Tuesday, December 30, 2014

LETTER - To The Honorable Edward M Kennedy - Feb. 25, 1998






Gloucester Fishermen’s Association


February 25, 1998


The Honorable Edward M. Kennedy
United States Senate
Washington, DC 20515


Dear Senator Kennedy:


The Gloucester Fishermen’s Wives Association has, for decades, prided itself in helping to protect our ocean environment and the fishermen’s way of life in all New England fishing communities. In the past, we have successfully opposed drilling for oil and gas offshore on the Georges Bank, lobbied for a ban on ocean dumping, and worked diligently with local, state, and federal officials and many private organizations to protect our ocean resources for the good of our nation. Additionally, we have been instrumental in establishing a comprehensive medical insurance program, the Fishing Partnership Health Plan, that currently covers nearly 1000 fishermen and their families.

Now, the Gloucester fishing community faces perhaps its greatest challenge. A small, Texas-based, oil and gas company, Tatham Offshore, has proposed to build the world’s longest undersea gas pipeline. This 1500-mile long pipeline which will purportedly bring natural gas from Canada’s Grand Banks to Seabrook, New Hampshire cuts directly across some of the richest fishing grounds on the East Coast across the Gulf of Maine and Jeffreys Ledge). As of May 1, 1998, 1200 square miles of prime fishing grounds in the Gulf of Maine including Jeffreys Ledge will be closed to fishing for three years. In addition larger rolling closures lasting two months each will close all Gulf of Maine inshore fishing grounds where the pipeline will be present. Although the company claims it’s $3 billion project will have little adverse impact on the fisherman and environment of New England, the facts tell a very different story. Common sense and the history of accidents and environmental failures in the petroleum industry says that even a 500 mile pipeline (Phase I is scheduled for completion in November 1999) which is pressurized to 3000 psi and stands 4 feet above the seafloor represents a major threat to the region.



Gloucester Fishermen & Wives
February 25, 1998 – Page 2

The following package of materials summarizes the project and details our case against the offshore pipeline. Most of the documents and research are sourced either from the gas industry’s own documents or from government agencies. These materials illustrate the three fundamental reasons why we oppose this pipeline project.

Our first concerns are the inherent risks and safety issues involved in permitting a gas project of this magnitude to go forward in such a critical area. The statistics provided the by the US Government’s own Office of Pipeline Safety show a total of 891 gas pipeline incidents by transmission operators over a recent 10 year period resulting in 37 fatalities, 170 injuries and more than $180 million in damage. Furthermore, more than half of these incidents appear to have been the result of corrosion problems or defects. The accompanying case histories show that contrary to the company’s assertions, gas leaks can and do lead to catastrophic explosions and fires.

Moreover, our extensive research has unearthed a significant risk of a major earthquake occurring along the route which could result in a catastrophic failure of the pipeline. As the maps show, one of the highest risk areas is located near the proposed route and only 50 miles offshore Gloucester. This startling revelation is supported not only by the historical records of major quakes going back 350 years, but by the recent tremors in the same vicinity which were reported in the local newspapers. This earthquake record alone should preclude any consideration of industrial developments in this region of the Gulf of Maine.

Our second concern is the very shaky financial position of the proposed operator.
Examination of Tatham Offshore’s own quarterly reports show that the company is deeply in debt and losing money. On July 21, 1997, the company declared that it would take a write down of approximately, $42 million to reflect its production-related problems. Since then, it has announced that the company is in danger of being de-listed on the NASDAQ National Market. After incurring losses for 3 of the last 4 years last October it failed to maintain a $1 per share value for 10 consecutive days. With net assets less than $4 million, the company, nevertheless, claims to have invested nearly $5 million in pre-development costs for the offshore pipeline proposal and plans to spend another $5 million by the spring of 1998.

The parent Company, Deeptech Int’l Inc., is also in poor financial condition. Deeptech’s net income for the three months ended September 30, 1997 totaled $2.4 million. According to one stock analyst it lost $18 million in the previous 12 months. This company, too, is burdened with debt. Deeptech’s quarterly report states, “In the future, the Company anticipates that it will need significant additional funds from outside sources to fund its debt obligations which mature in 1998 and beyond.” This is not the kind of company that could be expected to operate and maintain a multi-billion dollar pipeline in a safe and responsible manner. Nor, does it have the resources to cope with the liabilities and financial consequences if a major problem develops.



Gloucester Fishermen & Wives
February 25, 1998 – Page 3

Finally, we are deeply concerned about the potential adverse impacts such a development could have on the fish habitats which we consider essential for the survival and recovery of the New England fishery. Unlike Canada, the proposed route does not avoid rock outcrops, steep slopes and significant fishing areas. Contrary to Canadian practices, the pipeline will not be trenched or buried and according to the company’s own brochure, “no valves or other protruding features to catch nets and no exclusion zone is required.” In the absence of any control valves near a leak, it could take many hours to shut off the flow. During major leak or rupture, methane gas and other contaminants would bubble up to the surface causing a significant environmental and safety hazard.

If this project is completed, it will add impetus to the oil company frenzy which is presently taking place on the Grand Banks of Canada. These, partially subsidized oil and gas operations have already overrun centuries-old Canadian fishing grounds, and have encroached upon their most sensitive marine and wildlife sanctuaries. We cannot make the same mistake

For all of these reasons, the offshore gas pipeline should never be approved. The Gloucester Fishermen’s Wives Association and its allies will oppose the construction of this pipeline with every means at our disposal. We desperately need your support and assurance that such an ill-conceived plan will never make it off the drawing board.



Sincerely,



Angela Sanfilippo, President Gaetano G. Brancaleone, President
Gloucester Fishermen's Wives Assn. Gloucester Fishermen's Assn.


Attachments

The Truth About George's Bank Exploration and Production Operations

STRANGER THAN FICTION -
THE TRUTH ABOUT GEORGES BANK
EXPLORATION AND PRODUCTION OPERATIONS

The Oil industry traditionally makes sweeping claims and unsupported assertions based primarily on statistics and models. These generally go unchallenged due to a lack of hard data available to refute their evidence. Gradually, this situation is changing and we are now prepared to address these misconceptions individually using the latest scientific data. It is up to the reader to critically examine which truths will ultimately have the greatest impact on Georges Bank and those who depend on this vital resource.

CLAIM: Major oil spills are principally caused by tanker accidents not directly related to Exploration and Production Operations. [Yarmouth Chamber of Commerce Offshore Oil and Gas Conference October 1998]

FACT: Of the ten largest oil spills ever recorded, the largest is the Persian Gulf spill which was caused by an act of war and terrorism. Four other large spills were caused by Exploration and Production blowouts. The oil released by these four well blowouts far exceeds that of the remaining five tanker spills. (See attached list)
CLAIM: On a global basis offshore operations make only a small contribution to oil input to the sea. Offshore oil production accounts for only a small amount of the oil introduced into the world's oceans, perhaps 2% in an average year (National Academy of Sciences 1975).

