WESTERN GRAY WHALE ADVISORY PANEL MARINE OIL SPILL PREVENTION AND RESPONSE

Transcription

1 WESTERN GRAY WHALE ADVISORY PANEL WGWAP 1/INF.17 1 st Meeting 27 October 2006 MARINE OIL SPILL PREVENTION AND RESPONSE A response to the WWF report entitled Offshore Oil Spill Response in Dynamic Ice Conditions: A Report to WWF on Considerations for the Sakhalin II Project Prepared for SEIC by DF Dickens Associates Ltd, 30/05/2006 Submitted by SEIC WGWAP 1/INF.17

2 Preliminary Review Comments Offshore Oil Spill Response in Dynamic Ice Conditions A Report to WWF on Considerations for the Sakhalin II Project May 30, 2006 Submitted to: Sakhalin Energy Investment Company Ltd. Yuzhno-Sakalinsk Russia Submitted by: DF Dickins Associates Ltd. info@dfdickins.com

3 Acknowledgements Alan Allen of Spiltec and Ian Buist and Stephen Potter of SL Ross Environmental Research Limited provided peer reviews of this preliminary review, including editorial comments and additional technical inputs. Overview Remarks This preliminary review responds to the recent (April 2006) report Offshore Oil Spill Response in Dynamic Ice Conditions, commissioned jointly by WWF UK and WWF Germany. In that report, the authors claim that there is a response gap for spill response in dynamic ice that makes effective clean up unlikely, with significant consequences for the summer population of the western gray whale. The WWF report provides constructive suggestions for additional analysis and research where more information would improve the capabilities to undertake winter spill response and to assess the consequences of a spill in ice (p. 65). Sakhalin Energy is currently conducting a number of projects that relate directly to these suggestions. However, in developing and supporting the gap hypothesis, the authors quote from or paraphrase numerous references, including Shell-sponsored studies and outside literature. In some cases, these references are used to provide a convenient interpretation that is different in context and intent from the original report being referenced. In other cases, particularly with regard to long-term spill impacts, authors representing a particular point of view are used as the basis for sweeping general statements (disregarding other recognized scientists who may draw very different conclusions). This preliminary review presents a number of key issues where the findings of the WWF report contradict a broad knowledge base of experience (e.g. the efficacy of burning on and in ice). Additional, pagespecific comments are provided as an Appendix. Key Issues (cross-referenced to page number in the WWF report) 1. Findings from the Arctic Marine Assessment Programme (AMAP 1998) are quoted (without full reference) throughout the report in discussing the expected environmental consequences and behaviour of spills off Sakhalin various pages e.g. pp. 14/16/20/60 [There is a fundamental problem in transferring findings and conclusions developed specifically for an Arctic setting to the Sea of Okhotsk. For example: temperatures and duration of extreme cold are far less extreme than a true Arctic environment; coastal exposure to wave energy that plays a major role in controlling long term oil persistence is much greater along the Sakhalin coast than in most Arctic areas; and the frequent wind-induced flaw lead referred to as the Sakhalin polynya is not analogous to a recurring Arctic polynya linked to nutrient upwelling (p. 23). The ecology and ecosystems of the Sakhalin marine environment are unique to the region and cannot simply be put in an Arctic framework.] 2. Oil deposited on water or ice from an open orifice blowout will not ignite due to loss of volatiles. p. 51 [This is not borne out by extensive research where a wide range of weathered and partially emulsified crudes have been successfully ignited with and without ice see SL Ross various studies] info@dfdickins.com 2 05/30/06 Rev

