How Gateway’s plans to dredge Douglas Channel show the limitations of the JRP mandate and ruling

(First in series of reports on how the Joint Review Panel report will affect the Kitimat region)

JRP map of blasting on Douglas Channel
Joint Review map of Northern Gateway plans for dredging and blasting on Douglas Channel (JRP)

 

If there is a significant flaw in the Joint Review Panel report on Northern Gateway, it can be found in the panel’s analysis of Enbridge Northern Gateway’s plans to blast and dredge at the proposed Kitimat terminal site.

While the Joint Review Panel does consider what it calls “cumulative effects,” the panel plays down those effects and offers no specifics about interaction between the Northern Gateway project and the two liquified natural gas projects, the KM LNG project at Bish Cove and the BC LNG floating terminal at the old log dump.

It appears the JRP considered the legacy effects of the Rio Tinto Alcan smelter and other Kitimat industries while not taking into consideration future development.

The dredging and blasting planned by Northern Gateway, as Enbridge said in its evidence,  appears to have only a minimal effect on Douglas Channel.

A glance at the map in the Joint Review ruling shows that that the dredging and blasting site is directly opposite Clio Bay, where Chevron, in partnership with the Haisla Nation, plan a remediation project using marine clay from the Bish Cove construction site to cap decades of sunken and rotting logs.

The Clio Bay project was not part of the evidence before the Joint Review Panel, the plans for the project were not formulated until well after the time for evidence before the JRP closed. But those deadlines show one area where the rules of evidence and procedure fail the people of northwestern BC.

The JRP is a snapshot in time and changes in the dynamics of the industrial development in the Kitimat Arm are not really considered beyond the terms of reference for the JRP.

It appears from the report that Enbridge plans to simply allow sediment from the blasting and dredging to float down Douglas Channel, dispersed by the currents and the outflow from the Kitimat River.

Northern Gateway said that dredging and blasting for marine terminal construction would result in a sediment plume that would extend over an area of 70,000 square metres for the duration of blasting activities.

Approximately 400 square metres of the assessed area of the marine terminal is expected to receive more than 1 centimetre of sediment deposition due to dredging. Outside of this area, typical sediment deposition levels alongshore where sediment is widely dispersed (a band approximately 4 kilometres long and 400 metres wide) are very low; in the range of 0.001 to 0.1 centimetres. Dredging and blasting activities are expected to occur over a period of approximately 18 weeks.

Northern Gateway expected most of the sediment plume created by construction activities to be minor in relation to natural background levels.

Northern Gateway would use bubble curtains to reduce pressure and acoustic effects of blasting, and silt curtains to reduce the effect of sedimentation from dredging. It said that bubble curtains are used extensively for other activities, such as pile driving, to reduce the effect of high pressure pulses that can cause injury to fish.

It added that bubble curtains have been tested extensively with blasts, and literature shows they are effective.

Northern Gateway said that physical effects from suspended sediment on marine fish and invertebrates could include abrasion and clogging of filtration mechanisms, which can interfere with ingestion and respiration. In extreme cases, effects could include smothering, burial, and mortality to fish and invertebrates. Direct chemical-related effects of suspended sediment on organisms, including reduced growth and survival, can also occur as a result of the uptake of contaminants
re-suspended by project construction activities, such as dredging and blasting, and as a result ofstorm events, tides, and currents.

The Haisla Nation and Raincoast Conservation objected to Northern Gateway’s figures, noting

Northern Gateway’s sediment and circulation model and its evidence related to contaminated sediment re-suspension at the terminal site. Both parties said that the sediment model was applied for the spring, when the increase in total suspended solids would be negligible compared to background values. In the event of delays, blasting and dredging would likely occur at other times of the year when effects would likely be higher, and these scenarios were not modelled.

The panel’s assessment of the area to be blasted found few species:

Species diversity within Kitimat Arm’s rocky intertidal community is generally low. Barnacles, mussels, periwinkles, and limpets can be found on rocky substrate. Sea urchins, moon snails, sea anemones, sea stars, and sea cucumbers are in shallow subtidal areas. Sandy areas are inhabited by commercially-harvested bivalves such as butter clams and cockles.

Northern Gateway told the JRP that it would “offset” any damage to Douglas Channel caused by the blasting and dredging

Northern Gateway said that construction, operations, and decommissioning of the marine terminal would result in both permanent and temporary alteration of marine fish habitat. Dredging and blasting, and installing physical structures in the water column for the marine terminal would permanently alter marine fish habitat. Based on the current terminal design, in-water site preparation would result in the physical alteration of approximately 1.6 hectares of subtidal marine habitat and 0.38 hectares of intertidal marine habitat. Northern Gateway expected approximately 353 square metres of subtidal marine habitat and 29 square metres of intertidal habitat to be permanently lost.This habitat would be compensated for by marine habitat offsets.

The project’s in-water vertical structures that would support the mooring and berthing structures could create new habitat, offsetting potential adverse effects. The structures may act as artificial reefs, providing marine fish habitat, food, and protection from predation. Although organisms currently inhabiting the work area would be killed, the exposed bedrock would be available for colonization as soon as the physical works are completed.

In its finding on marine sediment, the panel, as it does throughout the ruling, believes that the disruption to the environment caused by previous and ongoing human activity, means that the Northern Gateway Kitimat terminal won’t make that much difference.

Sediment quality in the marine environment is important because sediment provides habitat for benthic aquatic organisms. Northern Gateway’s baseline data for the area immediately surrounding the marine terminal indicated some contamination of water, sediments, and benthic organisms from previous industrial activity. Industrial activities in the Kitimat area have released contaminants through air emissions and effluent discharges since the 1960s. Sources of contaminants to Kitimat Arm
include effluent from a municipal wastewater treatment plant, the Alcan smelter, Methanex Corporation’s methanol plant, and the Eurocan pulpmill, as well as storm water runoff from these operations and the municipality.

Area is largely controlled by natural outflow from the Kitimat River with suspended sediment levels being highest during peak river runoff (May to July, and October) and lowest during winter. Storm events, tides, and currents can also suspend sediments. Levels of total suspended solids fluctuate seasonally and in response to climatic variations, but are generally highest during the summer.

Commercial and recreational vessels currently operating in the area may increase suspended solids by creating water turbulence that disturbs sediments. Given the current sediment contamination levels and the limited area over which sedimentation from construction activities would be expected to disperse, the Panel finds that the risk posed by disturbed contaminated sediment is low. Northern Gateway has committed to monitoring during construction to verify the predicted effects on sediment and water quality for both contaminants and total suspended solids..

The dredging and blasting section of the Joint Review Report is small when compared to the much more extensive sections on pipeline construction and tanker traffic, and the possible effects of a catastrophic oil spill.

Although minor, the marine sediment section exposes the question that was never asked, given the disruptions from years of log dumping at Clio Bay and Minette Bay and the decades of  developments at the mouth of the Kitimat River, and future development from LNG, when do cumulative effects begin to overwhelm? How much is enough? How much is too much? If every project continues to be viewed in isolation, what will be left when every project is up and running?

 

Pension funds pressure Rio Tinto to dump out of controversial Alaska Pebble Mine

Rio_Tinto_LogoRio Tinto says “it intends to undertake a strategic review” of its stake in the highly controversial Pebble Mine project near Bristol Bay, Alaska.

In a news release, Rio Tinto says it is considering its future holdings in a Vancouver-based mining company named Northern Dynasty, which now is the main proponent of the copper and gold mine project. Rio Tinto “through QIT-Fer et Titane Inc., an indirect wholly-owned subsidiary of Rio Tinto plc, owns 18,145,845 common shares of Northern Dynasty, representing approximately 19.1 per cent of Northern Dynasty’s issued and outstanding shares.”

Rio Tinto says the review is part of the financially troubled conglomerate’s review of its mining holdings: “Rio Tinto will consider the Pebble Project’s fit with the Group’s strategy of investing in and operating long life and expandable assets, and with the strategy for its Copper business, which is focused on its four producing assets (Kennecott Utah Copper, Oyu Tolgoi and its interests in Escondida and Grasberg), and two development projects, La Granja in Peru and Resolution in Arizona.”

The Pebble Mine project is as controversial in Alaska and the western United States as the Northern Gateway pipeline project is in British Columbia. Critics say the proposed huge open pit copper and gold mine could endanger the Alaska headwaters of the Kvichak and Nushagak rivers, considered two of the world’s great salmon spawning grounds. Both flow into the “salmon nursery” in Bristol Bay, where young salmon go to feed, possibly also imperiling salmon stocks from both Alaska and British Columbia

On November 4, 2013,  the City of New York and the State of California, whose pension funds have large holdings of Rio Tinto stock, wrote to CEO Sam Walsh, asking the company to reassess the project.

New York City controller John Liu and California state controller John Chiang said their letter was prompted when Rio Tinto rival Anglo-American sold its share of the controversial project in September.