FACT: Two percent of total marine oil input is a tremendous amount especially when much of it is concentrated near coastal areas. Nearly 49 million gallons (167,000 tonnes) of oil spilled worldwide into the marine and inland environments from all sources as the result of 136 incidents during 1997, according to the Oil Spill Intelligence Report.

In the UK context current N Sea Oil activities and associated onshore developments present a significant threat to the marine environment.” (R. Johnston 1980) 1.

CLAIM: Current level of communications, cooperation and compensation mechanisms appear to allow the fishery and the oil industry to co-exist on the Scotian shelf9. [The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui. 1998]

Canada Oil and Gas Lands Administration (COGLA) has recommended that operators on Georges Bank should be participants in the Fishermen’s Compensation Policy for unattributable damage due to exploration and Production Activities on Canada's East Coast.13 [Regulation; Number 4 of a series of papers on energy and the offshore November, 1998]


FACT: Oil companies can and should be held accountable for their actions and treatment of fishermen. However, experience in other parts of the world reveals a reluctance to pay fair claims. Historically, companies have under-compensated fishermen and have fought lengthy court battles to avoid paying. (See article below)

The Seattle Times
Saturday, June 28, 1997
Copyright © 1997
The Seattle Times Company

In its October 1991 settlement, Exxon agreed to pay $900 million for “restoring, replacing, enhancing, rehabilitating or acquiring the equivalent of natural resources” harmed in the spill.

The company also paid fines of $125 million to state and federal governments, much of which has been spent on scientific research and, purchasing other land.

An Alaska jury also awarded $5 billion in punitive damages to 28,000 fishermen; native villagers and others harmed by the spill. This month, Exxon appealed that award in the 9th U.S. Circuit Court of Appeals in San Francisco.

Right after the spill, they said they'd make us whole,” said Cheri Shaw, executive director of Cordova District Fishermen United, based southeast of Valdez. “Then they fought us tooth and nail. It's been eight years, and we haven't seen a dime.”
An appellate brief filed by Exxon cited juror misconduct, jury instructions, compensatory-damage errors and the “excessiveness” of punitive damages.

We're going to exercise our right to protect the interests of our shareholders and employees,” said Ed Burwell, a spokesman for Exxon in Irving, Texas.

CLAIM: Blowouts and spills are a risk, albeit an unlikely one, of offshore hydrocarbon production.12 (Offshore Production, Storage and Transportation number 3 of a series of papers on energy and the offshore, November, 1998.)

The well also contains blowout preventers; devices on the top of the casing that can close off the well in the event of uncontrolled pressures.).11 [Exploring for Offshore Oil and Gas number 2 of a series of papers on energy and the offshore November, 1998]

BOP’s are large valves that help control the flow of fluid from the well. One type of BOP can seal off the annulus if the drillpipe is still in the hole. Another can shear off the drill-pipe and thus seal off the entire well, while a third can seal off the well if no pipe is in the hole. If the well is likely to encounter high pressures, all of these BOP’s may be used in a BOP stack. [Our Petroleum Challenge 1993 Petroleum Communication Foundation.

According to the DFO, “blowout preventers are routinely installed on all wells at the seafloor that stop or slow the flow of petroleum product in unusual circumstances.5 (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

The following remarks are excerpted from the trade journal “World Oil” (May and June 1991) entitled, How to Prevent or Minimize Shallow Gas Blowouts2 (parts 1 &2).

FACT: “Shallow gas flows are a critical issue because field experience and mathematical modeling have shown that it is difficult, and almost impossible, to control or stop a flow with existing rig equipment once it begins. Once flow has started, it is almost inevitable that a blowout will occur. The response time based on field experience is low or virtually non-existent in many cases. Sufficient time does not exist in most cases to recognize the situation, dose the diverter, and begin the kill operation before the flow becomes uncontrollable2.” [World Oil” (May and June 1991)]

Diverter system failures occur at such an alarming rate during shallow gas blowouts that contingency plans probably should be based on their anticipated failure rather than an expectation that they will function effectively. Previously published studies show that failure rates range from 50 to 70% of all applications2.” [World Oil” (May and June 1991)]

Many operators and contractors now design diverter systems for the primary purpose of providing time to evacuate the rig. They do not plan to remain on the rig and attempt to control shallow gas blowouts2”.

CLAIM: Natural gas released in a blowout is mostly dispersed in the air by winds.12 (Offshore Production, Storage and Transportation, number 3 of a series of papers on energy and the offshore, November, 1998)

The high volatility of the gas usually allows much of it to evaporate into the atmosphere and the bulk of the material dissipates rapidly through the action of the wind. This is often true of the lighter components of the condensate and oil.

Impacts would be local and short lived, although depending on the timing and location could result in significant mortalities5. (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

FACT: With shallow gas blowouts, “Flow outside casing usually results in severe situations such as a damaged well and rig or platform loss. (See attached tables) Also, flow can exit to the surface through fault planes or around poorly cemented casing2.”

Cratering occurs when flow outside the casing displaces large volumes of surface sediment. The eruptive force of blowouts can be dramatic and has been documented as lifting large boulders weighing several hundred pounds into the air and dropping them as much as 150 ft from the well site2.

Their areal extent can be large. One well had a crater with dimensions of 1,300 ft x 250 ft x 300 ft deep. However, the actual depths of craters are not easily determined. Large rigs and platforms have been lost in craters without any evidence of the rig remaining at the surface2.

A Natural gas explosion on the Piper Alpha oilrig in the North Sea resulted in a fire that completely destroyed the platform. It is the worst platform disaster in history in which 167 men died tragically in 1988.

CLAIM: “Not all blowouts lead to significant loss of hydrocarbons because often they seal naturally and cease flowing within a matter of days 5.” (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

FACT: “Records show that if a shallow gas blowout does not bridge within the first one to two days, then the well will probably continue to blow for an extended period of time, i.e., weeks or months. Some have continued for years2.”

Shallow gas flow rates have generally been grossly under estimated. Bends, bore size changes and flow path discontinuities produce high particle impact angles and local increases in velocity 2.

CLAIM: Approximately 1% of exploratory wells worldwide have had blowouts and the resulting releases are normally relatively small. In over 22,000 wells of all kinds drilled in US coastal waters from 1971 to 1993, only five blowouts occurred and the total discharge was 170 m3. 11(Exploring for Offshore Oil and Gas number 2 of a series of papers on energy and the offshore) November, 1998

FACT: The following chart (see table) is condensed from a database of 950 shallow gas blowouts. Of the 56 rigs listed more than half suffered extensive damage or the total loss of the rig. At least 24 shallow gas blowouts appear to have occurred in US waters between 1971 and 1993. 2 [How to Prevent or Minimize Shallow Gas Blowouts (parts 1 &2). World Oil-May and June 1991]

OIL SPILLS

CLAIM: “Detectable impacts of oil on biological resources are restricted to the coastal zone…The distance from the Georges Bank moratorium lands to the shore and the residual current, may somewhat reduce the probability of encountering the shoreline. If it does it is likely to contact the US shoreline. There is also the Stellwagen Bank Marine Park off the Coast of Massachusetts that might be impacted5.” (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

Scientists have been unable to detect effects of offshore oil blowouts on the abundance or wholesomeness of fisheries resources including the Uniacke Blowout near Sable Island5.” (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

FACT:
Georges Bank oil spill cleanup is presently impractical and will probably remain so 6” (Howarth 1987).

