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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

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.

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.

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

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

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.”

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Clio Bay: What happens to sunken logs?

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

Logs at Clio Bay — Floating logs at Clio Bay, September 14, 2013. (Robin Rowland/Northwest Coast Energy News)

The forest industry has been operating on the Pacific coast from Oregon to Alaska for more than a century. Over that time, it is likely that millions of logs from booms and other operations have sunk to the bottom of bays, cove, estuaries and inlets along the coast.

During that century, scientists in both Canada and the United States have been studying the effects of the those sunken logs on the sea bottom. It is only in recent years that the cumulative effect of all those logs has become an environmental concern.

As well as logs on the sea bottom, ranging, depending on location, from a couple of hundred to the tens of thousands of logs, there are wood chips, wood fibre and discarded log parts and bark. Often metal cables, bolts, ropes, and other manufactured material either dropped accidentally or deliberately discarded are also found among the old logs, further contaminating the seabed. Compounding the problem of the sea bottom is organic material that would occur naturally on the seabed, including tree trunks, roots, branches, conifer needles, deciduous leaves and other material from terrestrial plants.

Anyone who sails Douglas Channel after a storm can see with all the floating tree trunks in the Channe. That means that storms and spring run off ads debris to the natural pile up of old logs and debris. At logging sites, this natural material, brought in by creeks and rivers, piles up on the already sunken logs.

Over the years, depending on the salinity, teredos, more popularly known as ship worms eat the wood, often leaving a tube of bark that eventually collapses. The rotting wood, bark and other material is often, depending on conditions, pounded into fragments by the action of waves, currents and outflow from rivers. Some species of teredo can live in brackish water, but since teredos are not a fresh water species, that means that logs in fresh or mostly fresh water last longer.

A DFO report on sunken log sites on Douglas Channel, published in 2000, noted:

very few comprehensive, quantitative field studies describing the effects of wood and bark have been published and those that did focused on log handling and storage sites which handled high volumes of more than one million cubic metres.

The DFO report said that thick bark and wood debris deposits resulting from log handling can cause substantial, long-term negative impacts to benthic (sea bottom) ecosystems. Under the worst conditions, the cumulative debris can deprive an area of oxygen and, according to DFO, “virtually eliminate aerobic” sea bottom animal life.

The report noted that studies had shown that “negative biological impacts were localized,” but added that “the cumulative effect of several hundred sites located on the B.C. coast is currently unknown.”

Studying the problem has been a low priority for DFO and other agencies and that meant a limited budget and few studies. Other problems is that, according to the DFO, parts of BC fjords are steep and “much of the likely impacted habitat is beyond diver range.” There is also pressure to study the effect on “economically or socially important species.” Although the use of remotely operated vehicles has increased since the 2000 report, using an ROV can also be a budget buster for a low priority project.

As the ready timber supply in British Columbia particularly old growth forest declined in the last part of the twentieth century, the DFO report says “forest companies have harvested areas where access is more difficult and cut-blocks are smaller.” That meant many smaller dump sites were developed that were used for only one to five years. Plans for log handling at the time, DFO said, were evolving to ensure ensure that fisheries resources and overall fish production capability were not adversely affected by development of log handling facilities and planning was focused on ensuring that sites for log handling facilities did “not have sensitive fish habitats or fisheries resources (such as eel grass beds or shellfish resources) which may be affected by the log handling,”

One of the reasons for the disagreements over Clio Bay is that while some people call it “dead” saying there are no halibut and fewer cod, others say that Clio Bay is very much alive, pointing out that it is easy to catch crab and rock cod.

The studies that have looked at life on the bottom of log dumps sites have shown that it can be highly variable even within one bay or cove, with many factors creating small local ecosystems, including depth, nature of the sea bottom, for example sand, mud, clay or a mixture, whether or not the sea bottom sediment is “enriched,” the flow of currents, fresh water flow into the site, the percentage of wood on the bottom, the percentage of bark on the bottom, whether the wood and/or bark debris is “continuous’ or “discontinuous,” whether or not the seabed is contaminated as was the case with the cleanup of pulp mill sites at Ward Cove and Sitka, Alaska.

Ward Cove had been so polluted for decades by pulp mill effluent that it was eligible for US Superfund clean up funding and was estimated to hold 16,000 sunken logs. At the same time, an EPA report on Ward Cove noted that at the point Ward Creek emptied into Ward Cove was “a popular sport fishing location during salmon season, including commercially guided fishing. Some sport fishing and personal-use crab pot fishing has taken place in the past and may continue in the waters of the cove.” At the same time of the cleanup, the EPA identified that the degradation of Ward Cove put at risk eight species of salmon, 75 “non-salmonid esturine and marine fish species and benthic invertebrate fauna.” (The EPA says Ward Cove is recovering after the reclamation and fishing is continuing)

In other words, those say Clio Bay is in danger and those who say Clio Bay is a rich source of life are likely both right.