Their letter cited environmental concerns, including the fact that the project would leave 10 billion tonnes of mining waste near the salmon spawning grounds, increased regulatory scrutiny from the US Environmental Protection Agency and what the two controllers called “reputational risks” including opposition from Alaska First Nations and even jewelry companies like Tiffany & Co and Zales and Jostens. The letter cited a poll which showed 73 per cent of Americans, 84 per cent of Alaskans and 98 per cent of Bristol Bay residents opposed the project.

Rio Tinto replied on November 14, in a letter not from CEO Walsh but from John-Sebastian Jacques, chief executive of the copper division, saying Rio Tinto would “encourage a responsible approach among all shareholders” and the company would continue to “review and analyze” the risks involved.

On December 19, the two controllers then called upon Rio Tinto to divest itself of the Northern Dynasty shares, calling, according to the Associated Press, Rio Tinto’s response “perfunctory.”

Rio Tinto spokesman David Outhwaite told AP the strategic review is not connected to that letter or a letter the financial officers sent Walsh.

Ango-American, one of Rio Tinto’s giant mining rivals, pulled out of the Pebble Mine project in September.  Teck Cominco and Mitsubishi had pulled out earlier, leaving Rio Tinto as the only major company involved in the project.

When it decided to sell its share back to Northern Dynasty, Anglo-American also cited a “strategic review” of the company’s operations.

At the time, Rio Tinto’s Jennifer Ruso told the Alaska Dispatch,  the company “will only participate in the project if it can be constructed, operated and closed in a manner that preserves the water, salmon, fisheries, wildlife and the environment. The project must also be developed in accordance with our strict standards for health, safety, environmental protection, cultural heritage, and community relations.”

Northern Dynasty and Rio Tinto then said they were considering an underground mine instead of an open pit operation, which did not satisfy environmental critics of the project.

On December 13, Northern Dynasty reported that it had re-acquired 100 per cent ownership of the Pebble Mine project after completing the pull out deal with Anglo-American.

The company, however, is looking for new partners. It says:

Our primary focus is to select the right partner for Northern Dynasty and the right investor for Alaska, a company with sufficient financial resources and technical capabilities, working experience in the United States and a shared commitment to environmentally sound and socially responsible development. We have little doubt that Pebble will attract major mining company interest in the months ahead.

The news release says that Northern Dynasty has spent US$556 million over the past few years and “substantial progress has been made toward our goal of permitting, constructing and operating a world-class, modern and environmentally responsible mine at Pebble that will co-exist with the fisheries resources of southwest Alaska.”

Northern Dynasty LogoIn the news release, Northern Dynasty President & CEO Ronald Thiessen said Pebble’s engineering design, environmental science and regulatory planning were advanced that the company would begin to ask for US and Alaska permitting under the National Environmental Policy Act (NEPA) sometime the first quarter of 2014.

It describes the project this way:

The Pebble Project is an initiative to responsibly develop a globally significant copper, gold and molybdenum deposit in southwest Alaska into a modern, long-life mine, which will benefit not only Northern Dynasty, but the people, culture and industries of the State of Alaska, as well as suppliers, consultants and industries in the Lower 48 United States of America.
A recent study authored by IHS Global Insight, entitled The Economic and Employment Contributions of a Conceptual Pebble Mine to the Alaska and United States Economies found the Pebble Project has the potential to support 15,000 American jobs and contribute more than $2.5 billion annually to US GDP over decades of production.

The Pebble Project is located 200 miles southwest of Anchorage on state land designated for mineral exploration and development. It is situated in a region of rolling tundra approximately 1,000 feet above sea-level, 65 miles from tidewater on Cook Inlet and presents favourable conditions for successful mine site and infrastructure development.

As the Alaska Dispatch reported when Anglo-American pulled out, the copper and gold deposits are so extensive and potentially valuable that pressure to develop the mine will continue despite the threat to salmon and the Alaska environment.

Bitumen excluded from data for federal tanker study, documents reveal

Tanker risk map
Transport Canada tanker report map shows current risk for spills in BC (Transport Canada)

 

Genivar report
Cover of Genivar tanker report (Transport Canada)

 

The possible effects of a bitumen spill on Pacific waters were not considered in the oil response preparedness report released last week by the Harper government, the background data study reveals.

The consulting firm that did the study for Transport Canada, Genivar Inc, had no reliable data on the effect of a bitumen tanker disaster—because, so far, there has been no major ocean disaster involving diluted bitumen.

Instead, Genivar, based its findings on potential hazards and response on existing data on crude oil spills.

The Genivar study, however, does warn, that if the Enbridge Northern Gateway project does go ahead,  the spill risk from diluted bitumen carrying tankers in Douglas Channel and along the north Pacific coast will jump from “low” or “medium” to “very high.” If the twinning of the Kinder Morgan pipeline goes ahead, then the risk in Vancouver also jumps to “very high.”

The question of how bitumen might behave in the cold and choppy waters of the North Pacific was hotly debated during the Northern Gateway Joint Review hearings earlier this year. Enbridge Northern Gateway based its position on laboratory studies, studies that were challenged by environmental and First Nations intervenors, pointing both to the unknowns of the ocean environment and the continuing problems Enbridge has in cleaning up the spill in the Kalamazoo River in Michigan.

Genivar tried to base its report to Transport Canada on existing data on oil spills and related hazards. What it found instead is that that there are often gaping holes in the reporting and monitoring of oil spills world wide, especially small and medium sized spills.

Lack of data also meant that Genivar had little to go on when it calculated the effect on an oil spill on key areas of interest to northwest British Columbia, the recreational fishery and tourism.
Genivar, however, did uncover disturbing data about the long term effects of oil spills, studies that show even minute amounts of remaining oil can still disrupt the marine environment 40 years after an event.

The Genivar report, Risk Assessment for Marine Spills in Canadian Waters Phase 1: Oil Spills South of 60th Parallel, was completed in November, then passed on to the “expert panel” that released their own report: A Review of Canada’s Ship-source Oil Spill Preparedness and Response Regime — Setting the Course for the Future. That second report was based not only on the data provided by Genivar but on the expertise of three panel members, their visits to some locations and input from government, industry, First Nations and municipalities.

Transport Minister Lisa Raitt and Natural Resources Minister Joe Oliver unveiled the second report at a glitzy media event  in Vancouver on Tuesday, December 10. At that time the expert panel report was released to the media along with an abstract of the data.

The actual data report was not posted; it had to be requested through the Transport Canada website, which is how Northwest Coast Energy News obtained the background study.

High risk for Kitimat

Transport Canada tanker report
Expert panel tanker risk assessment report cover (Transport Canada)

The expert panel found “a very high risk” of oil spills in two areas of the Pacific Coast, in the north around the ports of Kitimat and Prince Rupert and in the heavy ocean traffic area of southern British Columbia, especially Port Metro Vancouver and into Washington State.

The expert panel made 45 recommendations that covered a wide range of issues including eliminating the present $161-million liability limit for each spill and replacing it with unlimited liability for polluters, annual spill training involving the Canadian Coast Guard, Environment Canada, provincial and local authorities and the private sector, increased and improved annual spill training exercises, basing risk assessment on local geography and conditions and faster emergency responses to spills.

The expert panel calls for greatly increased research on the ocean environment at a time that Harper government has been gutting environmental research across Canada, while spinning that its policies are “science based.”

The science and technology around both the movement of oil and spill response has advanced significantly over the past several decades. We feel that while some aspects of the Regime have kept pace with these developments, in some areas, Canada has fallen behind world-leading countries like Norway and France. This can be attributed to a general lack of investment in research and development as well as the lack of coordination between industry and government over research priorities.

The Government of Canada should work closely with industry to establish a national research and development program for oil spill preparedness and response. The program should be co-funded by industry and the Government, and the research priorities should be set through a collaborative process that involves academia, where possible. Like the Regime itself, we view this program as a partnership between industry and government.

We envision that this program would also seek to leverage the work being done internationally on oil spill preparedness and response. The program should seek to establish partnerships with other world-leading countries in order to stay current on international advances and new technologies.

The expert panel, however, does not say how the federal government is expected to pay for meeting BC Premier Christy Clark’s condition for a “world class” spill prevention and response system at a time that Finance Minister Jim Flaherty is determined to balance the budget and the Harper government is continuing to cut back government services.

Bitumen excluded

On bitumen, the Genivar data study says:

Modified bitumen products represent the majority of the “crude carried as cargo” in
Pacific sub-sector 5. They are not modelled as a separate category in this spill behaviour analysis but are represented as “persistent crude”.

Changes in spill behaviour depend to some extent on the environmental conditions at the time of the spill, as described in greater detail below. However, over the range of wind and sea conditions typically experienced in the Canadian marine environment, changes in oil properties are not overly sensitive to variations in climatic values, so a single set of wind and sea conditions will be used in the analysis.

The idea that “changes in oil properties” not being sensitive to variations in climate was also frequently challenged before the Joint Review Panel.

On the increase in traffic volume if the Northern Gateway project goes ahead, the Genivar report says.