The truth is that the biological impacts of oil spills have been poorly studied until recently. Even the Uniacke Gas blowout which released condensate in 1984 was not evaluated for biological impacts. “There are unique physical and biological features about Georges Bank that suggest the potential impacts could be greater than in other offshore regions and perhaps even detectable at both the resource and ecosystem level 5.” (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

EXPLORATION

CLAIM: “Given that the rock formations underlying the Canadian portion of Georges Bank appear to be similar to those around Sable Island, gas and condensate, and possibly light oil would probably also be found.” 10 (Hydrocarbon Resources number 1 of a series of papers on energy and the offshore, November, 1998)

Natural gas and condensate, a light oil with similar properties to gasoline, are the hydrocarbons most likely to be found on the Canadian portion of Georges Bank. Although condensate is quite toxic, both disperse or evaporate rapidly, and do not tend to stay in the marine environment as long as do the heavier crude oils11.”
(Exploring for Offshore Oil and Gas number 2 of a series of papers on energy and the offshore November, 1998)

Fact: The companies do not yet know which type of hydrocarbon will be encountered. Vintage seismic cannot distinguish between oil and gas with certainty and geochemistry was difficult to interpret. Before drilling, they will conduct a hazard survey primarily to reduce the chances of encountering shallow gas.

Shallow seismic surveys of the upper few hundred meters of the seabed are often carried out to determine the structure of the sediments and scan for potential hazards to drilling (e.g., shallow gas pockets). 11 [Exploring for Offshore Oil and Gas number 2 of a series of papers on energy and the offshore November, 1998]

CLAIM: Marine seismic effects on adult fish are minor short-lived and localized. Most of the observed mortalities occur close to the source. Using reasonable caution seismic exploration is unlikely to result in any significant impacts. 5 (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

FACT: “Sound exposure levels of 150 160dB are where potential reactions might occur for large whales and fish. On the Scotian shelf these noise thresholds are reached at distances of 4.5 to 14.5 km. depending on the specific location.” 9[The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui. 1998]

Broadband sounds at or above 180 dB would be experienced within 1500 m of the array. Stationary fish would be exposed to this level or greater for about 20-25 minutes9”. [The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui.1998]

It is not yet possible to establish unequivocal criteria for determining the zone of influence around a noise source. Sound waves are created by the explosive release of compressed air from an array of air guns towed behind seismic vessels (specialized ships), firing every 5 - 12 seconds. Streamers can be up to 6 km long and are stored on a large winch11” [Exploring for Offshore Oil and Gas number 2 of a series of papers on energy and the offshore November, 1998]

CLAIM: “Impacts on fish larvae, including those in nursery area, would be minor, sublocal and short-term and likely to occur” 9. [The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui.1998]

FACT: Herring is also relative sensitive to sound. At 50-1200 Hz its hearing threshold is about 75-80 dB. Yolk sac larvae (2 day old) showed peak pressures of 217-220 dB (75- 100 kPa) had detrimental effects on anchovy. A 50% mortality for 2 day and 4 day old larvae occurred at this level9 [The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui.1998]

Pulses from an airgun damaged larvae mainly with a radius of 5m. Eggs of the anchovy, the most sensitive species experienced some damage at this distance. Kostyuchenko (1973). Lethal effects on eggs and larvae would be expected from an airgun array at a distance of 6.5m. 9[The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui.1998]
CLAIM: “Direct impacts of seismic exploration on adult fish would be negligible.9 [The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui.1998]

FACT: “Peak pressures of 217-220 dB (75- 100 kPa) had detrimental effects on anchovy. Adult anchovy also experienced swim bladder damage in this range””
Also “In one study, the fish [Herring] changed direction and moved away from the source, but schooling behavior was not affected. The fish reacted to sounds of 144 dB.” 9[The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui.1998]
There may be some situations in which movement to other areas will not detrimentally affect the population. However the safest assumption is that population occupies optimum habitat and movement away from the habitat is likely to be detrimental, at least if the animals are displaced for more than a brief period” 9 [The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui.1998]

There are no data on behavioral effects of seismic pulses on fish eggs and larvae…A small change in the survival rate of larvae can have a large effect on recruitment to the adult population.” 5 (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)
CLAIM: “A volume of water equivalent to about 1% of the volume of water in the study area would contain impulses lethal to fish larvae.” Therefore, “fewer than 1% of fish larvae in this volume of water would be exposed to lethal peak levels.” 9 [The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui.1998]

FACT: Fish larvae are generally planktonic for a considerable period. The study assumed a depth of water of 50 m and averaged the mortality throughout that water column. If you assume that most larvae are found near the surface then the mortality could be 50 times as great. This is particularly alarming since the size of the 1998 seismic program exceeded 1000 sq km.

CLAIM: “Herring spawning occurs close to shore in very shallow water and eggs would not be affected by seismic exploration.” 9 [The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui.1998]

FACT: This statement of course does not apply to Georges Bank where herring have historically spawned in large numbers along the northern peak.

CLAIM: “Pressure pulses from black powder and airguns have slower rise times and cause relatively little injury to fish.” 9 [The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui. 1998]


FACT: “Information based on tests with black powder is at least partly relevant.” Further, “eight of nine anchovy on the surface were killed by an 18 kg charge on the bottom at 29m.” 9 [The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui. 1998]

CLAIM: “Impacts on catch caused by presence of the array and associated noise in typical shooting area are predicted to be minor, sublocal, short, term and likely to occur.” 9 [The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui. 1998]

FACT: Experiments on the effects of seismic shooting on abundance and catch of cod and haddock were conducted in the Barents Sea. “Acoustic density of cod and haddock decreased over the entire study area by 45% during the shooting and 64% during the 5 d period after shooting ceased. More than 90% of the catch was cod. During shooting, catch in the shooting area decreased by 60% and catch in the other areas (up to 18 km from the exploration area) decreased by 45-50%. Catch rates did not recover during the 5-d period after shooting ended. The longline catch decreased by 45% in the exploration area, but the decline was smaller with increasing distance from the exploration area. With no reduction in catch at distances of 16-18 nautical mi. from it. Catches increased after cessation of shooting.” 9 [The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui. 1998]

In a study in Norway, longline “catch was reduced by 55%-80% within the seismic survey area and there was some reduction in catch to a distance of 5 Km.” In the same area, “trawls were made before and during shooting. Cod catches during shooting were reduced by 79-83% compared to pre-shooting levels within the exploration area and within 9 km of it.” 9 [The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui. 1998]

In a fishing experiment on rockfish in California, catch per unit effort (CPUE) declined by an average of 52.4% when air gun pulses were emitted at levels of 186 to 191 dB. Skalski et al (1992) speculated “in an area where sound had caused the fish to disperse, a lowered CPUE might persist.” 9 [The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui. 1998]