For example, while Chris Picard’s (then with the University of Victoria, now with the Gitga’at First Nation) study of Clio Bay said: “Dungeness crabs were observed five times more often in the unimpacted Eagle Bay than in Clio Bay,” and tied that to log dumping and low oxygen.
Picard’s study noted that both Dungeness crabs and sunflower seastars, while more abundant in Eagle Bay, in Clio Bay “both species were several-fold less abundant in wood-dominated habitats in Clio Bay than in non-wood habitats in that bay.”

Several people have pointed out that since Clio Bay is one of the closest crabbing spots to both Kitimat and Kitamaat Village, while Eagle Bay is further down Douglas Channel, overfishing at Clio may be a factor in the reported species decline.

The DFO study noted

The dumping of logs into water down skids can result in the generation of a considerable amount of bark and wood debris. The abrasive action of boom boats and waves during the sorting and storage of bundles can also generate quantities of wood debris. Bark and wood lost during dumping often forms thick, continuous, anoxic fibre mats extended from the base of the dump skids. The debris mat tends to dissipate with distance from the entry point; however, wood debris can often be observed substantial.” distances from the dump skids as seen at all four of the sites sampled. Debris deposits can also be generated as logs resting on the sea floor decay. Wood boring organisms (e.g., Toredo) quickly reduce the wood fibre content of logs, but the bark of some species (e.g., western red cedar (Thuja plicata) which has a high lignin content) is left relatively untouched. The amount of wood debris generated during handling and storage can be different depending on tree species, tidal levels, and dumping methods. Debris accumulation, distribution, and the resulting biological impacts are affected by physical factors including depth, sea floor slope, dump site aspect, water currents, and wind or wave exposure.

One of the main problems with log dumping is that it has the potential to deplete vital oxygen, especially at deeper levels. Seasonal variations can mean that, even if there are thousands of logs at the bottom, the levels of dissolved oxygen can vary. Years of studies at the cleanup site at Ward Cove, Alaska showed how the oxygen levels can vary by season. In Minette Bay, near Kitimat, a DFO study showed that the Minette is somewhat stagnant and therefore has naturally occurring low oxygen levels, but also that the low levels usually last from May to November and are worst in July.

The DFO study went on to say that oxygen poor thick anoxic bark or wood fibre deposits are likely to cause damage to bottom dwelling species, although in the short term, logs may not cause any impacts. It says that some studies have indicated that large pieces of wood debris can, for a time, increase diversity by providing suitable base for some filter feeders as well as food and cover for epifauna and wood boring organisms. Several species not normally found in sand-bed have occasionally been found in log and rock debris.

(Studies have shown that salmon the ability to detect low oxygen areas and avoid them and some active invertebrate species can migrate away from a low oxygen area.)

In the long term, logs do decay and the wood and bark left behind can contribute to the wood debris accumulation. One study cited by the DFO survey of Douglas Channel found found that crabs avoided bark deposits when given a choice but when they were forced to live among bark deposits, they were had fewer offspring, had lower feeding rates, and had a decreased survivorship.

One theory is that the decaying organic material produces hydrogen sulphide in combination with ammonia and other unmeasured toxicants. One study of Dungeness crabs, living at a log dump in southeast Alaska with elevated hydrogen sulphide and ammonia concentrations in the bark debris, shows the colony had less than half as many reproducing females as a control population.

The EPA and Alaska reports from Ward Cove show that sand capping does help restore the seabed environment.
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Clio Bay: Links and Documents

Links and documents relating to sunken logs and site remediation

Note many, not all, external links are to pdf files.

Canada

DFO study of sunken log sites in Douglas Channel

DFO Study Dissolved oxygen cycle in Minette Bay

Impact of Wood debris in British Columbia estuaries

Chris Picard’s study of Clio and Eagle Bays as posted on the University of Laval website

United States

Links

Alaska Department of Environmental Conservation

Environmental Protection Agency

Ketchikan Paper Company
This is the EPA Web site on the Ward Cove cleanup and remediation with numerous documents.

EPA capping guidance
EPA contaminated sediment capping guidance

US Army Corps of Engineers

US Army Corps of Engineers capping guidance

Documents

Alaska log site remediation guide (pdf)

EPA study of dissolved oxygen in Ward Cove (pdf)

Marine Log Transfer Facilities and Wood Waste (pdf)

Academic paper by Ward Cove consultants Geramano & Associates on sediments in Ward Cove and Thorne Bay, Alaska.