Enbridge Inc. has proposed to construct a marine terminal at Kitimat, B.C. and a dual pipeline from the terminal to oil sands production in northern Alberta. The terminal would handle up to 193,000 barrels/day of imported diluents (i.e., low-gravity condensate) that would be piped to Alberta and used to dilute bitumen to enhance its flow properties. The diluted bitumen would then be piped to Kitimat at rates up to 525,000 barrels/day that would be shipped by tanker to export to markets in Asia and California.

At full capacity, the import of diluent and export of diluted bitumen would total up to 35 Mt/year. This amount is comparable to the currently-shipped volume in the Pacific sector related to volumes being exported from Vancouver and related to volumes being exported from the Alaskan to Washington State trade.

It goes on to say that the current tanker traffic on the north Pacific coast “has negligible risk in the near shore and intermediate zones, but significant potential spill frequency in the deep-sea zone related to the Alaskan trade.” Similarly, according to Genivar the environmental risk in the region “currently ranges from ‘medium’ to “very low” from near shore to deep-sea zones, respectively…. mainly driven by a combination of physical and biological features.”

The increase in traffic from Northern Gateway would likely increase the environmental risks. The the near shore risk from would jump from “very low” to “very high.” For the largest spill category, deep-sea risk would likely increase from “low” to “medium.”

No data on recreational or traditional First Nations fishery

To study the effect on an oil spill on the fishery, Genivar used data from the Department of Fisheries and Oceans as the provinces to gauge “the port value of commercial fishing and the value of the fish, shellfish and aquaculture” in each zone it studied and then compared it to the the national averages for commercial fishery. Those figures included any commercial fishery by First Nations.

But Genivar noted, there is no reliable data on either the recreational fishery or the First Nations traditional, food, social and ceremonial fishery, saying:

It is important to highlight that this indicator does not consider recreational or traditional fishing. The importance of this industry is notable and an oil spill could damage the recreational fishing stock as well. However, the absence of comparable data and the fact that this study is restricted to federal and international data, and some provincial data from Quebec and Ontario for commercial fisheries, limits the ability to include recreational fishing… Nevertheless, as an absolute index, it will provide an overall vulnerability in the event of an oil spill.

The ongoing impact of cutbacks at Fisheries and Oceans has had a continuing impact on the northwest, especially in the controversial halibut recreational fishery, where DFO has admitted that it is basically guessing the size of each year’s recreational halibut catch.

Tourism

Genivar also notes that lack of reliable data on the effect on a oil spill on tourism. The consultants go so far as to say one of the indicators they will use to measure the effect of any oil spill on tourism would come from “data extracted from the 2011 National Household Survey at the census division level and the accommodation and food services data will be used.”

The “National Household Survey” is also known as the long form census and it is the National Household Survey that the Harper government made voluntary rather mandatory, decreasing the reliability of the data. Global News recently analyzed those who had contributed to the survey and found that it poor people, the very rich and people in low population areas were least likely to fill out the voluntary census—which means the data for northwest BC is likely highly unreliable from the 2011 survey even though “The census divisions in coastal regions will be selected for each of the sub-sectors. This method will express the economic vulnerability of each sub-sector to a potential collapse in tourism following a spill.”

Despite the importance of cruise ship traffic on the west coast, Genivar notes, “In Canada, data for passenger vessels were unavailable.”

It also notes that “this study does not specifically take into account national parks and other landmarks, since their influence on tourism is indirectly included in the tourism employment
intensity index” so that Genivar could create what it calls the Human-Use Resource Index (HRI), even though that index appears to be based on incomplete data.

Oil spill dangers can linger for 40 years, report shows

Genivar report
Cover of Genivar tanker report (Transport Canada)

The Genivar report for Transport Canada on oil spills say that some persistent effects can last for more than 40 years, based on a study of a spill in Cape Cod, Massachusetts. The report  notes that persistent sub-surface oil is still a problem at Prince William Sound, site of the Exxon Valdez disaster in 1989.

On long-term effects, Genivar reports: “The ingestion of contaminated food (such as oiled mussels), may represent the most important exposure pathway for aquatic fauna during a chronic
phase. Chronic exposure to contaminated sediments is also important for fauna or
vegetation.”

 

 

 

It goes on to stay that “large-scale oil spills might have considerable long-term
consequences on social structure and public health, interfering with traditions and
causing cultural disruptions.”

It appears that in the case of an oil-spill, time may heal some wounds, but not all of them, at least if time is considered within human lifetimes and the lifetimes of other species.

Ecological recovery is measured by how quickly individuals and populations of
species return to pre-spill conditions. It is determined by factors such as oil type,
exposure duration, water temperature, degree of weathering, spill response and the
individual and species-specific life history traits. In most environmental habitats,
recovery is completed within 2-10 years after a spill event, but in some exceptional
cases, such as in salt marshes, effects may be measurable for decades after the
event.

In the case of the Exxon Valdez oil spill in Prince William Sound… in 1989, the persistence of sub-surface oil in sediments and its chronic exposure continues to affect some of the wildlife through delayed population reductions, indirect effects and trophic interactions 20 years beyond the acute phase of the spill.

It then goes on to stay that

Four decades after the oil spill In Wild Harbor (USA), Spartina alterniflora beds had a reduced stem density and biomass and mussels in oiled locations showed decreased growth and filtration rates.

According to a Boston Globe story, published at the time of the Deepwater Horizon oil leak in the Gulf of Mexico, in 2010, the Wild Harbor, an oil barge ran aground near Cape Cod in September, 1969, spilling 200,000 gallons of fuel, some of which is still there.

The Boston Globe story noted:

Today, Wild Harbor looks much like any other Cape Cod marsh, but the oil below the surface affects its resiliency. Fiddler crabs normally burrow deep down, funneling oxygen to the roots of marsh grass. Here, they stop digging when they reach the oil, turn sideways, and burrow back to the surface. They also act “drunk’’ from the oil they ingest, and predators can catch them more easily, research shows.

The Woods Hole Oceanographic Institute has been studying the Wild Harbor spill for the past 40 years.

At a recent conference, Dr. John Teal updated scientists on the “multi-decadal effects” of the Wild Harbor spill. According a blog on the conference:

At the time of the 1969 spill, lobsters, clams, and fish died by the thousands, but most people believed the harm would be temporary, reflecting the conventional wisdom of the time. Barge owners and oil industry experts even told residents that most of the oil would evaporate and any damage would only be short-lived. However, researchers at WHOI were not so sure and immediately began cataloging species and tracking where the oil was and kept at it for years. The researchers understood that the immediate, short term effects of oil pollution were already obvious and fairly well-understood, but that everyone was rather ignorant about the long-term and low-level effects of an oil spill….

Beginning three to five years after the spill, marsh grasses and marsh animals were again occupying most of the oiled area. An observer unfamiliar with Wild Harbor would not have been able to visually detect the oiled areas after just 10 years, and by the second decade after the spill, the marsh’s appearance had returned to normal. However, the WHOI researchers pointed out that for more than a decade after the spill, an oil sheen still appeared on the surface of the water when mud from the most heavily oiled parts of the marsh was disturbed….

In 2007, WHOI researchers documented that a substantial amount of moderately degraded petroleum still remained within the sediment and along eroding creek banks of the marsh oiled in 1969. They also demonstrated that the ribbed mussels that inhabit the oiled salt marsh, and are exposed to the oil, exhibited slower growth rates, shorter mean shell lengths, lower condition indices, and decreased filtration rates even when placed in a healthy marsh. Researchers have also documented detrimental effects of the 1969 oil spill on the salt marsh plants themselves.

 

Related Oil Spill on the Wild Harbor Marsh by John M. Teal and Kathryn A. Burns
The Genivar report goes on to note:

Long-term effects on the population in the aquatic environment (especially on mobile fauna) are especially difficult to confirm. Benthic [bottom dwelling] invertebrates may be more at risk than fish species due to the fact that more or less sessile organisms are likely to suffer higher initial rates of mortality and exhibit long recovery times as a result of
exposure to oil-saturated habitats.

Nearshore demersal [bottom-dwelling] fish can also suffer from long-term chronic exposure, as indicated in masked greenlings and crescent gunnels by biomarkers on hydrocarbons 10 years after the Exxon Valdez spill. Mortality in sea ducks and sea turtles due to chronic exposure was also reported many years after the spill and other results indicate that effects on cetacean populations can last beyond 20 years after the acute exposure phase.

As for the recovery of the economy after a spill, Genivar notes it is based “on the time required for effected industries to be fully restored to pre-spill conditions.

The length of time required is influenced by the duration of the aquatic area closures (e.g. commercial fisheries, recreational fisheries), the public perceptions on seafood safety and the perceived effects of the aesthetic quality of the environment. Even after the full ecological recovery of the aquatic resources, fisheries can be far from reestablished, as is still the case for herring fisheries in the Exxon Valdez spill area…

As reviewed by Genivar, negative perceptions associated with the quality of fishery products, even for fisheries that have not been contaminated and also for regions not directly affected by the spill, can be far more important than the direct economic losses. This also holds true for the tourism sector and all other related spinoff sectors.