4 3. Burn residues will sink and cause significant, long lasting harm to the WGW feeding grounds p. 64 [Conjecture - there is extensive evidence that burn residues are largely non-toxic and pose less risk to the marine environment than not burning refer to committee conclusions In Situ Burning Guidelines for Alaska (US EPA, USCG and ADEC). Although actual test data on Sakhalin oils would be required to definitively counter this statement the available data from tests on other crude oils strongly suggests that the cooled residue from burns of these crudes in broken ice would float, not sink. 4. If a major well blowout, pipeline release, or tanker spill occurred during the six months of the year when broken ice conditions prevail, an effective cleanup is unlikely Large oil spills in ice cannot be effectively removed or recovered, regardless of the technique used. various e.g. pp. 7/50/53/63/66 [Not true these statements presuppose that only mechanical recovery would be used. Previous scenarios for dynamic ice conditions off Prudhoe Bay for example have shown a range of effectiveness for ISB in broken ice of 35-87% (avg. 52%), well above what can typically be achieved with offshore spill response in temperate waters SL Ross et al. (1998)] 5. Low visibility, strong winds and waves are important factors combining to dramatically reduce response effectiveness during the ice season. Various e.g. pp. 57/63 [Visibility and winds are important limiting factors for ISB operations but not to the extent that such conditions are dominant. For example, in the Chayvo area, low visibility (less than 800m) persists for about 1 day per month in the winter (blizzards during the same time period average about 6 days). Fog is more prevalent during break-up in May and June but still persists for less than 6 days per month on average in the two worst months. Strong winds sufficient to curtail ISB occur about 10% of the time in Dec and Jan and less than 5% of the time for the rest of the winter. Waves over 2 m during the winter are effectively damped by the presence or proximity of ice. It is important to note that a condition representing a maximum operating threshold for one technique may represent optimum conditions for another strategy. For example, high sea states that restrict mechanical containment and recovery in open water can promote rapid natural dispersion of oil droplets into the water column and enhance the effective use of chemical dispersants; high ice concentrations that interfere with mechanical recovery in the winter may promote the presence of thick oil films for efficient burning and so on--] 6. The available response windows in broken ice range from short bursts of hours to nonexistent. p. 63 [This misquotes a statement in Dickins and Allen (2005) where the point was made that limited operations with booms and skimmers and/or fire booms were possible in the intermediate range of ice concentrations (3-6/10) by taking advantages of local openings in the ice cover for short periods. This point applied only to the specific case of making every effort to take advantage of available openings in a very specific, short-lived set of ice conditions and was not intended as an assessment of response limitation for the entire range of broken ice concentrations.] 7. The range of ice concentrations considered most problematic for either mechanical recovery or burning (3-6/10) persists for half the year off Sakhalin. various e.g. pp. 5/7/17/58/63 [The Sakhalin ice environment can be characterized as having a range info@dfdickins.com 3 05/30/06 Rev

5 of winter pack ice concentrations from 2 to 8/10 (quoted correctly from Dickins and Allen (2005). However, the WWF authors neglected to quote from the rest of the same paragraph that goes on to say that Over the entire winter period, heavy pack ice defined as over 6/10 of medium first year ice ( cm thick) will likely persist for less than one month. In some seasons, the polynya dominates the offshore environment to such an extent that any pack ice exists for as little as 15% of the ice season. In other words, the critical range of ice concentrations that truly represent the dynamic response gap may exist for a relatively small part of the winter much different than saying 6 months of the year.] 8. There is considerable technical debate among experts about the efficacy of in-situ burning as a primary oil spill response tool in the Arctic p. 5/62 [This is a misrepresentation of the unanimous opinion of experts in the field who concur that ISB is the preferred, most effective spill response strategy for Arctic areas.] 9. An expedited peer review was conducted prior to the release of this report -. p. 8 [Not clear what is meant by expedited review. It would help to know which experts reviewed the report and their qualifications.] 10. However, in situ burning has not been widely used, particularly in cold climate onwater spill response p. 44 [The authors neglect to mention the vast body of worldwide experience with burning in a wide variety of situations (open water, salt marshes, Arctic rivers, solid ice, and broken ice). ISB has been used successfully on a variety of spills in ice in the Canadian, Russian, and Norwegian Arctic as well as in the Baltic. This experience is in addition to a number of large-scale field tests on cold open water and ice in Canada and Norway. Controlled burning was also used successfully on weathered North Slope crude oil in Prince William Sound, Alaska, following the grounding of the Exxon Valdez. Ref. Allen (1990)]] the science of how spilled oil behaves and how it can be cleaned up in ice-infested waters is dominated by unknowns. p. 65 [This is not true. There are 35 years + of studies into the behaviour of oil in ice and developing and testing clean-up strategies for oil in solid and broken ice. Field research has demonstrated that oil trapped in ice for over six months is readily ignitable (e.g. Norcor 1975)] info@dfdickins.com 4 05/30/06 Rev

