# Unexamined Risks, Unacceptable Consequences 

# OIL SPILL PREVENTION and 

# RESPONSE IN THE U.S. ARCTIC OCEAN(Photo credits for cover, clockwise from le ! : Oil rig, Stockbyte/Getty Images; spectacled eider, U.S. Fish and Wildlife Service; children, Burgess Blevins/Getty Images; bearded seal, Brendan Kelly. Background ice photo: Nuka Research and Planning LLC.)

# OIL SPILL P R EVENTI O N and R E S P O N S E

I N THE U.S. ARCTIC OCE A N :
Unexamined R isks , Unacceptable C onsequenc es

N o vember 2010

Report Prepared by: Nuka Research and Planning Group, LLC Pearson Consulting, LLC Commissioned by: U.S. Arctic Program, Pew Environment Group

Scientific peer review conducted by three experts in oil spill response, oceanography and Arctic marine ecology.i OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



## Acknowledgments

We wish to thank three individuals for reviewing this report in its ! nal draft form: Nancy Bird, Prince William Sound Science Center; Rolf Gradinger, University of Alaska Fairbanks; and one anonymous reviewer. These individuals were asked to review the draft because of their diverse perspectives and technical expertise. The purpose of this independent review was to provide candid and critical comments on the analysis and reasoning contained in the report to assist the Pew Environment Group in making it as sound as possible. Although these reviewers provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations, nor did they see the ! nal report before its release.

We also wish to thank the many people who helped make this report possible:

• Nuk a Research and Planning Group LLC sta " , especially lead authors Elise De Cola and Tim Robertson, and designer Kathleen George.

• L eslie Pearson of Pearson Consulting LLC, for her role as a lead author.

• U .S. Arctic Program sta " , who helped write and develop the report and policy recommendations: Raychelle Daniel, Mary Engel, Steve Ganey, Marilyn Heiman, Eleanor Hu # nes, Eleanore Humphries, Henry Huntington, Melissa Prior and Marlyn Twitchell.

• F or additional editing and layout, we thank the Pew Environment Group’s Publications team: Carol Hutchinson, Jerry Tyson and Liz Visser.

• And ! nally , Susan Harvey, Andrew Hartsig and Eric Jorgensen, who reviewed drafts of the report and provided
extensive constructive criticism.ii N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group 

# CONTENTS

E xecutive Summary 1
C hapt er 1: I n troduction 3
1.1 P urpose and Scope 3
1.2 B ackground 4
1.3 K ey Concepts 5
1.3.1 The Arctic Ocean Is Di ff erent From Other Areas of the U.S. OCS 5
1.3.2 G overnment and Industry Oil Spill Plans Underestimate Blowout Risks 6 1.3.3 An Oil Spill C ould Devastate the Arctic Ecosystem 7 1.3.4 Oil Spill R esponse Systems Are Unproved in the Arctic Ocean 8 1.3.5 An Oil Spill R esponse Gap Exists 8
1.4 P olicy Recommendations 9
C hapt er 2: T he U .S. Arctic Ocean 11
2.1 C haracteristics of the Arctic OCS Environment 11 2.1.1 Clima te 11
2.1.2 S ea Ice 15
2.2 Transportation Infrastructure 20
C hapt er 3: Oil E xploration, I nfr astructure and P r oduction Operations and Spill R isks in the A rctic Ocean 27 3.1 Historical Perspective on Oil and Gas in the Arctic Ocean 28
3.1.1 Worldwide 28
3.1.2 Unit ed States Arctic Ocean
3.2 O il Exploration and Production Operations 3.2.1 Explor atory Drilling
3.2.2 Oil P roduction
3.3 C hallenges to Oil Exploration and Production in the Arctic Ocean
3.3.1 Seasonal Ice
3.3.2 Ex treme Storms
3.3.3 I nfrastructure and Logistics
3.4 P otential for Blowouts and Oil Spills from Exploration and Production in the U.S. Arctic Ocean
3.4.1 Well Blowouts
3.4.2 O ther Spills from Oil Production Operations
C hapt er 4: I mpac t of Oil Spills on Arctic E nvironment and E c ology
4.1 F ate and Behavior of Oil Spilled in Arctic Waters
4.1.1 Weathering and Emulsification
4.1.2 Oil-Ic e Interactions
4.1.3 P redicting the Fate of Oil in Sea Ice
4.1.4 L ong-Term Fate of Oil Spilled in Cold-Water Environmentsiii OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences

4.2 Vulnerabilities of the Arctic Ecosystem to Oil Spill Impacts
4.2.1 Oil Toxicity
4.2.2 P ersistence of Oil Spilled in the Arctic
4.3 I mpact of Oil Spills on the Arctic Environment, Ecology and People 4.3.1 Lower Trophic Level Species
4.3.2 F ish
4.3.3 M arine Mammals
4.3.4 Bir ds
4.3.5 P eople
C hapt er 5: L imitations of E xisting Oil Spill R esponse T echnolo gies in the U.S. Arctic Ocean
5.1 A rctic Ocean Challenges
5.2 S topping a Subsea Well Blowout
5.2.1 Subsea Well Containment and Control
5.2.2 R elief Wells 5.2.3 Challenges t o Well Control in the U.S. Arctic Ocean
5.3 A pplying Oil Spill Cleanup Methods in the Arctic Ocean 5.3.1 Spill Tracking, Surveillance and Modeling
5.3.2 M echanical Recovery Methods
5.3.3 I n-Situ Burning 5.3.4 Dispersan ts 5.4 R esearch and Development to Improve Oil Spill Response in Arctic Waters
5.4.1 Join t Industry Program on Oil Spill Response for Arctic Waters
5.4.2 F ield Exercises and Oil Spill Drills in the U.S. Arctic Ocean
C h apter 6: Gaps in Oil Spill P r evention P l anning, R e sponse C a pacity and Oversight in the U.S. Arctic Ocean 6.1 A rctic Oil Spill Response Gap
6.1.1 R esponse Limit Estimates for U.S. Arctic Ocean
6.2 G aps in Oil Spill Response Planning for the U.S. Arctic Ocean 6.2.1 Oil Spill C ontingency Planning for Chukchi Sea Leases
6.2.2 P lanning Assumptions in Shell’s Chukchi Sea Oil Spill Contingency Plan
6.2.3 G aps in Response Capacity for Subsea Well Blowout in the Chukchi Sea
6.2.4 G aps in Planning and Response Capacity in the Beaufort Sea
C hapt er 7: R ecommendations
7.1 I mprove Arctic Oil Spill Science, Monitoring and Assessment
7.1.1 Close the K nowledge Gaps Regarding Arctic Oil Spill Impacts
7.1.2 I mprove Spatial Data on Environmental Sensitivities
7.1.3 D evelop Arctic Oil Spill Trajectory Models
7.1.4 C onsider Cumulative Impacts of Oil Exploration and Production in Arctic OCS
7.2 A ssess and Plan for Worst-Case Blowout Risks
7.2.1 C onduct Risk Assessment
7.2.2 R equire More Realistic Worst-Case Blowout Scenarios 7.2.3 Improve Oil Spill Prevention Technologies for Arctic Exploration and Productioniv N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group 7.3 Improve Arctic OCS Oil Spill Response Capacity 7.3.1 Assess Existing Oil Spill Response Capacity for Oil Spills in Arctic OCS
7.3.2 R equire Operators to Demonstrate Oil Spill Response Capabilities During Agency-Led Field Exercises
7.3.3 I mprove On-Water Oil Spill Response Systems and Techniques for Arctic OCS Conditions
7.4 C onduct an Arctic OCS Oil Spill Response Gap Analysis
R eferences
A ppendixes
A ppendix A: Acronyms and Abbreviations Appendix B: Glossary



## L ist of Figures
Figure 1-1. U.S. Arctic O C S R egion
F igure 1-2. Arctic C oastline

. F igure 2-1. M ajor A rctic Ocean Storm System During October 2004
F igure 2-2. E rosion of the Arctic Ocean Shoreline Area
F igure 2-3. Arctic Ocean Fog
F igure 2-4. T ypic al Sea I c e Freeze-Up and B reakup C y cle
F igure 2-5. U.S. Arctic Ocean Sea I c e M aps F igure 2-6. Shore-Fast I c e B et ween B arr ow and P oin t B arr ow F igure 2-7. Surface of P ack I c e in the U.S. Arctic Ocean

. F igure 2-8. Satellite I mage S howing I c e Zones in the U.S. Arctic Ocean
F igure 2-9. I mages fr om E arly July I c e B reakup, P oin t B arr ow, Alaska, 2010
F igure 2-10. C hanges t o September I c e C o verage in the Arctic, 1979-2009
F igure 2-11. Airstrips, P or ts and R oads in the U.S. Arctic
F igure 2-12. Wainwright, Alaska, Aerial P hotograph
F igure 2-13. Overland T r ansportation Options in the U.S. Arctic During Winter
F igure 2-14. L ack of M ajor Do cks or P or ts in the U.S. Arctic Ocean
F igure 2-15. Distance from B arr ow, Alaska (in U.S. Arctic Ocean), to N ear est M ajor P or t (Dutch H arbor) and N ear est C oast G uard Air Station (Kodiak) Figure 3-1. Arctic Oil and Gas P r ovinces and B asins , Showing E xisting and P ending P r oduction in the Arctic Ocean Worldwide
F igure 3-2. E xploration Wells Drilled in the U.S. Arctic Ocean Figure 3-3. E xisting and N ear-F uture Oil P r oduction in the B eauf ort Sea
F igure 3-4. M ap of A ctive L ease A reas in Arctic O C Sv OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences

Figure 3-5. V arious E xploratory Drilling C on fi gur ations
F igure 3-6. T he K ulluk Drill Ship
F igure 3-7. E xample of Gravel I sland- B ased P r oduction in P r udhoe B a y Figure 3-8. T he U .S. C oast G uard L aunching a V essel in the S hallow Waters N ear B arr ow, Alaska
F igure 3-9. M ajor Well B lowouts
F igure 4-1. Open L ead N ear P oin t H op e, Alaska
F igure 4-2. Oil- I c e I n teractions
F igure 4-3. E xample of I c e Formations
F igure 4-4. U.S. Arctic Ocean H abitat for Seabirds T ha t M igr ate to Other Areas of Alaska
F igure 4-5. T he I mpac t of Oil on Wildlife
F igure 4-6. E xposure P a thways to Oil T o xicity
F igure 4-7. T ypic al Arctic M arine F ood Web
F igure 4-8. P olar B ear on I c e F igure 4-9. L o wer T r ophic L e vel Species
F igure 4-10. Whales in I c e F igure 4-11. B o whead Whale M igr ation R outes and C onc entration.
F igure 4-12. H er d of P aci fi c Walrus H auled Out on Sea I c e F igure 4-13. Arctic Seabirds Figure 4-14. C ultur e and Subsistence Figure 5-1. Subsea Well C on tainment System P r oposed for Use in Gulf of M e xico
F igure 5-2. Oil Spill T r acking and Surveillance M etho ds in Arctic Ocean
F igure 5-3. T ypic al On-Water M echanic al R ecovery System
F igure 5-4. Skimmers
F igure 5-5. Stationary Deployment of a Weir Skimmer During T r aining E xercise
F igure 5-6. I c e I n terference
F igure 5-7. T ypic al On-Water I n-Situ B urning Operations
F igure 5-8. Smoke P lume from I n-Situ B urn T est
F igure 5-9. T ypic al Dispersant Application and M onit oring Operations Figure 5-10. Dispersant Application
F igure 5-11. SINTE F J IP C on trolled Study with P r e- P ositioned B o oms and R esponse F igure 5-12. E xample of T ank T est f or M echanic al R ecovery of Oil Spilled in Sea I c e F igure 5-13. 2000 B roken I c e E xercise in B eauf ort Sea
F igure 6-1. I c e Obstaclesvi N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group 

## L ist of T ables

T

able 2-1. A rctic C onditions T ha t M a y A ff ect Oil E xploration and P r oduction Activities
T

able 3-1. E xploration Wells Drilled in the U.S. Arctic Ocean, 1970s-1990s
T

able 3-2. A lphabetical L ist of M ajor Well B lowouts T hr ough 2010
T

able 4-1. O il Weathering P r ocesses A ff ected by Sea I c e T

able 4-2. T hr eatened and E ndangered Species Found in the U.S. B eauf ort and C huk chi Seas
T

able 5-1. T ypic al Arctic C onditions and P ot ential I mpac ts on Spill R esponse Options
T

able 6-1. M a trix of Approximate Oil Spill R esponse L imits
T

able 6-2. E nvironmental Factors A ff ecting Operational L imitations in the U.S. Arctic Ocean

T

able 6-3. R esource R equirements and Operating L imitations2 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### 2. I mprove spatial data and mapping of Arctic species, habitat and sensitive ecosystems.
3. D evelop oil spill trajectory models with the capability to model oil fate and behavior in the presence of a range of sea ice conditions.

4. R equire operators to plan for the possibility of a worst-case well blowout and adopt all available engineering and management measures to prevent blowouts.

5. C onduct full-scale deployment exercises under a range of o " shore Arctic conditions to determine the limits for safely and e " ectively mounting a large-scale o " shore response in the U.S. Arctic Ocean.
6. C onduct an Arctic oil spill response gap analysis to delineate the upper operating limits of existing response technologies in the U.S. Arctic Ocean and then estimate the frequency and duration of periods when no oil spill response may be feasible.

2 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences11 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### for people and equipment operating in the U.S. Arctic, where the average annual wind speed is 12 mph. When the temperature is 30 degrees, a 12-mph wind creates a wind chill of 20 degrees; at 13 degrees, a 12-mph wind creates a wind chill of minus 1 degree (Western Regional Climate Center 2009a and 2009b).

T

able 2-1. Arctic C onditions T ha t M a y A ff ect Oil E xploration and P r oduction Activities (AMAP 2008a, MMS 2007b and Grebmeier et al . 2010).

Characteristics RelevancePhysicalEnvironment Cold Di # cult work conditions, particularly in winter; slow weathering of oil compounds. Light/dark regime Limited visibility and di # cult work conditions in winter; extreme seasonality of biological production.
Sea ice Di # cult site access and di # cult operating conditions for vessels. Oil spill response systems may be ine " ective. Spilled oil di # cult to locate and track; may migrate with ice $ oes or become trapped/frozen.
Wind and sea state Hurricane-force storms in fall. Sea states producing up to 20-foot waves.BiologicalEnvironment Seasonal aggregation of animals Major impacts possible even from localized spills or other disturbances.

Migration Impacts in the Arctic a " ect other parts of the world, and impacts elsewhere a " ect the Arctic.
Short and e ffi cient food webs Disruption to key species may have cascading e " ects for other species.HumanEnvironment Remote, limited access Di # cult to reach by air, water or land during emergency or oil spill, with limited capacity to transport equipment and personnel.
Limited infrastructure Lack of resources to support major spill response or other sudden in $ ux of personnel and equipment. Small population Signi ! cant demographic changes from industrial activities; in $ ux of people from other places to support activities. Indigenous people Impacts to subsistence food supply with potential for entire communities to face starvation conditions; impacts on local livelihood, culture, environment and indigenous rights and interests, including landownership.



### The predominant summer winds in the U.S. Arctic Ocean are from the east and northeast, with speeds of 10 to 25 mph, but the major storm winds blow from the southwest, a direction that gives them maximum fetch (open-water distance over which to blow uninterrupted) for the southwest-facing coastline of the Chukchi Sea. The Beaufort Sea is more protected. The higher wind speeds progress northward beginning in the Bering Strait in June and continuing into the U.S. Arctic Ocean from July to October. In November and December, the maximum winds in the area start to decrease with a southward migration into the Chukchi Sea and eventually back through the Bering Strait into the Bering Sea, coincident with the sea ice retreat and advance in the area. The maximum daily average wind speed 2 

### for Barrow is highest in October (44 mph), November (40 mph) and December (35 mph). The yearly variance of wind speeds follows a similar

2 The maximum daily wind speed is the maximum speed measured over a 24-hour period.14 N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group 

### 2.1.2 Sea Ice
S ea ice coverage varies by season and location. In the U.S. Arctic Ocean, sea ice is typically present eight months of the year, from October to June. During the summer, the Beaufort and Chukchi seas experience a period of open water (predominantly ice-free, though scattered sea ice may be present) lasting approximately three months in the Beaufort and four months in the Chukchi. The brief ice-free summer ranges from late June to late October, depending upon location, distance from shore, and the conditions of each year. The Chukchi Sea tends to break up before the Beaufort and freeze up afterward. Sea ice formation and melting are cyclical, with ice taking on di " erent forms (Figure 2-4). Freeze-up begins with “frazil” ice forming ! rst as small pieces in open water. As frazil ice gradually thickens, it forms “grease” ice and “pancake” ice. Sheets of pack ice typically form by late October and persist until spring (late May into June). Breakup begins in June or July.
Figure 2-4. Typical Sea Ice Freeze-Up and Breakup Cycle— Sea ice formation and deformation are cyclic. ! e process through which sea ice begins to form on open water is dynamic and gradual, and ice conditions may vary and change considerably within a relatively small geographic area. Ice less than 10 cm thick constitutes new ice and includes “frazil,” “grease” and “pancake” ice formations that build layers to form the pack ice. As solar radiation increases, melt ponds appear, melting accelerates, and cracks form, and eventually the ice disintegrates.



### Throughout the eight- to nine-month ice season, solid or “fast” ice extends from the surface to the seabed at shallow depths and may continue out to water depths of 50 to 100 feet, where it transitions into what is known as a shear zone. The shear zone is a highly variable area where ridging and rubble occur (Eicken et al. 2006). Seaward of the shear zone is pack ice, which may encompass many types of sea ice. Pack ice contains young ice (newly formed and typically less than 30 cm thick), ! rst-year ice and multiyear ice that has survived the previous summer melt season and can measure up to 10 meters thick (Arctic Council 2009). Figure 2-5 shows typical ice coverage for the U.S. Arctic Ocean based on satellite ice observations from four dates during 2007. Figures 2-6 and 2-7 show examples of Beaufort and Chukchi sea ice coverage. ,&(

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 U.S. Arctic Program, Pew Environment Group 

### A combination of factors, including decreasing production from existing reservoirs, new oil exploration technologies and reductions in Arctic ice coverage, have led to recent increases in oil activities in the Arctic Ocean. Exploration and production from marine facilities farther o " shore in the Arctic Ocean create challenges for operators (Arctic Council 2009 and AMAP 2008a).



### 3.1.2 United States Arctic Ocean In the U.S. Arctic, oil exploration began in the 1960s and production began in 1977, 10 years after the discovery of the Prudhoe Bay oil ! eld. That year, the Trans-Alaska Pipeline System (TAPS) was completed, connecting Prudhoe Bay production units with a major oil terminal in Valdez, Alaska. The majority of the existing oil production infrastructure and oil ! elds in northern Alaska are on land and in state waters of Prudhoe Bay in the Beaufort Sea. Although oil production in the U.S. Arctic Ocean remains clustered in state and nearshore federal waters in Prudhoe Bay, some exploration drilling has taken place in federal waters farther o " shore in the Beaufort and Chukchi seas. Exploratory drilling in the Arctic OCS was most prevalent from the mid-1970s to the mid-1980s. Figure 3-2 shows sites where exploratory drilling has been conducted in the U.S. Arctic Ocean. A few of those exploratory drilling projects resulted in production from state and federal waters in the U.S. Beaufort Sea from arti ! cial islands near Prudhoe Bay (Figure 3-3). There are no production operations in the Chukchi Sea. Exploration activities in the Arctic OCS declined during the 1990s and into the 2000s. Although lease sales continued during this period, little exploratory drilling resulted. There is no concise explanation for this trend, but it is reasonable to assume that declining oil prices contributed to an economic disincentive to continue exploration in these frontier seas. No new exploratory drilling has taken place in the Chukchi Sea since the early 1990s. In 2008, the MMS held Lease Sale 193, and as a result of that sale, oil companies leased 2.75 million acres in the Chukchi Sea. Several active leases exist in the Beaufort Sea from past lease sales (Figure 3-4). Exploratory drilling was planned for the Chukchi and Beaufort seas in 2010 but was put on hold because of Interior Secretary Ken Salazar’s decision not to approve ! nal drilling permits in the wake of the Deepwater Horizon disaster. 2

2 S everal conditions probably must be met before Shell can proceed with exploratory drilling in the Chukchi Sea: (1) the Interior Department must ! nalize its revised ! ve-year leasing program for 2007-2012; (2) Interior must completeadditional analysis of Lease Sale 193 to comply with a federal district court order; (3) Interior must approve Shell’s application for a permit to drill; and (4) the Environmental Appeals Board (an independent body within the Environmental Protection Agency) must issue a decision on Shell’s air permit under the Clean Air Act.30 N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group 

### 3.2 O il Exploration and Production Operations
This section describes the basic mechanics of oil exploration (test drilling into a formation to determine whether the petroleum resources in that formation are viable to extract) and production (drilling into a previously tested or explored reservoir to bring oil to the surface for processing, storage and transport). Exploratory drilling and subsequent oil production may be conducted from land, concrete drilling islands or water. Drilling con ! gurations di " er depending upon their location. For drilling in Arctic waters, the water depth, seasonal ice conditions and distance from land are all considerations. The discussion here focuses on drilling technologies for use in Arctic waters and explains how the Arctic marine environment can limit or impair drilling operations.


