Sunday, December 28, 2014

An open letter to the South Shore on oil exploration and extraction

NOTE:  In addition to the presentation at Municipal Council next month, below, John Davis will be on CBC on Monday: “Information Morning” interview between 7 and 7:30 on Monday morning, December 29th.

Shell Oil Company
Shell Oil Company (Photo credit: Wikipedia)

This is one of the most thorough and correct assessments of the management, control and impacts that can be expected from current oil explorations off Nova Scotia. The assessment applies almost equally, but with wide variation in dispersion, to the Gulf of St. Lawrence. It is a must read for residents of these shores in Nova Scotia, PEI, New Brunswick, Newfoundland and Labrador and Quebec.

Art MacKay

Published on December 16, 2014
The Shelburne County Coast Guard

By John Davis
Shell Oil is moving steadily through the regulatory process which will allow the drilling of exploratory wells on the edge of the Scotian Shelf in an area known as the Shelburne Gully. It looks very much as if this process on the Scotian Shelf will become a major offshore oil play for many years to come. Shell’s plans are to drill up to 7 exploration wells over a 4 year period (2015-2019). This represents a $1 Billion investment. British Petroleum holds a lease to the North East of the Shell holdings. They are planning a similar project.
Randy Hiscock, Manager of Business Development and New Ventures at Shell, stated recently”
“the earliest drilling could take place in the Shelburne Basin in late 2015, and that depends on the results of the seismic research, rig scheduling and getting the proper equipment in place.”
Mr. Hiscock went on to say, “Oil is what Shell is banking on. “The sun is rising hopefully on a new day in offshore Nova Scotia.” “We look forward to getting some wells out, having some exploration success and being here for at least another 70, 80 or 90 years.”
This is very good news for the Nova Scotian economy but it is a clear indication that there is work to be done on the South Shore to see that good working relationships are created and maintained between our coastal communities, our fishing industry and, what is for us, a new offshore industry. Paramount in this process is for Shell to demonstrate a respect for the environmental integrity of the South Shore and a respect for our primary economic engine, our fishing industry.
As an example of the type of issues we face, and this is one of many, let’s look for a moment at potential fishing ground impacts and spill response plans starting with section 8.0.0 of the environmental assessment produced by the consulting firm, Stantec.
Shell states in the plan:
“Shell is committed to responding to an offshore oil spill with a full complement of response tools and strategies including surface, aerial and subsea dispersants; mechanical recovery; in situ burning; shoreline protection and recovery and well control.”
Shell could very well be committed to this list of response tools and strategies but it is essential that South Shore communities to take a close look at the realities surrounding their actual ability to contain and secure spilled oil. Mechanical recovery as it exists at
ECRC and with any other potential responders consists of suction pumps, skimmers and rotary brush skimmers as well as offshore booms to contain the oil. This is, at this point, the only equipment available to Shell to deal with the actual cleanup of oil at the off shore site of the spill.
ECRC is a group, certified by Transport Canada – Marine Safety, as a Response Organization under the Canada Shipping Act (CSA). They maintain an office and an equipment site in Dartmouth, Nova Scotia. As a certified Response Organization, ECRC requires annual fees from ships and oil-handling facilities (East of the Rocky Mts.) in the Great lakes and the Atlantic Coast that must have an oil spill cleanup plan as required under Canadian Law. In other words Shell and all oil handling facilities, vessels, refineries, etc are all required by law to have an active arrangement to clean up oil spills and ECRC provides that plan for an annual fee.
This forced marriage arrangement between Shell and ECRC meets a legal requirement under Canadian law but let’s review a real world scenario. If a major spill occurred at the Shelburne Gully site Shell would, in all probability, notify ECRC in Dartmouth and make a request for equipment and an operational team. ECRC does not have a vessel in Halifax capable of reaching the rig. A lease rental would have to be arranged. The boom equipment and skimmers would have to be mobilized and delivered to a vessel in Halifax Harbour. Mob time is about 72 hrs. Transit time, depending on weather is another 20 hrs so, in, a best case scenario it would take 3 to 4 days to get the required equipment to the Shelburne Gully drill site and once on site the equipment can only be deployed effectively in Beaufort Scale wind and sea conditions no greater than scale 3-3.5.