6 APPENDIX SPECIFIC COMMENTS (by page in the PDF document) Note: The background Sakhalin Energy report attributed to Dickins (2005) throughout the WWF report should be correctly referenced to Dickins and Allen (2005) Page covered with sea ice from November until May each year. Earliest freeze-up offshore NE Sakhalin is first week of December, latest beginning of January. End-of -season dates (any ice) can range from early May to mid-june in extreme years. This report concludes a dynamic ice response gap due to well-documented limitations on the effectiveness of oil spill response technologies when sea ice is present. This is not a true statement. Yes, there are well-documented limitations on mechanical response effectiveness. However there is a vast body of knowledge on the efficacy of burning in a range of ice conditions with results showing the potential for much higher effectiveness in many winter scenarios involving broken ice than possible with conventional mechanical recovery of oil spills in temperate open water see Key Issue No. 3 under general remarks above ice formations that range in coverage from 20% to 80% --- See Key Issue No. 6. Above There is considerable technical debate among experts about the efficacy of in-situ burning as a primary oil spill response tool in the Arctic----- This statement is completely false. The world s experts with direct handon experience burning oil on and in ice all concur that ISB is the preferred, most effective spill response strategy for Arctic areas. There is no considerable technical debate about this issue. see Key Issue No. 9 Page 6 This report does not attempt to quantify the response gap Quantification of the gap is critical to drawing any conclusions about its potential significance. Page 7 Oskins and Bradley 2005 Not in reference list Page 7 &11 However until more effective clean-up methods are ----the oil spill response gap must be considered Sakhalin Energy is working to develop and implement Best Available Technologies to cover the full range of expected oil in ice scenarios. One study estimates the risk of a major pipeline release at 24% over the lifetime of a project, and a blowout at 3% (ISRP 2005). This is misleading use of the term risk. Risk incorporates a measure of the combined frequency of occurrence of an event and its consequences. info@dfdickins.com A-1 05/30/06 Rev

7 The quoted spill probabilities refer to a major spill without specifying the threshold volume, which greatly affects the frequency of an event Page 8 An expedited peer review What does expedited mean rushed, cursory? Who was contacted to perform the peer review qualifications? See Key Issue No. 10 Page 11 Once study estimates the risk of a well blowout See comment on same issue raised on Page 7. Page 13 Preliminary Sakhalin Energy Phase 2 documents propose in-situ burning as the primary response tactic ---- Sakhalin Energy documents indicate ISB as a method to be used, but the primary response tactic remains containment and recovery. The presence of ice does not alter priorities/preferences of response methods but simply the applicability of a particular technique. Sakhalin Energy has indicated that mechanical recovery is the only response option that will be allowed in the Piltun feeding area --- Dispersants will not be used in the feeding area or near the feeding area. ISB is not recommended for non-ice conditions; containment and recovery in open water is the primary option. In winter, ISB will be considered within the whale feeding area, provided studies of residue chemistry and behaviour indicate that such an approach is acceptable (with NEBA). Page 14 AMAP 1998 Not referenced used throughout the report. Also need to make the point that AMAP and its reports are focused on the true Arctic North of 60 where in most areas sea ice predominates for 8 months or more of the year. Sakhalin has significant ice for less than half that time (most of it not formed in situ) and cold winters, but is definitely not an Arctic environment. See Key Issue No. 1 WMO The authors introduce this reference correctly as the defining ice glossary and international standard but fail to follow basic WMO definitions in the following pages. Page 14 Page 15 Fast Ice The description is generic and applies mainly to Arctic and high Arctic regions makes little sense in the context of the Sakhalin environment. Drift Ice This is a colloquial subset of pack ice (not a category in its own right) used to define ice concentrations in the 1-7/10. The terms drift ice and pack ice are often used interchangeably for lower pack ice concentrations. No reference for WMO (2005) used in several places. info@dfdickins.com A-2 05/30/06 Rev

8 Pack Ice Incorrectly described as any ice not attached to land and exceeding 6-7/10. Pack ice is any form of ice not fast to shore according to WMO, regardless of thickness or concentration. Dickins and Buist (1999) talk about close pack as being over 6/10 using the WMO definition. Dynamic Drift Ice This is not a recognized ice term it simply means pack ice, which by definition must be dynamic because it is not fast. The authors indicate that dynamic drift ice is limited to chunks of ice up to 6-7/10 coverage above this it would be pack ice. It is quite possible to have rapidly moving, thereby dynamic, pack ice in concentrations over 7/10. The report confuses and mixes inappropriate ice definitions can gouge the sea floor as the ice moves (Dickins 2005) This statement is correct but cannot find any reference in Dickins report. Ice Development ---- some ice may persist through the summer melt--- This is generic to Arctic locations and misleading when used in the context of Sakhalin Island there is no multi-year ice in the Sea of Okhotsk. Ice Development --- may be covered with a thin slurry of ice or a thicker slushy layer (Dickins 2005) This is a colloquial paraphrase of the description of freeze-up progressing from frazil and grease to new ice not as stated in Dickins text Page 16 Polynyas Discussed in the ecological context of the High Arctic the wind driven flaw lead with continually moving ice off the Sakhalin coast (often referred to as the polynya condition in Sakhalin Energy documents) is not analogous to recurring Arctic polynyas with nutrient upwelling such as North Water. Page 17 During the winter dynamic drift ice dominates with coverage ranging from 20-80% (though pack ice over 60% coverage typically lasts for less than a month) Confused terminology pack ice is by definition drift ice and can have any concentration. In reality, the polynya condition dominates in many winters interspersed with periods of pack ice. Most years have less than 12 weeks with any pack ice (ice over 30 cm thick of any concentration) and many years have less than 10 weeks with substantial ice cover generally ice free ---- through late October or early November Incorrect earliest date for any ice in vicinity of the production platforms is the beginning of December or the last few days of Nov. Page 18 If the type of oil and presence of waves lead to emulsification ---- The lack of high sea states in the presence of ice will lead to a dramatic reduction in emulsification rate. info@dfdickins.com A-3 05/30/06 Rev