Ward Cove Sediment Remediation Project Revisited

Academic paper by Ward Cove consultants Integral Consulting

Other Links

Kitimat LNG (KM LNG)

Stantec

Stantec remediation project page

Integral Consulting

Integral Consulting Ward Cove web page

Exponent

Exponent Ward Cove web page

Exponent LNG Safety web page

Germano & Associates

(Note not all documents used in this report are available online. Some sent to NWCEN are too large to upload)

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“Trust me is not good enough,” harsh BC government argument slams Enbridge, rejects Northern Gateway project

The government of British Columbia has filed a harsh assessment of Enbridge Northern Gateway in its final arguments submitted May 31 to the Joint Review Panel—much harsher than the government press release giving notice of the rejection suggests.

“‘Trust me’ is not good enough in this case,” the filing by BC government lawyer Christopher Jones says of Enbridge’s plans to handle any possible disaster from either a pipeline rupture or a tanker spill.

Some of the arguments from the province’s lawyers echo points about the Kitimat Valley raised by Douglas Channel Watch and the Haisla Nation, at one point, pointing directly to evidence from Douglas Channel Watch’s Dave Shannon.

The news release repeats Premier Christy Clark’s five conditions for the Northern Gateway and other projects, putting a positive spin on the much harsher legal argument.

“British Columbia thoroughly reviewed all of the evidence and submissions made to the panel and asked substantive questions about the project including its route, spill response capacity and financial structure to handle any incidents,” said Environment Minister Terry Lake. “Our questions were not satisfactorily answered during these hearings.”

“We have carefully considered the evidence that has been presented to the Joint Review Panel,” said Lake. “The panel must determine if it is appropriate to grant a certificate for the project as currently proposed on the basis of a promise to do more study and planning after the certificate is granted. Our government does not believe that a certificate should be granted before these important questions are answered.”

The provincial government has established, and maintains, strict conditions in order for British Columbia to consider the construction and operation of heavy-oil pipelines in the province.

Successful completion of the environmental review process. In the case of Northern Gateway, that would mean a recommendation by the National Energy Board Joint Review Panel that the project proceed;

World-leading marine oil spill response, prevention and recovery systems for B.C.’s coastline and ocean to manage and mitigate the risks and costs of heavy-oil pipelines and shipments;

World-leading practices for land oil spill prevention, response and recovery systems to manage and mitigate the risks and costs of heavy-oil pipelines;

Legal requirements regarding Aboriginal and treaty rights are addressed, and First Nations are provided with the opportunities, information and resources necessary to participate in and benefit from a heavy-oil project; and

British Columbia receives a fair share of the fiscal and economic benefits of a proposed heavy-oil project that reflect the level, degree and nature of the risk borne by the province, the environment and taxpayers.

Final argument

In its filing the province tells the JRP:

While the Joint Review Panel (“JRP”) may of course consider other factors in its recommendation, the Province submits that the JRP must accord very significant weight, in the case of this project, to the fact that NG’s plans for terrestrial and marine spill response remain preliminary and that it cannot, today, provide assurance that it will be able to respond effectively to all spills. Given the absence of a credible assurance in this regard, the Province cannot support the approval of or a positive recommendation from the JRP regarding, this project as it was presented to the JRP.

In the alternative, should the JRP recommend approval of the pipeline, the JRP must impose clear, measurable and enforceable conditions that require NG to live up to the commitments it has made in this proceeding.

Hazards from Kitimat’s geoglacial clay

The provincial government identifies a major potential hazard in the Kitimat valley, glacio-marine clay deposits that “threaten the integrity of the pipeline.”

Overall the province appears to accept the arguments from Douglas Channel Watch and other environmental groups that geo hazards along the pipeline route present a significant risk, one perhaps underestimated by Enbridge Northern Gateway.

NG does not dispute that spills from the pipeline may occur. While the project will be new, and built using modern technology, the fact remains that pipeline spills do happen. Indeed, Enbridge had 11 releases greater than 1000 barrels between 2002 and 2012…

The Province has concerns about the assertions NG has made regarding the probability for full-bore releases resulting from geohazards. NG asserts that full-bore spills will be very rare. However, this assertion must be considered in light of the fact that NG’s analysis of the geohazards that the pipeline could face is at a preliminary stage….