The U.S. Government E.P.A. states:
“Generally, booms will not operate properly when waves are over 1 meter or currents are faster than one Knot per Hour.”
Given a blow out scenario, or even a medium sized spill, the oil in even moderate wind speeds and sea states would, after a 3 to 4 day operational delay, have dispersed over an area of a size that relegates the offshore booms and skimmers virtually useless. Since “Offshore In situ Burning” also requires quick response, calm seas, and an offshore boom to contain the oil, this option too is unlikely to be utilized.
In a blow out scenario Shell states in the CEAA/Stantec report that the very best case for a capping event, if that action were to be required, has equipment on site from Norway in 14 days and it is at that point that the work to cap the well would begin.
The reality is, if you read the Stantec report carefully, that Shell’s only available plan for dealing with any large offshore oil spill is to use dispersants, specifically a dispersant named “Corexit” Given the equipment that they now have available and their current lack of desire to consider new mechanical cleanup technology this is really their only existing option. Knowing that this is the case let’s return to the Stantec Report and take a look at their modeling for oil spills at Shell’s Shelburne Gully site.
Looking at the report you will see that Stantec cannot seem to find a single scenario where a major oil spill would have any significant impact on any of the important fishing banks surrounding the drill site. This simply does not seem reasonable.
The Stantec Report makes a number of assertions. One of the basic tenants they use in their oil spill modeling is the following comment found in section
“During the Winter, strong prevailing winds from the North and West are observed which would transport surface oil to the East.”
Although it is counter intuitive I am prepared to give Stantec the benefit of the doubt and, based on their assertions, believe that on average, there are more days over the winter on the Scotian Shelf where the wind is from the West other than from the North East or the South East combined but this averaging process has its perils.
I can see a situation here where Mr. Shell is standing on the edge of a wide river and saying, “I can’t swim and I need to cross this river how deep is it?” and Mr. Stantec answers, “Oh don’t worry your six feet tall and on average this river is only three feet deep.” Well, Mr. Stantec did only tell the truth but Mr. Shell still drowns.
Section of the report states, “based on the information above, the predicted residual adverse environmental effects from any accidental event scenario on fish and fish habitat would not be significant”
Well this in my estimation is another major stretch that can be assumed only if you believe that in the winter, on the Scotian Shelf, an oil spill will flow to the East.
The Labrador Current streams from the North East at the Grand Banks to the South West directly down the edge of the Scotian Shelf. Shells “Exploratory Drilling Project Area” sits within that massive current which then sweeps directly over Georges Bank and into the Gulf of Maine. If the flow of the Current is exacerbated by any of the many North Easterly storms we experience over the winter months then Georges Bank could face a devastating oiling event in a very short timeframe.
Very importantly, the Labrador Current has a very significant relationship with Georges Bank. The current flows down the edge of the Scotian Shelf through the deep ocean and then, when approaching the North East tip of Georges Bank through Corsair Canyon, Georges Canyon or Nygren Canyon that water depth quickly changes from about 1,500 fathoms to about 40 fathoms and then on to areas of less than 15 fathoms in only a few Nautical Miles. This abrupt change in water depth causes the current to turn sharply upward and to the South. This upwelling of deep ocean water is a major contributor the vertical movement in the water column on Georges and helps to create the circular, counter clockwise Gyre which encircles the Bank. It is this action that distributes nutrients vertically through the water column helping to make Georges Bank one of the richest fishing and spawning grounds in the world and it is this rich biological environment which has such important commercial value for the South Shore. Introducing oil and potentially oil laced with dispersants into the Labrador Current and thus into this vertical mix of nutrients has a maximum potential for devastating impacts on Georges Bank. This very specific relationship between the Labrador Current and Georges Bank is not addressed anywhere in the Stantec report so I will reiterate an important point which should be in the report. “