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10 NAR 2003 Missing reference The slick can also move underneath ice floes/pancakes, or be tossed----- (Wilson and Mackay 1987) Outdated reference that does not consider findings from two field spills in broken ice (SL Ross and Dickins 1986 and SINTEF 1993) these field tests showed very small volumes of oil being transported either beneath the floes or onto the top surface by floe interactions. Page estimated that 1.5 million liters/km2 of oil could be stored---- (Dickins and Buist 1999) Referenced volume is 400,000 bbl (63 Million litres) not 1.5 million. Oil trapped under multi-year ice----- Not relevant to Sakhalin there is no multi-year ice in the Sea of Okhotsk. Pumping of oil into leads ---- Scientists hypothesized in the 1970 s and 80 s about this phenomenon and lead pumping whereby oil could be transported onto the top of adjacent ice sheets when leads close (both processes were recreated in lab and tank tests with rapidly converging ice sheets). Actual field experiments with oil in ice and studies of lead closure rates in nature provide no evidence that either of these processes is significant in redistributing spilled oil in ice. Page 20 Ultimately any oil that moves during initial spreading --- could end up on the shoreline Unclear how oil can reach the shoreline during the winter when even a narrow band of fast ice a few hundred meters wide is sufficient to keep the oil off the coast. Comment also applies to the following statement that oil under or moving to fast ice could reach the shoreline (presumably during the winter) and remain invisible until break-up. Again no reference for AMAP 1998 Oil spilled on snow, or which migrates through an ice sheet --- has not been fully studied This is not correct. The processes of oil migration in sea ice have been extensively studied and documented in numerous tank and basin studies as well as several intensive large-scale field experiments lasting through an entire winter (Norcor 1975, Allen and Nelson 1981, Dickins and Buist 1981, SL Ross and DF Dickins 1982, Dickins and SINTEF 2006 ongoing, SL Ross and DF Dickins ongoing ---models to estimate the evaporative rate in snow are inadequate This statement is not made anywhere in the Owens et al. (2005) reference nor is it in the Buist (2000) reference. There is an established model to predict the evaporation of oil in snow (SL Ross). info@dfdickins.com A-5 05/30/06 Rev

11 --- twelve years after the spill, oil was still present (Short et al., 2004) There is considerable disagreement among scientists around claims as to the degree of long-term impact and present state and or prevalence of oil in the beach sediments. The trustees charged with defending the suit against ExxonMobil funded Short and his co-authors. Their supposedly random sample of beaches was not random but targeted known areas where oil was still present. A rebuttal to their work can be found in Taylor and Reimer IOSC 2004 (Owens, pers. Comm.. with D. Dickins - May 2006) Oil spilled on fast or pack ice during fall freeze-up will likely migrate downwards as the ice develops This is not true. There is no credible mechanism or driving force, which would cause the oil to migrate downwards. Oil spilled under ice will tend to migrate upwards through any cracks or open brine channels as a simple result of relative specific gravity oil/ice/water. Oil spilled on the ice surface will remain on the surface. A rapid freeze can cause this to happen quickly, making oil recovery operations futile This statement was based on a limited set of observations in a cold basin. Regardless of how fast freeze-up occurs, oil spilled into newly forming ice and/or slush in sufficiently thick films will remain on the surface and available for burning. Page 23 When considering wildlife impacts Leads, polynyas and ice edges --- (Stirling 1995). Stirling s paper on polynyas was directed at Arctic environments that are very different from the Sakhalin situation with continually moving ice and a transient wind-driven coastal flaw lead. While scientists believe ---- Which scientists? Page 35 OSRI 2004 Correct reference should be DF Dickins 2004 or Dickins et al (paper at Interspill, Trondheim). OSRI is the client not the author. Page 36 Page 39 Page 40 When shore fast ice is present vessels may become frozen in the ice and unavailable --- This applies to a Beaufort Sea situation where there is a reliable and extensive band of fast ice not relevant to Sakhalin. especially when they are towed through the water at speeds of 0.4 m/s and more. All normal containment booms begin to fail at speeds over 0.4 m/s, not just stainless steel ones. The researchers test results indicated that oil s with high API the suitability of in situ burning for oils in the 20 to 35 range could not be predicted The referenced test program was to assess the ignition and burning of emulsified crude oils. For oils with API gravity in the 33.6 range, the tests info@dfdickins.com A-6 05/30/06 Rev