### 3.2.1 Exploratory Drilling Exploratory drilling rigs use diesel engines to generate power to turn a drill bit, which cuts through the surface and the rock beneath with the help of hydraulic nozzles that spray large volumes of drill $ uids pumped down from the surface. As the well bore is extended, the hole is periodically cased with metal pipe (known as casing) inserted into the borehole and cemented into place. Drilling $ uids, known as drilling mud, are pumped down the center of the drill string, which refers to sections of pipe that are added as the bit descends. The drilling $ uid, which lubricates the drill string, removes the cuttings and holds back formation pressure, returns to the surface in the annular space between the drill string and the casing or borehole for cleaning and reuse. The hydrostatic weight of the drilling mud is the ! rst barrier to prevent any oil or gas in the formation from intruding into the well. Drilling engineers design drilling mud systems with su # cient weight to control the subsurface pressure expected for the oil reservoir, but it is not always possible to predict the exact magnitude of the subsurface pressure, especially when drilling an exploration well in a previously unexplored area (National Research Council [NRC] 2003b). If the subsurface pressure exceeds the pressure imposed by the column of drilling mud in the well bore, the reservoir formation $ uids (e.g., oil and gas) will $ ow into the well bore in what is known as a kick. A kick can eventually $ ow to the surface, potentially causing a blowout (an uncontrolled $ ow of oil and gas from the well). To prevent a kick from becoming a blowout, drilling rigs are equipped with heavy-duty valve assemblies called blowout preventers (BOPs) attached to metal casing cemented into the well bore. Properly designed blowout prevention systems should control excess pressure at the wellhead, but underdesigned or malfunctioning systems may fail to contain the excess pressure, resulting in a release of drilling mud and hydrocarbons. Three types of structures have been used to support Arctic exploratory drilling in the United States and other countries: (1) arti ! cial islands constructed of gravel or spray ice (winter only); (2) bottomfounded or gravity-based platforms such as the Concrete Island Drilling Structure (CIDS); and (3)31 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### $ oating drill ships (Masterson et al

. 1991). 3 

### Arti ! cial islands and bottom-founded drill structures are generally used in shallow water (less than 75 feet). Bottom-founded or gravity-based platforms are massive, dense structures anchored to the ocean bottom by a concrete base with wells drilled through it. Bottom-founded drilling is usually limited to water depths of 100 feet or less, but work is under way to engineer deeper structures. Drill ships can work in water thousands of feet deep (Paulin et al . 2010, Matskevitch 2007). Figure 3-5 shows examples of drilling con ! gurations. One important di " erence between bottom-founded drilling structures and $ oating drill ships is the location of the BOPs. In the bottom-founded structures, BOPs are located above water in an accessible location. In $ oating drilling operations, the subsea BOP is located on the sea $ oor and can be accessed only with divers or remotely operated vehicles. Subsea BOPs are more complicated to activate and harder to inspect and test. In the event of a blowout, subsea BOPs are more di # cult to access and control. Figure 3-5. Various Exploratory Drilling Con fi gurations— ! e blowout preventer sitting on the sea " oor was the type used with the Deepwater Horizon.

3 N ote that Masterson et al. (1991) also discuss jack-up rigs, which are mobile rigs that balance on the sea $ oor by resting on support legs and can be used in water depths of up to 500 feet but are not generally suited for ice-infested waters. Masterson notes that jack-up rigs may be ice-reinforced and adapted for Arctic use in the future, but this has not occurred. Drilling from Floating Platform Gravel Island Drilling Bottom-Founded Drilling Onshore Drilling O ! shore – Deep Water Nearshore – Shallow Water Onshore

Drill ShipWell CasingWell CasingWell Casing Land-Based Drilling RigWell Casing Onshore Drilling Rig On-Bottom Drilling Platform

= Blowout Preventer Typically < 100 ft Typically > 100 ft34 N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group 

### Until recently, bottom-founded production was not considered feasible when water depth exceeded 75 to 80 feet (Masterson et al

. 1991), although new gravity-based designs allow production in water depths of up to 250 feet (Ho " et al

. 1994, Matskevitch 2007). If oil production were to commence in the U.S. Arctic Ocean in areas where water depths were above the 75- to 80- foot threshold, the production operations would require some adaptation of those typically used for o " shore production in temperate regions: 1) a subsea completion and tieback to a shore-based processing center; 2) a gravity-based (bottom-founded) structure; or 3) a $ oating production, storage and o " -loading facility. None of these types of structures have been constructed or tested in the deeper areas of the U.S. Arctic Ocean. In a subsea completion, wellheads are located on the sea $ oor, manifolded together, and the produced oil/water/gas is piped directly to an onshore processing center. Subsea completions are not easily accessed to test or repair once the drilling rig has moved from the location. Gravity-based production operations produce oil from subsea wells through the bottom-founded concrete structure, and oil is processed and stored onboard. Produced oil would probably be transported from the structure via subsea pipeline. A gravity-based structure in the U.S. Arctic Ocean would have to be constructed to withstand millions of tons of moving ice.



### 3.3 C hallenges to Oil Exploration and Production in the Arctic Ocean
Exploration or production from $ oating structures in the Arctic Ocean, which would be conducted during the brief Arctic summer, must still overcome a number of obstacles.



### 3.3.1 Seasonal Ice The short open-water season compresses the exploratory drilling season for operators using a drill ship. Even during the summer, ice $ oes may be encountered, making it necessary for $ oating operations to have some contingency for dealing with unexpected or encroaching ice. Ice management strategies must be able to handle ! rst-year ice and must be prepared to deal with multiyear ice, should it encroach on drilling or production sites (Keener and Allan 2009, Hinkel et al. 1988). During the frozen winter, the drill ship and associated support vessels must either be moved o " site or closed in and left on site. Any equipment left over the winter must be ice class and able to withstand severe icing and tolerate temperatures to minus 40 degrees Fahrenheit. Ice can scour 4 

### subsea wellheads or pipelines in shallower water, requiring an extra level of precaution to prevent ice scours from damaging wells. Drill ships, $ oating processors and associated vessels will need to be able to overwinter in an emergency, in case ice conditions cause them to be iced in before they can be moved out of the region (Keener and Allan 2009).

4 Ice scour ing, sometimes referred to as ice gouging, occurs when collisions between fast (moving) ice and pack ice create physical abrasions along the sea $ oor.35 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### During exploratory drilling in the Arctic OCS in the 1980s and 1990s, several wells took two seasons to complete. Reasons for the delays included ice conditions in the Beaufort and heavy weather in the Chukchi. Whale migration also caused a suspension of drilling activities because of permit requirements imposed on the drilling companies. In an article documenting past exploration activities in the Arctic OCS, Regg and Kuranel (1992) describe challenges encountered during the 1991 drilling season: “In 1991, severe ice was responsible for delaying the start of drilling operations in the eastern Beaufort Sea until mid-September. This shortened the already limited drilling season to roughly 30 days. Chukchi Sea operations were initiated earlier (mid-July), but were continuously plagued by hazardous ice ! oes moving through the area and occasional heavy weather causing excessive vessel motion.”



### 3.3.2 Extreme Storms Severe storms are common in the fall and early winter in the U.S. Arctic Ocean and may overlap with the end of drilling season for $ oating o " shore production; global climate change may exacerbate the frequency or intensity of these storms (IARC 2015). During the months when the Arctic Ocean is ice-free, high winds and storms may drive higher sea states, with wave heights approaching 30 feet.



### 3.3.3 Infrastructure and Logistics Logistical challenges of the U.S. Arctic Ocean necessitate self-su # ciency because of limited support and infrastructure in many areas. All of the equipment required for exploratory drilling and production—well casings, drill strings, mud, cement, diesel fuel and associated drilling equipment, as well as the people required to operate this equipment—must be transported to the drilling site by air, land or sea. In the Arctic OCS, the basic logistics associated with supporting $ oating production are complicated by a lack of transportation infrastructure (NRC 2003b). A shift from exploration to production in the OCS will require development of waste-disposal and water-treatment programs (and possibly facilities), transportation of power generation sources, construction of additional infrastructure, and establishment of residential facilities for production workers. Logistical support requirements for the life cycle of an oil production facility are substantial, including on- and o " -road vehicles, aircraft ( ! xed and rotary wing), vessels of various types and sizes, and trained personnel. The ecological footprint of all these activities is signi ! cant, and in addition to the risk from oil spills, exploration and production activities also a " ect air and water quality (NRC 2003b). Oil exploration activities in the Beaufort Sea are concentrated during the winter season, because the logistical requirements of drilling activities are more easily met during the winter by building ice roads, pads and ice airstrips. A shift to $ oating exploration or production operations, which would be focused during the summer months, will require the development of new transportation methods and corridors and has the potential to be more environmentally damaging (NRC 2003b).38 N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group T

able 3-2. A lphabetical L ist of M ajor Well B lowouts T hr ough 2010 (Source: Oil Rig Disasters 2010, ADN 2008) —Though infrequent, well blowouts do occur. A review of major well blowouts worldwide shows that at least one blowout has occurred in most years since the mid-1970s. In the past decade alone, 16 well blowouts have been documented worldwide, two of which resulted in a major oil spill. Well blowouts resulting in reported oil spills are shaded in gray; blowouts that occurred in the United States are shown in bold text. *Key: DS—Drill Ship, JU—Jack-Up Rig, LR—Land Rig, P—Platform, SS— Semisubmersible, S—Ship

R ig N ame / Well N ame Year L o cation Spill Size R ig T yp e* C ommen ts

Actinia 1993 Vietnam SS Major release

Adriatic IV 2004 Mediterranean Sea, Egypt JU Fire destroyed rig and platform; gas blowout

Al Baz 1989 Nigeria JU Burned and sank, ! ve fatalities
Arabdrill 19 2002 Saudi Arabia JU Fire destroyed rig and platform

Atlantic No. 3 1948 Alberta, Canada LR Major release, ! re; blowout lasted six months Banjar Panji-1 2006 Java, Indonesia LR Mud volcano, major release
Beaver Creek 1A 1967 Cook Inlet n/a Gas to surface Beluga River 212-35 1962 Cook Inlet n/a Gas to surface

Blake IV/Greenhill 1992 Gulf of Mexico 72,000 to 112,000 gal. JU Major release, ! re

Bohai 3 1980 — JU Fire, 70 fatalities
Cerveza 1983 — P Abandon
Cirque No. 1 1992 North Slope n/a Gas to surface during exploratory drilling Cook Inlet State No. 1 1962 Cook Inlet n/a Gas to surface, exploration well

C.P. Baker 1964 Gulf of Mexico DS Catamaran type, explosion and ! re, 22 fatalities CPF1-23 1979 Kuparuk Field n/a Gas to surface

Deepwater Horizon 2010 Gulf of Mexico 4.9 million barrels (bbl) Three months required to control blowout; fi ve months to complete relief well Drake Point L-67 1969 Canadian Arctic LR Ice volcano
Eko ! sk B 1977 Norwegian CS 202,000 bbl P Major release
Enchova Central 1984 Enchova Field, Brazil P Fire, lifeboat fell to sea, 37 fatalities
Enchova Central 1988 Enchova Field, Brazil P Destroyed by ! re
Ensco 51 2001 Gulf of Mexico JU Setting casing string, ! re
F-20 1986 Prudhoe Bay n/a Gas to surface
Funiwa Platform 1980 Nigeria 200,000 bbl P Major release; 14 days to control blowout
Glomar Baltic I 2001 Gulf of Mexico JU —
Glomar Grand Isle 1983 Indonesia DS Fire Grayling Platform (Trading Bay Unit) 1985 Cook Inlet, Alaska P Gas to surface

Gubik #2 1951 Umita, Alaska n/a Gas to surface during exploration drilling
Hasbah Platform 1980 Persian Gulf 100,000 bbl P Major release, 19 fatalities39 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences

R ig N ame / Well N ame Year L o cation Spill Size R ig T yp e* C ommen ts

I-23/Q-20 1994 Endicott, North Slope n/a Gas to surface

Ixtoc-I 1979 Mexico 3.5 million bbl JU Nine months to cap well
Jim Cunningham 2004 Egypt SS Fire
J-23 1987 Prudhoe Bay n/a Gas to surface
Kavik #1 1969 North Slope n/a Gas to surface during exploration drilling Keyes Marine 303 1990 Gulf of Mexico JU — King Christian D18 1970 Canadian Arctic LR Ice volcano
Little Bob 1968 — JU Fire o " La. Coral Drilling, seven fatalities Lodgepole 1982 Alberta, Canada LR Amoco, major H2S release, two fatalities Lusi Mud Volcano 2006 Java, Indonesia LR Mud volcano, major release

Maersk Endurer 1980 Gulf of Suez JU Derrick collapse, renamed EDC Setty, estimated three fatalities Maersk Giant 2006 Norwegian CS JU Shallow gas
Marine IV 2001 Gulf of Mexico JU —
MGS State 17595 No. 1 1962 Cook Inlet n/a Gas to surface, exploration well Mississippi Canyon 311A 1987 Gulf of Mexico P Platform tilted
Mobil Moquawkie No. 1 1965 Cook Inlet n/a Gas to surface, exploration well Moquawkie No. 4 2008 Cook Inlet n/a Gas to surface

Mr. Louie 1963 German CS JU Crater

Montara/West Atlas 2009 Timor Sea, Australia 30,000- 220,000 bbl JU Major spill; size estimates vary greatly; 74 days to drill relief well
NFX Platform A 1999 Gulf of Mexico P Fire
NGI-7 1976 Prudhoe Bay n/a Gas to surface Ocean King 2002 Gulf of Mexico JU Fire Ocean Odyssey 1988 UK CS SS Fire, one fatality
Penrod 52 1983 Gulf of Mexico JU Collapsed during blowout
Petrobras P7 2001 Bicudo Field, Brazil P Fire
Petromar V 1981 South China Sea DS Sank after blowout
Placid L10a 1983 SNS, NL P Corrosion
Pride 1001E 1997 Gulf of Mexico P Fire Ron Tappmeyer 1980 Saudi Arabia JU Hasbah platform blowout, 19 fatalities Saipem Paguro 1965 O " Ravena, Italy JU Destroyed by ! re Sea Quest 1980 Nigeria SS Sedco 135C, ! re, scuttled o " Nigeria
Sedco 135F 1979 Mexico JU Ixtoc-I—Capped 1980 Mar 23
Sedco 252 1989 Indian Coast JU Fire, three fatalities Ship Shoal 246b 1980 Gulf of Mexico P Killed after one day
Simpson Core Test #16 1948 North Slope n/a Gas to surface while drilling exploration well Simpson Core Test #26 1950 North Slope n/a n/a Oil release to surface while drilling exploration well40 N O V EMBER 2010

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R ig N ame / Well N ame Year L o cation Spill Size R ig T yp e* C ommen ts

Snorre A 2004 Norwegian CS P Seabed gas blowout
South Timbalier 26 1970 Gulf of Mexico P Platform lost, four fatalities
Steelhead Platform 1987 Cook Inlet, Alaska P Fire. Unocal, Penrod rig also lost, nine months to complete relief well Sundowner 15 1996 Gulf of Mexico P Fire Teledyne Movible 16 1989 Gulf of Mexico JU Total loss
Treasure Seeker 1984 Norwegian CS SS Shallow gas
Trinimar Marine W327 1973 Venezuela P Major release

Union Oil Platform A 1969 Dos Cuadras F, U.S. OCS 80,000 to 100,000 bbl P Major release, 11 days to control blowout; spill estimated at 80,000 to 100,000 bbl Usumacinta 2007 Gulf of Mexico JU Storm, major release, 22 fatalities Viking Explorer 1988 SE Borneo DS Explosion and sinking. Total Oil, four fatalities

Vinland 1984 Sable Island, N. Atlantic SS Shell, Uniacke G-72

West Vanguard 1985 Haltenbanken, Norway SS One fatality

Zacateca 1986 Mexico JU Sank. Perforadora Co Yum II / Zapoteca 1987 Gulf of Mexico JU PEMEX Zapata Enterprize 1985 Javan coast JU Fire Zapata Lexington 1984 Gulf of Mexico JU Fire, four fatalities Zapata Topper III 1975 Gulf of Mexico JU Sank o ff La.



### The potential oil spill volume from a blowout is equal to the volume of the reservoir that can $ ow to the surface until the well is controlled. Oil reservoirs may contain billions of barrels of oil and may continue to spill into the environment until the well naturally bridges on its own (plugs with sand or debris); until the well is controlled by human or mechanical intervention (e.g., capping the well, igniting the well, drilling a relief well); or until the subsurface reservoir pressure ! nally drops to such a level that the oil stops $ owing out. Although blowouts are very infrequent, they can last for days, weeks or months. Engineers design drilling operations and manage drilling $ uids to reduce the risk of a blowout. Drilling $ uid systems and blowout prevention systems are critical safety factors, particularly during exploratory drilling, when unexpected reservoir pressures may be encountered.
3.4.2 Other Spills from Oil Production Operations Oil spill risks from production operations tend to increase with the age of the equipment. As oil reservoirs age, the balance of $ uids extracted may change, with a higher ratio of produced water to produced oil, a combination that is typically more corrosive. Valves and piping may eventually corrode or erode and face a higher risk of failure or leakage. Saltwater can also corrode pipelines and oil production equipment from the outside in. Routine maintenance, inspection, repair and replacement programs help to reduce the risk of oil spills from production operations, but they never eliminate the risks. There may also be a tendency toward complacency in older production operations, a factor that can contribute to the risk of an accident or oil spill.41 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### As discussed in Section 3.4.1, a catastrophic blowout from a producing well would be the worstcase discharge during production, but several other sources could also cause a damaging spill. Any subsea pipeline used to transport oil from production wells to onshore facilities could experience a sudden breach that results in a rapid discharge of the pipeline contents. Small, undetected leaks from subsea pipelines can also be extremely damaging if they are undetected for long periods. Signi ! cant amounts of undetected oil can be spilled from pipeline leaks, as occurred in the largest oil spill from Alaska’s North Slope production operations in March 2006. In that incident, more than 200,000 gallons of crude oil were released to the environment onshore through a leak that went undetected for several days (Alaska Department of Environmental Conservation [ADEC] 2006). A release from a subsea pipeline that occurs when sea ice is present may spread under the ice or within ice $ oes or become incorporated into newly forming ice. A pipeline release at or above the waterline or a spill on land that travels to the water would discharge oil to the sea surface. It is critical that pipelines are designed with materials that are appropriate for the environment and length of expected service. O " shore pipelines experience higher external corrosion rates (saltwater exposure), have higher potential to harm the fragile o " shore environment, are typically hard to access during most of the year (e.g., buried subsea or under ice) and are more di # cult to inspect and repair. Pipelines installed in ice-laden waters must be properly designed and constructed with double walls, and in some cases it is necessary to bury the pipeline well below the seabed or protect the pipeline with a thick cement casing to avoid ice scouring. Pipelines must be protected from internal and external corrosion and erosive forces and should undergo routine maintenance, inspection, repair and replacement programs to ensure their integrity. In addition to spillage from transmission pipelines, oil may be spilled from storage tanks, facility piping or manifold valve systems on o " shore platforms, or from onshore storage tanks required along the pipeline route. The potential worst-case oil spill volume would be the volume of the tank or tanks or the volume of oil in the piping. The amount of oil discharged into the water depends on how much escapes secondary containment around the tanks and piping, and how quickly the leak is controlled. Spills from tanks associated with o " shore platforms may $ ow directly to the water or sea ice surface because these tanks typically have no additional containment around them. Prevention systems for o " shore storage tanks and piping may include use of double-walled piping, double-walled storage tanks and improved containment structures to capture and pump recovered $ uids before they reach water.
Increased vessel tra # c associated with oil production may also present additional spill risks. Oil tankers or barges pose a spill risk during oil transfer operations and while in transit. The potential spill volume from a tanker or other vessel ranges from a small spill during oil transfer to a complete cargo loss. Vessel spills pose an additional response challenge because they can occur anywhere along the vessel route. A vessel spill may release hydrocarbons above or below the sea surface, depending upon where the tank breach is located. Spill prevention measures for tankers and other vessels may include structural features such as double hulls or double bottoms. Engineered systems that detect leaks or ice or monitor weather can also increase onboard safety. Navigational safety programs such as vessel tra # c systems, navigational restrictions during periods of adverse weather, and monitoring of vessel tra # c42 N O V EMBER 2010

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### may help to prevent accidents. Prevention measures that target human factors—the human or organizational errors that are estimated to cause as much as 85 percent of marine vessel accidents—are also important. These may include personnel training, drug and alcohol testing, medical monitoring and watch-standing procedures that ensure adequate crew rest (U.S. Coast Guard 1998).44 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### and ! eld studies provide some insight into oil and ice interactions. This interaction is heavily in $ uenced by where the oil is released: above or below the ice (Dickins and Fleet Technology 1992). Oil behavior and movement in ice conditions may di " er from those exhibited in ice-free waters. For example, spilled oil may not spread as far in the presence of ice $ oes or irregularities on the ice surface, because the ice may create natural barricades to oil movement (Evers et al. 2004). Oil can move hundreds of miles from the spill site, however, if it is trapped under or within a piece of ice (Wilson and Mackay 1987, NRC 2003a). The behavior, fate and weathering of oil spilled in Arctic waters are a " ected by multiple factors, including the type of oil; the temperature of the oil and water; and the wind, current, tides and weather. The presence of sea ice and low ambient temperatures will slow the weathering process and also a " ect spreading and other physical processes (Table 4-1). If the oil is frozen or trapped in ice, the weathering process may stall until the oil is thawed and exposed to air and water. Sea ice slows the process of water uptake and evaporation (Dickins and Fleet Technology 1992, Evers et al. 2004). Evaporation will be slowed by cold weather and may be completely arrested if the oil is buried in snow or ice (Singsaas 2005). If the type of oil and the presence of waves lead to emulsi ! cation, the volume of the oil-water mixture will increase the size of the slick, and other weathering processes will slow (NRC 2003a).

T

able 4-1. O il Weathering P r ocesses A ff ected by Sea I c e (adapted from Evers et al. 2004)

P r ocess Open Water E xtreme C old or I c e Spreading and Dispersion A thick layer of oil grows thinner and covers a larger area of water (depending on the oil). Ice acts as a physical barrier (broken ice) or retardant (grease ice); oil does not spread or disperse as far and ends up in a thicker layer.
Drift Oil moves with wind/current. Oil will drift separately from the ice at less than 30 percent ice coverage, and with the ice at 60 to 70 percent (or greater) coverage. Unpredictable in broken-ice conditions.
Evaporation Relatively fast (thin oil ! lms). Slower where oil spills are thickened.

Emulsi ! cation Higher in areas with breaking waves. Rate of emulsi ! cation, total water uptake, and stability of emulsion depend on type of oil. Total water uptake and rate of uptake may be lower as a result of reduced wave activity because of the presence of ice.