With the exception of the California studies of rockfish, investigators did not measure received noise levels. Thus, it is not possible to say, with any certainty, what sound levels could cause reduction in catchability cod and haddock.” 9 [The Environmental Effects of Marine Seismic Exploration on the Fish and Fisheries of the Scotian Shelf, P. Tsui. 1998]

DRILLING MUDS

OIL BASED MUD

CLAIM: For drilling deeper wells and when problems such as pipe sticking occur, oil-based muds (OBM) are normally used. The typical difference from water-based muds is the high content of mineral oil (typically 30%). OBMs also contain barite, a powdered heavy mineral, and a number of additives. 12 [Offshore Production, Storage and Transportation, number 3 of a series of papers on energy and the offshore, November, 1998]

Early drilling frequently used diesel oil in drilling fluid, but its use was stopped because it was so toxic. Stringent regulations, expected to be in place at the turn of the century, will greatly reduce the oil content in cuttings, and virtually eliminate the releases of oil-based mud and cuttings in the offshore. 11(Exploring for Offshore Oil and Gas number 2 of a series of papers on energy and the offshore November, 1998)

The CNSOPB has already stated publicly that oil-based muds will not be permitted on Georges Bank, should the moratorium be lifted. Their use is also being stopped on the Scotian Shelf. 13(Offshore Regulation, number 4 of a series of papers on energy and the offshore, November, 1998)

FACT: The issue of oil based mud is largely a paper tiger. Of the eight wells drilled on Georges Bank during 1981 and 1982 only one used oil based mud and another used a small amount of mineral oil. Historically, diesel fuel was added to mud systems to increase the rate of penetration, but advances in drilling bit technology have made this practice largely unnecessary. Although N. Sea operations have switched from diesel oil to mineral oil, experience has shown that this change has not reduced the benthic impact zones around the drilling rigs. The amount of barite contained in water based mud can actually be greater than in oil based muds.

WATER-BASED MUD

CLAIM: “One type of mud known as water-based mud (WBM) is a mixture of water, bentonite clay, and chemical additives, and is used to drill shallow parts of wells. It is not particularly toxic to marine organisms and disperses readily. Under current regulations, it can be dumped directly overboard. Companies typically recycle water-based drilling muds until their properties are no longer suitable, and then dump the entire batch overboard over a period of hours. These types of muds are relatively non-toxic to marine organisms (including scallops).” 12 [Offshore Production, Storage and Transportation Number 3 of a series of papers on energy and the offshore, November 1998]

The concern is not the bottom area covered by the cuttings pile, as this is very small compared to the total amount of sea floor in the area; nor is it problems of toxicity or sublethal effects of the ingredients for these are so localized as to be negligible.” 7 (Sable Island Development Plan)

Most acute toxicity thresholds for muds and their components are much higher than concentration expected under field conditions. 5(Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

Results indicate that WBM levels in excess of 50 mg -1[or 50 gm x10-3 per liter] are required before significant effects on haddock or lobster survival are detected. Acute and chronic exposure of scallop to 100 mg l-1 [or 100gm x10-3 per liter] WBM had no significant effect on survivorship or growth3. [(A) - Effects Of Water Based Drilling Mud On Early Life Stages Of Haddock, Lobster And Sea Scallop. P. Cranford, K. Querbach, G. Maillet, J. Grant, C. Taggart, And K. Lee
Executive Summary 5 November, 1998]

FACT: Of 415 acute lethal bioassays lasting 48-144 hrs with 68 drilling muds involving 70 species, 8% showed 50% mortality (LC50) below 10,000 ppm (Petrazuollo, 1983). The 96-hour LC50 test and the sublethal tests Table 52.4 and 52.5 (Neff 1987) revealed the most sensitive species were as follows:

Copepods- 5500 ppm in 96 hrs (LC50)
Lobster
Larvae- 2000 ppm (increase in larval development by 3 days)
Stage IV 8 ppm (partial inhibition of molting, delayed detection of food cues)
Stage IV-V - 1-4 mm layer (altered burrow behavior delays in construction)
Stage V - 5000 ppm (LC50)
Adults- 10 ppm Decreased response of walking leg chemosensors to food cues)
1-2mm layer for 4 days- inhibition of feeding behavior
Scallops
Juveniles and embryo's -
Scallop larvae - 49ppm (decreased rate of shell growth)
2 day larvae -100 ppm in 96 hrs (significant inhibition of shell formation)
Mysid shrimp

ECOSYSTEM IMPACTS
“There is concern that the routine discharge of wastes during drilling for oil and gas could impact valuable fishery resources. Recent studies have indicated that intensive drilling efforts in the North Sea have caused detrimental effects in adult and larval fish and benthic invertebrates at greater distances from drilling platforms than previously envisaged”8. (Neff 1987)

Abundance of benthic organisms near one N.J. rig site plunged from 8011 animals /sq m. before drilling to 1729 animals /sq m. during drilling. One year after drilling was completed, the number had risen to only 2638 animals /sq m. Diversity was also impacted from 70 to 38 species /0.02 sq m rebounding only to 53 species /0.02 sq m one year afterwards. 8 (Neff 1987)

In the Gulf of Mexico, the benthic fauna is “decidedly reduced relative to other studies and that the majority of the benthos in an offshore Ecology Investigation (OEI) study area is composed of two species, both of which have been documented as precise individuals of severely polluted environment.” 6(Howarth 1987)

DISCHARGES

CLAIM: “Observations and predictions of particulate drilling waste concentrations in suspension around exploratory drilling platforms indicate that the zone of impact of WBM discharges on the early life-stages of haddock, lobster and scallop would be highly localized and that the effects on the future strength of each fishery would not be detectable3.” (A) - Effects Of Water Based Drilling Mud On Early Life Stages Of Haddock, Lobster And Sea Scallop. P. Cranford, K. Querbach, G. Maillet, J. Grant, C. Taggart, And K. Lee Executive Summary 5 November, 1998

FACT “Much of the observed growth loss was due to retarded gonad development and not adductor muscle. Therefore it is likely that drilling wastes would have more effect on spawning potential (An impact not apparent in the fishery until reduced recruitment in future years) than on muscle size.” The net effect might be reproductive loss which could affect strength of future year classes. 5(Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

CLAIM: “Analysis of the number of hours that concentrations exceed 10 milligrams/l at various distances along the primary drift line indicates that the waste concentrations predicted in these applications are not likely to cause scallop mortality, even at the release point. 3.” (A) - Effects Of Water Based Drilling Mud On Early Life Stages Of Haddock, Lobster And Sea Scallop. P. Cranford, K. Querbach, G. Maillet, J. Grant, C. Taggart, And K. Lee Executive Summary 5 November, 1998
FACT: The benthic boundary layer transport (bblt) and mortality studies on scallops have the following limitations and are inadequate for predicting the biological impacts of drilling discharges. Therefore estimates of lost growth days and safe distances from rigs are invalid

1. Scallops were exposed only intermittently for 12 hrs each day for up to 68 days. Even the hypothetical well was projected to be drilled 24 hrs per day for 93 days with wastes released on 59 of those days. There is no evidence that the benthic concentrations of barite would decrease significantly during the brief periods when mud and cuttings were not actually being discharged.