LNG Canada maps air shed study area

Kitimat Airshed Map
Map released by LNG Canada shows the air shed area that the company will study as part of the environmental assessment. (LNG Canada)

Two of the maps filed by the LNG Canada project with provincial and federal environmental assessment agencies look at the air quality problems from the project, including the controversial prospect of cumulative problems from multiple industrial projects in the Kitimat Valley, one of them the RTA Kitimat Modernization Project which will increase sulphur dioxide emissions while decreasing some other emissions.

One map covers what is being called the airshed, in the case of LNG Canada, air quality will be assessed with the LNG facility at its centre. A second map covers the tanker route, and as well as a 40 km square grid around the plant that will also assess Hartley Bay, Kitkatla and Metalkatia which may be impacted by vessel emissions.

As well as scientific data, the assessment will also take into consideration traditional knowledge and traditional use from “aboriginal and other groups.”

The possible cumulative effect on the air quality in the Kitimat valley and surrounding areas has prompted the BC government to commission its own study of the Kitimat airshed.
On Oct 3, the provincial ministries of the environment and gas development announced a $650,000 scientific study “to help inform regulatory and policy development for future industrial activity in the Kitimat area. The goal is to ensure the potential impacts from industrial air emissions are clearly understood prior to new projects being approved and in operation.”
It says

The Kitimat Airshed Impact Assessment Project will look at the cumulative effects of existing and proposed industrial air emissions in the airshed. These include emissions from: an existing aluminium smelter, three proposed LNG terminals, a proposed oil refinery, a crude-oil export facility, and gas-turbine-powered electrical generation facilities. The study will focus on sulphur dioxide and nitrogen dioxide emissions from these facilities.

The study will assess the impact of emissions through a number of scenarios, including their potential effects on water and soil, as well as on vegetation and human health from direct exposure.

BC defines an airshed as

An airshed is generally described as an area where the movement of air (and, therefore, air pollutants) can be hindered by local geographical features such as mountains, and by weather conditions. The most obvious example in British Columbia is a mountain valley. Since air pollution knows no political boundaries, airshed activities may be focused on a single community or on a number of neighbouring communities faced with similar air quality problems and requiring similar action.

The LNG Canada assessment will look at two potential adverse effects, first a change in ambient air quality in the Kitimat airshed or along the marine access route and second any change in acidic deposition pattern in the Kitimat Valley.

The first study will look specifically at estimated levels of “criteria air contaminets” including sulphur dioxide, Nitrogen oxides, carbon monoxide, atmospheric particulate matter and hydrogen sulphide. The particulate matter study will use the international standard of 2.5 micrometres. 

The assessment will also study possible cumulative effects on air quality of multiple projects and those projects over time.

LNG Canada air quality map
LNG Canada map shows the marine and land areas that will be studying for air quality. (LNG Canada)

 

 

Commentary: The earthshaking difference between Enbridge and LNG

Joint Review Panel
The Northern Gateway Joint Review panel, Kenneth Bateman, Sheila Leggett and Hans Matthews, listen to final arguments in Terrace, June 17, 2013. (Robin Rowland/Northwest Coast Energy News)

Buried deep in the LNG Canada environmental assessment application, a reader will find a key difference in attitude with at least one of the group of companies planning liquified natural gas development in the northwest and Enbridge Northern Gateway.

It’s an earthshaking difference, since it’s all about earthquakes.

The documents filed by LNG Canada with the BC Environmental Assessment Office and the Canadian Environmental Assessment Agency acknowledge that there is a possibility of an earthquake (a one in 2,475 year event) at the LNG terminal site.

Northwestern British Columbia was shaken by two major earthquakes in the months before the Joint Review Panel concluded its hearings in Terrace. Both were far from Kitimat, but felt across the District. On October 27, 2012, there was a magnitude 7.8 earthquake on the Queen Charlotte Fault off Haida Gwaii. That quake triggered a tsunami warning, although the actual tsunami was generally limited to the coast of Haida Gwaii. Both landline and mobile phone service in Kitimat was briefly disrupted by both the quake and overloads on the system. Kitimat was also shaken by the 7.5 magnitude earthquake centered at Craig, Alaska a few weeks later on January 9, 2013.

With the exception of one vague reference in its final argument documents presented to the Joint Review Panel, Enbridge has stubbornly refused to consider any seismic risk to the region.

That was the company’s policy long before the October. 27, 2012 Haida Gwaii earthquake and was Enbridge policy after October 27, 2012.

In a public meeting in Kitimat on September 20, 2011, more than a year before the Haida Gwaii earthquake, John Carruthers, Northern Gateway president, insisted to skeptical questioners at a community forum at Mount Elizabeth Theatre that there was no earthquake danger to the proposed Northern Gateway pipeline and bitumen terminal in Kitimat.  One of the questioners, Danny Nunes, of Kitimat, asked could the pipes withstand an earthquake? Carruthers repeated that Kitimat was not in an earthquake zone, that the fault was off Haida Gwaii and so would not affect Kitimat.

After the September, 2011 meeting, I asked Carruthers if Enbridge knew about the March 27,1964 “Good Friday” magnitude 9.2 Alaska earthquake that, because of its high magnitude, had caused major shaking in Kitimat. That earthquake destroyed much of Anchorage and triggered tsunamis that caused damage and death across Alaska and in parts of British Columbia, Oregon and California.

Carruthers promised to get back to me and never did.

On June 17, 2013, six months after the Craig, Alaska earthquake, in his opening summation before the Joint Review Panel, Richard Neufeld, lead lawyer for Northern Gateway, stayed on message track, telling the JRP, referring to pipelines: “The route is not seismically unstable. The seismic risk along the pipeline right-of-way is low, with only a few locations of moderate risk encountered, none of which are within the Haisla territory.”

That brought a gasp from spectators in the room, or at least those who had felt the October and January earthquakes.

The following day, June 18, Murray Minchin of Douglas Channel Watch found an anomaly in the Enbridge documentation, arguing in the group’s summation:

“The Proponent’s written final argument gets on shaky ground regarding design and construction of the storage tanks on a ridge beside Douglas Channel in paragraph 249 where they say:

“‘It also involves the safe construction and operation of the Kitimat terminal in Kitimat Arm in an area subject to seismic activity which encompasses both terrestrial and marine components.’

“Now, that’s interesting because isn’t that the first time — the first admission by the Proponent in a little over 10,000 pages of documents that the area they intend to build their project is in a seismically-active area?

“Haven’t they been telling us all along to this point that the only seismic concerns would be from the distant Queen Charlotte fault off of Haida Gwaii?

“Now, this completely contradicts Mr. Neufeld’s statement yesterday where he described the Project area as not “seismically unstable”. So what is it? This is their final argument and they’re contradicting themselves.”

Minchin went on to quote from the Enbridge argument: “’Seismic conditions in the project area have also been addressed.’

“Well, really? Is that a truthful statement, considering Natural Resources Canada has only submitted a preliminary report concerning a 50-kilometre fault line and massive submarine landslides they accidentally discovered last year in Douglas Channel while doing a modern survey of the Channel for navigation hazards.

“How can the Proponent claim to have adequately addressed seismic forces in their design of this Project when they don’t know what those forces are or for what duration they may be subjected to those forces.

“Has there ever been a paleoseismological study in the Project area to establish past earthquake or tsunami history?

“Wouldn’t it be in the best interest of the Proponent, the Panel and Canadians to know the risks before 1.3 billion litres of liquid petroleum products are allowed to be stored on a low ridge right beside Douglas Channel?”

In his final rebuttal on June 24, Neufeld did not address the contradictions that Minchin had pointed out.

Compare Enbridge’s attitude to the view of LNG Canada, which at very least, appears willing to consider that major events could have adverse consequences on the terminal and liquifaction facilities.

    • The first one is a bit puzzling to Kitimat residents “A 1 in 100 year 24 hour rain event,” after all the town often gets rain for 24 hours straight or more fairly often.
    • The second, 1 in 200 year flood of the Kitimat River. Flooding has always been a concern and will be even more so, because as the pipelines come into town, whether natural gas or bitumen, those pipelines will be close to the river bank.
    • The 1 in 2,475 year seismic event. That figure is probably correct for a local event given the geology of the Kitimat Valley—unless, of course, the fault line discovered by the Geological Survey of Canada on Hawksbury Island proves to be a potential danger.
    • A tsunami.
    • Change in flow of the Kitimat River.
    • Even more interesting is that LNG Canada is willing to consider possible effects of climate change on the project, saying: “Predicted climate change effects during the project lifecycle on sea-level rise, precipitation and temperature. Where relevant and possible, the implications of such climate induced changes to the extreme weather events given above will also be addressed.”

.

Although the hydrocarbon industry as a whole is reluctant to acknowledge climate change, it appears that on a practical level, the LNG Canada partners, if they are about to invest billions of dollars in a natural gas liquifaction plant and marine terminal, will certainly take steps to protect that specific investment from the effects of climate change.