12 indicate that the unemulsified oils should be easily ignitable, and that even weathered oils in this category with up to 25% water content should be ignitable. Testing of the actual oils would provide definitive answers. The 2001 tests did not include Sakhalin crude oils.. Not Sakhalin Energy oils, but SL Ross have conducted extensive ISB testing with Chayvo crudes for ExxonMobil URC, including as part of the 2001/2002 tests. Page 43 During the fall of 2002 a team of researchers from MMS, ExxonMobil and ---- Incorrect researchers were SL Ross, DF Dickins and ACS. Clients were MMS, and ExxonMobil. Page 43 Page 44 The Prudhoe Bay tests. Need to emphasize that these tests specifically addressed thin oil slicks. The lower burn efficiencies quoted would not be representative of burning thick oil slicks in brash and pack ice. Burn rates in frazil ice are approximately half the calm water rate. Burn rates in brash ice are approximately one-quarter the calm water rate Confusing representation. Should read Burn rates in frazil/slush ice are approximately half the rate in open water under calm conditions. Burn rates in rough brash ice are further reduced by half. Wave action slightly reduces the burn rates in either open water or ice but the relative reductions due the presence of slush or brash still apply. The referenced report specifically addressed the ignition and burning of only thin oil slicks. In the preamble to the report it is clearly stated that considerable research (e.g., Shell et al. 1983, Brown and Goodman 1986, Buist and Dickins 1987, Smith and Diaz 1987, Bech et al. 1993, Guénette and Wighus 1996) had shown that thick oil slicks in brash and slush ice can be ignited and burn efficiently, thus additional study of these types of slicks was not warranted. The data gap being studied was thin slick ignition and burning. Page 44 Further studies are needed Alaska and Alberta (Canada) operators include wellhead ignition as a standard response practice to deal with worst-case blowout scenarios in their existing C-Plans to MMS. In addition, 2004 revisions to the State of Alaska regulations concerning drilling restrictions during shoulder (broken ice) seasons allow industry to propose alternative strategies such as ISB to deal with blowouts during periods when mechanical recovery is impractical or ineffective due to ice. There is a broad base of knowledge in applying ISB to a wide range of blowout scenarios under Arctic conditions (e.g SL Ross et al. 1998). However, in situ burning has not been widely used, particularly in cold climate onwater spill response; therefore the body of knowledge is based primarily on experimental data This is not true. ISB has been used successfully on a variety of actual spills in ice in Canada, Russia and Scandinavia. This experience is in info@dfdickins.com A-7 05/30/06 Rev

13 addition to a number of large-scale field tests on cold open water and ice in Canada and Norway. Key Issue No. 11 Page tests that examined the dispersibility of Alaska North Slope Crude ---The trials were repeated in The results from the 2006 trials, carried out using revised protocols to address the concerns quoted in the NAS report, indicated that the dispersant effectiveness was the same or better than in the tests. Page 46 Chemically dispersed oil has been demonstrated In quoting three different research groups to back up their contention that dispersed oil may be more toxic than untreated oil the authors failed to consult the one large-scale international experiment conducted in the Arctic and designed to answer exactly that question the 1981 Baffin Island Oilspill Project (BIOS) see Sergy, Owens and others in Arctic and other peer reviewed journals (numerous references). ). It is important that decision makers also consider that impact assessments (with or without dispersants) need to cover exposure and duration, not simply toxicity and concentration. Page 50 A study commissioned (Dickens et al. 2000) Unable to find this statement expressed directly in the referenced report although don t disagree fundamentally with what is being expressed here. Two types of technologies Agree that mechanical recovery has shown limited effectiveness in ice covered waters, but do not agree that the same statement can be applied to ISB. ISB has show high levels of effectiveness under Arctic conditions and in scenarios created for large spills in ice (SL Ross et al., 1998). Page 51 Volatile oil components Don t agree. See Key Issue No. 2. The issue is slick thickness, not volatility Page 53 Compared to temperate open water conditions, the ability to clean-up oil spills in the presence of sea ice is extremely limited and conditional. Strongly disagree. There are many scenarios involving spills in broken ice where a realistic application of ISB results in predicted removal effectiveness far above any credible numbers achieved or predicted for oil recovery in open water. Recovery in broken ice depends on a wide range of factors oil properties, film thickness, weather conditions, ice concentration etc. as does recovery in open water (wind, waves, emulsification etc.). The conditional nature of spill response is a given and not unique to oil in ice. See Key Issue No. 4 Page 54 These complexities ---- All spill response is complex it does not mean that meaningful guidelines are not available or cannot be developed. The makeup and characteristics of the ice off Sakhalin are well understood and Sakhalin Energy has developed sophisticated systems and procedures to track, monitor and info@dfdickins.com A-8 05/30/06 Rev

