to the five sites assessed in a 1992 draft EIS, and from other sites proposed by a state where a site has been previously studied by DOE. (In his State of the Union Address on January 23, 2007, the President proposed an expansion of the Reserve to 1.5 billion barrels. Any DOE proposal in this regard is independent of the current expansion to 1 billion barrels and would be subject to a separate NEPA review process.)
In developing the range of reasonable alternatives for the EIS, DOE first considered expanding existing storage sites to capitalize on existing infrastructure and then considered new sites to add 273 million barrels of storage capacity to reach the 1-billion barrel goal.
Storage capacity at new and expansion sites would be created in underground salt domes through solution mining (that is, using water to dissolve the salt) and disposing of the resulting brine by ocean discharge or underground injection. New pipelines, marine terminal facilities, and other infrastructure would be required. Proposed construction and operation activities include clearing and preparing sites; constructing pipelines and facilities for raw water intake, brine disposal, and crude oil distribution; constructing transmission lines to provide electrical power to the sites; and constructing or augmenting support buildings and other facilities.
EIS Process Accommodates Hurricane and Additional Alternative Site
In its Notice of Intent to prepare the EIS, DOE proposed to expand storage capacity at existing sites at Bayou Choctaw, Big Hill, and West Hackberry (up to an additional 30, 108, and 15 million barrels, respectively) and to develop one new storage site with a capacity up to 160 million barrels at either Clovelly or Chacahoula, Louisiana; Stratton Ridge, Texas; or Richton. Following the scoping period that was to extend from September 1 to mid-October 2005, DOE planned to issue the draft EIS in early Spring 2006 and complete the EIS process in August 2006 as directed by the Energy Policy Act.
Due to the regional impacts of Hurricane Katrina, DOE extended the scoping period and rescheduled scoping meetings. Near the end of the revised scoping period, the Governor of Mississippi proposed the Bruinsburg site for DOE’s consideration, and DOE reopened the scoping period with an additional scoping meeting. DOE adjusted its planned EIS schedule to consider the new site.
Candidate Site Shown Unreasonable Between Draft and Final EIS
After issuing the draft EIS, DOE completed additional geotechnical studies of the suitability of the salt dome at Clovelly. Because of the salt dome’s hourglass shape and small size, DOE’s conceptual design was to place new caverns below and in between existing commercial caverns at the site. Additional geotechnical studies showed that this configuration would pose risks to the integrity of the existing caverns, infrastructure, and overall operation of the site. DOE concluded that its development for the Reserve is not feasible, and thus not reasonable, and did not analyze it in the final EIS. DOE also deleted from the final EIS the analyses of existing site expansions that had been proposed in combination with Clovelly. One of these combinations included expansion of Bayou Choctaw by 30 million barrels, which DOE later found desirable to reconsider, as discussed below.
Conceptual Design for Water Use Changed in Response to Comments
During the public comment period for the draft EIS, the U.S. Fish and Wildlife Service, Mississippi Natural Heritage Program, Gulf Restoration Network, Sierra Club Mississippi Chapter, and others expressed concern about the proposed withdrawal of water from the Leaf River, which would be used in solution mining to create storage caverns at the Richton site and later for removal of the stored oil from the caverns (drawdown). As commenters emphasized, the river has a highly variable but frequently low flow rate, and water withdrawal during certain low- flow conditions may adversely impact protected species.
DOE consulted with the U.S. Fish and Wildlife Service and the Mississippi Natural Heritage Program to identify other sources of fresh water. When this effort did not succeed, DOE modified the Richton alternatives in the final EIS to reduce dependence on the Leaf River by adding water from the Gulf of Mexico as a secondary water source. To do so, in the final EIS DOE proposed a larger pipeline that would allow transport of sea water to Richton during periods of low flow in the Leaf River for cavern creation, albeit at a slower rate than by use of fresh water.
Changed Circumstances Affected Preferences
The final EIS identified DOE’s preferred alternative as developing a new storage facility at Richton and expanding the capacity of three existing sites: Bayou Choctaw, Big Hill, and West Hackberry (by 20, 80, and 15 million barrels, respectively). Following issuance of the final EIS, DOE continued to evaluate the Reserve’s distribution capabilities, commercial activities, and other factors. The preferred alternative in the final EIS was no longer preferred by the time of decisionmaking.