On the other hand, the National Energy Board, as matter of policy and the Northern Gateway Joint Review Panel, both still stubbornly refuse to even consider any effects of climate change, even possible effects locally on a specific project application.

The Joint Review Panel decision on the Northern Gateway is expected sometime in the next three weeks. While most reports seem to indicate that the decision will be released after Christmas before the Dec. 30 deadline, there has been recent media speculation that the decision could be released next week.

In the meantime, Enbridge has pulled out all stops in a public relations campaign to build support for the Northern Gateway. While a recent poll indicates that advertising campaign may be having some success in the Lower Mainland, the same poll showed that 65 per cent of northern BC residents oppose or strongly oppose the Northern Gateway.

The problem for Enbridge is that the new public relations campaign is repeating the blunders that began when they first proposed Northern Gateway in 2005. There have been meetings across the northwest, but those meetings have been invitation only affairs at chambers of commerce and community advisory boards, with possible opponents or skeptics and media perceived as critical of Enbridge not invited. So Enbridge still wants to control the message and will only talk to friendly gatherings.

Then there are the television spots featuring Janet Holder, the Enbridge vice president in charge of Northern Gateway, supposedly showing her commitment to wilderness. Those commercials would have had more credibility if the agency had produced the ads with actual video of Holder walking through the bush, rather than shooting the spots in front of a green screen in a studio, with pristine wilderness stock video in the background, and Holder acting as if she was a model for an adventure clothing company rather than  vice president of a pipeline company.

Right-wing business columnists in Toronto and the countless Albertans fume at the so-called “hypocrisy” of British Columbians who support LNG and oppose bitumen.

Of course, those critics didn’t feel the earth move under their feet.  The critics don’t see the difference between natural gas and bitumen, differences very clear to the people of British Columbia.

It’s more than the fact, that so far, the LNG projects have been relatively open and willing to talk to potential adversaries,  as Chevron has done on the controversial Clio Bay project; more than the fact that if even a fraction of the LNG projects go ahead, the money coming into northwestern BC means that the handful of permanent jobs promised by Enbridge will be literally a drop in a bucket of warm bitumen.

Although there are many other environmental issues on the Northern Gateway project, the fact the potential for earthquakes in Kitimat is brushed off by Enbridge while LNG Canada is at least willing to consider the problem, sums it all up.

 

Updated with link to Sept. 2011  questions and answers

 

 

 

 

 

 

 

Clio Bay: Haisla desire to clean up bay led to proposal to cap Clio with marine clay, Ross says

Special report: Clio Bay cleanup: Controversial, complicated and costly

Clio Bay
Clio Bay, looking toward Douglas Channel, September 14, 2013. (Robin Rowland/Northwest Coast Energy News)

 

Haisla First Nation Chief Counsellor Ellis Ross says the Haisla made the proposal to the KM LNG project, a partnership of Chevron and Apache, to use the marine clay to cover the thousands of logs at the bottom of Clio Bay after years frustration with the Department of Fisheries and Oceans and the BC provincial government, which for decades ignored requests for help in restoring almost fifty sunken log sites in Haisla traditional territory.

The problem is that remediation of the hundreds of sites on Canada’s  west coast most containing tens of thousands of sunken logs has been so low on DFO’s priority list that even before the omnibus bills that gutted environmental protection in Canada, remediation of sunken log sites by DFO could be called no priority.

Now that the KM LNG has to depose of a total of about 3.5 million cubic metres of marine clay and possibly other materials from the Bish Cove site, suddenly log remediation went to high priority at DFO.

The controversy is rooted in the fact that although the leaders of the Haisla and the executives at Chevron knew about the idea of capping Clio Bay, people in the region, both many residents of Kitimat and some members of the Haisla were surprised when the project was announced in the latest KM LNG newsletter distributed to homes in the valley.

Chevron statement

In a statement sent to Northwest Coast Energy News Chevron spokesperson Gillian Robinson Ridell said:

The Clio Bay Restoration Project  proposed by Chevron, is planned to get underway sometime in early 2014. The proposal is fully supported by the Federal Department of Fisheries and Oceans and the Haisla First Nation Council.  The project has been put forward as the best option for removal of the marine clay that is being excavated from the Kitimat LNG site at Bish Cove. Chevron hired Stantec, an independent engineering and environmental consulting firm with extensive experience in many major habitat restoration projects that involve public safety and environmental conservation.  The Haisla, along with Stantec’s local marine biologists, identified Clio Bay as a site that has undergone significant environmental degradation over years of accumulation of underwater  wood debris caused by historic log-booming operations. The proposal put forward by the marine biologists was that restoration of the marine ecosystem in the Bay could be achieved  if marine clay from Chevron’s facility site, was used to cover the woody debris at the bottom of the Bay. The process outlined by the project proposal is designed to restore the Clio Bay seafloor to its original soft substrate that could sustain a recovery of biological diversity.

Kitimat worried

Non-aboriginal residents of Kitimat are increasingly worried about being cut off from both Douglas Channel and the terrestrial back country by industrial development. These fears have been heightened by reports that say that Clio Bay could be closed to the public for “safety reasons” for as much as 16 months during the restoration project.

The fact that Clio is known both as a safe anchorage during bad weather and an easy to get to location for day trips from Kitimat has made those worries even more critical.

There is also a strong feeling in Kitimat that the residents were kept out of the loop when it came to the Clio Bay proposal.

In a letter to the District of Kitimat, DFO said:

Clio Bay has been used as a log handling site for decades which has resulted in areas of degraded habitat from accumulations of woody debris materials on the sea floor. The project intends to cap impacted areas with inert materials and restore soft substrate seafloor. The remediation of the seafloor is predicted to enhance natural biodiversity and improve the productivity of the local fishery for Dungeness crab. The project area does support a variety of life that will be impact and therefore the project will require authorization from Fisheries and Oceans Canada for the Harmful Alteration, Disruption or Destruction (HADD) of fish and fish habitat.

The letter avoids the controversy over the use of marine clay but saying “inert material” will be used. That can only increase the worries from residents who say that not only clay but sand, gravel and other overburden from Bish Cove and the upgrade of the Forest Service Road may be used in Clio Bay. (The use of “inert material” also gives DFO an out if it turns out the department concludes the usual practice of using sand is better. That, of course, leaves the question of what to do with the clay).

Although Ellis Ross has said he wants to see large numbers of halibut and cod return to Clio Bay, the DFO letter only mentions the Dungeness Crab.

DFO website cites pending changes after the passage of the omnibus bills.
DFO website cites pending changes after the passage of the omnibus bills.

Try to search “remediation” on the DFO site and the viewer is redirected to a page that cites the omnibus bills passed by the Conservative government and says

On June 29, 2012, the Fisheries Act was amended. Policy and regulations are now being developed to support the new fisheries protection provisions of the Act (which are not yet in force). The existing guidance and policies continue to apply. For more information, see Changes to the Fisheries Act.

On April 2nd, 2013 the Habitat Management Program’s name was changed to the Fisheries Protection Program.

So, despite what communications officers for DFO and the Harper government may say, there was no policy then and there is no policy now on remediation of log sites. Given Harper’s attitude that LNG and possibly bitumen export must proceed quickly with no environmental barriers, it is likely that environmental remediation will continue to be no priority—unless remediation becomes a problem that the energy giants have to solve and pay for.

Alaska studies

On the other hand, the State of Alaska and the United States Environmental Protection Agency spent a decade at a site near Ketchikan studying the environmental problems related to sunken logs at transfer sites

Those studies led Alaska to issue guidelines in 2002 with recommended practices for rehabilitating ocean log dump sites and for the studies that should precede any remediation project.

The Alaska studies also show that in Pacific northwest coast areas, the ecological effects of decades of log dumping, either accidental or deliberate, vary greatly depending on the topography of the region, the topography of the seabed, flow of rivers and currents as well as industrial uses along the shoreline.

The Alaska policy is based on studies and a remediation project at Ward Cove, which in many ways resembles Clio Bay, not far from Kitimat, near Ketchikan.

The Alaska policy follows guidelines from both the US Environmental Protection Agency and the US Army Corps of Engineers that recommend using thin layers of “clean sand” as the best practice method for capping contaminated sites. (The Army Corps of Engineers guidelines say that “clay balls” can be used to cap contaminated sites under some conditions. Both a spokesperson for the Corps of Engineers and officials at the Alaska Department of Environmental Conservation told Northwest Coast Energy News that they have no records or research on using marine clay on a large scale to cap a site.)

The EPA actually chose Sechelt, BC, based Construction Aggregates to provide the fine sand for the Ward Cove remediation project. The sand was loaded onto 10,000 tonne deck barges, hauled up the coast to Ward Cove, offloaded and stockpiled then transferred to derrick barges and carefully deposited on the sea bottom using modified clam shell buckets.