### 4.1.2 Oil-Ice Interactions The fate and behavior of oil spilled into ice-infested waters depends to a large extent on the type of ice present and the timing of the release relevant to the ice formation and breakup cycle (Figure 2-4). Oil may move above or below the ice or become trapped within it (Figure 4-2). If oil is released underneath a solid sheet of ice (e.g., from a subsea blowout or pipeline rupture), it will rise until it reaches the ice cover, then spread laterally and accumulate in crevices under the47 N O V EMBER 2010

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### Conversely, the oil can a " ect ice formation by acting as an insulator to slow ice formation or can speed it by reducing wave activity. The presence of oil will typically slow early ice development (Ross in Wilson and Mackay 1987). When oil and gas are released together, as in a well blowout, the gas may also a " ect the oil by causing fractures or heaving (Dome’s Petroleum Ltd. in Fingas and Hollebone 2003). Areas of open water such as ice leads and polynyas can change oil behavior as well. Polynyas and leads will allow oil to spread more rapidly than it would on the ice surface or below the ice, causing the oil to pool in those areas (Arctec in Wilson and Mackay 1987). The weathering process will resume once the oil is exposed to open water, air and wind in the polynyas and leads, unless it is encapsulated by freezing water conditions. Water moving in or out of a lead can cause a pumping action, which moves oil out from under ice and into the lead. This is particularly common in the early hours of the spill when the oil ! rst encounters the ice (Reed et al. 1999). Oil that is frozen in ice or transported with ice $ oes has the potential to end up on the shoreline, where the oil can mix with the sediment, form emulsions or cover beaches, depending on the type and amount of oil and how much it has weathered. Oil released under ice or encapsulated within it could reach the shoreline but be invisible until the ice begins to break up or melt (AMAP 1998). When the spring melt starts, oil tends to move upward through the ice and form pools that will begin to weather and eventually be released to the water (AMAP 1998). As ice begins to melt, brine channels open up and may allow oil trapped in or under the ice to travel to the surface (Dickins and Fleet Technology 1992). This process of releasing oil from within the ice will accelerate as spring temperatures rise, forming increasingly thicker pools. Fine droplets of oil, such as the spray released from an oil well blowout, may take more time to reach the surface than a thicker slick (Dickins and Buist 1999). The release of encapsulated oil during spring melt has been correlated to the time at which it becomes frozen into the ice. In general, the earlier the oil was encapsulated in the ice formation, the earlier the oil will be released in the spring. One study found that 85 percent of oil encapsulated into the ice sheet early in the fall was released to the surface before spring breakup. Encapsulated oil that has not emulsi ! ed tends to remain non-emulsi ! ed, and emulsi ! ed oil entrapped in ice tends to remain in its emulsi ! ed form (Dickins and Fleet Techonology 1992). Microorganisms such as bacteria and some fungi slowly degrade petroleum hydrocarbons spilled in the marine environment (AMAP 1998). However, degradation is slower in coldwater areas than in temperate regions, because the oil tends to be more viscous and does not evaporate as quickly, making it less accessible to bacteria (Atlas 1985 in AMAP 1998).



### 4.1.3 Predicting the Fate of Oil in Sea Ice Predicting the fate of oil in sea ice requires new and improved algorithms to take into account the seasonal variation, weathering and other factors, described above, that a " ect the behavior of48 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### oil spilled on, in or under ice. Standard models used to predict the fate of oil spilled in temperate marine waters are inadequate for modeling the fate of oil in dynamic sea ice conditions. Despite considerable research into the fate and behavior of oil in sea ice, little progress has been made in integrating this information into existing oil spill models. A 2010 study considering the state of oil spill modeling in ice found: “Modeling oil spills in ice-infested water is much less developed than oil spill modeling in open water. This is not necessarily due to the lack of quantitative understanding of the fate and behavior side. ... Overall, it appears that there is a lag between the advancement of understanding the fate and behavior and the integration of the results into operational oil spill models.” (Khelifa 2010) The 2010 study, conducted by researchers at Environment Canada, found that existing modeling approaches that do include oil-in-ice interactions are more than two decades old and essentially use the same parameters as open-water oil spill models, with a correction factor that is meant to account for the presence of ice but is oversimpli ! ed and not technically accurate (Khelifa 2010). Upon reviewing theoretical models of oil behavior in ice conditions, Fingas and Hollebone (2003) conclude that the existing models are inadequate because most are tested only against laboratory or very small-scale ! eld experiments and are unable to adequately replicate the complexity or uniqueness of di " erent ice-ridden marine environments. Reed et al

. (1999) concluded that the ice leads play a dominant role in oil behavior but are not incorporated into most models. It is especially challenging to develop accurate modeling algorithms to predict the behavior of oil in ice over time, because the characteristics of the oil are constantly changing, as are the ice conditions. Predicting the fate of oil in the speci ! c circumstances surrounding any incident, especially in an ice environment, is beyond the capacity of existing models. In fact, in current oil trajectory studies that have been completed for the o " shore Alaska Arctic, ice conditions have been excluded entirely because of the inability of NOAA models to account for oil-ice interactions. To improve oil spill modeling capabilities in sea ice, models must be validated against data from Arctic oil spills or large-scale ! eld trials. Because of the high variability of oil behavior in sea ice conditions, models developed for one region of the Arctic may require some adjustment before being applied to other Arctic regions. Data are available for only a limited range of oil and ice types (Singsaas and Reed 2006). Understanding and predicting how oil and ice may interact in the o " shore Arctic is only one component of assessing the potential impact of a major Arctic oil spill. Another equally important consideration is how oil spilled in di " erent regions at di " erent times of the year may a " ect the Arctic ecosystem.



### 4.1.4 Long-Term Fate of Oil Spilled in Cold-Water Environments Follow-up studies of past oil spills, including the Exxon Valdez incident, have increased our49 N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group 

### understanding of the long-term consequences of oil spills in cold-water regions (AMAP 2008b). A 2003 study on impacts of the Exxon Valdez spill found that although most of the oil on the beaches was removed in the ! rst few years, oil remaining beyond that time was generally found in areas that were protected from physical weathering, and further degradation was very slow (Peterson et al

. 2003). In 2005, Exxon Valdez oil was found only slightly weathered under beaches across the spill impact area (Integral Consulting Inc. 2006). The lingering oil remains toxic and biologically available, and scientists predict that this subsurface oil may persist for decades (Short et al

. 2004). A series of intentional oil spills was conducted during 1982 and 1983 on Canada’s Ba # n Island to study the impact of oil spilled in Arctic environments, focused primarily on shoreline cleanup technologies and shoreline impacts. Much of the oil weathering documented on Ba # n Island and in Prince William Sound was due to physical processes. Low temperatures, lack of sunlight and ice cover slow all forms of oil weathering—in addition to the slowing of bacterial degradation by cold weather—causing oil to linger in cold-water environments longer than in more temperate regions (AMAP 2002). The long-term e " ects of oil spills have also been documented in Cape Cod, Mass., where recent studies published by the Woods Hole Oceanographic Institution found that oil remains in the sediment layer of some coastal marshes from a 1969 oil spill. The lingering oil continues to a " ect the behavior of burrowing ! ddler crabs, which avoided digging burrows into this oiled sediment layer. The crabs have also shown signs of toxic e " ects from the 38-year-old oil (Culbertson et al

. 2007 )

.


### 4.2 V ulnerabilities of the Arctic Ecosystem to Oil Spill Impacts
The U.S. Arctic Ocean hosts a productive ecosystem and provides vital habitat to walrus, polar bears, ice-associated seals and whales, along with seabirds, ! sh and myriad smaller organisms that support a complex food web (Figure 4-4). Arctic species are well adapted to the area’s conditions and are found nowhere else in the United States. Millions of birds and various species of whales migrate great distances to the Arctic each year. More than 100 species of ! sh—including Arctic cod, capelin, herring and sa " ron cod—underpin the region’s marine food chain. Ice is present in the Arctic Ocean for much of the year, and the interface between ice and water is the heart of the Arctic ecosystem. A spring bloom of phytoplankton at the sea ice margin forms the base of the food chain. Cracks in the ice provide spaces for marine mammals and birds to surface to breathe, and ice provides a platform for animals to rest, hunt and give birth (Smith and Barber 2007). The Arctic Ocean is not a homogeneous environment, and certain areas are especially important to the ecosystem. Among the most important are the openings in the ice, both at recurring polynyas (patches of open water within the sea ice) and at the edge of the primary ice pack. This edge moves hundreds of miles as the ice expands and retreats with the seasons. Additional important ecological areas are likely to be found in areas where the sea $ oor community is especially diverse or productive. Other important areas include the migration corridors of whales53 N O V EMBER 2010

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### up until much later in the life of these ! sh. Hydrocarbons are rapidly taken up from the water by ! lter-feeding invertebrates such as clams and mussels (Majewski and Scherer 1985 in AMAP 2008b) and are consumed with contaminated sediments by bottom-feeding invertebrates. The contaminants are known to bioaccumulate in their organs. Invertebrates metabolize hydrocarbons more slowly than do vertebrates, and in areas with contaminated sediments, they can be continually reexposed (AMAP 2008b). After the Exxon Valdez spill, clams and other invertebrates living in subtidal and intertidal areas with contaminated sediments remained contaminated for more than a decade, a " ecting animals that fed on them (Peterson et al

. 2003). Studies in Prince William Sound from 1999 to 2003 showed that some species, including harlequin ducks and sea otters, were still ingesting toxic oil compounds from their food sources and had not recovered as expected (Peterson et al

. 2003). Exposure to sunlight can greatly increase the toxicity of PAHs, complicating the determination of risk levels. Photo-enhanced toxicity can occur when PAHs are exposed to sunlight before organisms encounter them, when exposure is simultaneous or when small translucent organisms (such as larvae, eggs or plankton) are exposed to PAHs and then to sunlight. For some compounds, the toxicity can be increased up to 400 times (Landrum et al

. 1987 in AMAP 2008b). Arctic species have not been speci ! cally studied, but the increased toxicity has been shown for sub-Arctic species of copepods and herring (Barron et al

. 2003). This e " ect could have a signi ! cant impact in the Chukchi or Beaufort Sea if organisms were exposed to an oil spill during the near-constant daylight of the summer open-water season, either from a spill at that time or from a spill under or into ice that melted out in the spring.



### 4.3 I mpact of Oil Spills on the Arctic Environment, Ecology and People
Oil can persist in the Arctic environment for decades, continuing to have toxic e " ects long after the initial spill. Most of the published data on oil spill impacts are based on research from past spills in Arctic and other cold-water regions. Based on this relatively small data set, we have a limited understanding of the actual and potential negative e " ects of spilled oil on the natural environment and the human populations that depend upon this environment (AMAP 2008b). Characteristics of many Arctic species put them at a heightened risk for impacts from oil spills. Many Arctic animals have long life spans and slow reproductive rates, potentially prolonging population level impacts. Some animals that are high on the food chain already experience the

e " ects of bioaccumulation of persistent organic pollutants. As a predator consumes its prey, the toxins in the body of the lower-level organism are incorporated into the predator’s body in what is known as bio-magni ! cation. This continues in each predator-prey interaction, and animals at the top of the food chain (or food web, as shown in Figure 4-7), such as polar bears and humans, can accumulate high levels of these toxins (AMAP 2002).57 N O V EMBER 2010

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### and salmon generally return to their birth streams, putting both at risk if their spawning habitat were exposed to an oil spill (MMS 2008). As seen in the aftermath of the Exxon Valdez spill, contamination of nearshore spawning habitats can persist for many years, a " ecting multiple generations of young ! sh. Paci ! c herring populations in Prince William Sound su " ered a dramatic decline after the 1989 spill, which occurred a few weeks before the spawning season. It is estimated that 40 to 50 percent of the egg biomass was exposed to oil from the spill, as was a signi ! cant proportion of the adult herring. Lesions and elevated hydrocarbon levels were documented in some adult Paci ! c herring from the oiled areas. Laboratory studies showed abnormalities and possible depressed immune functions in Paci ! c herring exposed to oil. Four years after the spill, there was a major collapse of the herring ! shery, which has yet to recover to pre-spill levels (Brown and Carls 1998). Arctic cod is a key species in Arctic food webs. This abundant ! sh is the primary connection between plankton and larger animals, and impacts on them would be likely to a " ect many of their predators, such as the ringed seal. Arctic cod spawn under sea ice in winter, and the eggs hatch during the plankton bloom that occurs with spring breakup of the sea ice (AMAP 2008b). They would be vulnerable to an under-ice spill during the spawning period, or to a spill that concentrated in the lead system during breakup.



### 4.3.3 Marine Mammals Impacts on marine mammals could include the ingestion of oil and the inhalation of vapor from crude oil, loss of insulation by oiling, and e " ects from contaminated prey (NRC 2003b). Inhalation of volatile compounds from fresh crude oil is known to damage the respiratory system, nervous system and liver of marine animals surfacing to breathe (AMAP 2008b, NRC 2003b). However, there are few data supporting a link with mortality (NRC 2003b). An estimated 302 harbor seals were killed in the Exxon Valdez spill, probably from inhalation of toxic fumes (Frost and Lowry 1994). PAHs from weathered oil are toxic to developing fetuses in at least some mammals and probably have other health consequences. However, the long-term health impact of sublethal oil exposure on marine mammals is generally not known. Some marine mammals are dependent on fur for insulation, and oiling of their fur causes substantial acute mortality. Direct oiling of fur killed 1,000 to 2,800 sea otters in the Exxon Valdez spill (Peterson et al

. 2003). In the Arctic, this could a " ect ice seal pups, polar bears and Arctic foxes. A 1969 spill o " the coast of Canada during harp seal breeding season oiled 10,000 to 15,000 seals, causing signi ! cant mortality to the pups (AMAP 2008b). Polar bears and Arctic foxes, both present in the Beaufort and Chukchi Sea regions, would also be vulnerable to oil ingestion from grooming their fur. Predatory mammals such as toothed whales (e.g., beluga whales), seals and polar bears are vulnerable to bio-magni ! cation of contaminants from their food sources (Figure 4-10). Even when marine mammals have the potential to escape the oil spill, they may not do so. Although some whale species, such as the ! lter-feeding bowhead whales, have been observed to avoid oilcontaminated areas, other species have shown no avoidance behavior. After the Exxon Valdez spill,59 N O V EMBER 2010

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### Paci ! c walrus distribution varies seasonally and is limited by water depth and ice conditions. Walrus have historically followed the receding sea ice, from which they have easy access to feeding grounds in shallow water on the continental shelf (USFWS 2010), Jay and Fishback 2008, Burns et al

. 1980, Fay et al

. 1984, Fay 1982, Fay 1985). Most of the population spends the summer months in the pack ice of the Chukchi Sea while the (predominantly) male portion of the population hauls out onto land in the Bering Sea (Fay 1981). Walrus are considered an ice-associated species because they use $ oating sea ice for giving birth, nursing calves and resting and as passive transport to feeding areas (Figure 4-12). In the Chukchi Sea, they also concentrate at coastal haul-outs, particularly when the ice edge has shrunk away from their feeding grounds on the continental shelf. This is becoming more frequent as global climate change leads to a shrinking of the summer ice cover (USFWS 2010b, Jay and Fishback 2008, USGS 2010, Hassol 2004). Although Paci ! c walrus are not listed as threatened or endangered under the Endangered Species Act, several petitions have been made to the USFWS to o # cially list this species (USFWS 2009). An oil spill that contacts an aggregation of walrus or displaces them from this important habitat may have a severe impact on the population, exacerbated by their low natural rate of reproduction. They would also be sensitive to impacts on their food supply. Information is scarce on the large mollusks that form the walrus’s primary food source, but they are slow-growing and would be expected to recover slowly after an oil spill (MMS 2008). Suspension-feeding invertebrates such as mollusks metabolize hydrocarbons slowly, so walrus would be exposed to contamination by eating them. Walrus also stir up sediment when feeding and could be exposed to oil residue. Because of their long life span, walrus could su " er severe e "ects from this bioaccumulation of oilderived contaminants.



### 4.3.4 Birds Seabirds are very vulnerable to oil, particularly in cold environments. A square-inch spot of oil can compromise the water repellency of the feathers, potentially causing hypothermia (MMS 2008). A large spill can cause a massive acute die-o " of oiled birds. Seabird deaths from the Exxon Valdez spill were estimated at 250,000 (Peterson et al

. 2003). Many Arctic bird species have characteristics that make them especially vulnerable to oil spills. These birds make long-range migrations, aggregate in colonies and have low reproductive rates and long life spans (Figure 4-13). Birds nesting in dense colonies are especially vulnerable to spills a " ecting their breeding sites. Many seabirds congregate to feed at ice edges, polynyas and open leads, where their prey species congregate and where oil may concentrate (AMAP 2008b). A number of studies have shown that seabird colonies can be wiped out by oil spills. A pu # n colony crashed after the Amoco Cadiz spill in 1978 (Clark 1984 in AMAP 2008b), and a guillemot colony in Southern California was wiped out because of a number of oil spills in the 1980s (Parker et al

. 2007 in AMAP 2008b). Oil spills from sinking ships were probably responsible for the disappearance of pu # ns and guillemots from the English Channel during World War II (Gaston and Jones 1998 in AMAP 2008b).62 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### 4.3.5 People A large oil spill could signi ! cantly a " ect the people and communities along the Chukchi and Beaufort seacoasts. The most signi ! cant impact to the approximately 8,000 people living in this region would be on the subsistence resources that provide much of their diet and form the basis for their culture and social well-being. In the short term, both the spilled oil and the response activities could lead to disturbance or displacement of species important to subsistence ! shers and hunters. Concerns over tainting or contamination of subsistence foods could lead to avoidance, both in the short term and into the future. If the oil spill caused signi ! cant populationlevel impacts to these species, their availability to hunters would be a " ected for a long time after the spill (Figure 4-14). A reduction in the availability or safety of subsistence foods could have a profound impact on the economy and culture of Arctic communities on the U.S. and Russian coastlines (AMAP 2008b and MMS 2008). Reductions in the overall caloric input from subsistence food have also been documented to have negative impacts on the physical and mental health of Arctic indigenous communities (Wernham 2007). Bowhead whales are an important subsistence resource for native communities in the U.S. Arctic. Depending on the timing, a spill could stop the spring or fall hunt because of displacement of the whales or concerns about tainting of the meat. Also, local hunters could be pulled into spill response e " orts, preventing them from hunting (MMS 2008). Even if the oil spill has no long-term impact on whale populations, bowheads are known to avoid contaminated areas, making them more di # cult for hunters to access. In 1944, Barrow elder Thomas Brower Sr. observed an oil spill from a U.S. Navy vessel in the Plover Islands east of Barrow, where about 25,000 gallons spilled.
“In 1944, I saw the e # ects of an oil spill on Arctic wildlife, including the bowhead. ... The " rst year... I observed how seals and birds who swam in the water would be blinded and

su # ocated by contact with the oil. It took approximately four years for the oil to " nally disappear. I have observed that the bowhead whale normally migrates close to these islands in the fall migration. ... But I observed that for four years after that oil spill, the whales made a wide detour out to sea from these islands. ... If there were a major blowout, all the Inupiat could be faced with the end of their marine hunting.” (Brower, 1978) In addition to bowhead whales, many other subsistence resources of the Arctic Ocean are causes for concern, including birds, ! sh and other marine mammals. On the Arctic coast, marine mammals and ! sh often make up 60 percent of a community’s diet (MMS 2008). An oil spill could cause these foods to be less abundant, more di # cult to access, or tainted by contaminants or perceived to be tainted. Loss of these subsistence resources could have economic impacts as people are forced to buy more of their food. Such a loss could also have negative social impacts from the loss of culturally important foods and activities, as well as adverse e " ects on physical and mental health. Psychological impacts of oil spills have been documented in other areas, especially among indigenous peoples (AMAP 2008b). Although the impact of oil spills on local communities is an obvious concern, the broader impact of oil and gas activities adjacent to human populations is not well understood. An Arctic Council65 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### This chapter reviews the major technologies in use for stopping a well blowout and cleaning up an oil spill and examines how each may be limited in the Arctic Ocean environment.



### 5.1 A rctic Ocean Challenges
Arctic conditions—sea ice, low visibility, high winds, rough seas and cold temperatures (discussed in Section 2.1)—would complicate all aspects of a spill response, from stopping a well blowout to predicting or tracking the movement of an oil spill trapped in sea ice (Table 5-1). All of the major spill cleanup technologies face operating limits that are tied to wind speed, wave height, ice conditions and visibility (Potter 2004). Once the limit is reached for any one or combination of these factors, spill response operations may be slowed or shut down for days, weeks or months.

T

able 5-1. T ypic al Arctic C onditions and P ot ential I mpac ts on Spill R esponse Options (Adapted from N uka R esearch 2007b)

1 S ea ice is a prominent feature of the Arctic marine environment. The generic term “sea ice” encompasses a wide range of ice conditions. Sea ice may be present year-round, or it may follow an annual freeze-melt cycle. Ice conditions may be described in terms of the formation of the ice or the percent coverage. The World Meteorological Organization ice classi ! cation system and terminology are used in this report (WMO 2005). A RCTIC
C O N D ITI O N S P O TENTI A L IMP A C T S T O S PILL RE S P O N S E
A ll R esponse Options M echanic al R ecovery I n-Situ B urning Dispersants
Sea Ice 1 Challenges: Di # cult for vessels to access spill site.