“The attributes which make Georges Bank one of the richest biological sites on the planet also make it more susceptible to hydrocarbon pollutants.”
This is why both the US and Canadian Governments created and sustain the drilling moratorium. The upwelling action of the Labrador Current is, in a sense, a back door into the circular Gyre on Georges Bank. We need to take every precaution to see that that portal stays closed.
Once Shell begins activity on the Shelburne Gully they will, over the winter months, experience numerous North Easterly storm systems and fewer, but just as severe, storms from the South East. To disregard this reality because some “averaging process” says there are x% more days when the wind is Westerly is total folly and it misrepresents the actual conditions on the Shelf. In certain, very probable, oil spill scenarios Shell needs to be prepared to deal with strong North Easterly Winds in combination the strong Labrador current nearly immediately threatening Georges Bank. In other scenarios strong South Easterlies will very quickly threaten Baccaro, LaHave, Western and Emerald Banks. If Shell goes out on the Gully with the sense that oil spills are just going to glide off to the East they will not be properly prepared.
The Stantec report figures stated in section say that there is up to a 10% chance that an oil slick in concentrations large enough to disrupt the fishery can be on Georges Bank in a period of 5-10 days. I am convinced you could get the oil there much more quickly than 5 days and that their 10% probability assessment is too low but let’s use Stantec’s minimum of 5 days to arrival on the Bank. Actually putting oil on Georges means that the slick has to have traveled about 220 Kilometers in that time period. This means, by Stantec’s calculations that the slick can cover about 44 km per day. In addition to the North Easterly winds which must have been in play to move this oil, we have, on the Scotian Shelf, a substantial number of storms out of the South East that carry with them very strong winds. Based on movement of 44 km per day why hasn’t Stantec modeled a scenario which puts an oil slick on LaHave Bank in less than two days or a slick on Emerald Bank or Western Bank in less than 3 days? I somehow missed that part of the report. These are real potentials that Shell will face every winter and it does seem reasonable that they should be mentioned.
The reality is, The Canadian Environmental Assessment Agency/Stantec report notwithstanding, given specific wind, tide and sea state conditions six of Nova Scotia’s most important fishing grounds are all within a few days of an oiling event in a major blowout scenario. In fact if you look on a chart you will see that these fishing banks form a semi-circle that covers about a 180 degrees of the Eastern side of the compass and there are only about 120 degrees out of 360 where prevailing winds would work to move a major oil spill away from important fishing grounds. Starting in the South West the banks and their approximate distances from the Shell well sites are as follows:
Georges Bank 220Km from Shell’s Exploratory Drilling Project Area
Browns Bank 240Km from Shell’s Exploratory Drilling Project Area
Baccaro Bank 120Km from Shell’s Exploratory Drilling Project Area
LaHave Bank 80Km from Shell’s Exploratory Drilling Project Area
Emerald Bank 120Km from Shell’s Exploratory Drilling Project Area
Western Bank 120Km from Shell’s Exploratory Drilling Project Area
I am quite certain that the Canadian Environmental Assessment Agency report, produced by the consulting firm Stantec underestimates the potential dangers associated with drilling on Shell’s Shelburne Gully site. This is unfortunate as it leaves Shell less prepared to deal with the realities they will face when working there.
Although everyone is hopeful that no major accidence occur during the time Shell is exploring and extracting at this site the potential of a spill cannot be ignored and proper planning and preparation must be done. One immediate effort is for shell to enhance its capabilities for offshore capture and containment of oil spills. There is a Nova Scotia Company, Extreme Spill Technology that holds patent on an oil collection and containment process which is proven and requires only a larger platform in order to operate in Beaufort wind and sea states up to Beaufort 6-7. This technology was developed at Dalhousie University so it is totally an Atlantic Canadian design. It is imperative that we move away from what looks to be Shell’s total reliance on dispersants as the first and only line of oil spill defence.
There is an ever growing body of evidence generated from the Deep Water Horizon blow out in the Gulf of Mexico that is clearly delineating the dangers associated with the use of dispersants.