The EPA says

Nearly 25,000 tons of sand were placed at the Ward Cove site to cap about 27 acres of contaminated sediments and 3 other acres. In addition, about 3 acres of contaminated sediments were dredged in front of the main dock facility and 1 acre was dredged near the northeast corner of the cove. An additional 50 acres of contaminated sediments have been left to recover naturally.

A report by Integral Consulting, one of the firms involved at the project estimated that 17,800 cubic metres of sand were used at Ward Cove.

In contrast, to 17,800 cubic metres of sand used at Ward Cove, the Bish Cove project must dispose of about 1.2 million cubic metres of marine clay at sea (with another 1.2 million cubic metres slated for deposit in old quarries near Bees Creek).

Studies at Ward Cove began as far back as 1975. In 1990 Alaska placed Ward Cove on a list of “water-quality limited sites.” The studies intensified in 1995 after the main polluter of Ward Cove, the Ketchikan Paper Company, agreed in a consent degree on a remediation plan with the Environmental Protection Agency in 1995. After almost five years of intensive studies of the cove, the sand-capping and other remediation operations were conducted from November 2000 to March 2001. A major post-remediation study was carried out at Ward Cove in 2004 and again in 2009. The next one is slated for 2015.

Deaf ears at DFO

“We need to put pressure on the province or Canada to cleanup these sites. We’ve been trying to do this for the last 30 years. We got nowhere,” Ellis Ross says. “Before when we talked [to DFO] about getting those logs and cables cleaned up, it fell on deaf ears. They had no policy and no authority to hold these companies accountable. So we’re stuck, we’re stuck between a rock and hard place. How do we fix it?”

Ross says there has been one small pilot project using marine clay for capping which the Haisla’s advisers and Chevron believe can be scaled up for Clio Bay.

Douglas Channel studies

The one area around Kitimat that has been studied on a regular basis is Minette Bay. The first study occurred in 1951, before Alcan built the smelter and was used as a benchmark in future studies. In 1995 and 1996, DFO studied Minette Bay and came to the conclusion that because the water there was so stagnant, log dumping there had not contributed to low levels of dissolved oxygen although it said that it could not rule out “other deleterious effects on water quality and  habitat`from log dumping.”

That DFO report also says that there were complaints about log dumping at Minette Bay as far back as 1975, which would tend to confirm what Ross says, that the Haisla have been complaining about environmentally degrading practices for about 30 years.

Ross told Northwest Coast Energy News that if the Clio Bay remediation project is successful, the next place for remediation should be Minette Bay.

A year after the Minette Bay study, DFO did a preliminary study of log transfer sites in Douglas Channel, with an aerial survey in March 1997 and on water studies in 1998. The DFO survey identified 52 locations with sunken logs on Douglas Channel as “potential study sites.” That list does not include Clio Bay. On water studies were done at the Dala River dump site at the head of the inlet on Kildala Arm, Weewanie Hotsprings, at the southwest corner of the cove, the Ochwe Bay log dump where the Paril River estuary opens into the Gardner Canal and the Collins Bay log dump also on the Gardner Canal.

In the introduction to its report, published in 2000, the DFO authors noted “the cumulative effect of several hundred sites located on BC coast is currently unknown.”

DFO list of sunken log sites on Douglas Channel   (pdf)

Since there appears to have been no significant follow-up, that cumulative effect is still “unknown.”

In 2000 and 2001, Chris Picard, then with the University of Victoria, now Science Director for the Gitga’at First Nation did a comparison survey of Clio Bay and Eagle Bay under special funding for a “Coasts Under Stress” project funded by the federal government. Picard’s study found that Eagle Bay, where there had been no log dumping was in much better shape than Clio Bay. For example, Picard’s study says that “Dungeness crabs were observed five times more often in the unimpacted Clio Bay.”

Although low oxygen levels have been cited as a reason for capping Clio Bay, Picard’s study says that “near surface” oxygen levels “did not reliably distinguish Clio and Eagle Bay sediments.” While Clio Bay did show consistent low oxygen levels, Eagle Bay showed “considerable interseasonal variation” which is consistent with the much more intensive and ongoing studies of oxygen levels at Wards Cove.

Chevron’s surprise

It appears that Chevron was taken by surprise by the controversy over the Clio Bay restoration. Multiple sources at the District of the Kitimat have told Northwest Coast Energy News that in meetings with Chevron, the company officials seemed to be scrambling to find out more about Clio Bay.

This is borne out by the fact, in its communications with Northwest Coast Energy News, Chevron says its consulting firm, Stantec has cited just two studies, Chris Picard’s survey of Clio Bay and a 1991 overview of log-booming practices on the US and Canadian Pacfic coasts. So far, Chevron has not cited the more up-to-date and detailed studies of Ward Cove that were conducted from 1995 to 2005.

Chevron says that Stantec marine biologists are now conducting extensive field work using divers and Remote Operated Vehicle surveys to “observe and record all flora and fauna in the bay and its levels of abundance. Stantec’s observations echoed the previous studies which determined that the massive amount of wood has harmed Clio Bay’s habitat and ecosystem.”

In its statement to Northwest Coast Energy News, Chevron cited its work on Barrow Island,  in Western Australia, where the Chevron Gordon LNG project is on the same island as a highly sensitive ecological reserve. Chevron says the Australian site was chosen only after a thorough assessment of the viability of other potential locations, and after the implementation of extensive mitigation measures, including a vigorous quarantine program for all equipment and materials brought on to the Barrow island site to prevent the introduction of potentially harmful alien species.

Reports in the Australian media seem to bare out Chevron’s position on environmental responsibility. Things seem to be working at Barrow Island.

Robinson went on to say:

Those same high environmental standards are being applied to the Kitimat LNG project and the proposed Clio Bay Restoration project. The proposed work would be carried out with a stringent DFO approved  operational plan in place and would be overseen by qualified environmental specialists on-site.

The question that everyone in the Kitimat region must now ask is just how qualified are the environmental specialists hired by Chevron and given staff and budget cuts and pressure from the Prime Minister’s Office to downgrade environmental monitoring just how stringent will DFO be monitoring the Clio Bay remediation?

Alaska standardsIn the absence of comprehensive Canadian studies, the only benchmark available is that set by Alaska which calls for:Capping material, typically a clean sand, or silty to gravelly sand, is placed on top of problem sediments. The type of capping material that is appropriate is usually determined during the design phase of the project after a remediation technology has been selected. Capping material is usually brought to the site by barge and put in place using a variety of methods, depending on the selected remedial action alternative.

Thick Capping

Thick capping usually requires the placement of 18 to 36 inches of sand over the area. The goal of thick capping is to isolate the bark and wood debris and recreate benthic habitat that diverse benthic infauna would inhabit.

Thin Capping

Thin capping requires the placement of approximately 6 – 12 inches of sand on the project area. It is intended to enhance the bottom environment by creating new mini-environments, not necessarily to isolate the bark and wood debris. With thin capping, surface coverage is expected to vary spatially, providing variable areas of capped surface and amended surface sediment (where mixing between capping material and problem sediment occurs) as well as limited areas where no cap is evident.

Mounding

Mounding places small piles of sand or gravel dispersed over the waste material to create habitat that can be colonized by organisms. Mounding can be used where the substrate will not support capping.

[rps-include post=5057]

Clio Bay remediation project “killing two birds with one stone,” Ross says

Special report: Clio Bay cleanup: Controversial, complicated and costly

 

Ellis Ross
Haisla Nation Chief Counsellor Ellis Ross at Bish Cove, June 19, 2013. (Robin Rowland/Northwest Coast Energy News)

Haisla Chief Counsellor Ellis Ross says that capping the logs at Clio Bay was a Haisla idea, taking advantage of the opportunity to use the marine clay from Bish Cove to bring back the Clio ecosystem.

The Haisla were told by experts who video taped the bottom of Clio Bay that are between 15,000 to 20,000 sunken logs in Clio Bay.

“I know because I’ve spent a lot of time down there plus my dad actually worked for the booming company for years and knew what was going on out there,” Ross said. “There are two extreme areas we’re talking about, if you look at Clio Bay where it’s estimated that there 15,000 to 20,000 logs down there, imagine what Minette Bay looks like? And it’s all iron, it’s steel. It’s not just wood, there are a lot of cables down there.

Retrieved cables
Cables retrieved from Ward Cove, Alaska, during dredging and capping in 2001. (EPA)

“The Haisla have known about the degradation of our territory for years. The problem we have as Haisla members is to restore the habitiat is that nobody wants to clean up the habitat. This was our idea, after review from technical experts from DFO as well as our own experts. We’re looking for a three way solution, with the company, DFO and the Crown and the Haisla.”

“I’d love to go and catch halibut and cod, like my ancestors used to.”

He said that the Haisla have beem aware of environmental problems from sunken logs for decades and have been asking for cleanup of degraded areas since 2004, not just at Clio Bay, but in the Kildala Arm and at Collins Bay, which were studied by DFO in 1997.