The rugged topography of West Central British Columbia is prone to slope failures.
Terrain instability may pose significant challenges for linear development.
Despite these challenging admits that its assessment of existing and potential geohazards along the pipeline route is not complete and that further investigations and more detailed geohazard mapping are required. For instance, although NG acknowledges that the potential presence of glacio-marine clays in the lower Kitimat Valley can threaten the integrity of a pipeline; its report on glacio-marine clay fails to identify a significant area of potential instability that had been previously reported in the relevant literature…

Since all geotechnical hazards have not been identified with the investigations carried out to date, and since comprehensive investigations will not be completed until the detailed design phase, NG has but a rough idea of the mitigation measures that may be employed in order to mitigate the geotechnical hazards that may be encountered…

Spill response

The province’s arguments also indicates that Enbridge Northern Gateway has not done a good enough job regarding spill response, whether from a full bore rupture or a pin hole leak.

it must be remembered that full-bore spills are less frequent than smaller spills, which could still have a significant environmental effect. Indeed, since risk equals consequence times probability, smaller spills could pose a higher risk as they are more frequent. While NG has produced considerable evidence with respect to the likelihood and effects of full-bore spills… the evidence concerning the potential for other spills is limited. While the Province supports assessing the effects of any spill based on a full-bore release, as it would allow for an analysis of the worst-case scenario, focus on full-bore releases should not eliminate consideration of the potential impact of smaller events…

NG stated that [a] table [in the evidence], which includes probabilities for medium sized spills, would be “replaced by. a detailed characterization of each pipeline kilometre and region as part of the ongoing risk assessment work,” but the province says, a later table that “now replaces the concept of large and medium spills”. focussed only on full-bore releases, a relatively rare event.

Similarly, NG also calculated spill return periods for pinhole and greater-than-pinhole events. Taking the figures NG for “greater-than-pinhole” releases results in a spill return figure of 76.7 years. The Province also has concerns about the information that NG has provided in this regard. First, because it focussed on spill events, there is no information about spill size, which, we submit is a critical issue in considering the risk posed by these kinds of events. Second, NG does not include the potential for spills that could occur as a result of “operating and maintenance procedures” that deviate from the norm. Finally, NG assumes that all geotechnical threats would result in a full-bore rupture. This assumption appears to be incorrect…

Premier Christy Clark has, as part of her five conditions, said there must be a world class spill response system. Enbridge responded by saying there will be. The province then turns around and says Enbridge has failed to do prove it.

Because of the potential for spills, and their impact, NG has committed to develop a comprehensive spill response capability. Indeed, NG has stated that it intends to have a “world-class response capability” for the Project. Given the real potential for spills to occur, and the devastating effect of a spill should a significant one take place, the Province submits that NG must show that it would be able to effectively respond to a spill. As set out below, the Province submits that it has failed to do so.

High stream flow, heavy snow at Kitimat

Again, the province appears to accept arguments from Douglas Channel Watch that Enbridge has underestimated the challenges of handling a spill in a remote area. The province also accepts the argument that booms are ineffective in high stream flow in the Kitimat River.

Although it asserts that it will be able to effectively respond to any spill, NG admits that responding to a spill from the pipeline will be challenging. In particular, it admits that a spill into a watercourse at a difficult to access location would present the greatest difficulty for clean-up and remediation…

Many parts of the pipeline will be located in remote areas, located some distance from road networks and population centres. For example, many of the rivers… are identified as remote or having no access. Road access to the pipeline and places where a spill might travel down a watercourse is important to allow for effective spill response…

In some cases, the steepness of the terrain will make responding to spills very challenging. NG acknowledges that the Coast Mountains’ topography is extreme…

As the JRP noted during cross examination by the Province of NG with respect to the Clore River, it has had the opportunity to take a view of the entire route. It will therefore know the steep and rugged terrain through which the pipeline would pass.

The presence of woody debris could also pose a challenge to spill response, requiring a shift of response activities to upstream locations…

If a spill were to occur during a period of high flow conditions, a common occurrence in British Columbia rivers, then some aspects of the response may have to be curtailed, or at least delayed until the high flow event recedes. At certain water velocities, booms become ineffective, and are potentially unsafe to operate.

The presence of heavy snow could also impede access during response operations, requiring use of snowmobiles, snow cats, and helicopters. In the Upper Kitimat and Hoult Creek Valleys, snow accumulation can reach 8-9 metres. However, weather may limit the ability of helicopters to aid in spill response…

Many of these challenges are recognized by NG. In the Preliminary Kitimat River Drainage Area Emergency Preparedness Report (“Kitimat Report”), NG refers to the challenges of winter conditions, avalanches and debris slides, heavy snow, spring melt, Fall freeze-up, patchy ice, and fast-flowing watercourses.

Sinking dilbit

The province also accepts the argument that under some circumstances that diluted bitumen can sink, arguments raised by David Shannon of Douglas Channel Watch.