According to research work done at Georgia Institute of Technology after the Deep Water Horizon blow out dispersants, by breaking down the oil add significantly to its toxicity. An oil spill, when left to weather on the surface, will partially evaporate. This process removes much of the toxic PAH elements from the oil and allows them to dissipate into the atmosphere so the oil that sinks through the water column to the sea floor is in a substantially less toxic state. (PAH is a term for several highly toxic molecules found in oil, two of which are Polycyclic aromatic hydrocarbons and polyaromatic hydrocarbons) When dispersants are used at the sea bed or are immediately spayed on the spill, the oil is denied this evaporation time and all its highly toxic elements enter the water column. These, very small, highly toxic dispersed oil elements descend through the water column much more slowly than un-treated oil allowing more time for negative interaction with life forms at various levels of the water column and for a much larger areas of dispersal. The study also found that mixing the dispersant with oil increased the toxicity of the mixture up to 52-fold over the oil alone. In toxicity tests in the lab, the mixture’s effects increased mortality of rotifers, a microscopic grazing animal at the base of the Gulf’s food chain. The findings are available online by the journal Environmental Pollution and appeared in the February 2013 print edition.
Dr. Terry Snell, chair of the School of Biology at Georgia Institute of Technology stated:
“What remains to be determined is whether the benefits of dispersing the oil by using Corexit are outweighed by the substantial increase in toxicity of the mixture,” Perhaps we should allow the oil to naturally disperse. It might take longer, but it would have less toxic impact on marine ecosystems.”
If Shell begins spraying dispersants at the Shelburne Gully site this same process will occur. The dispersant will immediately combine with oil breaking it down and submerging the toxic elements before the PAH's have an opportunity to evaporate into the air. The dispersant, combined with these toxic elements then distribute themselves throughout the water column in the strong Labrador Current.
It is important to remember, Dispersants do not “clean up” anything they simply make the oil change form and allow it to disappear below the ocean’s surface. Research done by Dr. Samantha Joye, University of Georgia has found though months of direct observation by submarine that there is an 80 sq. mile zone near the Deep water Horizon blow out site in the Gulf of Mexico which is covered with 3 to 4 inches of dispersant laced oil and is absolutely lifeless. The stuff does not just neatly disappear as oil companies would like us to believe and now we are faced with a plausible potential scenario that could place a similar blanket of death over areas of Georges Bank. This is absolutely unacceptable.
One of the main reasons that we fought, and continue to fight, so hard to keep drilling from occurring within the Gyre of Georges Bank is to keep highly toxic oil away. A well head blow out on the Bank would be pushing raw oil directly into the interior water column. There would have been no time for weathering, no time for any evaporation of PAH’s to take place. The oil would be at its most toxic state and would be immediately active in the vertical water column and in contact with all of the Bank’s important commercial species, their spat, their fry and their food supply. Now we have research stating that dispersants combined with oil are over 50 times more toxic than oil alone. We must be resolved that this combined oil and dispersant product never finds its way to Georges Bank.
So, a very important question for all of us on the South Shore is: Who decides when and how dispersants are used. Shell states that they have the capacity to surface spray, to release dispersants at the well head or have dispersants dropped by aircraft.
At least three Canadian Federal Departments, The Dept of Fisheries, Transport Canada and Environment Canada, say that it is unlawful to dump dispersants into the ocean and that criminal charges could follow such an action but new Federal Legislation, Bill C-22, put forward by our Prime Minister, states that Shell can decide to use the dispersant on their own initiative and report later to the Canada Nova Scotia Offshore Petroleum Board about their actions. Shell managers decide to undertake this action by consulting amongst themselves in a process called N.E.B.A., a Net Environmental Benefit Assessment and then they are apparently free to proceed. Well I don’t want to sound too cynical here but a net environmental benefit for Shell might be to spray and sink as much oil as they can as quickly as is possible in a kind of “out of sight, out of mind” process so I’m not at all sure that the interests of the South Shore or our fishing industry would be reflected in this process.