Di # cult to sense, track or model movement of oil in, on or under sea ice. Ice-class vessels required in higher ice concentrations. Slush ice can clog water intakes. Ice scouts may be needed. Ice-management vessels may be needed in addition to primary response vessels. Experienced vessel operators must be familiar with ice. Ice conditions may change suddenly and create dangerous conditions.
Bene fi ts: Oil may weather and spread more slowly. Challenges: Ice may tear, lift or move containment boom.
Reduced encounter rates for skimmers. Ice may clog skimmers or reduce

e # ciency. Ice may clog pumps or cause them to fail.
De $ ection of ice away from skimmers may inadvertently de $ ect oil. Limited maneuverability may prevent or delay accurate skimmer or boom deployment. Attempts to de $ ect the ice from recovery areas may also de $ ect the oil. Ice must be separated from recovered oil.
Bene fi ts:Ice may contain oil in pools for smallbatch recovery. Challenges: Certain ice conditions (i.e. slush ice) may reduce burn e " ectiveness or impede ignition.
Di # cult to deploy ! re boom.
Di # cult to track and recover burn residue. Impact of smoke plume and soot to ice unknown.
Bene fi ts: Ice may provide containment for burning. Challenges: Cannot access oil under ice. Ice reduces mixing energy. Dispersants generally less e " ective at lower salinities. In most regions, dispersants are not considered an operational technology for use in sea ice. Little information about dispersant toxicity to Arctic organisms.
Bene fi ts: None apparent.66 N O V EMBER 2010

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C O N D ITI O N S P O TENTI A L IMP A C T S T O S PILL RE S P O N S E
A ll R esponse Options M echanic al R ecovery I n-Situ B urning Dispersants High Winds Challenges: Unsafe to operate vessels and deploy on-water equipment during high winds.
Aircraft cannot $ y above certain wind thresholds. High winds drive sea state, may enhance wave height or create choppy seas. High winds may combine with low temperatures to create dangerous wind chill.
Bene fi ts: Strong directional winds may drive oil away from sensitive areas. Challenges: High winds can move boom or tear it from anchor.

Di # cult to keep vessels and equipment on station.
Bene fi ts: None apparent. Increasing winds make all aspects of on-water recovery more challenging and eventually create safety issues. Challenges: Di # cult to ignite oil in high winds. Aircraft cannot deploy heli-torches in high wind. High winds may drive plume.
Bene fi ts: None apparent. In-situ burning is not generally safe or feasible in high winds. Challenges: Di # cult to accurately spray dispersants. Aerial spraying not safe during high winds. Cannot conduct application monitoring from aircraft.
Bene fi ts: Wind-driven sea state will provide mixing energy for dispersants and oil if the dispersants can be safely applied.

Cold Temperature Challenges: Potential for hypothermia among responders. More frequent breaks (every 10 to 15 minutes in some cases) needed to warm up. Unsafe to work at extreme low temperatures. Cold may cause brittle failure in some metals. Cold air may freeze sea spray, creating slick surfaces. Icing conditions may make vessels unstable. Natural bio-degradation of oil slowed.
Bene fi ts: Oil may weather more slowly, increasing window of opportunity for response. Challenges: Skimmers freeze up. Sea spray may freeze on boom, causing it to fail. Pumps may freeze up. Increased oil viscosity makes oil di # cult to recover and pump.
Bene fi ts: None apparent. Cold temperatures will slow or limit nearly all aspects of spill response. Challenges: Ignition more di # cult. Oil may burn more slowly or less completely.
Bene fi ts: No speci ! c bene ! ts. Challenges: Increased oil viscosity may reduce dispersant e " ectiveness.
Some studies have shown reduced

e # ciency in cold waters.
Bene fi ts: None apparent.

Limited visibility (including darkness) Challenges: Limit or preclude safe vessel operations. Aerial operations typically not conducted during darkness, heavy fog or low ceiling.

Di # cult to see, track or locate oil spill. Challenges: Cannot conduct mechanical recovery in darkness or low visibility unless work lights can be used.
Bene fi ts: No apparent bene ! ts. Challenges: Cannot conduct in-situ burning during darkness. Fog or low visibility may limit aerial operations.
Bene fi ts:: No apparent bene ! ts. Challenges: Darkness or low visibility that limits aerial operations will preclude aerial application and observation. Vessel application requires visual

con ! rmation of slick location.
Bene fi ts: No apparent bene ! ts.

Sea state (high waves, strong tides) Challenges: High waves limit small boat operations. Strong currents challenge vessel operations.
Bene fi ts: Calmer, low current sea states are typically more favorable than high
sea state. Challenges: Booms and skimmers do not function well at high sea states. Short, choppy waves may be more limiting than longer period waves. Moderate to high currents cause boom to fail.
Bene fi ts: None apparent. Increases in wave height and period and moderate to high currents all make mechanical recovery more di # cult. Challenges: High sea states make containment and ignition di # cult and potentially unsafe.
Bene fi ts: None apparent. Increases in wave height and period and moderate to high currents all make in-situ burning more di # cult. Challenges: Vessel-based application limited by sea state based on vessel size.
Bene fi ts: Sea state should not inhibit aerial application (assuming no high winds). High sea states typically enhance the e " ectiveness of chemical dispersants.67 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### Other characteristics of the Arctic Ocean and the Arctic region—lack of infrastructure, limited transportation options, and distance from major ports (Section 2.2)—also a " ect the ability to meet the basic requirements for implementing a major oil spill response. Oil spill response equipment and systems face many limits, including the overall e # ciency of the technique or equipment. E # ciency is a measurement or estimate of how well the equipment or technique might function under ideal conditions to clean up or treat spilled oil. No oil spill cleanup technique is 100 percent e # cient, and even spill cleanup measures that are shown to have very high e # ciencies under test conditions face signi ! cant limits in real-world situations. There are several basic requirements for on-water oil spill cleanup operations that also apply in the Arctic, and failure to meet any of these requirements can reduce the response e # ciency signi ! cantly or halt operations altogether.

• Spill managers must be able t o locate and track the movement of the oil spill.

• R esponse equipment and trained responders must be transported to the spill site.

• A vailable response equipment must be able to access the spilled oil.

• T he response equipment and technologies must be appropriate for the type of oil spilled and the conditions under which the equipment is used.

• Su # cient st orage devices and disposal plans must be in place to deal with oil, oily liquid and other contaminated materials recovered during the response.

• C ommunications networks must be in place so that responders can communicate among themselves and with response managers in the incident command post. Ground-to-air, vessel-to-air, vessel-to-vessel and ground-to-vessel communication networks must be in place.

• V essels or aircraft that provide the basis for response operations must be able to safely operate in the weather and environmental conditions.

• F ood, water and housing must be provided for response personnel.

• All operations must meet basic saf ety parameters to prevent injury to responders.



### 5.2 S topping a Subsea Well Blowout
There are a number of well control measures that can be taken to mitigate the intrusion of oil and gas into the well bore, but if those measures fail for any reason, an open ori ! ce blowout can occur. In this case, the ! rst and most important task in any oil spill is stopping the $ ow of oil into the environment. Subsea blowouts are especially di # cult to stop because the blowout preventer and wellhead are located underwater. Controlling a subsea well blowout may require months, as was the case with the Deepwater Horizon spill.68 N O V EMBER 2010

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### The options for controlling a subsea well blowout are limited and time-consuming. The two options most often discussed are subsea well control or containment measures (sometimes described as capping) and drilling of a relief well (Grace 2003).



### 5.2.1 Subsea Well Containment and Control Once the well has bypassed the blowout prevention (BOP) system and achieved an uncontrolled blowout state, the wellhead control equipment may su " er considerable damage. In this case, one option to reestablish control of the well would be to install some kind of containment barrier. It is di # cult to install a containment barrier to control a subsea well blowout because of the di # culty of accessing the underwater wellhead. The Deepwater Horizon blowout provided the opportunity for responders to test and re ! ne several di " erent approaches to subsea well containment and control, and resulted in some novel approaches that have the potential to substantially improve existing technologies in this area (Joint Industry Subsea Well Containment and Control Task Force 2010). Before the Deepwater Horizon well blowout, no prefabricated subsea well containment devices were available for immediate use. Several devices were constructed after the Deepwater Horizon blowout, and ultimately one of those devices was successful in sealing in the oil. A joint industry task force is working on a long-term plan to develop tools and equipment to establish a standing capability to use prefabricated structures or equipment to quickly control subsea well blowouts. Areas of new research include well containment devices for use on the sea $ oor (Figure 5-1), equipment and technologies for use within the subsea well, and devices for subsea collection and processing of oil recovered from the blowout plume (Joint Industry Subsea Well Containment and Control Task Force 2010).
Figure 5-1. Subsea Well Containment System Proposed for Use in Gulf of Mexico— During the Deepwater Horizon well blowout, a subsea containment system was proposed to stop the uncontrolled " ow from the well. Research is ongoing into other potential subsea well control structures; however, at present there have been no technologies proposed or developed to control subsea well blowouts in the Arctic.69 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### The transfer of technologies from the Deepwater Horizon blowout and the ongoing work of the Subsea Well Control and Containment (SWCC) Task Force are likely to improve the techniques available for subsea well blowout control. An action plan for the SWCC Task Force is scheduled for completion Dec. 31, 2010. Preliminary documents from the task force do not indicate whether the research and development activities will include an Arctic component. The introduction of new techniques and technologies for subsea well containment and control is likely to improve future options for reducing the amount of oil released during a subsea blowout. If operators are able to develop and demonstrate the ability to quickly and e " ectively contain subsea wells, the risks would be signi ! cantly reduced. However, like all engineered systems, subsea well containment and control measures would require certain adaptations or enhancement for use in the Arctic Ocean. Equipment installed on the sea $ oor in shallow water would risk damage or destruction from ice scouring if left in place over the winter. The specialized equipment and trained personnel required to install subsea well control or containment devices would need to be transported to the well site, because no subsea well containment equipment or personnel are located in Alaska nor has anything been fabricated and demonstrated to withstand Arctic conditions.



### 5.2.2 Relief Wells A relief well intercepts the subsurface well bore of the out-of-control well. Drilling a relief well is often not the ! rst or only well control option selected because of the time it takes to move a rig into the area of the blowout and drill a relief well. However, a relief well is the most reliable method for stopping a blowout. If a rig is on location or nearby, it may be possible to shut down its drilling operations to aid the blowout response. If no rigs are available nearby, then substantial time will be required to move a rig into the area. In the interim, other well control operations may be initiated, as was the case in the Deepwater Horizon blowout in the gulf, where a subsea containment structure was successfully installed while relief well drilling continued to completion.



### 5.2.3 Challenges to Well Control in the U.S. Arctic Ocean The ability to control a blowout in the U.S. Arctic Ocean will vary, based on the ice season and the location of the well. Even if Arctic Ocean drilling is limited to open-water season, it is possible that a blowout that occurs late in that season could continue during the freeze-up, and the blowout control and response could be a " ected by encroaching sea ice. Data are sparse and poorly compiled on the international experience with Arctic subsea oil well blowout control. Some conclusions can be drawn, however, by considering the known challenges of well control technologies and relief well drilling in temperate or sub-Arctic conditions, and then factoring in Arctic conditions. All blowout control measures require time to mobilize and deploy the required equipment, and a period of weeks or months may pass before well control is achieved. For example, it took several months to mobilize a rig and drill the relief well in a gas well blowout at the Steelhead platform in Cook Inlet, Alaska. The blowout occurred in December 1987, but the relief well was70 N O V EMBER 2010

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### not completed until June 1988 (Petterson and Glazier 2004). In the U.S. Arctic Ocean, if a relief well cannot be completed before pack ice encroaches on a drill site, it is possible that a blowout could continue uncontrolled through the eight- to nine-month ice season. If subsea containment or control measures controlled the blowout, the containment system would have to be engineered to withstand the Arctic winter. Ultimately, a relief well would probably be required to completely control an Arctic subsea well blowout, unless the well were to naturally seal itself with rock fragments from the collapsing formation.



### 5.3 A pplying Oil Spill Cleanup Methods in the Arctic Ocean
The challenges associated with controlling a well blowout in the Arctic Ocean are only the ! rst part of the equation. Cleaning up spilled oil in the marine environment—whether from a blowout or another spill source—is a tedious and labor-intensive process that, even under the best of circumstances, may result in the recovery or removal of only a small fraction of the total spill volume. In the Arctic, every step of that process may be more di # cult or even impossible under certain conditions. Most technologies used in response to oil spills in sea ice have been adapted from those typically used on open water and land. Although on-water response technologies may transfer to open-water Arctic conditions, sea ice has been demonstrated to reduce the e # ciency of many response methods and to preclude the use of others (AMAP 1998). Oil spill response methods are generally divided into three main categories: mechanical recovery, in which oil is corralled using natural or man-made barriers and removed using skimmers and pumps; nonmechanical recovery, in which an oil slick is treated with chemicals, burning or bioremediation; and manual recovery, in which oil is removed with hand tools or machines. Most operations in Arctic waters rely on a combination of mechanical recovery and two types of nonmechanical treatment—in-situ burning and dispersant application—to clean up or treat spilled oil. All of these options face limits from environmental and weather conditions (Table 5-1). All three response technologies require surveillance and spill tracking to identify the location, extent and condition of the spilled oil so that the appropriate response equipment and tactics may be selected. All three also require logistical support to transport equipment and trained personnel to the spill site, deploy and operate the equipment, and decontaminate the equipment when response operations are complete. Spill responders must be able to safely access the spill site— often one of the biggest challenges, particularly in remote areas. With all three oil spill response options, time is critical. As soon as oil is spilled in water, it begins to spread, evaporate and emulsify, and as time passes, it generally becomes more di # cult to track, contain, recover and treat. The quick mobilization and deployment of response equipment and trained personnel are important to the overall response e " ectiveness.75 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### On-water mechanical recovery technologies are signi ! cantly less e # cient when sea ice is present (Abdelnour and Comfort 2001). Sea ice in its various forms a " ects the functionality of booms, skimmers and vessel operations and may limit or preclude the ability to operate certain classes of vessels. Cold-weather conditions can further complicate mechanical recovery. The presence of sea ice interferes with containment of oil in su # cient thickness to recover it. Oil tends to disperse and mix into the ice, creating an additional step for responders trying to separate the oil from the ice. Sea ice may reduce the e " ectiveness of containment booms by interfering with the boom position, allowing oil to entrain or travel under the boom or causing the boom to tear or separate. Sea ice may also reduce a skimmer’s e # ciency in recovering oil by lowering the encounter rate and increasing the time needed to position the skimmer for optimum recovery among ice $ oes (Abdelnour and Comfort 2001, Fingas 2004). Marine operations in sea ice are vulnerable to rapid changes in weather and ice conditions, and signi ! cant down time often occurs because of the movement of ice in response to wind conditions and sea state (Dickens and Buist 1999). Although sea ice coverage generally complicates on-water mechanical recovery, increasing ice concentrations may help contain oil under certain conditions. Dickins and Buist (1999) found that ice concentrations of 60 percent or higher provide “an e " ective means of reducing oil spill spreading.” Although the spreading rate is diminished, the recovery rate can be severely a " ected by responders’ inability to access the oil because of weather, visibility, or vessel, mechanical and human limitations. Higher ice concentrations make recovery operations extremely di # cult because of limits to vessel operations. In ice concentrations below 60 percent, additional containment is usually required to concentrate the oil so that it can be recovered by mechanical skimming devices. Dickins and Buist (1999) found that most containment booms can be used in light brash ice conditions and ice concentrations up to about 30 percent. Based on these estimates, ice conditions ranging from 30 percent to 70 percent coverage may present the biggest challenge to mechanical response, because conventional booms are likely to be ine " ective and ice conditions are not su # cient to contain the oil (Evers et al. 2006, Glover and Dickens 1999).79 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### stages of ! sh and crustaceans and reproductive stages of other plants and animals develop in this layer, which often contains dense populations of micro-algae with distinct species compositions from the phytoplankton in the layers below (Shigenaka and Barnea 1993). Surface micro-layer organisms are vulnerable to oil slicks, but the e " ects do not seem to be intensi ! ed by burning. Experimental data from a large o " shore burn showed that water temperature did not increase during burning, despite the intense heat generated by the burn (Fingas et al

. 1994). To date, no published studies address the potential impact of in-situ burning on the surface micro-layer in polynyas. Numerous published articles and reports refer to the potential use of in-situ burning in sea ice conditions. The reduced e # ciencies of mechanical recovery are frequently cited as a rationale for in-situ burning in ice leads. In-situ burning is also considered a viable option for treating oil on top of solid ice or oil that pools on top of melting ice in the spring (Solsberg 2008). The general consensus is that leads in broken and pack ice provide an opportunity for in-situ burning, because the ice acts as a natural containment barrier to the slick and the open water in the lead provides the necessary access. However, responders must also have access to ice class vessels and/or air support to carry out these operations. Before the Deepwater Horizon oil spill, in-situ burning had not been widely used, particularly in cold climate on-water spill response, so the body of information regarding in-situ burning in Arctic regions is based primarily on experimental data. The presence of sea ice appears to slow the rate of in-situ burning and create slightly larger quantities of residue than occur in open water (Fingas 2004, Buist et al

. 2003). However, in-situ burning studies in slush ice showed e # ciencies as high as 50 percent for weathered crude oils and 80 percent for fresh oil (Buist et al

. 2003).
Burn e # ciencies cited in laboratory studies (e.g., the 50 percent cited in Buist et al

. 2003) may not be duplicated in most ! eld conditions, because burn studies involve pouring oil into a containment area to the required thickness, rather than having to corral the oil under ! eld conditions in which vessels and ! re booms must be able to operate. It is also important to recognize that burn e # ciency rates describe the percentage of the corralled oil that is burned

o " , rather than the percentage of the total spill amount that is treated. For example, the in-situ burning operations after the Deepwater Horizon blowout reportedly included some highly

e # cient burns, yet burning was estimated to treat only 5 percent of the total spill amount. In the Arctic Ocean, even if individual burns removed 50 percent of oil present in a burn area, they might treat only a very small percentage of the oil spilled, leaving most of the total spill volume in the environment. As with mechanical recovery, the e " ectiveness of in-situ burning is related to the percentage of ice coverage. Both techniques face particular challenges in slush or grease ice; burn e # ciencies in the presence of slush ice are lower than in open water and leave behind more residue (Buist et al

. 2003). The major di " erence between mechanical recovery and in-situ burning in ice is that the natural containment provided by ice $ oes at higher ice concentrations may be conducive to in-situ burning if ignition can be attained. At ice coverage up to about 30 percent, in-situ burning80 N O V EMBER 2010

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### generally requires the use of man-made ! re booms to contain the oil to the desired thickness. Because of this, in-situ burn operations face many of the same constraints as mechanical recovery. Boom-towing vessels must be able to maneuver and position booms to contain the oil to the desired thickness, and an ignition source must be deployed from a vessel or aircraft. When ice coverage is above 60 or 70 percent, in-situ burning may be accomplished using the ice $ oes as natural containment. In this case, the ignition source will probably be from an aircraft, unless icebreaking or ice-reinforced vessels are available and capable of maneuvering in the vicinity of the spill. Ice conditions in the 30 percent to 70 percent range are considered to be the “most di # cult from an in-situ burning perspective” (Evers et al. 2006). In this range, natural containment by the ice is less likely, and containment boom deployment is generally not possible. Research into the use of herding agents—chemicals used to improve slick thickness—is ongoing, with a focus on use of herding agents in the presence of sea ice (Evers et al

. 2006, Buist et al

. 2010a and 2010b). In-situ burning relies on good visibility and weather. In-situ burns cannot be ignited when visibility conditions or darkness preclude $ ight operations.



### 5.3.4 Dispersants Dispersants are typically selected as a response technique because, although they do not physically remove the oil from the water, they may break up oil slicks and reduce the amount of oil that reaches and contaminates shoreline areas. Chemical dispersants have been the subject of signi ! cant research over the past decade, much of it focused on cold-water and Arctic applications (Evers et al

. 2006). However, substantial scienti ! c and technical work still must be done before dispersants can be considered a practical response tool for the Arctic. Under the spill responseframework established by the joint state/federal Alaska Regional Response Team, there is no preapproval for dispersant use in the U.S. Arctic Ocean. Therefore, most discussion of dispersant use in the U.S. Arctic Ocean is theoretical. Many questions remain about the e # cacy of dispersants in Arctic waters, the potential toxicities, and the operational feasibility of applying dispersants in ice-infested waters. Dispersants are chemicals sprayed or applied onto oil slicks to accelerate the dispersion of oil into the water column. The chemical mixtures contain three components: surfactants, solvents and additives. Surfactants are molecules with an a # nity for two distinct liquids that do not mix, acting as an interface between them. One part of the surfactant molecule used in dispersants has an attraction to oil (i.e. it is oleophilic) while another part has an attraction for water (i.e. it is hydrophilic). Dispersants promote the formation of tiny oil droplets in the water column and prevent the re-coalescence of droplets into slicks. Dispersants do not actually remove oil from the water but are intended to limit the amount of oil forming a slick on the water surface or shoreline by breaking the oil into smaller droplets. Dispersants are applied using spray nozzles, pumps and hoses and can be applied from a vessel83 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### A review of dispersant use in oil spill response conducted by the National Academy of Science recommends additional studies on the physical and chemical interactions of oil, dispersants and ice before dispersants can be considered a mature technology for use in sea ice (OSB 2005). A report on oil spill response technology in ice-covered waters recommends additional study into the potential use of dispersants in sea ice, including the potential use of icebreaking vessels to add mixing energy, which is the energy required to mix dispersants with surface oil so that they work as intended (D.F. Dickins Associates 2004). More dispersants were used in the Deepwater Horizon spill response than on any previous spill. Unlike most spills and published studies, in which a single dispersant is used, the Deepwater Horizon response involved combinations of several dispersant chemicals. Studies are ongoing on the impacts of dispersant use on species and the synergistic e " ects of multiple dispersant formulations mixed together and with oil in the marine ecosystem. The subsea application of dispersants during the Deepwater Horizon spill also represented a signi ! cant variance from typical dispersant use. Additional study is needed to determine whether subsea dispersant use is in fact a viable response tactic and to consider the e # cacy and the environmental impacts of applying dispersant chemicals to a subsea release. Use of dispersants is also limited by environmental conditions and weather. Aerial application of dispersants requires low winds and good visibility, and dispersants cannot be applied during periods of darkness. The damping e " ect of sea ice reduces the mixing energy necessary for dispersants to work as intended.