These challenges are compounded by the fact that in certain conditions diluted bitumen (“dilbit”) can sink in a watercourse. This occurred in the case of Enbridge’s spill in Michigan. This was, as a result, an issue of significant importance to the parties in this proceeding…

The evidence presented by NG in this regard is inconsistent. For example, some evidence it presented suggests that dilbit may sink when it enters water, after a process of weathering; other evidence it has submitted suggests that dilbit will only sink if it combines with sediment. In its response to [a submission by the Haisla Nation] NG states that “If diluted bitumen becomes heavily weathered some oil may sink in fresh water environments.” Similarly, in its response to Dave Shannon’s IR No. 1, NG states that

Diluted bitumen emulsions will remain buoyant in waters with densities greater than approximately 1.015 g/cc. If the water density drops below approximately 1.015 g/cc,in zones of fresh-water intrusion, weathered and emulsified diluted bitumen products may sink to the depth where the density increases to above 1.015 g/cc.

Similar also is NG’s response to Dr. Weir’s IR No. 2.6, where NG states:

The weathered diluted bitumen would have a density approaching 1.0 g/cc, which indicates that once the diluted bitumen weathers it may be susceptible to sinking in fresh water.

Finally, in the Kitimat Report NG states that:

Examples that may lead to oil not remaining on the water surface include:
• Oils with specific gravities equal to or greater than the receiving medium (fresh- or saltwater)
• Oils that have weathered and, in losing lighter-end fractions, have reached a specific gravity equal to or greater than the receiving water
• Oil that is near the same density as the receiving water and that is characterized as a 3-dimensional flow (non-laminar to turbulent flow such as found in streams, rivers, areas with fast tidal currents, breaking waves)
• Oil with sediment (mixed into oil or adhered to oil droplets)…

…submerged oil may eventually sink with increased weathering, if in receiving water with lower density, or if sufficient sediment is incorporated.

Northern Gateway contradictory

The province’s argument goes on to point more inconsistencies with Northern Gateway’s submission on dilbit in rivers, telling the JRP “In short, what dilbit will do when it enters water remains unclear.”

On the other hand, another NG witness stated that dilbit cannot sink, as this would be contrary to an “immutable fact of physics”. In cross examination, Dr. Horn, Mr. Belore and other witnesses maintained that dilbit will only sink in the presence of suspended solids, or after a long period of weathering.

However, NG’s evidence with respect to the type of sediment that could combine with dilbit to form material that may sink in water is unclear. Dr. Horn testified that “fine grain sediments…provide the greatest amount of surface area which is one of the reasons that oil sank in [Michigan]”. On the other hand, Mr. Belore appeared to suggest that, in the marine context at least, finer sediments reduce the potential for oil to sink as they are lighter. The evidence with respect to the material that may bind to dilbit and contribute to its sinking is unclear…

NG’s views with respect to the flow conditions under which dilbit may sink is also contradictory. On the one hand, it states that “Higher flow rates and increased turbulence typically will entrain more oil into the water column leading to the potential for oil to enter pore spaces in permeable sediments.” On the other, it states that “Oil sinking is unlikely to occur in areas with fast currents…”

Evidence provided by other parties suggests that dilbit may sink when weathered. In particular, Environment Canada’s evidence in this proceeding contrasts sharply with NG’s. For example, Environment Canada states that:

Northern Gateway’s response planning model does not account for sinking oil or for oil suspended particulate matter interactions…For oils with densities close to that of water, like both the diluted bitumen and synthetic crude products, even small amounts of sediment can cause sinking. Environment Canada is concerned that oil sinking and oil-sediment interactions have been
underestimated in the provided scenarios. In the cases of both the Enbridge-Kalamazoo and the Kinder Morgan-Burnaby spills, significant oil-sediment interactions occurred.

The changes to dilbit as it ages in the environment may affect cleanup. Although initially buoyant in water, with exposure to wind and sun, as well as by mixing with water and sediment in the water, the density of dilbit can increase to the point that the oil may sink. Recovery and mitigation options for sunken oils are limited.

Not only has Environment Canada expressed the view that even small amounts of sediment may cause oil to sink, its witness also stated under cross-examination that high velocity rivers may carry high suspended sediment concentrations, and that, at certain times of the year, sediment load could enter the marine environment. Although NG acknowledges that sediment loads and oil-sediment interactions are a critical factor in predicting the behaviour of spilled oil, it has not, in Environment Canada’s opinion, provided a complete baseline data set on sediment loads, despite requests that such data be provided.

While NG has submitted information respecting the laboratory testing of dilbit, an Environment Canada expert testified that tests conducted in a laboratory setting provide only limited information that cannot be relied upon in isolation to predict the fate and behaviour of hydrocarbons spilled into the environment. Instead, information gathered from real spill events must inform the analysis, and consideration must be given to the conditions, including water temperature, suspended sediment concentrations and wind speed, to be encountered in the “real world”.