To increase storage capacity at West Hackberry, DOE had proposed acquiring three existing commercial caverns. These caverns were purchased, however, by Sempra Pipelines and Storage Corporation in August 2006 as part of its gas storage system. In commenting on the final EIS, Sempra expressed its intention to use the caverns as early as Spring 2009. As a result, DOE concluded that it might not be able to acquire the West Hackberry caverns at a reasonable cost.
In addition, DOE’s evaluation of the Reserve’s distribution capabilities identified the need for additional oil reserves at Bayou Choctaw to address potential refiner demands in the lower Mississippi River valley and to achieve the Reserve’s needed overall drawdown rate. DOE determined that it could meet these needs by increasing expansion at Bayou Choctaw by 33 million barrels (and Big Hill by 80 million barrels).
Supplement Analysis Examined Additional Options for Existing Sites
DOE prepared a supplement analysis (under 10 CFR 1021.314(c) of its NEPA implementing regulations) to analyze the potential environmental impacts at Bayou Choctaw from increasing expansion to 33 million barrels compared to the 20-million barrel expansion analyzed in the final EIS. (As noted above, expansion of Bayou Choctaw by 30 million barrels was analyzed in the draft EIS, but removed from consideration when DOE decided not to consider the Clovelly site further.)
As shown in the supplement analysis, development at Bayou Choctaw of two new caverns of 11.5-million barrel capacity each (instead of 10-million barrel capacity each) would extend the duration of cavern leaching and brine disposal by about 4 months, but would not impact the salinity of the source water nor of the aquifer into which brine would be disposed. Use of these new caverns and an existing 10-million barrel commercial cavern would not substantially change the potential impacts from those analyzed in the final EIS. DOE concluded that the additional expansion at Bayou Choctaw was “not a substantial change to the proposed action that is relevant to environmental concerns” and that a supplement to the final EIS was not needed.
Mitigation Commitments Made
Richton was selected as the new site for development (with Big Hill and Bayou Choctaw as expansion sites) because, in part, it can be developed without impacts to commercial operations at or near the site and without high geotechnical risk, and its inland location provides a significant buffer to potentially damaging effects of hurricanes on surface structures. The Richton alternatives (with Richton as the new site and various combinations of expansions at existing sites) were not identified as environmentally preferable alternatives in the Record of Decision because development of the Richton site would affect several hundred acres of wetlands through more than 200 miles of pipeline and power line rights-of-way and may affect designated critical habitat of a protected species.
In its Record of Decision, DOE identified consultations that it will undertake with appropriate Federal, state, and local natural resource agencies to develop and adopt detailed mitigation measures. These consultations include a wetlands permitting process, in which DOE will prepare, among other analyses, a wetlands compensation plan. As expanding the Reserve may cause adverse impacts to cultural resources, DOE has signed Programmatic Agreements with Louisiana, Mississippi, and Texas, the Advisory Council on Historic Preservation, and tribes to ensure that DOE fulfills its responsibilities under the National Historic Preservation Act.
For More Information
LLQR reported on this EIS in an article on the Energy Policy Act of 2005 (September 2005, page 3) and on DOE’s extension of public scoping following Hurricane Katrina (December 2005, page 30).
The following documents are available on the DOE NEPA website at www.eh.doe.gov/nepa/documents.html and the Strategic Petroleum Reserve website at www.fossil.energy.gov/programs/reserves/spr/expansioneis.html: the Notice of Intent (70 FR 52088; September 1, 2005); Draft Environmental Impact Statement on the Expansion of the Strategic Petroleum Reserve: Alabama, Louisiana, Mississippi, and Texas (DOE/EIS-165, 1992); Site Selection for the Expansion of the Strategic Petroleum Reserve Final Environmental Impact Statement (DOE/EIS-0385; December 2006); the associated Supplement Analysis (DOE/EIS-0385-SA-1; February 8, 2007); and the Record of Decision, signed on February 14, 2007 (72 FR 7964; February 22, 2007). For further information, contact the NEPA Document Manager, Don Silawsky, Office of Fossil Energy, at email@example.com or 202-586-1892.