### 5.4 R esearch and Development to Improve Oil Spill Response in Arctic Waters
The need to improve mechanical recovery capabilities in sea ice is cited repeatedly in the published literature (Abdelnour and Comfort 2001, Dickens and Buist 1999, Fingas 2004). This poses a signi ! cant research and development challenge, because oil leasing, exploration and production in the Arctic are outpacing oil spill response technologies, particularly in sea ice. A 2004 report prepared for the Prince William Sound Oil Spill Recovery Institute and the U.S. Arctic Research Commission (D.F. Dickins Associates 2004) identi ! es a need to “expand the operational capability of existing spill response equipment to enable oil recovery in ice.” The same document indicates a “low” con ! dence in the ability to improve mechanical response in ice, noting “improvements likely to be incremental, resulting in modest increases in recovery e " ectiveness.” Recent research and development focused on improving oil spill response in ice has considered the use of oil de $ ection systems, which apply technologies such as air jet blowers, propeller wash, booms, belts, plates or small “curtains” of water bubbles to redirect the $ ow of oil into a collection area while moving ice in a di " erent direction (D.F. Dickins Associates 2004). Researchers in Finland have developed oil spill response devices for sea ice conditions that may be attached to the bow of a vessel and include a combination of ice-processing belts and skimming systems (Rytkonen et al

. 2003). Although there have been incremental improvements in individual skimming technologies, there have been no breakthrough technologies reported in the literature that would signi ! cantly84 N O V EMBER 2010

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### improve mechanical recovery in sea ice. One skimming technology that has shown some promise is a brush drum skimmer that can be deployed from a hydraulic arm on a response vessel, because of its ability to recover oil from pools in ice. In general, the use of skimmers in ice is considered more appropriate for “batch” removals, focusing on small pockets of oil, than for recovery of oil from a major blowout (BPXA 2003).



### 5.4.1 Joint Industry Program on Oil Spill Response for Arctic Waters In 2006, a Joint Industry Program (JIP) on Oil Spill Response for Arctic and Ice-covered Waters was initiated with funding from several major international oil companies and research by consultants, academicians and a few national agencies. A team of researchers from SINTEF, a large Norwegian research organization that is active in oil spill response technologies research and development, led the JIP e " orts. The purpose of the JIP, which was completed in 2009, was to improve “oil spill response techniques for Arctic waters” through a combination of laboratory and ! eld trials, and to gather more knowledge about the fate and behavior of oil spills in ice and cold water temperatures (Sorstrom et al

. 2010). JIP was funded jointly by SINTEF, the Norwegian Research Council, and seven major oil companies; there was no public participation in or review of the JIP published ! ndings. The JIP experiments focused on aspects of in-situ burning, dispersant use, and mechanical recovery in various sea ice conditions and also looked at remote sensing and tracking technologies and physical and chemical processes associated with oil weathering in Arctic waters. The program culminated in a series of ! eld experiments during 2008 and 2009 in the Norwegian Barents Sea. Results from the JIP are summarized in a synthesis report (Sorstrom et al

. 2010) and in a series of technical reports presented at technical conferences. The reported ! ndings from the JIP paint an optimistic picture of the potential applicability of several technologies to Arctic oil spills. The overwhelming emphasis of the program appears to have been on nonmechanical technologies. Of the eight papers presented on JIP studies during the 2010 Arctic Marine Oil Pollution (AMOP) Technical Seminar sponsored by Environment Canada, four dealt with in-situ burning technologies (Buist et al. 2010b, Potter and Buist 2010, Brandvik et al. 2010b, Brandvik et al. 2010c), one with dispersant application (Daling et al

. 2010), two with oil-water interactions and weathering (Faksness et al

. 2010, Brandvik et al

. 2010a), and one with remote sensing (Dickins et al

. 2010). No papers were presented on mechanical recovery, which is the only preapproved oil spill response technique for the U.S. Arctic. The JIP ! nal report presents a brief discussion of the mechanical recovery testing program, which focused only on skimmer technologies and resulted in the identi ! cation of two skimmer designs, modi ! cations of typical open water-skimmers with the addition of ice processing mechanisms that show “promise” for Arctic application (Sorstrom et al

. 2010).
The JIP was a ! rst step toward more rigorous study of oil spill response technologies under Arctic conditions, and the inclusion of ! eld testing, in which small oil spills were released among sea ice for the purpose of experimentation, adds a ! eld element to the experiments. However, the studies were conducted under controlled conditions, at preselected times and locations where86 N O V EMBER 2010

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### the surface tension of the surrounding water. When the surfactant layer reaches the edge of a thin oil slick, it changes the chemical balance that caused the oil to contract and fold against itself and serves to form thicker layers over a smaller area. The application to response involves thickening the slick to the point where it will support ignition and burning. During the JIP ! eld study, two experimental burns were conducted on chemically herded oil slicks in pack ice. The researchers report that 80 percent of the oil was burned in the ! rst application, a 26-gallon oil slick, and 90 percent in the second experiment, a164-gallon oil slick (Buist et al. 2010b). Although these results con ! rm that chemically herded oil slicks are indeed combustible, a number of considerations must be made when these results are extrapolated to the real world. For example, in the second application, in which 90 percent of the oil was burned, chemical herders were applied 15 minutes after the slick (fresh crude oil) had been released to the pack ice. Boats were standing by to surround and spray the slick. The fresh oil was easily accessed because there was no need to track it, travel to it, or mobilize the equipment needed to apply the herder and ignite the oil. The experiment demonstrated that chemical herders work, but to jump from such a small, controlled ! eld exercise to assumptions about real-world spill response may be premature. The JIP dispersant tests report focuses on new application technologies to apply chemical dispersants to small pockets of oil in sea ice, reporting that the application system resulted in highly e # cient dispersant application. Because sea ice dampens wave activity, which is required for dispersants to mix with oil and work properly, propeller wash from boat engines was used to add mixing energy. Interpretation of the results is subject to the same types of considerations discussed for the chemical herder studies; real-world logistical and operational constraints were not present during the ! eld trials. The JIP program was an important step forward in researching oil spill response technologies for use in Arctic waters. The results, however, are subject to interpretation before assumptions can be made about the applicability of the technologies to spill response in the Arctic. For example, the two skimmer models looked at the recovery e # ciencies of these skimmers deployed under controlled ice conditions, with ready access to pooled oil. The other components of an on-water recovery system—the booms required to contain the oil, the vessels required to operate the booms and skimmers, the on-water storage for recovered oil, and the overarching spill response system required to support major on-water response operations—would still prove daunting. Even if the skimmer e # ciencies are extremely high, there may be days or weeks during which the skimmers cannot be deployed because conditions are too rough, windy, foggy or dark (See Chapter 6 of this report).



### 5.4.2 Field Exercises and Oil Spill Drills in the U.S. Arctic Ocean Most of the published studies on oil spill response in Arctic waters focus on the use of speci ! c techniques or technologies under a range of ice conditions (Figure 5-12). These studies are often conducted in a laboratory or small test tank. Field testing is less common, and most ! eld trials involve arti ! cial controls of weather or ice conditions, or use only one or two components of a88 N O V EMBER 2010

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### Drills and exercises typically occur well after a ! eld trial or research and development program has been completed. For example, while the JIP ! eld trials looked at two speci ! c skimmer designs and tested those skimmers in a controlled area to measure their recovery capacity, the 2000 Beaufort Sea ! eld exercise in Alaska deployed skimmers, boom, multiple vessels, ice scouts and ice management and assessed the operating limits of the entire system. Both types of research and testing are important to furthering our understanding of oil spill response capabilities and limits in the Arctic, yet there have been few ! eld exercises in the Alaskan Arctic Ocean. A review of State of Alaska records shows that over the past decade, there have been four ! eld exercises in which spill response equipment has been deployed in sea ice conditions and evaluated by state regulators. The ! rst such exercise was the 2000 broken ice trials in the Alaska Beaufort Sea (Figure 5-13), where it was demonstrated that the actual operating limits for mechanical recovery systems—which are typically de ! ned in the literature as being operable in up to 30 percent ice coverage—were closer to 10 percent. During fall freeze-up, ice conditions as low as 1 percent constituted the operating limit for a barge-based mechanical recovery system using conventional booms and skimmers (Robertson and DeCola 2001, NRC 2003a). A follow-up ! eld trial testing the barge-based tactic, conducted in 2002, showed no major improvements (State of Alaska Senate Natural Resources Committee Hearing 2010) 2 

### and was followed shortly thereafter by the removal of that barge (the Endeavor) from the Alaska North Slope spill response equipment inventory. Two other ! eld trials were conducted on the North Slope during open-water or brokenice season, one in 2003 and one in 2009, but no reports were published documenting the lessons learned there. Once the distinction between drills, exercises and ! eld trials is understood, it becomes clear that it is not appropriate to extrapolate results from isolated ! eld trials into expectations for a spill response. For example, in-situ burning tests conducted as part of the JIP showed that 98 percent of pooled oil can be burned in three-tenths ice coverage (Potter and Buist 2010). However, the oil was introduced into a pre-contained area at the desired thickness, then immediately ignited, and all vessels were on site and standing by. In the real world, the oil would have to be contained using ! re booms or other barriers, and vessels would have to be able to navigate in and around the burn area, all before the oil became signi ! cantly weathered or emulsi ! ed. And even if the burn were extremely e # cient and removed 98 percent of the oil within the containment area, the oil contained within that single burn might represent only a fraction of a percent of the total amount spilled.

2 T here is little written documentation from ! eld trials in the U.S. Arctic Ocean since the 2000 broken ice exercises. A Freedom of Information Act request to the State of Alaska from Oceana yielded documentation that did not show that any subsequent tests had successfully deployed equipment under broken ice conditions.91 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### recover oil would be unsuccessful. When a response gap exists 65 percent of the time at a given oil spill location, it means that on 65 out of 100 days, no response would be conducted and no oil would be recovered, for reasons that may vary from logistical to practical to safety. Recovery percentages and response e " ectiveness would come into play during the other 35 days, when it would be possible to send out oil spill response equipment. Although it has not been described as such, a response gap occurred several times during the Deepwater Horizon response, when high winds and storm conditions prompted managers to cease on-water operations for a period of hours or days.



### 6.1.1 Response Limit Estimates for U.S. Arctic Ocean In considering the response gap for the U.S. Arctic Ocean, it is necessary ! rst to identify the upper limits of the response systems in place. A response gap exists during periods when at least one of these upper limits is realized. Upper limits may include ice conditions, visibility, wind, sea state, temperature or other physical or environmental parameters. (Table 5-1 summarizes how each of these parameters limits oil spill response.) The upper limits of a spill response system involve a dynamic interplay among multiple factors and the individual components of a response system. However, once the upper limit is reached for one component of a system, it has been reached for the entire system. Establishing response limits for oil spills in the Arctic Ocean is a challenge, especially given the limited data available from actual spills in Arctic waters. The degradation of spill response capability does not occur at a single point, nor is it necessarily linear in nature. For instance, if 30 percent ice coverage is considered to be the operating limit for mechanical recovery, this does not mean that mechanical response e # ciency would plummet to zero as ice coverage increases from 29 percent to 30 percent. Likewise, ice coverage of 15 percent does not indicate that the response e # ciency is twice as high as it would be at 30 percent. The degradation curve is probably di " erent for each environmental factor that a " ects spill response. This further complicates the task of setting discrete operational limits for any one factor. In considering operating limits for the Arctic Ocean, it is also important to recognize that these limits are just as likely to be realized because of limits to the vessels or aircraft required to carry out the response as they are because of limits to the spill recovery or treatment technology. If helicopters or vessels cannot access an area to initiate in-situ burning because of ice conditions or visibility limits, then the response is not feasible, even if experiments have shown that oil can be ignited under similar conditions. In addition to ice coverage, the type of ice has a documented impact on spill response limits. Each of the di " erent ice regimes (solid ice, open water, fall freeze-up, spring breakup) will limit the safety, e " ectiveness or operational feasibility of oil spill response systems. During the transitional ice seasons in the U.S. Arctic Ocean (freeze-up and breakup), ice conditions are so dynamic that a technique that may be appropriate for use one day could be useless the next (Evers et al. 2006). During times when ice conditions may be favorable for response, other conditions, such as wind and waves, may create a response gap. For example, the “Field Guide for Oil Spill Response in Arctic92 N O V EMBER 2010

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### Waters” recommends that wind speeds above 30 mph and wave heights above six feet be the maximum operating limit for in-situ burning and mechanical recovery (Owens et al. 1998). Waves that are considerably smaller than six feet in height may limit response if the wave period (distance and time between waves) is short. Rules of thumb have been developed to estimate whether oil spill response techniques or equipment may be used under a range of ice conditions. It is important to recognize that these are theoretical estimates only; little real-world data are available to corroborate these ! gures. Several published sources estimate the operating limits to oil spill response techniques posed by ice coverage, wind, waves and visibility (Owens et al. 1998, Fingas 2004, Evers et al. 2006, Robertson and DeCola 2001). The response gap for oil spill response in the U.S. Arctic could be quanti ! ed by comparing historical climatic data against a set of upper limit parameters, such as those listed in Table 6-1.

T

able 6-1. M a trix of Approximate Oil Spill R esponse L imits —This matrix summarizes the generallyaccepted response limits to mechanical recovery (with and without ice management) and in-situ burning as they correlate to a range of ice coverage, wind, wave height and visibility conditions. Green blocksindicate conditions generally considered to be favorable for the response technique. Yellow blocks indicate that conditions may impede response operations. Red blocks indicate that response would not be possible under these conditions. Note that any single red factor could shut down a response. Similarly, a combination of yellow factors may have an aggregate impact on response. More work is needed to understand these limits and their impact on oil spill response capability in the U.S. Arctic Ocean. Green indicates only that the technique may be feasible; the e ff ectiveness of that technique in removing or treating oil may still be limited. Dispersants are not included in this table because they are not a mature technology and have not been pre-authorized for use in the U.S. Arctic Ocean.

LIMITIN G F A C T O R ICE C O VER A G E W IN D WA VE HEI G HT VI S IBILIT Y

Conditions <10% 11% to 30% 31% to 70% >70% Solid Ice 0-20 mph 21-35 mph >35 mph <3 ft 3-6 ft >6ft High Moderate* Low*

Mechanical recovery with no ice management

Mechanical recovery with ice management n/a

In-situ burning

*Moderate visibility = light fog or <1 mile visibility; low visibility = heavy fog, < 1⁄4 mile visibility, or darkness 

### Response limits may also be driven by a combination of factors that individually would not a " ect the response. The cumulative e " ect of two or more environmental factors is not necessarily equal to the sum of the two factors individually, and the interaction of the factors could cause94 N O V EMBER 2010

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able 6-2. E nvironmental Factors A ff ecting Operational L imitations in the U.S. Arctic Ocean (adapted from data at Western Regional Climate Center 2009a & 2009b)

E nvironmental Factors and R esponse Gaps (Estimated Percentage of Time When Operating Limits Are Impaired or Exceeded in U.S. Arctic)
Winter (Jan- M ar ch) Spring (April-June) Summer (July-Sept) Fall (Oct-Dec)
Ice Condition: Solid (100%) Approx. Daylight Hrs 4.5 Avg. # Days Peak Gust >30: 20 (22%) Avg. # Days of Fog: 51 (57%) Avg. Ext Min Temp: -49F Ice Condition: Solid (80%), Broken Ice (20%) Approx. Daylight Hrs 19 Avg. # Days Peak Gust >30: 12 (1%) Avg. # Days of Fog: 53 (58%) Avg. Ext Min Temp: -9F Ice Condition: Broken Ice (60%) Open Water (40%) Approx. Daylight Hrs 21 Avg. # Days Peak Gust >30: 19 (21%) Avg. # Days of Fog: 44 (49%) Avg. Ext Min Temp: 20F Ice Condition: Open Water (20%), Broken Ice (60%), Solid (20%) Approx. Daylight Hrs- 5.5 Avg. # Days Peak Gust >30: 30 (34%) Avg. # Days of Fog: 51 (57%) Avg. Ext Min Temp: -32F



### 6.2 G aps in Oil Spill Response Planning for the U.S. Arctic Ocean
Plans to drill exploratory wells up to 200 miles o " shore in the Chukchi Sea would have created the potential for a subsea well blowout in an area of the U.S. Arctic Ocean where there is no ongoing oil exploration or production, and where the capacity to clean up an oil spill in the presence of seasonal sea ice is unproved.



### 6.2.1 Oil Spill Contingency Planning for Chukchi Sea Leases Under existing U.S. regulations, once an o " shore lease sale is completed, the lessees begin the process of developing an exploration oil discharge prevention and contingency plan 1 

### (ODPCP or “C-plan”), which is an important link between operational risks and response capabilities. The plan describes how available resources would be applied to a release of oil under a range of potential circumstances. A C-plan for OCS exploration and production operations is required under 30 CFR Part 254 and must be submitted to the BOEMRE (formerly MMS) for review and approval. A lessee’s C-plan must include a worst-case discharge scenario. Section 311 of the Clean Water Act (33 USC § 1321 (a)(24)) de ! nes “worst-case discharge” as “the largest foreseeable discharge in adverse weather conditions.” 2 

### Under the MMS regulations (30 CFR 254.47(b)), an operator’s worstcase discharge scenario is the daily volume possible from an uncontrolled blowout. In determining the daily discharge rate, the operator must consider any known reservoir characteristics. If reservoir characteristics are unknown, the operator must consider the characteristics of any analog reservoirs from the area and give an explanation for the selection of the reservoir(s) used. The scenario must discuss how to respond to a well $ owing for 30 days (30 CFR 254.26(d) (1)). The adverse weather conditions that must be addressed include, but are not limited to, fog, inhospitable water and air temperatures, wind, sea ice, current and sea states (30 CFR 254.6). It

1 Also r eferred to as a response plan. 2 A dverse weather conditions are conditions found in the operating area that make it di # cult for response equipment and personnel to clean up or remove spilled oil or hazardous substances (30 CFR 254.6).95 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### does not refer to conditions such as a hurricane under which it would be dangerous or impossible to respond to a spill (30 CFR 254.6). Shell, the largest leaseholder in the Chukchi Sea, submitted exploration plans and a C-plan to the MMS, which were approved in December 2009 and ! nalized in March 2010 (Shell 2010). The Shell C-plan includes blowout scenarios, but the scenarios presented do not re $ ect a true worstcase discharge or response. They fall short of the regulatory requirement to plan for a “worst case discharge under adverse conditions” and thus do not provide any real assurance, should a major well blowout occur from drilling in the o " shore Arctic.



### 6.2.2 Planning Assumptions in Shell’s Chukchi Sea Oil Spill Contingency Plan
F L OW R A TE F OR B L OWOUT 

### Shell’s C-plan is based on the ADEC well blowout response planning standard of 5,500 barrels per day, multiplied by the federal response planning period of 30 days. Uncontrolled well $ ow may be signi ! cantly higher, because other North Slope wells have had production rates in excess of 10,000 barrels per day when ! rst drilled.

S P ILL R E COVER Y E S TIMATES 

### Shell includes a planning assumption that 90 percent of the oil discharged from a blowout would be contained and recovered by the primary o " shore response task forces, and that only 10 percent would escape and drift toward shore. Shell expects that half the oil reaching the nearshore environment would be recovered by additional skimming systems deployed from a response barge using a tactic similar to the one that was tested during the 2000 broken-ice exercises and shown to be limited to very low ice concentrations. The C-plan does not explain how Shell arrived at the assumption that 90 percent of the oil would be contained and recovered from the sea surface. By comparison, only 3 percent of the estimated 4.9 million barrels of oil spilled during the Deepwater Horizon incident was recovered by o " shore containment and skimming operations. Recovery of such a large amount of oil, though unrealistic as a planning assumption, would create a storage crisis, based on the resources Shell has identi ! ed in its plan. Shell lists a total of 545,246 barrels of on-water storage capacity for recovered oil and water. With a blowout scenario of 5,500 barrels per day, assuming that the oil is recovered as an emulsi ! ed oil/water mixture, Shell would ! ll this available storage on day 13 of the blowout. If Shell were permitted to decant the oil/water mixture (separate the oil from the water and discharge the water), then the storage could last 30 to 45 days.

S O URCE C O NTROL 

### The Shell C-plan is predicated on a number of assumptions. One of the most problematic assumptions is that the Frontier Discoverer, the drill ship that would drill the exploratory wells, would be able to drill its own relief well if a subsea blowout should occur. This requires that the drill ship be undamaged by a well blowout, which is highly unlikely. The two most recent well blowouts—the Montara platform blowout in the Timor Sea and the Deepwater Horizon blowout in the Gulf of Mexico—involved explosions and ! res that damaged the drilling structure. Fire and96 N O V EMBER 2010

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### explosion are not uncommon for well blowouts, because the materials that are released typically include $ ammable gases. (See list of well blowouts, Table 3-2.) Even if a ! re or explosion did not occur, ignition of $ ammable gases is always a concern. A blowout typically results in evacuation of personnel from the drill ship, which would make starting and moving the ship extremely di # cult. A review of all available data about well blowouts worldwide does not show a single example of a drill ship drilling its own relief well after blowing out. Thus the Shell strategy is without precedent. During the 1980s, the original exploration plans for the Chukchi Sea also called for the drill ship to drill its own relief well in the event of a blowout, but before drilling commenced, the operators were required to arrange for a second drill ship to be on standby in the Canadian Arctic in case the ! rst rig was damaged or unable to complete the relief well (Hinkel et al. 1988). Shell justi ! es the drill ship/relief well plan on the basis that several layers of protection are in place to prevent a blowout from occurring, and the assumption that the blowout would never be severe enough to prevent the drill ship from drilling another well. The Deepwater Horizon provided an example of how protective barriers can fail. Given the fact that the C-plan is questionable, the 30-day time frame for controlling the well may also be overly optimistic. The relief well plan included in the C-plan even acknowledges that it could take 34 days to drill a relief well to 14,000 feet true vertical depth. Shell does not consider the possibility that more than one attempt may be required to drill a successful relief well. The Montara blowout took more than 70 days to control, in part because the ! rst four attempts to drill a relief well were unsuccessful. Shell’s worst-case discharge scenario assumes that a well blowout would occur early in the drilling season, allowing enough time to drill a relief well and control the blowout before fall freeze-up (October or November) begins to encroach on the drill site. A spill that occurred later in the drilling season might not allow enough time to drill a relief well before sea ice conditions made it unsafe to continue drilling. Under such a scenario, the well would continue to blow out through the winter ice season until well control could be attempted after the spring thaw in May or June.