2. “The biological effects predicted apply only to adult scallops (4-5 years old)” Known impacts on eggs and larvae were not incorporated.

3. “For these applications, drilling waste concentrations were averaged for the bottom 10 cm of the water column.” 5 The concentrations obviously would increase at the sediment water interface.

4. No safe level of barite was experimentally determined for adult scallops. Both the “zero growth concentration” threshold and the “no effects concentration” threshold were estimates not supported by experimental results. Zero growth occurred at the lowest concentration tested (0.5 milligrams/L and could actually have been much lower. The "no effects" threshold could easily have been in micrograms or even nannograms per liter but was arbitrarily set at 0.1 milligrams/L

CLAIM: A reasonable range of effective settling velocities for flocculated drilling wastes under natural conditions in tidally energetic environments is 0.1-0.5 cm/sec (assuming a 50/50 mixture of bentonite and barite) 5

Waste concentrations predicted by bblt were assumed to be half barite and half bentonite. “Although the drilling waste scenario indicates some change in the proportion of each component with time, this change was not large and the use of a variable proportion of waste constituents would require separate bblt runs for each component and hence a doubling of computational demand.” 5 (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

FACT: The actual ratio of barite to bentonite averaged over the total depth of the eight Georges Bank exploratory wells ranged from 47 to 77% (avg. 66%) 8[Neff 1987]. This ratio also increases with depth to compensate for increasing pressures. Increased mud densities result in higher settling velocities.

The predicted near-bottom concentrations are very sensitive to the effective settling velocities of drilling wastes. Those at the higher velocity are about an order of magnitude greater than those at the lower velocity.” 5 (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

The expected range of settling velocities was estimated using measured drilling waste concentration profiles around the Copan site [on Sable Island], but it appears that these did not fully resolve the dense mats seen in video images. Thus higher settling velocities and hence near bottom concentrations are possible but considered unlikely to occur under the tidally energetic conditions on Georges Bank. If they were to occur on the Bank, near bottom concentrations and scallop loss could be increased by several fold above the present model predictions.” 5 (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

CLAIM: There is no reason to believe that smothering will kill significant numbers of slow moving or sessile organisms living under a drill rig. Smothering of benthic organisms by deposited mud and cuttings would not be anticipated outside about 0.5km radius from the rig. 5 (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

FACT: “As mush as 90% of the discharged solids settle directly to the bottom. (Brandsma 1980). The remaining 10% including clay-sized particles and soluble materials is diluted by the current and dispersed over large areas8. ” Furthermore “during the entire [one well] scenario a total of 468 MT of drilling mud and 2569 MT of cuttings are released to the marine environment. 5 (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)
Studies examining the effects of exploratory drilling on the U.S. portion of Georges Bank found that small amounts of some drilling muds (in particular the weighting agent barite) had been transported as much as 60 km from the well site.” 11 [Exploring for Offshore Oil and Gas number 2 of a series of papers on energy and the offshore November, 1998]

Furthermore, “Elevated barium concentrations (up to 1014 ppm compared to a background of 250 ppm) in the clay-sized fraction of the sediments were detected up to 65 km. downcurrent of the drill-site in block 312.” (Neff 1987) 8. Bothner et al 1983 estimated that between 21-31% of the barite and by inference 21-31% of the settleable fraction of drilling fluid discharged during drilling on block 312 remained within 6 km of the drill site.” Therefore “the remaining 69% to 79% of the drilling-fluid solids presumably were carried to greater distances from the rig site.” (Neff 1987) 8


MITIGATION MEASURES

CLAIM: Any of the following steps should decrease the predicted effects on scallops
Reduce the amount of barite in the WBM (which in turn will reduce both the toxicity and the effective settling velocities); Reduce the mud density; Limit discharges to times of the year when scallop growth is low (November to February) 5.
[Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998]

FACT: There is currently no economical alternative to barite in WBM which will achieve the desired mud weight (density). The mud weight is dictated by the subsurface pressures encountered while drilling and cannot be easily reduced.

Considering that gametogenesis is near continuous on Georges Bank, exposure to drilling wastes would have some impact on fecundity and egg viability regardless of the time of drilling.” 5 (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

SENSITIVITY TO HYDROCARBONS

CLAIM: Background levels of hydrocarbons might make it difficult to distinguish the effects of a discharge. [Yarmouth Chamber of Commerce Offshore Oil and Gas Conference October 1998]


FACT: “Background levels of hydrocarbons in the water column on Georges Bank are low (< 1 microgram/L). Hydrocarbon levels in the sediments normally range from 1 microgram/gram to 20 microgram/gram dry weight” 6(Howarth 1987).

CLAIM: Oil spills are unlikely to have any major impact on stocks of commercial fish (Royal Society 1980) 6

FACT: Many organisms are extremely sensitive to very low concentrations of oil.
Very low concentrations (from less than 1 microgram/liter of oil to 1 milligram/l of oil have been found to have harmful effects on various marine organisms in laboratory tests. 6 (Howarth 1987)

On Oct. 3, 1998, NMFS scientists reported at a international conference in Anchorage, AK, that contaminants, especially longer-lived polycyclic aromatic hydrocarbons, from lingering oil after the Exxon Valdez spill at concentrations as low as one part per billion [1 nannogram/gram] will continue to stunt pink salmon growth and cause other chronic problems for generations. Exxon scientists disputed these findings”. [Reuters]

PHYTOPLANKTON

CLAIM: “Exposures of a diatom culture to produced water concentrations up to 10% for 10 days did not result in significant changes in algae biomass or physiological condition4.” (B) - Effects Of Produced Water On Early Life Stages Of Haddock, Lobster And Sea Scallop. P. Cranford, K. Querbach, G. Maillet, J. Grant, C. Taggart, And K. Lee Executive Summary 5 November, 1998

FACT: “Fertilization of algae was completely inhibited by 0.2 micrograms/L of fuel oil6” (Howarth 1987). Some large species of phytoplankton [typical of Georges Bank] are sensitive to oil and growth is inhibited by concentrations as low as 40 micrograms/L of fuel oil. In laboratory studies (consisting of initial oil concentrations of 100 micrograms /L), large celled diatoms were displaced by small cells in 9 days. “Greve and Parsons 1977 have speculated that a change from an ecosystem dominated by large phytoplankton (Like Georges Bank) to one dominated by small phytoplankton, might alter food chains to the detriment of the production of commercially valuable fish species.” They concluded that “the release of very small amounts of hydrocarbons in ocean areas where oil exploration is in progress could cause a decrease in the harvestable fisheries of the areas through indirect interference in the natural; food web.” 6 (Howarth 1987)

ZOOPLANKTON

CLAIM: It is difficult to demonstrate that either major spills or chronic oil input have any irreversible impacts on the marine biological communities. 5 (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

FACT: “Even though estimates of adult stocks are more precise than those of the young, mortalities as high as 25% could go undetected … It is also possible that significant impacts on aquatic populations do occur but may be not be detected with present methodology.” 5

Oil concentrations on the order of 100 ppb or less have been demonstrated to cause both lethal and sublethal effects on planktonic organisms. 5 (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

Nannoplankton contamination and fish egg mortality are correlated (see chart) Greatest contamination of Zooplankton with oil occurred at Argo Merchant stations having no obvious slick. 6 (Howarth 1987)

FISH EGGS
HERRING

Following the Tsesis spill in the N. Baltic Sea in 1980 “The hatching success of herring eggs, which develop on the sediment surface, spawned in the spring was only about half as great in oil contaminated areas sediments as in control areas.