14 forecast ice conditions proven through the efficient and safe operation of Phase 1 seasonal production. info@dfdickins.com A-9 05/30/06 Rev

15 Page 55 Page 56 Page 56 Cold weather may pose a particular challenge ---- pumping large quantities of sea water Seawater injection on a large scale, year round has been a routine part of Prudhoe Bay operations for decades. This involves pumping and moving vast quantities of seawater throughout the winter period with ice conditions and temperatures much more severe than Sakhalin. There is extensive experience over the past 35 years in constructing spray ice islands in the US and Canadian Arctic involving pumping massive volumes of seawater under extreme temperature conditions noting that the window of opportunity to use many of these tactics may be limited to a few hours (Dickins, 2005) This is a complete misquote out of context. Key Issue No. 6. took responders three days to locate the spill source. Cleanup crews were limited to 25 minute exposure times. And yet they successfully cleaned up the largest spill ever on the N orth Slope. Page and 2 m wave height as the maximum limit It makes no sense to talk about a 2 m wave height in conjunction with the presence of ice. See Key Issue No. 5 Release of volatile hydrocarbons from the oil during dispersion may also impede ignition. Not true. Extensive testing has shown that a range of weathered crudes and emulsions (up to 25%) can be successfully ignited and burned the real issue is whether there is sufficient film thickness not whether the oil has lost volatiles during the plume/deposition process. Key Issue No. 1 Page 58 Table 4-1 Upper Limits January to March Ice is 20% to 80% Neglects to mention that the polynya condition is dominant and that there may only be weeks with significant pack ice. freeze-up starts again in November Only true in a very extreme year. No significant ice until early-mid December in most years. winter storms average m/s--- This is misleading when you look at the proportion of time that winds exceed a certain value. For example, typical data from Chayvo shows winds exceeding the 10 m/s burn threshold in Feb-May less than 5% of the time. during the ice season, maximum wave height ranges from 1-4 m This is misleading if you look at probabilities of winter wave heights exceeding 1-2 m they will be extremely low due to ice damping and the reduction in fetch created by the offshore pack. Winter waves will not be a significant operational issue. info@dfdickins.com A-10 05/30/06 Rev

16 Mechanical recovery of a large spill is not feasible (Dickins -----) It would not be unreasonable to derive this conclusion from the two reports referenced but there is no direct quote in either report to this effect. Page concluded that the containment effect of sea ice would likely not concentrate the deposited oil at a sufficient thickness to allow in-situ burning (SL Ross et al., 1998) Not true. An addendum to that report conducted with more realistic ice and weather conditions than allowed in the original scope of work proved that ISB was an effective strategy with a large-scale open orifice blowout in broken ice average removal effectiveness over 15 days of 52% there have been no documented studies that test the ignitability of oil that has been encapsulated in sea ice for extended periods of time Not true. Norcor 1975 (D. Dickins field project manager) demonstrated that oil spilled under ice early in the winter could be successfully burned with over 80% removal after more than 6 months trapped in the ice.. Also Dome Petroleum demonstrated the same for oil droplets discharged under ice from a simulated subsea blowout (Dickins and Buist, 1980). The oil was encapsulated for as long as 5 months, and still ignited and burned effectively in melt pools. Similar results were achieved in other field experiments in Alaska (Allen and Nelson, 1981). --- from the tanker Exxon Valdez caused in part by a shift in the tanker s navigational course due to the presence of sea ice Attempting to tie the Valdez accident to the presence of ice is completely incredible. At the very most, ice was a tertiary factor in the whole incident. there are any numbers of scenarios for catastrophic spills Not clear what purpose is being served here to list the well known potential causal factors involved in any marine accident whether it be tankers, ferries, bulk carriers etc. in open water or ice? Initial environmental assessment documents indicate that Aniva Bay ---- also experience dynamic drifting ice for much of the winter Not true. The ice environment in the vicinity of the terminal is highly variable but definitely does not represent much of the winter Typical duration of significant ice in vicinity of the tanker loading is averages about 56 days (range ). Page 60 Page double hulled was struck by an ice floe while moored at a dock, causing a mooring line to part---- This incident is not analogous to the situation where tankers will be loaded in Aniva Bay. Cook Inlet experiences dramatic tidal flushing of ice at high velocities, which has no comparable in the Sakhalin environment. Response options would be limited to mechanical recovery---- This statement ignores the option of using ISB in the winter with appropriate environmental safeguards. info@dfdickins.com A-11 05/30/06 Rev