Environment Canada has also made it very clear that the evidence provided to date by NG does not allow for a full understanding of the behaviour of spilled dilbit. In the opinion of Environment Canada witnesses, the evidence has not provided sufficientclarity with respect to the weathering, evaporation or sedimentation processes dilbit may be subjected to in the environment. Given the unique nature of this product, further research is warranted before one can ascertain whether dilbit will sink or remain on the water surface. Those concerns were echoed by an expert retained by the Gitxaala Nation.

In addition, the evidence of other parties raises the possibility of the need to respond to submerged oil. NUKA research, on behalf of the Haisla Nation, opined that “submission documents overall still grossly underestimate the potential for sunken or submerged oil, particularly for pipeline spills to rivers.” EnviroEmerg Consulting, for the Living Oceans Society summarizes well the uncertainty that remains with respect to the behaviour of oil:

There are no definitive statements in the [Environmental Impact Statement] EIS to explain if bitumen diluted with condensate will emulsify, sink or do both if spilled. The supporting technical data analysis in the EIS is based on laboratory tests. There are no in-situ field tests, empirical studies, nor real incidents to validate these findings. This raises significant uncertainty that current spill response technologies and equipment designed for conventional oil can track and recover the diluted bitumen in temperate marine waters. In essence, the assumption that the diluted bitumen can be recovered on-water has yet to be tested.

In short, what dilbit will do when it enters water remains unclear. NG recognizes this lack of clarity itself. As was stated by one of its witnesses, “it’s extremely difficult to predict the behaviour of this product”.

NG admits that additional research needs to be done with respect to understanding how dilbit behaviour.

The provincial argument concludes:

The Province has serious concerns about the lack of clarity and certainty about what dilbit will do if it were to enter the water, the preliminary and indeed contradictory nature of the evidence with respect to NG’s remediation strategies and actions to address sunken oil, and the fact that its proposed tactics have not been evaluated for use in British Columbia. These factors, taken together, suggest that, at least as of today, NG is not yet prepared to deal with sunken oil in the event there were a spill of dilbit into a British Columbia watercourse. By itself this is a cause for serious concern in relation to the fundamental question in this proceeding, namely whether the JRP should recommend approval of this project. But at the very least, this means that a strong condition must be imposed requiring further research on the behaviour of dilbit.

Spill response only preliminary “All roads are driveable”

The provincial argument says, in italics, that the Northern Gateway’s spill response plans are “only preliminary” and adds Northern Gateway’s plan to provide detail operational plans six months before the beginning of the pipeline operations is not good enough. “It is not possible for NG to assert, nor for the JRP to conclude, that NG will be able to access all those places where a spill may travel, and to respond effectively.”

Despite the challenges to responding to a spill from the pipeline, including the challenge of responding to submerged and sunken oil, NG’s plans for responding to a spill have not yet been developed. NG has committed only to providing its detailed oil spill response plans to the National Energy Board 6 months in advance of operations. In the context of this project, the Province remains very concerned that NG has not yet demonstrated its ability to respond effectively to spills from the pipeline.

When specifically asked “In the absence of that planning…to address the challenges that we’ve been discussing, how is it we are to be confident that Northern Gateway will, in fact, be able to effectively respond to a spill?” NG replied that “There is a lot of work that needs to be done.”

Of particular concern, despite its admission that a spill into a watercourse in a remote location would pose a significant challenge, NG has not yet determined those locations it could access to respond to a spill, including the control points utilized for capturing and recovering oil passing that location. Such access will only be determined, if possible, during detailed planning. At this time, NG also does not know what portion of water bodies would be boat-accessible in the event of a spill. The 2010 Michigan spill, which was the subject of much questioning during the hearing, occurred in a populated area, where there were many potential access locations. This will of course not be the case if a spill were to occur in a remote river in British Columbia.

While NG has prepared a document showing some possible control points that might be used for spill response in the event of a spill in some rivers, NG concedes that its work in this regard is preliminary, and only pertains to some of the control points that would ultimately have to be established. NG helpfully provided additional information to that which was originally filed with respect to the travel distance between pump stations or the terminal and certain potential control points. However, travel times to the control points that have been identified do not take into account mobilization time, and assumes all roads are drivable.

Given the incompleteness of NG’s evidence in this regard, the Province submits that NG cannot currently assert that there would in fact be viable control points where a spill could travel to. In addition, even if accessibility to control points had been fully validated, in order for NG to assert that it could respond effectively to a spill, it would also have to know the means by which personnel and equipment would gain access to respond to oil that had come ashore or sunken to the sediment. Given the preliminary nature of the evidence presented by NG, this is of course not known.