W E ATHER C O NDITIONS 

### Shell’s C-plan contains a scenario that presumes that the weather, temperature and sea state remain consistent throughout the 30-day response period and have no negative impacts on response capability and capacity. This is an unrealistic assumption. Even during the Deepwater Horizon response, weather and sea state caused response operations to be curtailed several times. In the o " shore Chukchi Sea, the combination of wind, waves and dynamic sea ice can severely hamper or even preclude oil spill cleanup (Table 6-1). Shell states in its C-plan that the well drilling activities would not be conducted after Oct. 31. Typically, the Chukchi Sea is ice-free in mid-September. By early September, the ice edge is at its northernmost point. During the last week of September, new ice typically begins to form within the marginal ice zone. As the temperatures begin to decrease, new ice continues to thicken, and the ice edge gradually moves southward. By the second week of October, new ice growth is well97 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### underway. The Arctic pack ice will be drifting southwest with concentrations of multiyear ice at more than seven-tenths, with the remainder being young ice. As the amount of sunlight rapidly declines, temperatures decrease in mid-October, and rapid refreezing of leads and any other openings in the ice is expected. Ice will also begin to grow along the Alaskan coast during the ! rst week of October, with fast ice forming along the Barrow coast by the third week of October. The average wind speed in mid-September through November for Wainwright, Alaska, is approximately 12 mph, with daily gusts averaging 23 mph. The average wind speed and daily gust average for Barrow, Alaska, are similar. Sea state data is less reliable, but seas of 10 to 20 feet are not uncommon. The plan does not address visibility limits for on-water and aerial surveillance and support activities. Fog is persistent throughout the area, with an average number of 21 foggy days per month. Heavy fog with visibility less than or equal to one-quarter mile occurs an average of three days per month during this time. Fog would make on-water and aerial response activities unsafe or unfeasible. The Shell C-plan does acknowledge the possibility that oil spilled late in the drilling season could become encapsulated in fall freeze-up or trapped under ice $ oes through the winter. The spill plan presents this as a favorable condition, assuming that any oil trapped over the winter would remain in place and be as easy to remove or treat after eight months in the sea ice. Sea ice is dynamic and constantly moving, however, and oil trapped under or within ice could be extremely hard to even locate in the springtime. Oil trapped under multiyear ice could remain in the marine environment for many years. A scenario developed in the mid-1980s for the Chukchi Sea estimated that spilled oil trapped in ice could move as much as 300 to 500 miles (Lewbel and Galloway 1984 in NRC 2003b). The period from August until freeze-up is typically the most active storm season in the o " shore Chukchi, with severe storms resulting in high winds and sea states, freezing spray and coastal erosion. An oil spill plan should take into consideration historical weather patterns and plan for the possibility that conditions may not be ideal. Federal regulations speci ! cally require that worst-case oil spill scenarios address “adverse weather conditions,” but the Shell plan, approved by the MMS, certainly does not address adverse weather (30 CFR 254.26(d)).



### 6.2.3 Gaps in Response Capacity for Subsea Well Blowout in the Chukchi Sea Based on the major response activities described in the Shell scenario and the resource requirements to meet the response commitments made in the C-plan, there appear to be major gaps in the capacity of existing response equipment and technologies to respond to a blowout from a subsea well in the Chukchi Sea or elsewhere in the U.S. Arctic Ocean. 3 

### One major gap apparent in the Shell Chukchi C-plan is that, in many cases, spill response operations depend upon the same pieces of equipment or vessels to support multiple functions simultaneously. Another problem is a lack of consideration for the logistical challenges of

3 This analysis takes into consideration only mechanical recovery operations, not the use of chemical dispersants or insitu burning. Although Shell’s Chukchi leases are in federal waters, the C-plan conforms to State of Alaska requirements that planholders demonstrate that they can meet their oil spill cleanup requirements solely through mechanical recovery. The state of Alaska prioritizes mechanical recovery over dispersant use and in-situ burning.98 N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group 

### mounting a major spill response o " shore in a region with limited coastal infrastructure. The Shell C-plan indicates that the primary incident command post would be in Anchorage, Alaska (see Figure 2-15). The plan does not identify the number of industry, contractor and agency personnel needed to sustain the response. Logistical support and staging areas would also need to be established in Barrow, Wainwright, Point Lay or Point Hope, the only coastal communities with

su # cient airstrips. In an attempt to demonstrate some of the shortfalls in the level of contingency planning accepted for Arctic Ocean oil spills, the major response activities in the Shell C-plan and the response limitations are considered, based on the discussion in Section 6.1. Table 6-3 (at the end of this section) summarizes the resource requirements, task force, function, response tactics, minimum required response resources, and source of resources listed in the Shell C-plan. The resources summarized are for surveillance and tracking, o " shore recovery, transfer and storage of recovered oil, nearshore recovery and sensitive area protection. Alaska Clean Seas (ACS) is the primary oil spill response contractor for the U.S. Arctic region. The Alaska Clean Seas Equipment Manual provides a guide to the location, ownership, type, amount and speci ! cations of most of the North Slope response equipment (ACS 2009). Although ACS has a signi ! cant equipment stockpile to support operations in shallower, nearshore waters, it has limited o " shore capabilities.

S U RVEILLANCE A ND T R ACKING 

### The Shell Chukchi Sea contingency plan does not clearly identify the resources that would be used to carry out the aerial surveillance of oil on the water. Two helicopters are identi ! ed in the C-plan. It is assumed that the Twin Otter aircraft with forward-looking infrared radar (FLIR) from Kuparuk would be used initially and based in Barrow for this response, but FLIR technology is limited by ice conditions (it cannot be used to detect oil under fast ice). It is also a " ected by cloud cover and fog and can be used only during daylight. This resource can be obtained through the mutual aid contract with North Slope Operators and Alaska Clean Seas. As with all o " shore oil spill response operations, other commercial aircraft and helicopters would need to be contracted to conduct aerial surveillance and tracking of the oil and to support the operation. (More than 100 ! xed-wing aircraft and helicopters were used during the Deepwater Horizon oil spill response.) An impediment to aerial surveillance during this time frame is the presence of fog or ice. As noted, the monthly average of foggy days in the region is 21 during the ice-free season. In the Shell C-plan, spill tracking buoys will also be deployed to assist in determining where the oil is being transported and at what rate. In addition to the hand-held tracking buoys, Shell plans to track the discharge using satellite technology. In cloud-free conditions, visible imagery is an excellent aid. However, because the Arctic has few days that are cloud free, high-resolution all-weather imagery will be necessary for consistent operational support. As freeze-up sets in, tracking and monitoring the movement of oil will be increasingly di # cult, and innovative options or commercially available technology will need to be used. Shell’s contingency plan suggests the possible use of the Shell Global Source Light Touch System (gas detector), ground-penetrating radar and laser $ uorosensors. Although commercially available, all of these technologies are experimental when applied to tracking oil that is under or mixed in ice.99 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences

O F FSHORE R E COVER Y


### Shell’s o " shore recovery revolves around four primary response vessels and eight workboats that would be on site for the drilling period and other response resources located hundreds of miles from the drill site. MMS never required Shell to demonstrate, beyond its descriptions in the C-plan, whether this equipment was su # cient to clean up a worst-case oil spill far o " shore that lasts 30 days or longer. The immediate availability and signi ! cant amount of spill response equipment in the Gulf of Mexico after the Deepwater Horizon blowout demonstrates that when a catastrophic spill occurs, no amount of equipment is enough. The limited personnel, vessels and a few thousand feet of ocean boom that Shell plans for its o " shore spill response would be insu # cient for cleaning up a major spill in the remote Chukchi Sea. Alaska Clean Seas has limited equipment suitable for o " shore operations. MMS did not require any testing or exercises to explore the limits of existing spill cleanup equipment for o " shore response when sea ice is present.

N E ARSHORE R E COVER Y A ND P R OTECTION O F S E NSITIVE R E SOURCES 

### The Shell C-plan shows that three task forces are assigned to nearshore recovery to apply ! ve di " erent response tactics. Shell intends to deploy protective boom at seven priority protection areas (PPA) identi ! ed in the scenario along Chukchi Sea shoreline areas. Table 6-3 summarizes the resource requirements for boom, workboats and personnel to deploy all of these strategies when they arrive on Day 5. As these activities are going on simultaneously with o " shore recovery and nearshore recovery, the resources required to deploy sensitive area protection tactics are presumed to be dedicated to sensitive areas and are not available to other task forces. The resources listed in the Shell C-plan are:

• Amount of boom r equired to implement all priority protection strategies is 6,200 feet.

• F ourteen workboats and 44 trained responders/vessel operators to deploy and seven workboats and 21 trained responders/vessel operators to tend and maintain boom.

• M obilization plan for vessels, personnel and boom is unclear from the scenario. ACS provides all equipment, vessels and personnel.

• A CS vessels and personnel would probably require transportation via vessel or barge from Prudhoe Bay to the protection sites. Some sites have signi ! cant draft restrictions. The Shell C-plan clearly indicates that the shoreline protection will be sharing resources and personnel, which will create a con $ ict of resource priorities.

S H ORELINE I M PACT 

### Shell’s C-plan discounts the potential for shoreline impacts, noting that it is “highly unlikely that oil could impact the nearshore environment in less than six days.” The C-plan goes on to state that “even if oil did survive that long in the open ocean, there would be ample time to monitor its movement, prepare to intercept and recover it, and to position shoreline protection and cleanup crews at priority protection sites well before the oil may arrive.” This statement seems to all but dismiss the potential for a spill from the exploration operations to a " ect shoreline areas, even though the closest drill site is about 60 miles from the shoreline.100 N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group 

### A large oil spill would undoubtedly have shoreline impacts, as we have seen time and again in major oil spills. The Exxon Valdez oil spill migrated 460 miles and a " ected more than 1,300 miles of noncontiguous shoreline. The Deepwater Horizon spill has a " ected coastlines in four Gulf Coast states. Little is known about currents and wind direction in the U.S. Arctic Ocean, so it is virtually impossible to know what direction the oil will go. During the ! rst week of October, ice will begin to form along the shoreline, and oil would probably become encapsulated in ice, making access to sites and any shoreline cleanup activities challenging.

CAS C A D I N G O F A D D I TI O N A L OIL SPILL R E S P O N S E R E S OU R CE S 

### Shell’s C-plan indicates that if additional response resources were needed to adequately clean up an oil spill, the company would activate existing contracts with the Marine Spill Response Corporation, Oil Spill Response in Southampton, United Kingdom, and the mutual aid agreements through Alaska Clean Seas. Personnel and equipment would join the response from other locations in Alaska and worldwide. Shell’s C-plan does not explain how these additional resources would be mobilized from the various airports (Barrow, Point Hope, Wainwright) to the spill location. The infrastructure and road system in the smaller communities are limited and cannot support a Deepwater Horizon size response. Accessing the North Slope communities by vessel also presents a challenge and is weather dependent. The entrance to Wainwright Inlet is a narrow, winding channel. Its depth is approximately six feet, enough to accommodate shallow-draft barge tra # c, but passage should not be attempted without the aid of local guides and/or pilots during open-water season. Shoals extend approximately seven-tenths of a mile o " the inlet and are well de ! ned by breakers during moderate weather. During west storms, the breakers stretch across the channel. Point Hope is located on the Chukchi Sea with a nearshore current of 1 knot, increasing to 2 to 3 knots near Point Barrow. Barrow can be accessed by vessel during open-water season, but there is no protection from heavy weather.101 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences

Shell T ask F orce P urp ose and N ame M inimum R equired R esponse R esources 1 P ot ential Shortfalls or Operating L imitations E N VIR O N MENT A L F A C T O R S A N D OPER A T IN G L I MIT A

T I O N S

W inter (Jan- M ar ch) Spring (April-June) Summer (July-Sept) Fall (Oct-Dec)
Surveillance

a nd Tracking

(No task force number assigned in C-plan) 1 Kuparuk Twin Otter aircraft with FLIR Spill tracking buoy system 1 workboat (deploy tracking buoys) 6 trained personnel per shift Satellite tracking Resources not clearly identified in Shell scenario.
No contract found in Shell C-Plan for this service. Primary limitation for aerial operations will be associated with visibility (57%). Day visual flight rule (VFR) only for field ops. Whiteout, blizzard conditions, limited daylight hours and ice fog. Limitations: Visibility associated with fog, ice fog (58%) icing on aircraft, day VFR operations only for field ops. Limitations: Visibility associated with fog (49%), day VFR operations only for field ops. Limitations: Visibility associated with whiteouts, fog, ice fog (57%) icing on aircraft, day VFR operations only for field ops.

O ! shore R ecovery 2

TF-1 1 oil spill response vessel (OSRV) with 12,000 bbl storage
1 Transrec 150 Skimmer 1 OSRV supervisor 1 OSRV operator
3 34-ft workboat operators (shared with TF-2)
3 34-ft workboat

crew 7 OSRV deck crew
1 100-bbl bladder Three 34-ft workboats, operators and crew are shared with
TF-2. Solid ice precludes on-water vessel operations. Limitations for

o ff shore oil recoveryinclude: Visibilitywhiteout, blizzard conditions, ice fog and extreme temperatures (58%). May-June breakup will preclude use of vessels nearshore. Solid ice present

o ff shore precludes vessel operations. Limitations: Broken ice conditions and open water. Ice management needed in broken ice areas for e ff ective response. Open water a ff ected by wind speeds and gusts >30 kts (21%), visibility due to fog (49%). Limitations: Open water and broken ice. Ice management needed in broken ice areas for e ff ective response. Open water a ff ected by wind speeds and gusts >30 kts (34%), visibility due to fog (57%). Extreme temperatures would cause icing on vessels and response recovery equipment.

O ! shore R ecovery

TF-2 (24 hr) 1 Transrec 150 skimmer
1 Vessel of Opportunity Skimming System (VOSS) w/ 3,200 bbl storage 1 VOSS supervisor
2 VOSS deck crew
3 34-ft workboat operator (shared with TF-1)
3 34-ft workboat

crew Beginning Day 2, the TF team leader/ field supervisor is accounted for in TF-1. Solid ice precludes on-water vessel operations. Limitations for

o ff shore oil recoveryinclude: Visibilitywhiteout, blizzard conditions, ice fog and extreme temperatures (58%). May-June breakup will preclude use of vessels nearshore. Solid ice present

o ff shore precludes vessel operations. Limitations: Broken ice conditions and open water. Ice management needed in broken ice areas for e ff ective response. Open water a ff ected by wind speeds and gusts >30 kts (21%), visibility due to fog (49%). Limitations: Open water and broken ice. Ice management needed in broken ice areas for e ff ective response. Open water a ff ected by wind speeds and gusts >30 kts (34%), visibility due to fog (57%). Extreme temperatures would cause icing on vessels and response recovery equipment. T

able 6-3. R esource R equirements and Operating L imitations102 N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group Shell T ask F orce P urp ose and N ame M inimum R equired R esponse R esources 1 P ot ential Shortfalls or Operating L imitations E N VIR O N MENT A L F A C T O R S A N D OPER A T IN G L I MIT A

T I O N S

W inter (Jan- M ar ch) Spring (April-June) Summer (July-Sept) Fall (Oct-Dec)
Transfer & St orage of R ecovered O il

TF-3 1 Oil Spill Tanker (OST)
1 Tanker Deck Person-in-Charge (PIC) 1 Tanker operator
3 Tanker deck crew (1 per shift) Crude oil capacity = 513,000 bbl. All TF-3 tasks including PIC will be performed by tanker crew with no additional response sta ff from Shell or ACS. Solid ice precludes on-water vessel operations. Solid ice and spring breakup conditions near retreating ice edge would preclude the OST to be in the area until July. Open water

a ff

ected by wind speeds and gusts >30 kts (21%), visibility due to fog (49%). Open water

a ff

ected by wind speeds and gusts >30 kts (34%), visibility due to fog (57%). Extreme temperatures would cause icing on vessels and response recovery equipment. OST would need to depart region prior to freeze-up.
Nearshore & Shoreline R ecovery

TF-5 (96 hr) 1 oil spill response barge (OSRB)/tug with16,000 bbl capacity 1 OSRB supervisor
1 nearshore recovery supervisor
4 Lamor LSC-5 skimmers (2 per vessel)
1 47-ft skimmer boat
1 47-ft skimmer boat operator
2 47-ft skimmer boat crew
3 34-ft workboats
3 34-ft workboat operator 3 34-ft workboat

crew 4 249-bbl storage
200 m boom 6,000-ft coastal boom Solid ice precludes on-water vessel operations. Solid ice and spring breakup conditions near retreating ice edge would preclude the OSRB to be in the area until July. Limitations: Broken ice conditions and open water. Ice management needed in broken ice areas for e ff ective response. Open water a ff ected by wind speeds and gusts >30 kts (21%), visibility due to fog (49%) Limitations: Open water and broken ice. Ice management needed in broken ice areas for e ff ective response. Open water a ff ected by wind speeds and gusts >30 kts (34%), visibility due to fog (57%). Extreme temperatures would cause icing on vessels and response recovery equipment. Shell T ask Force P urpose and N ame M inimum R equired R esponse R esources 1 P otential Shortfalls or Operating L imitations E NVIR O NMENT A L F A CT O R S A N D OPER A TIN G L IMIT A

TI O N S

Winter (Jan- M arch) Spring (April-June) Summer (July-Sept) Fall (Oct-Dec)
Surveillance and Tracking

(No task force number assigned in C-plan) 1 Kuparuk Twin Otter aircraft with FLIR Spill tracking buoy system 1 workboat (deploy tracking buoys) 6 trained personnel per shift Satellite tracking Resources not clearly identified in Shell scenario.
No contract found in Shell C-Plan for this service. Primary limitation for aerial operations will be associated with visibility (57%). Day visual flight rule (VFR) only for field ops. Whiteout, blizzard conditions, limited daylight hours and ice fog. Limitations: Visibility associated with fog, ice fog (58%) icing on aircraft, day VFR operations only for field ops. Limitations: Visibility associated with fog (49%), day VFR operations only for field ops. Limitations: Visibility associated with whiteouts, fog, ice fog (57%) icing on aircraft, day VFR operations only for field ops.

O ! shore Recovery 2

TF-1 1 oil spill response vessel (OSRV) with 12,000 bbl storage
1 Transrec 150 Skimmer 1 OSRV supervisor 1 OSRV operator
3 34-ft workboat operators (shared with TF-2)
3 34-ft workboat

crew 7 OSRV deck crew
1 100-bbl bladder Three 34-ft workboats, operators and crew are shared with
TF-2. Solid ice precludes on-water vessel operations. Limitations for

o ff shore oil recoveryinclude: Visibilitywhiteout, blizzard conditions, ice fog and extreme temperatures (58%). May-June breakup will preclude use of vessels nearshore. Solid ice present

o ff shore precludes vessel operations. Limitations: Broken ice conditions and open water. Ice management needed in broken ice areas for e ff ective response. Open water a ff ected by wind speeds and gusts >30 kts (21%), visibility due to fog (49%). Limitations: Open water and broken ice. Ice management needed in broken ice areas for e ff ective response. Open water a ff ected by wind speeds and gusts >30 kts (34%), visibility due to fog (57%). Extreme temperatures would cause icing on vessels and response recovery equipment.

O ! shore Recovery

TF-2 (24 hr) 1 Transrec 150 skimmer
1 Vessel of Opportunity Skimming System (VOSS) w/ 3,200 bbl storage 1 VOSS supervisor
2 VOSS deck crew
3 34-ft workboat operator (shared with TF-1)
3 34-ft workboat

crew Beginning Day 2, the TF team leader/ field supervisor is accounted for in TF-1. Solid ice precludes on-water vessel operations. Limitations for

o ff shore oil recoveryinclude: Visibilitywhiteout, blizzard conditions, ice fog and extreme temperatures (58%). May-June breakup will preclude use of vessels nearshore. Solid ice present

o ff shore precludes vessel operations. Limitations: Broken ice conditions and open water. Ice management needed in broken ice areas for e ff ective response. Open water a ff ected by wind speeds and gusts >30 kts (21%), visibility due to fog (49%). Limitations: Open water and broken ice. Ice management needed in broken ice areas for e ff ective response. Open water a ff ected by wind speeds and gusts >30 kts (34%), visibility due to fog (57%). Extreme temperatures would cause icing on vessels and response recovery equipment.103 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences

Shell T ask F orce P urp ose and N ame M inimum R equired R esponse R esources 1 P ot ential Shortfalls or Operating L imitations E N VIR O N MENT A L F A C T O R S A N D OPER A T IN G L I MIT A

T I O N S

W inter (Jan- M ar ch) Spring (April-June) Summer (July-Sept) Fall (Oct-Dec)
Nearshore & Shoreline R ecovery

TF-6 (96 hr) 4 workboats 18-22 ft plus 4 operators and 4 crew
2 workboats 29 ft plus 2 operators and 2 crew
2 24-ft workboats plus 2 operators and 2 crew 2 landing craft plus 2 operators and 2

crew 18,000-ft boom
8 shoreline protection laborers Boats and landing craft are shared by TF-6 and TF-7.

TF-5, TF-6 and TF-7 operate one 12-hour shift per day. Solid ice precludes on-water vessel operations. Solid ice and spring breakup conditions near retreating ice edge would preclude the OSRB to be in the area until July. Limitations: Broken ice conditions and open water. Ice management needed in broken ice areas for e ff ective response. Open water a ff ected by wind speeds and gusts >30 kts (21%), visibility due to fog (49%). Limitations: Open water and broken ice. Ice management needed in broken ice areas for e ff ective response. Open water a ff ected by wind speeds and gusts >30 kts (34%), visibility due to fog (57%). Extreme temperatures would cause icing on vessels and response recovery equipment.
Nearshore & Shoreline R ecovery

TF-7 See TF-6 resources 20 oleophilic skimmers 36 bladders (500 to 2,640 gal.) 50 portable folding tanks (2,500 gal.) 8 shoreline recovery laborers Trained shoreline assessment teams (minimum of 4 personnel per team with requisite training).