17 An oil spill during the fall and winter ---- may remain largely untreated and become trapped This raises two issues (1) why would the oil remain largely untreated if you could implement burning in many winter ice scenarios? ; and (2) why would the oil released from the ice in the spring affect the whale feeding grounds as by this time the ice is going to be far to the south? Pollution lingers in cold climates briefly in the short summer season (AMAP 1998) Comment as before no proper reference for AMAP. Their findings are focused on the true Arctic where the summer is only a few months long contrasted with Sakhalin, which has a 6-7 month period of open water. Key Issue No. 1. Page 61 Page Tsesis spill in the Baltic resulted in considerable deposition of oiled sediments on the sea floor The Tsesis spilled heavy No. 5 fuel oil, not crude oil, so a comparison is unreasonable. The fact that spill response operations may be effectively precluded through the fall and winter ice season Why would OSR be precluded in the winter? Because of the so-called response gap? Even given the worst case of no response, oil deposited in winter ice would be far away from the main whale feeding areas by June and potentially devastating impacts Sensationalist statement (media cliché) and not borne out by long term studies of impacts from Arctic or cold-water spills. Page 62 In-situ burning though considered by some to hold promise for arctic spill response Not by some but by all credible, experienced engineers and scientists with actual real life experience in this field (Buist, Fingas, Dickins, Allen etc.). The 1986 Canadian field spill in broken ice proved that burns could be effective in a real-world dynamic ice condition of oil in slush filled leads. Experiences in the Baltic have demonstrated effective real world burns of tanker spills in ice. There is a large body of experience in burning oil in a variety of Arctic conditions (Ref. Fingas). Key Issues No. 9&11 At higher ice conditions ---- other logistical challenges Not to downplay the challenge of operating offshore Sakhalin in the winter, the technology exists with new generation icebreaker, helicopter transported Heli torches and the latest radar satellite imagery, GPS buoys and reconnaissance over flights to track the oiled ice and ignite the oil in multiple pools. The committee charged with developing in situ burning guidelines for Alaska (ADEC, USCG, EPA) essentially concluded that the environmental benefits of burning far outweigh any potential consequences of residue that remains in the environment compared with the alternative of leaving the oil in place or trying ineffective mechanical recovery info@dfdickins.com A-12 05/30/06 Rev

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19 Page 62 At Sakalin II where sea ice conditions This is completely false. Firstly, broken ice conditions do not dominate for more than 6 months of the year (actual range is more like 6-12 weeks). The polynya is the dominant condition for much of the ice season. The no response option may be a possibility during periods of extreme low visibility, strong winds or unsuitable ice conditions more likely in the order of 10-30% of the time over 6 months very different from half the year. Key Issue No. 7 During the 1990 s the State of Alaska The quoted periods when drilling restrictions apply are incorrect. They should be June 1 to some point after freeze-up when the fast ice around Northstar reaches 18 inches thickness (Oct/Nov). These restrictions were introduced to reflect the lack of mechanical response capability during the shoulder seasons of break-up and freeze-up. Under revised regulations introduced in 2004, industry is now able to present in situ burning as a primary response during these shoulder seasons, with the possibility that drilling restrictions will be modified or lifted in the future Inability to safely load oil Safety is a definite issue but equal drivers are the technical limits of the current system in place there are ongoing operations loading tankers throughout the winter in moving ice in the Russian Pechora Sea using different technology. The Arctic Council (2002) Not referenced Page 63 The highly dynamic ice conditions ---- six months of the year render ineffective most ---- oil spill response technologies See previous comments. The intermediate ice concentrations that can present problems with ISB and mechanical strategies persist for only a portion of the winter (in many years less than 10 weeks). For a large part of the winter, either ISB or mechanical response strategies can be applied effectively to a large-scale release (mechanical during periods of open water and very light ice, ISB during periods when the offshore pack moves closer to the coast). Key Issue No. 7 If a major spill occurs during the ice season and no response is possible the WGW will be in very real jeopardy This is pure conjecture: (1) a response will always be possible in some form; and (2) there is no evidence to support the contention that a winter spill will place the WGW in jeopardy the oil and ice will rapidly drift past and away from the feeding areas and residue toxicity is considered low. info@dfdickins.com A-14 05/30/06 Rev