The Province is very concerned that, in the event of a spill, some places where a spill could reach will be inaccessible, and therefore not amenable to spill recovery actions. While NG states that it will be able to access control points at any location along the pipeline, it has simply not provided the evidence in this proceeding to substantiate this assertion. The Province submits that, as of today, it is not possible for NG to assert, nor for the JRP to conclude, that NG will be able to access all those places where a spill may travel, and to respond effectively.

In addition to access, there are a number of other challenges to operating in British
Columbia in respect of which NG has completed only very preliminary work.

• The pipeline could be covered by heavy snow at different times of the year; NG states that it will have to review alternative methods of access to deal with this, but has presented no specific evidence on how this challenge will be addressed.
• NG has not yet developed specific plans about how it would deal with oil recovered from a spill, and has not yet determined disposal locations.
• NG has not yet determined the location or the contents of the equipment caches to be used to respond to spills.
• It has not determined year-round access to the pipeline, which will be evaluated as part of detailed planning.

Kitimat River response

The province takes a harsh look at Northern Gateway’s plan for a response on the Upper Kitimat River and Hunter Creek.

Similarly, the Province is concerned about the ability of NG to respond to a spill in the Upper Kitimat Valley. When asked by the Douglas Channel Watch

“…in the context of the Upper Kitimat Valley, does this mean because of the steepness of the terrain and limited road access to the river, that containment at some locations at the source will be impossible, and the majority of your efforts will be at the first accessible locations downstream?”

NG was only able to reply that:

“again it depends on the specific conditions. But as Dr. Taylor indicated, in the development of the response plans we would need to look at various scenarios, various times of year, develop plans so that it would identify the appropriate response locations at those times.”

NG’s targeted spill response time of 6-12 hours needs to be set against the reality that, in the case of a watercourse spill, oil may travel many kilometres downstream while NG is still mobilizing. In this proceeding NG has provided considerable information with respect to how far and fast oil can travel in a watercourse. For example, with a spill into Hunter Creek, NG has stated:

Based on water velocities, a release at this location could reach the Kitimat River estuary 60 km downstream within four to ten hours, depending on river discharge.

Dr. Horn has indicated that these figures are very conservative, and that the actual times to reach Kitimat would be a longer period. However, no other definitive evidence on these times was presented by NG.

Enbridge doesn’t learn from its mistakes

The provincial argument then goes on to say, again in italics, Enbridge does not follow procedures or learn from mistakes and concludes “while NG asserts that its spill detection systems will be world-class, it has not yet chosen to adopt spill detection technologies that would achieve that objective.”

The provincial argument goes over Enbridge’s spill record in detail, including the Marshall, Michigan spill which was harshly criticized by the US National Transportation Safety Board.

Concerns about NG’s inability to respond to a spill are magnified by Enbridge’s conduct with respect to the spill which took place in Michigan. NG concedes that, in that case, there were procedures in place that were not followed. NG asserts that it now has in place a number of “golden rules”, including that whenever there is a doubt with respect to whether the spill detection system has detected a leak, the pipeline must be shut down. However, NG concedes that this rule was in place before the Michigan spill; it self-evidently was not followed. In fact, the rule under which Enbridge would shut down its pipeline system within 10 minutes of an abnormal occurrence which could be immediately analyzed was put into place following a spill in 1991. At that time, similar commitments were made indicating that procedures would change and that a spill of that nature wouldn’t take place again….

despite the fact that the relevant technologies had been in existence for some
10 years, and despite the existence of crack-related failures that led to the development of such technologies, Enbridge had failed to put in place a program that would have detected the Marshall spill

The province wraps up the response saying by telling the JRP:

In short, if NG is relying on its ability to respond effectively to a spill for a positive recommendation from the JRP, then it must show that it will in fact have that ability. The Province submits that NG has not shown that ability in this proceeding.

The Province submits that requiring NG to show now that it will in fact have the ability to respond effectively to a spill is particularly important because there will be no subsequent public process in which that ability can be probed and tested. NG has pointed out that its oil spill response plans will be provided to the NEB for review, and has committed to a third party audit of its plans. However, it also acknowledges that there will be no means by which those plans could be tested through a public process.

On the pipeline project, BC concludes

The Province submits that the evidence on the record does not support NG’s contention that it will have a world-class spill response capability in place. The challenges posed by the pipeline route, the nature of the product being shipped, the conceptual nature of its plans to date and Enbridge’s track record mean that the Province is not able to support the project’s approval at this time. The Province submits that its concerns in this regard should be seriously considered by the JRP as it considers the recommendation it will be making to the federal government.

SFU study says spill hazards for Kitimat from tankers and pipelines much greater than Enbridge estimate

A study by two scholars at Simon Fraser University says that the Enbridge Northern Gateway project is much more hazardous to Kitimat harbour, Douglas Channel and the BC Coast than Enbridge has told the Joint Review Panel.