Apparently, this was not a direct result of oil on the eggs, but rather was due primarily to increased fungal infection of the eggs. Normally gammarid amphipods graze the fungi, keeping the infection of the eggs low. It is presumed the spilled oil killed the amphipods and that the resulting uncontrolled infection caused the low hatching success” (Nellbring et al 1980) 6. Amazingly, this situation was repeated nine years later in Alaska, but Exxon denied the connection.

Pacific herring spawned in intertidal and subtidal habitats in Prince William Sound shortly after the [Exxon Valdez] oil spill. A significant portion of these spawning habitats as well as herring staging areas in the Sound were contaminated by oil. Field studies conducted in 1989 and 1990 documented increased rates of egg mortality and larval deformities in oiled versus unoiled areas. Subsequent laboratory studies confirm that these effects can be caused by exposure to Exxon Valdez oil, but the significance of these injuries at a population level is not known.

The 1988 pre-spill year-class of Pacific herring was very strong in Prince William Sound, and, as a result, the estimated peak biomass of spawning adults in 1992 was at a record level. In 1993, however, there was an unprecedented crash of the adult herring population. A viral disease and fungus were the probable agents of mortality, and the connection between the oil spill and the disease outbreak is under investigation. Numbers of spawning herring in Prince William Sound remained depressed through the 1995 season

Pacific herring are extremely important ecologically and commercially and for subsistence users. Reduced herring populations could have significant implications for both their predators and their prey, and the closure of the herring fishery from 1993 through 1996 has had serious economic impact on people and communities in Prince William Sound.” 15
(See http://www.oilspill.state.ak.us/herring.html)

COD
Following the Argo Merchant spill “ an average of 20% of cod eggs and 46% of pollock eggs were dead or damaged at all stations near the oil slick”(Langwell 1978) 6

CAPELIN
“10- 25 micrograms/L of the water soluble component of crude oil adversely affected the hatching of capelin eggs.” (Johannsen 1976) 6.

PLAICE
“10 - 100 micrograms/L of refined oil products caused 40-100% mortalities in plaice eggs” (Miranov 1968). 6

WINTER FLOUNDER
“Exposure of winter flounder eggs to 100 micrograms/L of water- accommodated fuel oil significantly reduced their hatching”(Kuhnhold et al 1978) 6.

LARVAE

All major commercial species on Georges Bank have pelagic eggs and/or larvae and therefore are potentially vulnerable.” 5 (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

Low concentrations of oil have sublethal effects on fish eggs and larvae that also may be important to recruitment.” 6 (Howarth 1987). “Since eggs and larvae are very susceptible to predation, a slower development rate could increase mortality by predation. Larval growth rate, by changing the time of exposure to development may be the most important factor controlling recruitment (Cushing 1976) 6.

Oil pollution may lead to decreased spawning, can kill fish eggs and larvae and can delay the development of the fish eggs.” 6 (Howarth). Decreased spawning may lead to decreased recruitment. Contaminated spawning grounds may also decrease recruitment. Exposure of adult fish during gonadal maturation to an average concentration of 10 micrograms/L of dissolved oil for 10 days can cause reduced survival and growth of larvae coming from eggs laid by such fish. 6 (Howarth 1987) “Petroleum concentrations in the range of 2-10 micrograms/L can decrease fish larvae viability” (Vandermeulen and Capuzzo 1983) 6.

On the effects of offshore oil production on fish stocks the DFO concluded “ with respect to impacts on fish, there is clear evidence from laboratory studies that given the expected range of hydrocarbons in the water column there would be lethal as well as sublethal effects on the eggs and larvae of teleost fish”. (Wisman Payne and Akenhead 1982) 6

BENTHIC ORGANISMS

In mesocosm experiments which dispersed 190 micrograms of oil/ L of water over 4 months, mass budget calculations showed that roughly half of the oil added to the water had become incorporated in sediments. Contamination of the benthic fauna had increased by at least an order of magnitude. 6 (Howarth 1987). The researchers concluded “Changes in benthic community structure on Georges Bank could adversely affect commercial fish species because commercial important fish feed on invertebrates there. A decreased rate of benthic production could decrease fish production. Amphipods are among the most important foods for some fish and are sensitive to oil pollution, disappearing as a result of oil spills and chronic discharges. Their loss from the benthic community might slow the growth of adult fish or result in decreased spawning” 6 (Howarth 1987).

In addition, “concentrations of 1 to a few micrograms/L of the water-soluble fraction of kerosene were found to disrupt the normal feeding behavior of snails and crabs. Most of the water-soluble fraction of kerosene used in biologic studies consisted of benzenes, so such studies are quite appropriate in considering the potential effects of formation water in which benzene is a major fraction.” 6 (Howarth 1987)

SHELLFISH

Many Shellfish concentrate oil to fairly high levels; up to 30 milligrams/g dry weight of tissue (Boehm 1980). Contamination of shellfish can persist as long as the sediments they live in remain contaminated, which can be at least 6-12 years for fine grained organic-rich sediments. (Howarth 1987)

Survivorship of embryos and larvae was determined following 96-h acute exposures to 0, 0.1, 1, 10, and 25% solutions of produced water that were allowed to weather for several days before use. Significant decreases in survival of late stage haddock embryos (8-12 days old) were detected at the 25% concentration with 50% mortality (96-hour LC50) indicated at a concentration of 22%. Similar results were observed for early stage embryos (1-4 days old) and feeding stage (13-17 days post hatch) larvae. The yolk sac larvae stage (3-7 days post-hatch) was the most sensitive of the four haddock life stages tested with significant effects detected at the 10% concentration. The 25% concentration resulted in almost 100% mortalities in yolk sac and feeding stage larvae.

Results for first stage lobster larvae (7-17 days old) were highly variable, with an LC50 value at 0.9% produced water indicated in experiments with fed larvae. Cannibalism among lobster larvae may have influenced these results. Early veliger scallop larvae (5-7 days old) experienced a significant decrease in survival at the 10 and 25% concentrations with an LC50 value of 20.8% indicated. Scallop veliger growth was monitored after acute exposure to each produced water concentration. Veligers exposed to concentrations of 1% and less increased in mean size while a decrease in size was observed for larvae previously exposed to the 10 and 25% treatments. Fertilization success of scallop eggs (1 hour old) during 48 hour exposures of eggs and sperm to produced water was significantly effected at concentrations of 1% and above. The 10 and 25% concentrations prevented most eggs from being fertilized.