20 Page 63 during most of the Sakhalin ice season, ice conditions are highly dynamic with concentrations ranging from 20 to 80% Incomplete, misleading quote Dickins and Allen (2005) go on to say that the flaw lead/polynya conditions is dominant through much of the winter and in many years, heavy pack ice may only be present for 15% of the time. Key Issue No winter conditions often exceed ignition limits vessel operations in and among higher concentrations of sea ice may be unsafe Misleading and incorrect see Key Issue No 5. Combinations of low visibility and strong winds that could preclude burning occur for a relatively small % of the overall time during the winter (20% in the worst months for fog during break-up, generally less than 10% for most of the winter). Vessels used for Sakhalin winter response will be capable of safe operation in heavy ice. Sakhalin Energy proposes that in situ burning could be accomplished in small bursts during the narrow windows of opportunity Completely false misquoting Dickins and Allen (2005). Actual reference to making use of short windows of opportunity referred to situations where either mechanical booming and skimming or burning in fire booms could be used to take advantage of times in the winter when large areas of open water could exist for short periods as the polynya expands not to the overall winter response scenario. Key Issue No. 6 Page 64 Page 64 the crude oil from Sakhalin falls into this category, with a density of A density of converts to an API gravity of 31.2, different from the 33.6 quoted on page 40 The referenced study used experimental data from test burns of 50, 100 and 150-mm thick slicks (simulating slick thicknesses in the apex of a towed fire boom) of eight different crudes representing a range of crude oil densities. The results are not applicable to reside properties of burns in ice conditions that preclude the use of booms. Residues from naturally contained burns of thinner slicks of 33.6 API crude in ice conditions are not likely to sink. A definitive answer could be given by ISB testing of Sakhalin Energy crudes. Because of the challenges associated with operating small work boats in dynamic sea ice There is no intent to use small workboats that are not capable of operating safely and independently in dynamic ice. Spill response vessels will be designed to operate year round in the full range of ice conditions. Impacts to Polynyas: --- however these same polynyas are a major source of nutrients in the arctic and are considered The authors quote Stirling who discusses the relationship between Arctic polynyas to the marine food web this is not analogous to the ice environment off Sakhalin where the often quoted polynya is actually a wind-controlled flaw lead comprised of continually moving pack ice on one side and a static, variable band of fast ice on the other very different info@dfdickins.com A-15 05/30/06 Rev

21 than a recurring Arctic polynya related to water (and related nutrient) upwelling. Key Issue No. 1 Surface well blowouts that widely disperse oil will likely create A wide range of weathered and partly emulsified crudes have been tested and successfully ignited with their volatile components removed. The real issue in terms of ignition is one of film thickness and not volatility. There is nothing fundamental about a blowout that will prevent ignition, as long as thick enough oil films build up on the ice surface or on the water and slush between floes. Prevention Planning: the fact that oil spill response ---- may be extremely limited -- - There are definite limitations imposed by the ice environment on response capabilities but on a % basis these are no more limiting than different constraints associated with open water response (waves and fog for example). All offshore spill response has limitations the winter case is different but not necessarily worse than any other time of year. Key Issue No. 5 Page 65 Page the science of how spilled oil behaves and how it can be cleaned up in iceinfested waters is dominated by unknowns. This is completely untrue. There are 35 years + of studies into the behaviour of oil in ice and developing and testing clean-up strategies for oil in solid and broken ice. Our state of knowledge is far from perfect but to say that unknowns dominate is false. Key Issue No. 12 Available technologies may be able to clean-up small pockets of oil but no system has been developed to manage a large-scale clean-up in dynamic sea ice. In terms of mechanical recovery this statement is generally true. However, as pointed out by numerous Arctic specialists, ISB is the most effective and preferred oil removal strategy in broken ice, not mechanical. One study estimates the risk ---- at 24% ---- Incorrect use of the term risk. The authors mean frequency % or probability. Risk must account for frequency and consequences. Page 66 If a major blowout were to occur during the six months when dynamic ice conditions prevail --- the likelihood of a effective clean-up is extremely low Not a true statement. Using a combination of mechanical recovery when feasible and ISB on thick oil naturally contained by the ice, there is a good chance of undertaking a winter response operation that will achieve equal or better results than an open water spill under temperate conditions. Key Issue No. 4 info@dfdickins.com A-16 05/30/06 Rev

22 Page 66 Most or all of the spilled oil could and re-released to contaminate the whale s feeding grounds is very real Firstly, this statement presumes that no effective response is possible (see preceding comments) and secondly that the oil and ice will remain stationary over the whale s feeding grounds this is not the case with ice continually moving with net southerly drift of 20+ miles per day. Even if surface oil remained on the water surface at the time of the WGW arrival off Sakhalin it is not clear as to the mechanism or pathway for this oil to contaminate the benthic organisms in the feeding areas. info@dfdickins.com A-17 05/30/06 Rev