Helicopter for transportation. Solid ice precludes on-water vessel operations. Solid ice and spring breakup conditions near retreating ice edge and shoreline would restrict access to beaches needing cleanup. Visibility limitations due to fog (49%) to support shoreline cleanup crews via vessel and helicopter. Freeze-up and solid ice conditions

a ff

ect access to shoreline due to ice. Wind speeds and gusts >30 kts (34%), visibility due to fog (57%). Extreme temperatures would cause icing of recovery equipment. Aerial operations limitations: icing on aircraft, day VFR operations only for field ops (5.5-0 hours).

1 P er task force, with the exception of sensitive area protection, which shows the requirements for deployment of all priority protection sites simultaneously. Sequential

deployment of sensitive area protection resources will reduce the number of workboats and personnel required but will not a ff ect the total amount of boom. 2 T able 1.6-5 Shell Contingency Plan lists two skimming alternatives to be considered for use by TF-1 but only one option would be used in the scenario. 3 T his table contains no TF-4 “Non-mechanical response.” TF-4 includes designation of both a C-130 aircraft (based in Arizona) with integrated dispersant tank and spray

arms and the chemical dispersant Corexit 9500. This table addresses mechanical recovery options that are primarily in-state and readily available.104 N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group Shell T ask Force P urpose and N ame M inimum R equired R esponse R esources 1 P otential Shortfalls or Operating L imitations E NVIR O NMENT A L F A CT O R S A N D OPER A TIN G L IMIT A

TI O N S

Winter (Jan- M arch) Spring (April-June) Summer (July-Sept) Fall (Oct-Dec)
Nearshore & Shoreline Recovery

TF-6 (96 hr) 4 workboats 18-22 ft plus 4 operators and 4 crew
2 workboats 29 ft plus 2 operators and 2 crew
2 24-ft workboats plus 2 operators and 2 crew 2 landing craft plus 2 operators and 2

crew 18,000-ft boom
8 shoreline protection laborers Boats and landing craft are shared by TF-6 and TF-7.

TF-5, TF-6 and TF-7 operate one 12-hour shift per day. Solid ice precludes on-water vessel operations. Solid ice and spring breakup conditions near retreating ice edge would preclude the OSRB to be in the area until July. Limitations: Broken ice conditions and open water. Ice management needed in broken ice areas for e ff ective response. Open water a ff ected by wind speeds and gusts >30 kts (21%), visibility due to fog (49%). Limitations: Open water and broken ice. Ice management needed in broken ice areas for e ff ective response. Open water a ff ected by wind speeds and gusts >30 kts (34%), visibility due to fog (57%). Extreme temperatures would cause icing on vessels and response recovery equipment.
Nearshore & Shoreline Recovery

TF-7 See TF-6 resources 20 oleophilic skimmers 36 bladders (500 to 2,640 gal.) 50 portable folding tanks (2,500 gal.) 8 shoreline recovery laborers Trained shoreline assessment teams (minimum of 4 personnel per team with requisite training).

Helicopter for transportation. Solid ice precludes on-water vessel operations. Solid ice and spring breakup conditions near retreating ice edge and shoreline would restrict access to beaches needing cleanup. Visibility limitations due to fog (49%) to support shoreline cleanup crews via vessel and helicopter. Freeze-up and solid ice conditions

a ff

ect access to shoreline due to ice. Wind speeds and gusts >30 kts (34%), visibility due to fog (57%). Extreme temperatures would cause icing of recovery equipment. Aerial operations limitations: icing on aircraft, day VFR operations only for field ops (5.5-0 hours).

1 Per task force, with the exception of sensitive area protection, which shows the requirements for deployment of all priority protection sites simultaneously. Sequential

deployment of sensitive area protection resources will reduce the number of workboats and personnel required but will not a ff ect the total amount of boom. 2 Table 1.6-5 Shell Contingency Plan lists two skimming alternatives to be considered for use by TF-1 but only one option would be used in the scenario. 3 This table contains no TF-4 “Non-mechanical response.” TF-4 includes designation of both a C-130 aircraft (based in Arizona) with integrated dispersant tank and spray

arms and the chemical dispersant Corexit 9500. This table addresses mechanical recovery options that are primarily in-state and readily available. 

### 6.2.4 Gaps in Planning and Response Capacity in the Beaufort Sea Sections 6.2.1 through 6.2.3 of this report discuss the gaps in planning and preparedness for oil exploration in federal waters up to 200 miles o " shore in the Chukchi Sea. Many of the same challenges described for the Chukchi Sea would carry over to exploratory drilling in areas of the Beaufort Sea. A more detailed analysis of the extent and nature of the response gap in both the Chukchi and Beaufort seas is warranted and should address the similarities and di " erences between the two operating environments. Most of the limiting factors discussed in the context of the U.S. Arctic Ocean—such as high winds, severe storms, heavy seas, low visibility, cold temperatures and seasonal ice—apply to both the Beaufort and Chukchi seas. However, there are di " erences between the two operating areas that may alter the challenges.

WATER DEPTHS AND DISTANCE FROM SHORELINE 

### Existing production operations in state and federal waters of the Beaufort Sea are clustered in shallower areas within a few miles of the shoreline (Figure 3-3). Thus far, these operations have been conducted from man-made gravel islands at water depths below 80 feet. Expanded drilling or production in deeper waters farther from shore may require $ oating or bottom-founded structures, as discussed in Chapter 3. For now, drilling operations that are conducted from islands closer to shore have both advantages and disadvantages from a spill planning perspective. Oil spills from exploration and production operations closer to shore will have more rapid shoreline impacts. However, blowouts from island drilling structures may be easier to control because the blowout preventers are located at the surface rather than underwater. That factor, combined with seasonal drilling restrictions, gives responders a better chance of cleaning up oil spilled on top of solid ice.

SEASONAL DRILLING 

### Exploratory drilling in the Beaufort Sea has been conducted during the winter season when the nearshore Beaufort is frozen solid and spill response tactics would involve operating vehicles and equipment from the solid land-fast ice coverage. Spills on top of solid ice present their own challenges but are typically easier to clean up than spills in open water or broken ice during the freeze-up, breakup or open-water seasons. Because production operations continue year-round in the Beaufort Sea, the potential for a spill during freeze-up or breakup exists, and such a spill may be even more challenging because of the operating conditions there. The shallow nearshore Beaufort is not deep enough for ice-class vessels to operate; therefore, the small workboats that would form the basis of the response would be limited to operating in areas of lower ice concentration. The open-water season in the Beaufort Sea is about a month shorter than in the Chukchi Sea, further limiting the response window for on-water cleanup.105 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences

WORST

 CASE BLOWOUT VOLUMES 

### Although data are limited on well-bore pressure and potential blowout rates in the Chukchi Sea, more information is available about the potential blowout rates for Beaufort Sea wells. The contingency plan for the Liberty development project in the Beaufort Sea has the highest $ ow rates in the U.S. Arctic and a potential open-ori ! ce blowout of 20,000 barrels a day. A blowout from a Beaufort Sea well that occurs during the end of the brief open-water season could continue uncontrolled over the nine-month ice season and result in a spill larger than the Deepwater Horizon blowout if oil is trapped within and among sea ice until the spring melt.107 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### documentation of local and traditional knowledge in the U.S. Arctic. Arctic ecological science, monitoring and assessment should be integrated with oil spill prevention and response planning. The Arctic features a complex interplay of environmental conditions, climate, wildlife population dynamics and human activity. The prospect of conducting baseline studies to better delineate environmental and wildlife sensitivities, while increasing our scienti ! c knowledge base regarding the Arctic ecology and sensitivity to oil spills, is daunting. Yet such research is critical and must be initiated before the introduction of new oil spill risks.



### 7.1.1 Close the Knowledge Gaps Regarding Arctic Oil Spill Impacts Additional research is needed to better understand the fate and impact of oil spilled in a seasonal ice environment and to explore the short- and long-term toxicity of spilled oil to the Arctic ecosystem and food webs. A 2007 assessment of worldwide oil exploration and production activities in Arctic regions emphasizes that the current state of knowledge regarding Arctic oil spill impacts and oil toxicity to Arctic species is extremely limited. Signi ! cant research is needed on the behavior of oil spilled in ice- ! lled seas, the vulnerabilities of Arctic ecosystems to oil toxicity, and the short- and long-term impact of oil spills on Arctic food webs, plants, animals and people. The 2008 Arctic Oil and Gas Assessment Scienti ! c Findings and Recommendations discusses these “gaps in knowledge”:

“This assessment has identi " ed many gaps in knowledge of the impacts of Arctic oil and gas activities on the environment, biota, and human populations of the Arctic. This is partly due to an incomplete understanding of environmental conditions in the relevant areas of the Arctic and of the species and populations of the many plants and animals that live there as well as their ecological interactions. There is also incomplete knowledge of the socio-economic and health e # ects on the human populations of the development of the oil and gas industry in the often remote areas. ... Research is required on a wide range of the potential biological e # ects of these chemicals under conditions and with species and life stages appropriate to the Arctic, including, among others, studies of acute and chronic toxicity, genetic e # ects, and combined e # ects with, for example, exposure to sunlight. This includes studies of linkages between the diverse sub-lethal e # ects and the risks they pose to individuals and populations of Arctic animals.” (AMAP 2008b) Most of the existing knowledge regarding oil toxicity and chemical interactions comes from studies on temperate species. Studies from other cold-water oil spills, such as the Exxon Valdez spill in sub-Arctic Prince William Sound, suggest that oil spill impacts in cold regions can be signi ! cant and long-lasting. However, there are many gaps in the current body of knowledge on issues that include:

• T ransfer and accumulation of toxic compounds within the Arctic food web.

• S econdary or chronic impacts from oil exposure (e.g., reduced fertility, immunosuppression).108 N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group 

### • R elative sensitivities of various life stages of ! sh, birds and mammals.

• P hoto-enhancement of oil toxicity.

• S easonal variations in oil toxicity sensitivity of various species.

• P otential impact of global climate change to oil sensitivity and toxicological interactions. Gaps in knowledge regarding oil toxicology to Arctic species must be closed so that leaders can make informed decisions that will not increase the risk of a major oil spill in the U.S. Arctic Ocean. In the Norwegian Barents Sea, a study from 2004 through 2009 added to knowledge on the sensitivity of Arctic species to dispersed oil and produced water (water discharged during oil production, containing some crude oil and other contaminants). The objectives of this study were the following: 1) evaluate the relevance of biomarkers (tools used to evaluate exposure levels to contaminants such as oil) developed for temperate species to sub-Arctic and Arctic species; 2) consider whether biomarkers used in adult species could be applied to juveniles; 3) establish baseline levels for biomarkers in key Arctic species in the Barents Sea region; and 4) collect data that could be used to establish threshold levels for oil exposure based on biomarker levels (Bu " agni et al . 2010). The Barents Sea study looked at four ! sh species in juvenile and adult life cycles. The results of this study are relevant to that region only, but similar research on ! sh species in the Chukchi and Beaufort seas might provide a starting point for establishing critical exposure levels to organisms and understanding the potential implications of exposure to spilled oil at various life stages and times of year. Some baseline studies have been conducted in the western nearshore Beaufort Sea to establish baseline hydrocarbon levels in the region of the Northstar gravel island-based production facility (Durell et al . 2006). The impact of oil spills on polynyas and ice leads is another area of Arctic spill science in need of further study. The potential toxicity and adverse e " ects from alternative response methods such as chemical dispersants and in-situ burning should also be considered. Considerable additional research should be conducted, and all meetings, reports and work products should be available for public and stakeholder review and input. All research projects should be developed using peer-reviewed methodologies, and all results should also be peer reviewed.



### 7.1.2 Improve Spatial Data on Environmental Sensitivities “Ecologically sensitive areas should be mapped, and oil spill trajectory models should be further improved and used to determine areas most at risk from oil spills. This would improve the basis for attempts to decrease or eliminate the probability of an oil spill

a # ecting sensitive areas.” (AMAP 2008b) Limited information has been compiled to date regarding environmental sensitivities in the U.S. Arctic Ocean. For at least 800,000 years, there has been some sea ice in the Arctic Ocean. Not surprisingly, animals have adapted in many ways to these conditions. At the same time that oil development is being proposed in the o " shore Chukchi Sea, Arctic species are facing109 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### unprecedented stresses from climate change, which is bringing profound physical and biological impacts. The rapid loss of summer sea ice is having unparalleled e " ects on the Arctic ecosystem, with some changes already apparent. For example, the distribution of species has begun to shift (Grebmeier et al . 2006, Mueter and Litzow 2008) and may alter the structure of Arctic ecology (AMAP2008b, Moore and Huntington 2008). The shrinking of the ice has far-reaching e " ects on the entire ecosystem, beginning with the phytoplankton that bloom at the ice edge each spring. Climate change is expected to have a “widespread, annual, population-level e " ect on epontic (under ice) and other lower trophic-level organisms that depend on the summer/autumn ice cover,” leading to a major ecological impact at the base of the food chain even without oil exploration and production activities (MMS 2008). The loss of summer sea ice cover has impacts at all levels of the ecosystem, including e " ects on ice-dependent marine mammals such as walrus (Jay and Fischbach 2008) and polar bears (Hunter et al . 2007). Impacts from oil exploration and development, especially the potential for oil spills, will further stress an already fragile ecosystem. To minimize adverse impacts and assist with response priorities, it is necessary to identify and protect those areas of the ocean with high importance for the ecosystem, ecological processes or species. Important ecological areas (IEAs) can be de ! ned as geographical areas that contribute disproportionately to an ecosystem’s health, including its productivity, biodiversity, structure, function or resilience (Ayers et al. 2010). Furthermore, these areas may be more at risk to harm and would bene ! t in the long term from e " ective management (Ehler and Douvere 2009). However, the Alaskan Arctic Ocean is di # cult to access, particularly in the winter months. As a result, IEAs have not been identi ! ed for the Chukchi or Beaufort seas, and many of their species are poorly understood. IEAs in the Arctic seas are expected to be shifting and variable because of seasonal and year-to-year changes in wildlife populations and biological productivity. Better observation data (wind, current, visibility and ice conditions) should be developed to support oil spill contingency planning and to improve trajectory models. Alaska shore zone mapping and imagery should be expanded to include the Arctic. Regional oil spill contingency planning should include geographic response strategies (GRS) that identify priority protection sites and provide protective booming strategies and other tactics that may be quickly implemented to protect these areas ahead of a spill trajectory. Currently, sensitive sites are identi ! ed, but response tactics and strategies are not tested before exploration and production operations to ensure success. Su # cient resources must be dedicated to implement these tactics.110 N O V EMBER 2010

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### 7.1.3 Develop Arctic Oil Spill Trajectory Models “Better knowledge is essential to improve assessments of the transport, fate and e # ects of spilled oil in ice-covered waters, including oil under ice carried by currents and oil drifting with the sea ice.” (AMAP 2008b) Better trajectory modeling is needed to develop more realistic oil spill planning scenarios. Existing models have virtually no ability to accurately predict how oil and ice interactions will a " ect oil movement when sea ice is present (Khelifa 2010). This gap has implications for oil spill planning and response. From a planning perspective, the inability to model oil trajectories during various ice conditions makes it almost impossible for operators or regulators to assess the potential risks from a major oil spill, because we cannot reliably predict where an oil spill would travel and which resources might be a " ected. If a major spill were to happen during exploration or production operations in the U.S. Arctic Ocean and oil was present in the environment through ice season, responders would have a very limited ability to predict how or where the oil might move. Improved trajectory modeling will require of more data on environmental and weather conditions for new operating areas such as the Arctic OCS. Additional real-time observation and monitoring systems may need to be developed. This will also require that modelers develop more reliable algorithms to predict how sea ice and oil will interact in the Arctic Ocean.



### 7.1.4 Consider Cumulative Impacts of Oil Exploration and Production in Arctic OCS The cumulative impacts of oil exploration and production have been extensively studied in the onshore U.S. Arctic. Proposed expansion of oil exploration and production activities into deeper waters farther o " shore from the established Prudhoe Bay oil ! elds would introduce additional strains on the people and ecology of the region. It is important to consider the impact of additional activity and infrastructure associated with expanded o " shore oil exploration and the development of an enhanced spill response capacity. Roads, docks and other transportation infrastructure can have adverse environmental e " ects. Changes to the use of coastal areas and OCS waters may a " ect traditional cultural uses and have unforeseen impacts on indigenous people. Disruptions to traditional lifestyles brought by new infrastructure, changes to subsistence activities and an in $ ux of people to the region may all a " ect the local people.



### 7.2 A ssess and Plan for Worst-Case Blowout Risks

7.2.1 Conduct Risk Assessment To reduce the risks associated with uncontrolled spills from oil exploration in the Arctic OCS, it is ! rst necessary to conduct a comprehensive risk assessment. There are two components to a risk assessment: conducting a risk analysis that considers the likelihood and consequences of an undesirable event, and identifying risk management measures that target the highest-priority risks. To calculate risk, a risk analysis is conducted to answer the following questions:111 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### • What can go wr ong?

• Ho w likely is it?

• What ar e the impacts?
The ! rst question is typically answered by developing one or more risk scenarios—in this case, oil spill scenarios that describe what could happen based on the speci ! c operations to be conducted. The second question is answered using a predictive model that estimates the likelihood of occurrence for various types of oil spills that have been identi ! ed. The third question requires an analysis of the potential consequences of all possible spill scenarios, based on the sensitivities and vulnerabilities of the local environment, wildlife, culture and socioeconomic resources. The answers to these three questions, for all possible scenarios, are a complete expression of the risk being assessed. The result may be expressed quantitatively, qualitatively or through a combined approach. Signi ! cant information-gathering is required to conduct an e " ective risk analysis. The evaluation of Arctic OCS oil spill risks will require a realistic estimate of oil spill frequency in the o " shore Arctic and a synthesis of information about ecological vulnerabilities and environmental sensitivities. It also must include realistic assessments of the potential impacts from catastrophic blowout scenarios that occur in di " erent seasons and conditions. Expression of risks through a risk analysis is only the ! rst step; the next step is to identify and evaluate risk management options. This requires a prioritization of the identi ! ed risks by establishing some criteria for risk tolerance and then evaluating risk reduction measures based on their appropriateness to reduce or mitigate the highest-priority risks. There are several established methodologies for conducting oil spill risk assessments. A project is ongoing in the Aleutian Islands using a methodology suggested by the National Academy of Sciences. A similar process could be applied to the Arctic Ocean.



### 7.2.2 Require More Realistic Worst-Case Blowout Scenarios Worst-case discharge amounts—the maximum spill size that could occur from exploration or production operations—should be calculated on the basis of the highest possible $ ow rates for a well, based on all available data. Higher “default” $ ow rates should be established for operations in new regions such as the Arctic OCS—where previous o " shore exploration has con ! rmed that blowouts could exceed (by several orders of magnitude) the state response planning standard of 5,500 barrels of oil per day—and based on well data from similar reservoirs located onshore. Worst-case discharge estimates should also factor in the time required to stop the blowout. The Deepwater Horizon blowout continued for three months. Other blowouts have lasted longer, yet many oil spill contingency plans consider only a 15- or 30-day duration.



### 7.2.3 Improve Oil Spill Prevention Technologies for Arctic Exploration and Production Blowout prevention technologies and blowout control measures should also be assessed, because blowout control is the ! rst line of defense against a major oil spill.112 N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group 

### Additional requirements for reducing blowout risks and improving blowout control in the Arctic may include:

• Ar ctic design standards and best practices. All equipment used for oil exploration and production in the Arctic Ocean, including but not limited to vessels, pipelines, wells, tanks, processing equipment and structures, should be designed in accordance with Arctic engineering practices and should be able to withstand worst-case geological hazards, and Arctic temperatures, wind, water and ice hazards that may be encountered. Design criteria should be based on actual measurements of worst-case data for the site of development, or on conservative estimates. If operations are planned during ice conditions, vessels should be certi ! ed by the U.S. Coast Guard or the American Bureau of Shipping as Arctic Class and should be capable of operating safely in Arctic conditions.

• Emer gency shutdown devices (ESDs). ESDs should be installed on the o " shore drilling units and facilities to limit the scope of any single failure. Manual and automatic ESDs should be installed to allow operators to manually shut down systems, or to allow systems to automatically shut down if operators are unable to safely access the system. ESDs should be provided for all the primary systems of a drilling unit’s operation and facility operation and for fuel transfers. ESD systems should be tested before use and at regular intervals thereafter.

• Blo wout prevention systems (BOPs). BOPs should be capable of controlling at least 150 percent of the maximum anticipated pressure; equipped with two sets of blind shear rams; inspected by the manufacturer and an independent third-party certi ! ed inspector before use; tested on a seven-day interval versus the current requirement of 14 days; and have reliable emergency backup control systems and immediate access to su # cient remote operating vehicles to manually activate a subsea BOP if needed. Shear rams should be tested on the pipe planned for use to verify capability to sever that grade of pipe. Redundant BOPs should be considered and installed for $ oating drilling units when technically feasible.

• Back up drilling rigs on site. To facilitate relief well drilling in the event of a blowout, operators should be required to have a drilling rig on standby to initiate relief well drilling and to have purpose-built well capping structures (such as the one used during the Deepwater Horizon blowout) prefabricated and available on site before drilling begins. Oil spill removal organizations (OSROs) operating in the Arctic OCS should demonstrate that they have su # cient regional capacity to support an Arctic OCS well blowout. Resident blowout control capabilities are needed in the U.S. Arctic. Well control equipment and experts should be on site to take immediate action to control the well and/or contracts should be in place with well control experts to immediately bring additional personnel, equipment and expertise to the site in the event of a blowout.

• P refabricated containment structures. Containment structures must be designed, engineered and tested under Arctic conditions. Such structures—if they can be113 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### successfully engineered to withstand the ice and weather conditions in the Arctic Ocean—should be part of the toolkit for operators drilling in the U.S. Arctic Ocean.