The survival and growth of scallop veligers was monitored during chronic exposures (18 days) to 0, 0.01, 0.1, 1, and 10% solutions of produced water. The 10% concentration caused considerable mortalities with few animals remaining after 15 days. Larvae exposed to lower concentrations increased in mean size during the experiment, while animals in the 10% treatment exhibited a gradual decrease in mean size.” 4

Excerpted From (B) - Effects Of Produced Water On Early Life Stages Of Haddock, Lobster And Sea Scallop. P. Cranford, K. Querbach, G. Maillet, J. Grant, C. Taggart, And K. Lee. Executive Summary 5 November, 1998

RECRUITMENT

CLAIM: Even if an oil spill or chronic pollution killed large quantities of fish eggs or larvae, no major effect on recruitment would be likely…The effects of density dependent mortality are likely to compensate for additional density independent losses caused by pollution (Royal society 1980) 6.

FACT: In a typical “model that predicted a 42% mortality rate of cod larvae caused by an oil spill, the resulting cumulative loss of the year class was estimated at 24%”(Spaulding 1983) 6.

Some scenarios predict cumulative losses in excess of 20% for both cod and herring5. (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)


Commercial fisheries depend heavily on the production of large year classes, even though such year classes occur sporadically…Oil production on Georges Bank might have relatively little effect on fishery recruitment in years when recruitment would have been very low in any event, but it might significantly harm recruitment in years when recruitment otherwise would have been high…Thus the reduction in size would have significant economic impacts6” (Howarth 1987).
ADULTS

Catches per unit effort of commercially valuable fisheries have fallen historically in the Gulf of Mexico and the North Sea, but in both cases it is impossible to distinguish the effects of oil from other pollutant and effects from overfishing. (National Academy of Sciences 1975)

There are at least some reasons to suspect that the hydrology of Georges Bank and its importance as a nursery ground for larval fish may make fishery stocks there particularly vulnerable to oil pollution” 6 (Howarth 1987).

CLAIM:
Short-term concentrations that can be expected in the water column under blowout or spill conditions on Georges Bank are on the order of 10- 200 ppb with an upper maximum of about 300 ppb. 5 (Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)
Oil is not dispersed in harmful concentrations to depths greater than 1 or 2 m. (Royal Commission on Environmental Pollution 1981) 6

FACT: “On Georges Bank concentrations of 210 micrograms/l were detected up to 20 m immediately after the Argo Merchant spill…Toxic aromatic hydrocarbons persisted for at least 5 months, and the dissolved hydrocarbons were uniformly mixed from top to bottom during this time” 6 (Howarth 1987). Following the Amoco Cadiz spill in France, concentrations of 100 micrograms/L were found at depth of 100 m. 6 (Howarth 1987)

CLAIM: Evaporation rapidly removes the more toxic constituents of an oil slick so that the toxicity of an oil spill becomes negligible in a matter of hours. (Royal Society 1980) 6

FACT: Aromatic hydrocarbons are quite soluble and are both volatile and toxic. “The toxicity of an oil can increase as it is degraded. Photo-oxidation in particular can increase toxicity.” Moreover, exposure to ultraviolet light approximating the level found in nature increased the toxicity of an oil to yeasts fourfold.” Consequently, “the potential for toxicity can be underestimated.” 6 (Howarth 1987)

After the Argo Merchant Spill, “concentrations of dissolved oil remained elevated throughout Georges Bank for at least 5 months”. Once oil is dispersed in the water column, the toxic components are much more slowly lost than they are from a surface slick. Also “Oil has been observed in some anoxic sediments for 6-12 years after a spill… Some of the effects of the oil persist for as long as the oil remains or longer.” 6 (Howarth 1987)

DEVELOPMENT

CLAIM: Development can proceed safely after a discovery with little environmental impacts.. [Yarmouth Chamber of Commerce Offshore Oil and Gas Conference October 1998]

FACT In the case of multiple wells, these [hydrologic] forces might reduce the dilution effect by concentrating the discharges from multiple sites in convergence zones. The critical issue would be the threshold levels of sediment and toxins at important areas of the bank. 5(Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. DFO. November, 1998)

CLAIM: Impacts of development are usually highly localized. [Yarmouth Chamber of Commerce Offshore Oil and Gas Conference October 1998]

FACT: On certain occasions during development drilling [at Sable Island], fine particulates from drilling wastes were present up to 8 km. from the platform. [Yarmouth Chamber of Commerce Offshore Oil and Gas Conference October 1998]

PRODUCTION

CLAIM: Development and production impacts are localized and short-lived. [Yarmouth Chamber of Commerce Offshore Oil and Gas Conference October 1998]


FACT: The gradual ecological change of exposed marine systems resulting from the cumulative effects of all waste streams over the long life of a producing field, and the potential for chronic sublethal effects not measured in the present study could result in significant direct and indirect effects of development and production activities on fishery resources. 4 [(B) - Effects Of Produced Water On Early Life Stages Of Haddock, Lobster And Sea Scallop. P. Cranford, K. Querbach, G. Maillet, J. Grant, C. Taggart, And K. Lee
Executive Summary 5 November, 1998]


CLAIM: Actual exploration and development scenarios have not been developed for Georges Bank. Finally, a plan for development would be created, if enough oil and/or natural gas had been found. The four ongoing hydrocarbon developments on the East Coast all differ, but elements of these successful projects may be applied to development on Georges Bank. 12

FACT: Before an operator bids on a lease detailed exploration and development scenarios are generated and overall economics are carefully calculated. “There are two ways to get the hydrocarbons produced in an offshore well to market ­ pipelines or tankers. Tankers are normally used exclusively for liquid hydrocarbons such as crude oil and condensate. In some areas of the world where markets are suitable, gas may be liquefied (LNG) and transported by special tankers, but this is not a usual option for offshore operations. Pipelines can be used both for natural gas and liquid hydrocarbons.

Production facilities using tankers have flow lines which run along the sea floor where a mooring for a tanker is installed at a safe distance from the wells. In some cases, one tanker may be kept more or less permanently at the site to fill up or store liquid hydrocarbons. The hydrocarbons can be transferred rapidly to other tankers arriving on site for shipment” 12. [Offshore Production, Storage and Transportation
Number 3 of a series of papers on energy and the offshore, November 1998]

Even if oil is discovered it is highly unlikely that conditions would require a gravity-based structure like that at Hibernia. More likely a floating, rather than fixed, central platform like Terra Nova would be used. This will require sub-sea completions and flow lines to bring oil to the floating platform. If oil is found in relatively shallow water then Cohasset would probably be the model. The Cohasset Project has a central "jack-up" rig; light oil flows to it through seabed piping from the other wells, which are jackets installed on pilings in the seabed. Tankers then take the oil to onshore refineries.

If gas and condensate are discovered then development will probably proceed along the lines of the Sable Island Project. “SOEP's central Thebaud well will have a central processing jacket and staff quarters installed on the seabed. Remote wellhead platforms at each of the fields in the development feed into Thebaud by pipelines on the sea floor. There, gas and condensate will be de-watered and transferred by an undersea pipeline to mainland Nova Scotia.