“The logs are down there, they are oxidizing, but no one wants to do anything about it, including the company and including the Crown. We had independent people come in and review it and have them come up with a recommendation. There was a small scale project [involving marine clay] that proved that this could work.

“This system here is killing two birds with one stone, get rid of the clay and try to remediate some of the habitat,” Ross said.

He said that the original estimate of marine clay excavated at Bish Cove was 10,000 cubic metres. That has now risen to about 3.5 million cubic metres because the KM LNG project is digging deeper for the foundation of the LNG terminal. The original plan called for disposing 1.2 million cubic metres at sea and another 1.2 million cubic metres on land.

“The original idea was to dump the clay in the middle of the ocean. In small amounts it could have been mitigated, but in large amounts we said ‘no.’ If we try to dump clay in the middle of the channel, we have no idea where it’s going to end up, what the effect is going to be.” Ross said. “We did the same thing here for the terrestrial side, we said ‘OK that with the rock quarries above Bees Creek,’ use the clay to help remediate that as well, bring it back.”

Asked about Ward Cove in Alaska, where the US Environmental Protection Agency ordered a cleanup, Ross said. “The difference here is that no one is ordering these companies to clean up the sites, they walk away. No one is taking responsiblity, The Haisla are trying to do this within the parameters they’ve given us.So if someone could come in and order these companies and do something, we’ll look for something else to do with the clay. Until that day comes, the Haisla are still stuck with trying to bring back this land by ourselves. If the District of Kitimat wants to pay the bill, great. Let’s see it.

“We need to put pressure on the province or Canada to cleanup these sites. We’ve been trying to do this for the last 30 years. We got nowhere. Before when we talked about getting those logs and cables cleaned up, it fell on deaf ears [at DFO]. They [DFO] had no policy and no authority to hold these companies accountable. So we’re stuck, we’re stuck between a rock and hard place. How do we fix it?”

Ross also noted that Shell’s LNG Canada project also faces remediation problems, “Shell is going to have the same problem, their’s is going to be different, they’re going to have get rid of contamination on the ocean bottom and beneath that it’s basically going to be gravel, it’s not clay, they’re going to have get rid of that product.”

[rps-include post=5057]

Clio Bay: Ward Cove, Alaska, benchmark for log remediation

Special report: Clio Bay cleanup: Controversial, complicated and costly

Ward Cove
Ward Cove, Alaska, in 2005, after the remediation of the bay was completed in 2001 and old industrial buildings were being demolished. (EPA)

 

Ward Cove, just eight kilometres west of Ketchikan, Alaska, was so polluted by effluent from pulp and saw mills and a fish plant, and filled with 16,000 sunken lots that it qualified for a U.S. Environmental Protection Agency Superfund cleanup.

The Ward Cove project is now considered a benchmark for cleaning up similar bays. Alaska officials emphasized to Northwest Coast Energy News, that while Ward Cove does provide guidelines for capping and dredging logs, they were not aware of any project where logs were capped that did not have other forms of contamination.

If you take a look at satellite images of Clio Bay, BC and Ward Cove side by side you immediately you see the similarities and differences between the two bodies of water. (Note due to parameters of Google Earth, images are slightly different scales)

Satellite image of Clio Bay
Google Earth image of Clio Bay
Google Earth image of Ward Cove, Alaska
Google Earth image of Ward Cove, Alaska

Both Clio Bay and Ward Cove are 1.6 kilometres long, somewhat elbow shaped, off a main channel and surrounded by mountains.Ward Cove is 0.8 kilometres wide. Clio Bay is about 0.5 kilmetres wide, 0.8 at its widest point. Both have steep slopes from the mountains. Ward Cove is 61 metres deep at the mouth of the cove, descreasing toward the head. Clio Bay is deeper, 182 metres at the mouth, 90 metres in the centre and between 20 metres and 9 metres at the head.

Both Clio Bay and Ward Cove are subject to tidal circulation. Both Clio Bay and Ward Cove are also influenced by fresh water. Ward Cove is fed by Ward Creek, a smaller Walsh Creek and runoff precipitation the enters the cover from the steep mountain slopes. Clio Bay is fed by one creek, a number of small streams and mountain slope runoff, especially during the spring melt.

Haisla Chief Counsellor Ellis Ross estimates there are between 10,000 and 20,000 sunken logs in Clio Bay. The official summary from the United States Environmental Protection Agency said there were 16,000 sunken logs in Ward Cove.

The major difference with Ward Cove is that it was the site of major industrial development including a pulp mill, a sawmill and a fish plant. That meant the level of pollutants in Ward Cove were much higher than in Clio Bay, which has never been used for an industrial plant. It was the pollutants in Ward Cove, mainly ammonia, hydrogen sulfide, and 4-methylphenol combined with the thousands of sunken logs that made the cove a target cleanup and the associated studies.

A fish plant, Wards Cove Packing opened in 1912 and ceased operations in 2002. The Ketchikan Paper Company mill began operating in 1954 and closed in 1997. Prior to 1971, with the rise of the enviromental movement no permits were required by KPC for discharging effluent into the cove. After that the US Environmental Protection Agency issued a discharge permit and monitored effluent. Throughout the time the KPC mill was operating, the EPA says, “high volumes of log storage (approximately 7 billion board feet) caused accumulation of bark waste and sunken logs at the bottom of the cove.” Gateway Forest Products, a sawmill and veneer plant, continued to store logs in Wards Cove until 2002.

A 2009 monitoring report, conducted by the US Army Corps of Engineers after the cleanup for the EPA noted:

An ecological risk assessment was also conducted using a food-web assessment to estimate risks of bioaccumulative chemicals to representative birds and mammals at the top of the Ward Cove food web. The chemicals evaluated were arsenic, cadmium, mercury, zinc, chlorinated dioxins/furans, and PAHs. The results of this assessment indicated that there are no unacceptable risks to higher trophic level organisms in Ward Cove.

A human health risk assessment was conducted to identify potential risks posed by chemicals detected in sediments or seafood (e.g., fish, shellfish). Ingestion of seafood that may contain chemicals bioaccumulated from the sediments was identified as the only complete exposure pathway for humans. The chemicals that were evaluated included: arsenic, cadmium, mercury, zinc, phenol, 4-methylphenol, chlorinated dioxins/furans, and PAHs. Results concluded that sediments in Ward Cove do not pose an unacceptable risk to human health.

A 2007 report on the Wards Cove remediation from the Alaska Department of Environmental Conservation, noted:

The continuing residues impairment in Ward Cove is caused by the historical accumulation of wood waste on the bottom of the cove. The waste includes an estimated 16,000 sunken logs over at least 75 percent of the bottom and decomposing pulp, wood, and bark waste in sediments in thicknesses up to 10 feet over at least 50 percent of the bottom. Wood waste residues can displace and smother organisms, alter habitat, release leachates, create anoxic conditions, and produce toxic substances, all of which may adversely affect organisms that live both on top of sediments and within sediments.

That is a similar problem to Clio Bay.

The report notes that problems with oxygen increase with depth, noting:

The dissolved oxygen impairment was due largely to the fish-processing waste discharge from the seafood processing facility until 2002, and it was limited to the summer months in deeper waters of the cove (below the picnocline, or stratification layer, approximately 10 meters deep). With that discharge removed, limited monitoring in August and September 2003 indicated that dissolved oxygen impairment might remain near the bottom in waters at depths of 30 meters and greater at certain times and locations due to low natural levels of dissolved oxygen and the continuing decomposition of wood waste. Above 30 meters depth, the waters of the cove appeared to meet the [Alaska state] standard for dissolved oxygen. However, there may be limited capacity for waters at 30 meters and deeper to receive additional loading of oxygen-demanding materials and still meet the standard in summer months.

That should mean that the worries about oxygen depletion at Clio Bay are justified due to Clio’s greater depth.

Studies of the biology of Ward Cove began in 1951, with more in the 1960s and one in 1974. In 1995, Ketchikan Paper Company signed a consent decree with the EPA that called for remediation of Ward Cove, In 2000, KPC and Gateway Forest Products signed a second consent decree with the EPA. Those agreements called on the companies to dredge sediments to improve navigation, remove logs and other debris from the dredging areas and “placing a thin-layer cap of 15-30 cm (six to 12 inches) of sand over about 11 hectares (27 acres) of sunken logs.”

The major studies of Ward Cove began in 1995 after first consent decree. The remediation did not take place until the initial studies were complete in 1999, with dredging and capping taking place from November 2000 to March 2001.

The EPA positioned 13 water quality monitoring stations which operated from 1997 to 2002, to measure salinity, temperature and disolved oxygen, nine inside Ward Cove and four outside the cove in Tongass Narrows. Those studies showed that levels of dissolved oxygen in the cove varied by season, depth and location. Many species from salmon to mobile bottom dwellers like crabs were often able to detect and avoid low oxygen areas.

The plan

The EPA and the companies involved planned the remediation so that it included both dredging, capping logs and sediment and leaving some areas where nature would take its course.