This new proposed legislation is wrong headed and is just unacceptable. There are issues here that are absolutely clear. There will be wind, tide and current conditions when the use of Corexit or any dispersant will be contra-indicated on the Scotian Shelf. The communities of the South Shore and the South West Nova Fishing industry must be the ones to make any final decision on the use of dispersants
We have fought too long and too hard to protect our birthright fishing grounds to allow those who have no firsthand knowledge of winds, tides, currents, spawning times, fishing seasons, ground fish or pelagic stock activities to make decisions based on a NEBA protocol that, in reality, excludes those with the required knowledge to act responsibly and those who will be most impacted by decision making.
On the West Coast of our great country the people have spoken very definitively. There will be no use of dispersants, period. Art Sterritt, Executive Director of the Coastal First Nations on Canada’s West Coast stated when discussing the use of large oil tankers in BC coastal waters and the port of Kitimat:
“This project is dead,” said Sterritt, “The project can’t proceed with these conditions. We’ve been clear there is no technology to clean up an oil spill and the dispersants cause more damage than the oil itself.”
The UK has partially banned the use of dispersants.
Sweden will not allow dispersants to be used anywhere in their territorial waters.
In Australia, the Australian Maritime Safety Authority has decided to destroy its total stock of Corexit, the most commonly used oil spill dispersant. AMSA stated in their release that they have: “engaged chemical waste disposal companies who are required to certify that the disposal has been completed in accordance with environmental regulations and best practises” In Australia, Corexit is being treated as toxic waste.
It my absolute belief that There is no one that is equipped to make a risk benefit assessment concerning the use of dispersant in the Shelburne Gully other than the communities and fishing industry of the South Shore of Nova Scotia and no “Net Environmental Benefit Assessment” decision to utilize dispersants at the Shell Exploratory Drilling Project Area at the Shelburne Gully should be made without the explicit approval of the Municipal units of Shelburne County in consultation with the South Shore Fishing Industry, Bill C-22 and NEBA protocols notwithstanding.
In closing, I wish Shell every success in their endeavours in both exploration and extraction as long as the process in the Shelburne Gully is carried out in conjunction with and in respectful partnership with a watchful and supportive South Shore Community and fishing industry.
Below are suggested immediate actions for Shelburne County:
  1. The immediate formation of a committee comprised of members from each of Shelburne County’s 5 Municipal Units and representatives of the South Shore Fishing Industry. Similar to the original NORIG Model.
  2. An Immediate request by this newly formed committee for Official intervener status before the Canada NS Offshore Petroleum Board
  3. Immediate application by this newly formed committee to Transport Canada for status as a standalone South Shore Response Organization (RO)
  4. Immediate action by the new committee to assess E.S.T., Extreme Spill Technology offshore oil cleanup technology. This is Atlantic Canadian Technology designed at Dalhousie University and commercialized here in Nova Scotia. It is the only technology that I know of which is actually capable of successful offshore oil spill cleanup. If the Committee agrees then Shell must respond by securing the use of this equipment.
  5.  Immediate request by the new committee to open discussions with Shell Oil on creating real potentials for offshore cleanup of oil spill and coming to a complete understanding on the decision making process for the use of dispersants.

John Davis
John Davis is a long time Shelburne County resident. He now splits his time between his house in Dartmouth N.S. and his home in Atlantic on the Western side of Shelburne Harbour. In the 1980’s John was the founding Director of the original NORIGS committee. He has been a Shelburne County fish plant owner a vessel owner and was involved in the South Shore fishery for many years. For the past 18 years John has been leading dive expeditions for Discovery, National Geographic and History Television as well working with Google on their Google Oceans addition to the Google Earth platform. John has been working either on or in the oceans of the world for over 40 years. 

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