SOEP and the Cohasset Project's products are similar to those likely to be found on Georges Bank; it seems probable that the facilities and overall designs of all three projects would be somewhat similar” 12. (Hydrocarbon Resources number 1 of a series of papers on energy and the offshore November 1998)

CHRONIC OIL RELEASES

CLAIM: Even if an oil spill or chronic pollution killed large quantities of fish eggs or larvae, no major effect on recruitment would be likely. 5

FACT: There is convincing evidence that chronic oil releases from oil production contaminates sediments. (Ward, Massie & Davies 1980) 6 they found evidence of sediment contamination with aromatic hydrocarbons within 30 km of oil rigs in the N. Sea. (See Charts 53.3 and 53.4 from Howarth 1987) 6.

They also found “decreases in both the number of individual animals and the number of animal species in sediments within 5 km of a storage platform in the Ekofisk field after 4 years of operation.” 6(Howarth 1987)

PRODUCED WATER

CLAIM: Dispersion models show that a 1,000-fold dilution occurs within 50 m of discharge. Therefore, the concentration of produced water in waters beyond the immediate vicinity of the discharge should be well below the acute toxicity levels (reported here) (> 1% of discharge concentration). 4 [(B) - Effects Of Produced Water On Early Life Stages Of Haddock, Lobster And Sea Scallop. P. Cranford, K. Querbach, G. Maillet, J. Grant, C. Taggart, And K. Lee Executive Summary 5 November, 1998]

FACT: Produced water is a chronic problem, with the total volume discharged greatly exceeding the volume of hydrocarbons produced. 4[ (B) - Effects Of Produced Water On Early Life Stages Of Haddock, Lobster And Sea Scallop. P. Cranford, K. Querbach, G. Maillet, J. Grant, C. Taggart, And K. Lee Executive Summary 5 November, 1998 ]

Produced water usually, but not always, is a brine with a concentration of dissolved solids up to nearly 10 times that of seawater. In addition, produced water can contain elevated levels of several metals (barium beryllium, cadmium, chromium, copper, iron, lead, nickel, silver and zinc (Neff 1987) 8. In the past, operators have been allowed to discharge 50 -70 micrograms/L of oil with formation water. This means they could legally release 400 tons of oil in a 60-million bbl field development.

Oil discharged in formation water is much less likely to evaporate than is spilled oil because it is more soluble and because it is released beneath the sea surface6” (Howarth 1987). The release of oil in formation water is estimated to have made up more than half of the chronic oil discharge in the N Sea (Read 1980) 6.

TANKERS

CLAIM: Tankers bringing oil ashore from Georges Bank will supplant tankers now used to import oil to New England. 6

FACT: “If refinery capacity permits there may be more total tanker traffic. However, even if OCS tankers replace the tankers now importing oil, the likelihood of oil spillage on Georges Bank would increase. Most tanker spills occur during loading and unloading or while tankers are approaching or leaving port and loading facilities. Loading on Georges Bank would likely result in more oil spillage there.” 5 (Howarth 1987)

Most of the small spills associated with oil production in the N. Sea have occurred during the loading of tankers.” Small spills may be as frequent as one spill in 5 loadings6. (Howarth 1987)

.
PIPELINES

CLAIM: Canadian and US companies are world leaders in safety reliability, leak prevention and environmental practices. According to the Transportation Safety Board (TSB) statistics, The accident rate on pipelines is miniscule compared with railway, highway and air transportation. Despite the diligent efforts of pipeline companies. Accidents do happen.

FACT: In Canada, there are typically 30 to 40 failures each year on pipelines regulated by NEB, most of them leaks rather than ruptures.

Offshore in 1992 alone, there were 54 fires, explosions, blowouts and other mishaps reported to the Minerals Management Service (MMS) which oversees activities on the outer continental shelf. In the Gulf of Mexico where pipelines are ubiquitous there were 98 accidents reported to the MMS in 1995, an increase of 58% over the previous year.

CLAIM: Oil companies can explore and develop
without having a significant impact on the environment. [Yarmouth Chamber of Commerce Offshore Oil and Gas Conference October 1998]

FACT: Oil companies will say and do whatever is necessary to get approval to explore and develop hydrocarbons. In Long Beach Calif. after residents objected to activities along the coast they resorted to camouflage of the entire operation. To shield the islands' oil operations from public view, designers carefully disguised the oil drilling rigs “as high rise buildings, placed well heads and other support facilities below ground level, and masked other industrial installations on the islands with palm trees, concrete sculptures, waterfalls, and colorful night-lighting.
These fields still leak oil and have had dramatic impacts on the California coastline.
If multinationals are willing to completely camouflage a giant offshore oil field in the US, what would they be prepared to say and do in order to gain access to Georges Bank?


David Lincoln
Environmental Consultant
January 1, 1999



MAJOR SOURCES

1. Backus, Richard H. and Donald W.Bourne ed. 1987 Georges Bank. MIT Press

2. Adams, N.J. and L.G. Kuhlman, Neal Adams., Houston
How to Prevent or Minimize Shallow Gas Blowouts (parts 1 &2). Firefighters, Inc (World Oil-May and June 1991)

3. Cranford et al 1998(A).Effects Of Water Based Drilling Mud On Early Life Stages Of Haddock, Lobster And Sea Scallop. P. Cranford, K. Querbach, G. Maillet, J. Grant, C. Taggart, And K. Lee Executive Summary 5 November, 1998

4. Cranford et al 1998 (B). Effects Of Produced Water On Early Life Stages Of Haddock, Lobster And Sea Scallop. P. Cranford, K. Querbach, G. Maillet, J. Grant, C. Taggart, And K. Lee Executive Summary 5 November, 1998

5. DFO. 1998. Assessment of the Possible Environmental Impacts of Exploratory Activities on Georges Bank Aquatic Resources. November, 1998

6. Howarth, Robert W. 1987 “Potential Effects Of Petroleum On Marine Organisms On Georges Bank” In Georges Bank ed. by Backus, Richard H. MIT Press

7. Mobil. 1976 Sable Island Development Plan

8. Neff, Jerry M.,1987 “Potential Effects Of Drilling Effluents On Marine Organisms On Georges Bank” In Georges Bank ed. by Backus, Richard H. MIT Press

9. Tsui, Philip T.P. 1998 The Environmental Effects Of Marine Seismic Exploration On The Fish And Fisheries Of The Scotian Shelf. Mobil Resources Corporation

10. Hydrocarbon Resources number 1 of a series of papers on energy and the offshore November 1998)

11. Exploring for Offshore Oil and Gas number 2 of a series of papers on energy and the offshore November, 1998

12.Offshore Production, Storage and Transportation
Number 3 of a series of papers on energy and the offshore, November 1998]

13. Regulation, Number 4 of a series of papers on energy and the offshore, November 1998

14. Petroleum Communication Foundation, 1993. Our Petroleum Challenge.

15. http://www.oilspill.state.ak.us/herring.html