The reports say that complete dredging, removal and disposal of the contamination would have cost $200 million,  The total actual cost of the Ward Cove Remediation Project, beginning with development of the Remedial Design Work Plan, was estimated to have cost $3,964,000 (in 2000 US dollars).

The EPA says cost for the capping component of the project “including preliminary field investigations and reporting, design and plans development, post construction engineering, procurement, construction management, project management, mobilizationm demobilization, engineering/QC and science support, surveys, and capping items” was $2,563,506. Based on the volume of capping material placed, the unit cost of log capping for the Ward Cove Remediation Project was $110 per cubic yard.

Sunken logs retrieved at Ward Cove.
Old logs retrieved from Ward Cove, Alaska during dredging operations to improve navigation. (EPA)

The plan called for dredging about 17,050 cubic yards in the area near the cove’s main dock and the dredging of 3,500 yards metres nearby to improved navigation. Before the dredging, 680 tonnes of sunken logs had to be removed. After dredging, a “thin-layer cap of clean, sandy material” was placed in dredged areas unless native sediments or bedrock was reached during dredging.

In other areas, most covered in sunken logs, the plan called for placement of a thin-layer cap (approximately 6- to 12-inches) of clean, sandy material, with the possibility of “mounding” dropping mounds of sand on specific areas. The 2009 report says the area of sand deposits actually increased “due to the fact that thin layer placement was found to be successful over a broader area, and it was not necessary to construct mounding.”

The plan called for natural recovery in areas where neither capping nor mounding was practicable and so about 50 acres was left alone. (DFO says it plans to leave some parts of Clio Bay uncapped as “reference areas.”)
Slope and sand

Sand capping at Ward Cove
A dredging barge depositing clean sand (originally from Sechelt, BC) during capping operations at Ward Cove, Alaska in 2001. (EPA)

Two studies were carried out as part of the remediation at Ward Cove that do not appear to be contemplated at Clio Bay. The first looked at the “ability of the organic material to support the weight of 15 to 30 centimetres of sand.” Standard engineering equations used at other fill and capping sites were used as part of that study. A second study was carried out to determine the “minimum safety for a given slope,” which given the steep mountains that line Clio Bay, are likely to be factor in the deposit of marine clay. That study determined “For a silty fine sand and a factor of safety of 1.5, the maximum slope would be approximately 40 per cent.”

Those studies led to the conclusion that for the Ward Cove remediation project, the material to be placed on the fine organic sediment could not be gravel and course sand.”

That’s because the larger gravel and course sand “would tend to sink into the sediment and would not provide quality benethic (seabottom) habitat.”

The project decided to use “fine to medium sand with minimal fines.” It also concluded “Because of the very soft existing sediments and steep slopes at Ward Cove, the … material must be released slowly so that the settling velocity is low and bed impact minimized.”

That meant that the EPA had look for a source of quality sand that met their criterion. The sand was found at Construction Aggregates in Sechelt, BC, loaded on 10,000 tonne deck barges, tugged up the coast, unloaded onto land using a conveyor and stockpiled while more tests were done to determine how to deposit the sand on the sunken logs.

Sand bucket at Ward Cove
Dredging bucket modified to deposit sand during capping operations at Ward Cove, Alaska. (EPA)

Sand was placed on a smaller barge and taken to the deposit site. Initial tests were done with a mechanical dredge equipped with a clamshell bucket. The operator deposited the sand using “swaths” released from the bucket. To make it work properly, the bucket, as supplied by a manufacturer had to be modified by welding baffle plates to the bucket and lengthening the chains to insure consistent deposition of the sand. Two computers with special software called WINOPS, designed for dredging operations  “provided the operator and deck engineer the precise locations of the derrick barge position” in order to ensure precise deposition of the sand. WINOPS dredge positioning and guidance software. The WINOPS system made use of three differential global positioning receivers. One GPS receiver was located at the top of the derrick and provided the center positioning of the dredge bucket. Two fixed receivers, one near the starboard center spud and one near the center aft, provided the barge position and heading.

Although using marine clay is likely to produce different engineering challenges at Clio Bay, it is not currently clear that the project has contemplated the level of precision that was used at Ward Cove.

While KM LNG must find a way to dispose of the marine clay from the Bish Cove excavation site, there is a silver lining for the Haisla Nation’s aim of restoring both Clio Bay and the other 50 sites in their traditional territory, since the Kitimat Sand Hill would likely be a ready resource for any future projects.
Monitoring

The EPA considered the project finished in September 2001, and long term monitoring began, with major updates every five years in 2004 and 2009.

An EPA report on the 2004 review showed that the three sand-capped areas and one shallow natural recovery area (not sand-capped) had achieved biological recovery; three other natural recovery areas tested had not achieved biological recovery but were making significant progress.

The  2004 studies showed that benethic (sea bottom) communities in uncapped areas showed “species commonly found in areas where organic enrichment is low or declining.” adding “In three other natural recovery areas, benthic communities have not progressed as far toward recovery but are making significant progress.

By the time of the 2009 update, most of the old industrial infrastucture on land at Ward Cove had been demolished and the land area was slated for redevelopment. Many of the companies that had been there had either gone out of business or had declared bankruptcy and the land was taken over by the Ketchikan Gateway Borough,mostly through foreclosure.

The EPA declared that “The remedial action construction is complete, and the remedial action is an operating or ongoing remedial action.”

The 2009 report says that the project was successful in eliminating sediment toxicity. The area was then quickly being recolonized by a diverse bottom dwelling macroinvertebrate species and those species were spreading beyond the specific study areas, so recovery of Ward Cove is expected to continue.

However the 2004 report went on to say that “the achievement of stable benthic biological communities with balanced species composition in more than 75 percent of the area with documented coverage by wood residues on the bottom of Ward Cove” would happen within 40 years from the 2004 study.

The next review of Ward Cove is slated for August 2015.

 

Sand capping
Diagram of a sand capping operation from a barge. (US Army Corps of Engineers)

 

Diagram of a sediment capping operation knowing as diffusion (US Army Corps of Engineers)
Diagram of a sediment capping operation knowing as diffusion (US Army Corps of Engineers)

 

 

Termie
Diagram of a Japanese system called tremie that uses a hose system to deposit capping material on the seabed. (US Army Corps of Engineers)

[rps-include post=5057]

Clio Bay: DFO declines invitation to appear before Kitimat Council

Special report: Clio Bay cleanup: Controversial, complicated and costly

DFO logoThe Department of Fisheries and Oceans has declined an invitation from District of Kitimat Council to appear at a special meeting on Monday, September 30 to discuss the Clio Bay remediation project.  A representative of Chevron will be in the council chambers at the Kitimat branch of Northwest Community College to make a presentation and answer questions.

The letter from DFO to the council  from Dave Pehl works at DFO office in Kamloops says:

Thank you for the invitation to attend District of Kitimat Council meeting on September 30, 2013 to address plans by Chevron Canada and Apache Canada(Kitimat LNG) to remediate habitat conditions in Clio Bay. Regretfully, Fisheries and Oceans Canada (DFO) is unable to attend the scheduled council meeting.

Fisheries and Oceans Canada has reviewed a proposal to dispose of soil materials, generated at the Kitimat LNG plant, in Clio Bay, Clio Bay has been used as a log handling site for decades which has resulted in areas of degraded habitat from accumulations of woody debris materials on the sea floor. The project intends to cap impacted areas with inert materials and restore soft substrate seafloor. The remediation of the seafloor is predicted to enhance natural biodiverstiy and improve the productivity of the local fishery for Dungeness crab. The project area does support a variety of life that will be impact and therefore the project will require authorization from Fisheries and Oceans Canada for the Harmful Alteration, Disruption or Destruction (HADD) of fish and fish habitat.

Mapping of the seafloor in Clio Bay has been completed and the project plans prioritizes capping on areas of dense woody debris, followed by areas of soft substrate with woody debris distributed throughout. Mapped areas that are avoided include hard substrates and sensitive habitats such as freshwater streams and eelgrass beds. Buffers have been allocated around sensitive areas and no capping will be conducted in areas of less 10m in depth. Proposed mitigation to avoid potential impacts to areas outside Clio Bay includes avoiding deposition of material within 500m of the confluence of Clio Bay and kitimat Arm. Some areas of degraded or partially degraded habitat will not be capped to serve as reference areas.

Chevron will be required to conduct a pre-construction, construction and post construction monitoring program. Pre-construction monitoring will include collection of baseline information that will be used to assess effectiveness monitoring during and at the completion of the project. Water quality monitoring for turbidity and total suspended solids will be undertaken during construction to determine if established performance criteria are met. The monitoring plan for the project will evaluate

1. Water quality near the sea floor.
2. Fish habitat quality and quantity
3. Biodiversity of the seafloor ecosystem and
4. Distribution of a fishery resource (Dungeness crab)

Reference sites will be used to make comparison between capped and uncapped habitats. Monitoring will continue for a period of five years following the completion of the works. The proponent will be required to report the follow-up monitoring program to DFO in years 1,3 and 5 following construction.

[rps-include post=5057]