### 7.3 I mprove Arctic OCS Oil Spill Response Capacity

7.3.1 Assess Existing Oil Spill Response Capacity for Oil Spills in Arctic OCS To develop the response capacity needed to support o " shore exploration and production in the Arctic OCS, it is necessary ! rst to assess the capabilities of available oil spill response systems, to delineate the upper operating limits of equipment and systems, and to identify opportunities to improve responsibilities, while also establishing prevention measures to minimize spill risks when response capacity may be exceeded. This process should occur before oil exploration activities introduce the risk of a catastrophic spill to the Arctic OCS. Oil spill response capacity is much more than spill response equipment, particularly for o " shore areas where on-water response requires considerable logistical support. In addition to the booms, skimmers and recovered oil storage devices that make up a typical o " shore or nearshore spill response task force, the capacity also includes: the vehicles and vessels that transport the equipment from its storage location to the spill site; the workboats, barges, cranes and other support equipment that are used to support the on-water response operations; the personnel required to operate vehicles and vessels, run equipment and direct the response operations; and the tactical plans that outline how all of these components will operate to achieve oil spill containment, recovery and cleanup objectives. Assessing the e " ectiveness and limitations of oil spill response capacity for a given operation or operating area requires complex analysis. To a certain extent, this can be accomplished on paper by conducting scenario analyses in which a speci ! c spill size, location and trajectory are used to map out how and where resources would be applied during a spill, and to assess how much of the spilled oil the available resources might be able to recover. However, most oil spill response scenarios are predicated on a set of assumptions that require validation through ! eld deployment exercises (see Section 7.2.2).



### 7.3.2 Require Operators to Demonstrate Oil Spill Response Capabilities During A gency-Led Field Exercises There is little real-world information available regarding the e " ectiveness of Arctic spill response systems because there have been no major Arctic o " shore oil spills. Most of our assumptions about how spill response systems will perform in the Arctic OCS are derived from small-scale laboratory and tank tests, or ! eld tests that are limited to a speci ! c piece of equipment. The information gleaned from such tests may be misleading; for example, a tank test demonstrating that a skimmer will not clog until ice concentrations exceed 40 percent coverage does not mean that the full oil spill recovery system—vessels, boom, skimmer and storage barge—could operate safely or e " ectively up to that limit. The upper limit of a single piece of equipment or an individual technology does not guarantee that the response system required to deploy that technique will have the same functionality.114 N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group 

### Government approval of oil spill contingency plans should be based upon demonstrated capabilities veri ! ed through ! eld exercises, unannounced drills and audits. One necessity is fullscale ! eld trials, during which multiple vessels are deployed to test tactics in Arctic OCS waters and ensure that all components of a response system can operate e " ectively, and then to delineate the upper operating limits posed by environmental conditions such as wind, sea state, sea ice and visibility. During full-scale ! eld deployments, equipment is transported to the scene and deployed under a range of natural conditions. In some cases, a response system may fail not because of a primary equipment malfunction, but because one (or more) of the technologies or support platforms does not perform as intended. These support functions may be severely challenged by Arctic environmental conditions, remote locations or lack of infrastructure. During a series of ! eld trials held in the Alaska Beaufort Sea, responders found that the actual limits to a vessel-based skimming and recovery system were realized in much lower sea ice concentrations than previously assumed. Multiagency oversight of these drills and written documentation will help to build a knowledge base regarding the limits to oil spill response systems in the Arctic OCS. The plan review and approval process for all OCS oil spill response plans should include an opportunity for public review and comment and also should include consultation among agencies with roles in oil spill prevention and response as well as natural resource trustees.



### 7.3.3 Improve On-Water Oil Spill Response Systems and Techniques for Arctic OCS C

onditions Oil spill cleanup technologies have been slow to improve, and the basic tools used to contain and remove oil spills today are very similar to those in place decades ago. The Deepwater Horizon incident led to a number of innovations, forced by the imminent pressure of an exploding oil well. Moving forward, a more comprehensive and proactive research-and-development regime should be designed to expand the limits of existing spill response technologies, particularly mechanical recovery, the only technique that removes oil from the environment. Programs such as the JIP

are a ! rst step in this process, though the JIP had many $ aws, including a lack of peer review and a lack of transparency during the research. Spill response technologies have not kept pace with advances in drilling technologies. New technologies for subsea containment, such as the one developed and used during the Deepwater Horizon spill, should be developed for the Arctic Ocean.



### 7.4 C onduct an Arctic OCS Oil Spill Response Gap Analysis
A response gap exists whenever environmental conditions exceed the operating limits of oil spill cleanup equipment, meaning that if a spill occurred during this time, it could not be contained or cleaned up. Although it is clear that the environmental, oceanographic and climatic conditions in the Arctic Ocean represent a challenge to existing oil spill cleanup technologies, the extent to which these conditions might limit oil spill cleanup is not well understood. An Arctic oil spill response gap analysis will provide critical information regarding the oil spill response limits115 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### posed by Arctic environmental conditions (temperature, wind, sea ice, visibility) and will calculate how frequently those operating limits are reached in the area of oil exploration and production operations. The methodology for conducting such an analysis involves three key steps: Quantify the operating limits of o " shore oil spill response systems available to clean up oil spills in the Arctic. This process starts with examination of one or more o " shore spill response systems (equipment, vessels and personnel) and then consideration of the upper operating limits of that system or systems. This is typically determined by the component (or components) that is most likely to fail once a given condition—sea state, ice coverage, visibility, temperature or wind—is exceeded. When that limit is exceeded, the response system would be rendered inoperable. Calculate the frequency with which the operating limit is reached. Historical weather data and observations are analyzed to determine how frequently each of the limiting factors occurs during the operating season. If historical data are not available, modeling may be used. Assuming that multiple factors would limit Arctic o " shore spill response operations, the analysis would also have to consider the interplay among factors to account for any cumulative impacts. (For example, the combination of 10 percent ice coverage and less than 1 nautical mile visibility may present an operating limit, even though individually neither factor represents an upper limit.) Estimate the response gap by applying the operating limits to the environmental dataset. The result of this analysis will characterize the frequency of occurrence of one or more environmental factors that would render oil spill cleanup possible, impaired or impossible. Such an analysis was completed in Prince William Sound in Alaska in 2007, showing that during the winter season at one o " shore location, a response gap existed 65 percent of the time. There is no question that a response gap exists in the Arctic. Once it has been estimated, additional oil spill prevention or mitigation measures may then be put into place to reduce the likelihood of a spill occurring when no response is possible.117 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



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### Owens, E., et al. (2005). The behavior and documentation of oil spilled on snow- and ice-covered shorelines. Proceedings from the International Oil Spill Conference. Miami. May 15-19, 2005. PTT Exploration and Production Co. Australasia Ltd. (No date). Commission of inquiry; Montara well head platform; uncontrolled hydrocarbon release. www.montarainquiry.gov.au/ downloads/21%20PTTEP/SUBM.1000.0002.0026.pdf. Parker, M.W., et al . (2007). Assessment of social attraction techniques used to restore a common murre colony in central California. Waterbirds 30(1):17-28. Paulin, M.J., et al. (2010). Arctic o " shore technology assessment of exploration and production options for cold regions of the U.S. continental shelf. Oil Technology Conference 20698. Pp. 1-16. Peterson, C.H., et al. (Dec. 19, 2003). Long-term ecosystem response to the Exxon Valdez oil spill. Science 302(5653):2082-2086. Petterson, J.S., and E.W. Glazier. (2004). A study of the drift gillnet " shery and oil/gas industry interactions and mitigation possibilities in Cook Inlet. Prepared for the Minerals Management Service. OCS Study MMS 2004-038. Potter, S. (ed.). (2004). World catalog of oil spill response products. Ottawa, Ontario. S.L. Ross Environmental Research Ltd. Eighth edition. 2004-2005. Potter, S., and I. Buist (2010). In-situ burning in Arctic and ice-covered waters: Tests of " re-resistant boom in low concentrations of drift ice. Arctic Marine Oil Spill Program. Environment Canada. Pp. 743-754.
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### U.S. Coast Guard et al. (August 2006). Special Monitoring of Applied Response Technologies. Seattle. U.S. Department of the Interior. (May 27, 2010). Salazar Calls for New Safety Measures for O # shore Oil and Gas Operations; Orders Six Month Moratorium on Deepwater Drilling. News release. www. doi.gov/news/pressreleases/Salazar-Calls-for-New-Safety-Measures-for-O "shore-Oil-andGas-Operations-Orders-Six-Month-Moratorium-on-Deepwater-Drilling.cfm. U.S. Environmental Protection Agency. (2010). EPA Response to BP Spill in the Gulf of Mexico . www. epa.gov/bpspill/dispersants.html. U.S. Fish and Wildlife Service. (2009). Protection of Paci ! c Walrus Under the Endangered Species Act May Be Warranted, U.S. Fish and Wildlife Service Finds. News release. www.fws.gov/ news/newsreleases/showNews.cfm?newsId=9AB69D79-B55D-6855-C9C8E9E2D5536DB1 Accessed Aug. 11, 2010. U.S. Fish and Wildlife Service. (2010a). Endangered, Threatened, Proposed, Candidate and Delisted Species in Alaska. Updated May 11, 2010. U.S. Fish and Wildlife Service. (2010b). Paci " c walrus (Odobenus rosmarus divergens): Alaska Stock. Stock Assessment Review. Revised Jan. 1, 2010. http://alaska.fws.gov/ ! sheries/mmm/ stock/ ! nal_paci ! c_walrus_sar.pdf. U.S. Geological Survey. (2010). Walrus tracking and telemetry data acquired from walruses instrumented on the Alaska shores of the Chukchi Sea in September 2009 . Radio-Tagging Field Report. USGS Alaska Science Center, Walrus research project. http://alaska.usgs.gov/ science/biology/walrus/pdfs/EC09_Radio_Tagging_Field_Report.pdf. U.S. Government Accountability O # ce. (2010). Additional guidance would help strengthen the Minerals Management Service’s assessment of environmental impacts in the North Aleutian Basin. O " shore oil and gas development. GAO 10-276, Washington. University of Alaska Fairbanks Geophysical Institute. (2010). 2010 Sea ice break-up forecast for Barrow, Alaska. http://seaice.alaska.edu/gi/observatories/barrow_breakup. Accessed July 31, 2010. Wadhams, P. (1976). Oil and ice in the Beaufort Sea. Polar Record . 18(114):237-250. Weeks, W.F., and G. Weller. (1984). O " shore oil in the Alaskan Arctic. Science . 225(4660):371-378. Wernham, A. (2007). Inupiat health and proposed Alaskan oil development: Results of the ! rst integrated Health Impact Assessment/Environmental Impact Statement for proposed oil development on Alaska’s North Slope. EcoHealth 4(4):500-513. Western Regional Climate Center. (2009a). Station: Barrow-W Post-Will Rogers Memorial Airport (PABR): Climatological Summary. July 1996 to December 2008. www.wrcc.dri.edu/ summary/brw.ak.html. Western Regional Climate Center. (2009b). Station: Wainwright Airport (PAWI): Climatological Summary. September 1998 to December 2008. www.wrcc.dri.edu/summary/awi.ak.html.128 N O V EMBER 2010

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### Wilson, D., and D. MacKay. (1987). The behavior of oil in freezing situations. Environment Canada. Wolfe, M.F., et al. (1997). In $ uence of dispersants on trophic transfer of petroleum hydrocarbons in a marine food chain. Proceedings of the 20th Arctic and Marine Oil Spill Program Technical Seminar . Pp. 1215-1226. World Meteorological Organization. (2005). WMO sea-ice nomenclature. www.aari.nw.ru/gdsidb/ xml/nomenclature.asp.130 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



## Appendix A: Acronyms and Abbreviations

ACIA Arctic Climate Impact Assessment ACS Alaska Clean Seas ADEC Alaska Department of Environmental Conservation AMAP Arctic Monitoring and Assessment Program AMOP Arctic and Marine Oil Pollution Technical Seminar APD Application for Permit to Drill API American Petroleum Institute ARCOP Arctic Operational Platform BBO Billion Barrels of Oil BCB Bering, Chukchi and Beaufort Seas population BOEMRE Bureau of Ocean Energy Management, Enforcement and Regulation BOP Blowout Preventer BOSS Behavior of Spilled Oil at Sea BP British Petroleum Exploration & Production Inc. BPXA British Petroleum Exploration Alaska COCP Critical Operations and Curtailment Plan C-PLAN Contingency Plan DOE Department of Energy DOI Department of the Interior EIS Environmental Impact Statement ESI Environmental Sensitivity Index FLIR Forward-Looking Infrared Radar GAO Government Accountability O ffi ce GRS Geographic Response Strategy IARC International Arctic Research Center IEA Important Ecological Area JIC Joint Information Center JIP Joint Industry Project MMS Minerals Management Service NEPA National Environmental Policy Act NETL National Energy Technology Laboratory NOAA National Oceanic and Atmospheric Administration NRC National Research Council NRT National Response Team NSIDC National Snow and Ice Data Center OCS Outer Continental Shelf ODPCP Oil Discharge Prevention and Contingency Plan131 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### OSB Ocean Studies Board OSRB Oil Spill Response Barge OSRO Oil Spill Removal Organization OSRV Oil Spill Response Vessel OST Oil Spill Tanker PAH Polycyclic Aromatic Hydrocarbon PIC Person-in-Charge PPA Priority Protection Area PRB Polar Research Board PTTEP PTTEP Australasia Pty Limited SAC Science Advisory Council SERVS Ship Escort Response Vessel Services SIZONET Seasonal Ice Zone Observing Network SNAME Society of Naval Architects and Marine Engineers SWCC Subsea Well Control and Containment TAPS Trans Alaska Pipeline System TCFG Trillion Cubic Feet of Gas UAFGI University of Alaska Fairbanks Geophysical Institute USCG United States Coast Guard USEIA United States Energy Information Administration USFWS United States Fish and Wildlife Service USGS United State Geological Survey VOC Volatile Organic Compounds VOSS Vessel of Opportunity Skimming System WMO World Meteorological Organization WRCC Western Regional Climate Center WSF Water-Soluble Fractions132 N O V EMBER 2010

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## Appendix B : Glossary

B en thic: Pertaining to the environment and conditions of organisms living at the water bottom, or benthos.

B ioaccumulation: The concentration of a substance in a living organism, possibly with harmful e ff ects.

B iomagni fi cation: Also known as bioamplification or biological magnification. The increase in concentration of a substance that occurs in a food chain as a consequence of persistence, food chain energy or low rate of internal degradation/excretion of the substance.

B lowout P r eventer ( B O P ): A set of large valves at the top of a well that may be closed if the drilling crew loses control of formation fluids. By closing these valves (usually operated remotely via hydraulic actuators), the drilling crew usually regains control of the reservoir, and procedures can then be initiated to increase the mud density until it is possible to open the BOP and retain pressure control of the formation.

B rash I c e: Accumulations of floating ice made up of fragments not more than 2 meters across; the wreckage of other forms of ice.

B ridge: As in to bridge a well; to seal itself with rock fragments from the collapsing formation.

B roken I c e: An operating environment where a body of water has incomplete coverage of ice. Broken ice varies from less than 10 percent coverage to greater than 90 percent coverage. Mechanical oil spill recovery e ff ectiveness is diminished at ice concentrations greater than 10 percent and generally precluded at concentrations above 70 percent.

C alm Water: An operating environment where the sea state is usually less than 1 foot waves and currents are less than 0.8 knots; includes waters that are very sheltered from wind and waves or very small bodies of water. This is the least demanding operating environment for waterborne oil spills.

C andida te Species: A species for which the U.S. Fish and Wildlife Service has on file su ffi cient information on biological vulnerability and threat(s) to support proposals as threatened or endangered (under the Endangered Species Act).

C op epods: Small, shrimplike animal of the subphylum Crustacea (includes crabs and lobsters) that are only a few millimeters in diameter and are called zooplankton—or animals that float in the sea. They eat microscopic algae called phytoplankton. They are an important part of the food chain because they are typically eaten by fish.133 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### Decant: To remove free-water from an oil-water mixture by drawing the water o ff the bottom of the oil-water interface.
Dispersant: A chemical formulation containing surface active agents (surfactants) that lowers the surface tension between oil and water and facilitates the breakup and dispersion of oil into the water column in the form of finely divided droplets to allow for natural biodegradation.

Downhole: Farther into a well bore, rather than at the Earth’s surface.
Drilling Fluids: Any of a number of liquid and gaseous fluids and mixtures of fluids and solids (as solid suspensions, mixtures and emulsions of liquids, gases and solids) used in operations to drill bore holes into the Earth. Also known as drilling mud.

E mulsi fi cation: A process by which oil forms an emulsion or “mousse” consisting of many small droplets of water incorporated into the oil.

E ncapsulation: The absorption of a polymer film onto cuttings and well-bore walls to form a coat or barrier.

E ndangered Species: One that is in danger of extinction throughout all or a significant portion of its range.

E ntrain: To incorporate with and carry along.

E ntrainment: The loss of oil from containment when it is pulled under a boom by a strong current; typically occurs when booms are deployed perpendicular to currents greater than 1 knot (0.5 meter [almost 20 inches] per second).

Fast I c e: Sea ice that forms and remains fast along the coast, where it is attached to the shore, an ice wall or an ice front, or between shoals or grounded icebergs.

Federal Waters: Marine waters of the outer continental shelf from the three-mile state waters boundary to the border of the U.S. exclusive economic zone, 200 miles from the contiguous shoreline.

Floe: Any relatively flat piece of sea ice 20 meters (22 yards) or more across.

Frazil I c e: Fine spicules or plates of ice, suspended in water.
Geographic R esponse Strategies (G R Ss): Site-specific spill-response methods used to protect sensitive coastal environments from the deleterious e ff ects of petroleum or other hazardous-substance spills. GRSs provide first responders with specific guidance for a rapid deployment of pre-identified actions to protect priority sensitive sites.134 N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group 

### Grease I c e: When crystals have coagulated to form a soupy layer on the surface; a later stage of freezing than frazil ice.

H aul-Outs: Locations on land or ice where marine mammals such as walrus and seals climb out of the water to rest or nurse their young.

I c e Gouging or I c e Scour: The abrasion of material in contact with moving ice in a sea, ocean or other body of water.

I c e R ubble: Fragments of floating ice, 1 to 5 feet high, frozen in water.

L ead: Any fracture or passageway through sea ice that is navigable by surface vessels.

N earshor e: A shallow-water operating environment close to the coast.

Open Water: An operating environment where the sea state can reach 6 feet and moderate waves and whitecaps may occur. Includes open water that is not sheltered from wind and waves. This is the most demanding operating environment for waterborne spills.

P ack I c e: In a wide sense, includes any area of sea ice other than fast ice no matter what its form or how it is disposed.

P anc ake I c e: Predominantly circular pieces of ice from 30 centimeters to 3 meters (1 foot to 10 feet) in diameter and up to about 10 centimeters (4 inches) thick, with raised rims due to the pieces striking against one another.

P hytoplankton: Microscopic marine plant, or algae that floats in the ocean. They convert carbon dioxide and sunlight for energy and release oxygen as a waste product. They are at the base of the marine food web. In the Arctic food web, they play a very important role as they grow on the underside of the ice as in the spring and are a source of food for zooplankton such as amphipods.

P olyn ya: An area of open water surrounded by sea ice.

P r otected Water: An operating environment where the sea state can reach 3 feet and small waves and whitecaps may occur. Protected waters have limited shelter from wind and waves. Protected water falls between open water and calm water in the classification scheme.

R ecolonization: The process of a new community of plants and animals coming to inhabit a space after a disturbance has displaced most of the flora and fauna.

Sea I c e: Any form of ice found at sea that has originated from the freezing of seawater.135 OIL SPILL P R EVENTI O N and R E S P O N S E IN THE U.S. ARCTIC: Unexamined Risks, Unacceptable Consequences



### Sea State: A sea state is the general condition of the free surface on a large body of water— with respect to wind waves and swell—at a certain location and moment. A sea state is characterized by statistics, including the wave height, period and power spectrum.
Secondary C on tainment: Structures, usually dikes or berms, surrounding tanks or other storage containers and designed to catch material spilled from the storage containers.

Sessile: A plant or animal that is not able to move freely because it is permanently attached to the substrate, such as a rock. Examples of sessile marine plants include algae and such marine animals as barnacles and coral.

Slush I c e: Snow that is saturated and mixed with water on land or ice surfaces, or as a viscous floating mass in water after a heavy snowfall.

Solid I c e: Where a body of water has complete coverage of ice. Spill response activities may occur on solid ice only after it is determined that the ice is of su ffi cient thickness to safely support response personnel and equipment.
Staging Area: Location where incident personnel and equipment are available for tactical deployment. Can serve as a check-in location for equipment and personnel reporting to the incident.

State Waters: Marine waters out to three miles from the contiguous shoreline, over which the state has jurisdiction.

Substrata: The area upon which an organism, such as a clam or barnacle, is attached. It can also be a layer of rock or soil immediately beneath the surface of the Earth.

T

ask F orce: A group of resources with common communications and a leader assembled for a specific mission. Often used in oil spill response planning and management.

T hr eatened Species: One that is likely to become endangered within the foreseeable future throughout all or a significant portion of its range.

T r ophic L e vel: Trophic levels define the position of an organism in a food web or chain. Trophic is a Greek word that means feeding. The first level of a food chain contains the primary producers, which are generally the plants and algae that produce their own energy using light and carbon dioxide. Animals that eat plants are at the next level, while predators are at the third level.

Wave P erio d: The average amount of time between passages of successive crests (or troughs) of waves.
Weathering: The chemical and physical changes that occur once oil has spilled, including spreading, evaporation, dissolution, photooxidation, dispersion, biodegradation and emulsification.136 N O V EMBER 2010

 U.S. Arctic Program, Pew Environment Group 

### Well B a y: An area of an oil platform where the wellheads are located. It normally consists of two levels, including a lower level where the wellheads are accessed, often along with the various well control panels, which will have pressure gauges and controls for hydraulically actuated valves, including downhole safety valve and annular safety valve.

Well B or e: A hole created by drilling.Philadelphia, Pa. 19103 Tel. 215-575-9050 Washington, D.C. 20004 Tel. 202-552-2000 www.OceansNorthUS.org