The study by Dr. Thomas Gunton, director of the School of Resource and Environmental Management at SFU and Phd student Sean Broadbent, released Thursday May 2, 2013 says there are major methodological flaws in the way Enbridge has analyzed the risk of a potential oil spill from the bitumen and condensate tankers that would be loaded (bitumen) or unloaded (condensate) at the proposed terminal at Kitimat.

Enbridge Northern Gateway responded a few hours after the release of the SFU study with a statement of its own attacking the methedology used by the two SFU scholars and also calling into question their motivation since Gunton has worked for Coastal First Nations on their concerns about the tanker traffic.

Combination of events

One crucial factor stands out from the Gunton and Broadbent study (and one which should be confirmed by independent analysis). The two say that Enbridge, in its risk and safety studies for the Northern Gateway project and the associated tanker traffic, consistently failed to consider the possibility of a combination of circumstances that could lead to either a minor or a major incident.

Up until now, critics of the Northern Gateway project have often acknowledged that Enbridge’s risk analysis is robust but has consistently failed to take into consideration the possibilty of human error.

As most accidents and disasters happen not due to one technical event, or a single human error, the SFU finding that Enbridge hasn’t taken into consideration a series of cascading events is a signficant criticism.

Overall the SFU study says there could be a tanker spill every 10 years, not once in 250 years, as calculated by Enbridge.

It also says there could be 776 oil and condensate spills from pipelines over 50 years, not 25 spills over 50 years as projected by Enbridge. (And the life of the project is estimated at just 30 years, raising the question of why the 50 year figure was chosen)

Enbridge track record

The study also bases its analysis of the possibility of a spill not on Enbridge’s estimates before the Joint Review Panel but on the company’s actual track record of pipeline spllls and incidents and concludes that there could be between one and 16 spills (not necessarily major) each year along the Northern Gateway pipeline.

Findings for Kitimat

Among the key findings for Kitimat from the SFU study are:

Enbridge said the possibility of tanker spill was 11.3 to 47.5 per cent over the 30 year life of project. The SFU study says the possibility of a spill within the 30 years is 99.9 per cent.
The SFU study says it is likely there will be a small spill at the Kitimat Enbridge terminal every two years.
The SFU study estimates that there will be eight tanker transits each week on Douglas Channel if the Northern Gateway project goes ahead and more if it is expanded. (This, of course, does not include LNG tankers or regular traffic of bulk carriers and tankers for Rio Tinto Alcan)
The SFU study says that while Endridge did study maneuverability of tankers, it paid little attention to stopping distance required for AfraMax, SuezMax tankers and Very Large Crude Carriers.
The SFU study says Enbridge inflated effectiveness of the proposed tethered tugs and maintains the company did not study ports and operations that use tethered tugs now to see how effective tethering is.
The SFU says Enbridge’s risk analysis covered just 233 nautical miles of the British Columbia coast, where as it should have covered entire tanker route both to Asia and California, raising the possibility of a tanker disaster outside British Columbia that would be tied to the Kitimat operation.
Based on data on tanker traffic in Valdez, Alaska, from 1978 to 2008, the SFU study estimates probability of a 1,000 barrel spill in Douglas Channel at 98.1 per cent and a 10,000 barrel spill at 74.2 per cent over 30 year Gateway life. The Valdez figures account for introduction of double hulls after Exxon Valdez spill in 1989 and notes that spill frequency is much lower since the introduction of double hulled tankers.
According to a study by Worley Parsons for Enbridge in 2012, the Kitimat River is the most likely area affected by an unconstrained rupture due to geohazards in the region. According to the Worley Parsons study, geohazards represent the most significant threat to the Northern Gateway pipeline system.

Flawed studies

The SFU scholars list a series of what they say are major methological or analytic flaws in the information that Enbridge has presented to the Joint Review Panel, concluding that “Enbridge significantly understates the risk of of spills from the Northern Gatway.

Enbridge’s spill risk analysis contains 28 major deficiencies. As a result of these deficiencies, Enbridge underestimates the risk of the ENGP by a significant margin.
Some of the key deficiencies include:

Failure to present the probabilities of spills over the operating life of the ENGP

Failure to evaluate spill risks outside the narrowly defined BC study area

Reliance on LRFP data that significantly underreport tanker incidents by between 38 and 96%.

Failure to include the expansion capacity shipment volumes in the analysis

Failure to provide confidence ranges of the estimates

Failure to provide adequate sensitivity analysis

Failure to justify the impact of proposed mitigation measures on spill likelihood

Potential double counting of mitigation measures

Failure to provide an overall estimate of spill likelihood for the entire ENGP

Failure to disclose information and data supporting key assumptions that were used to reduce spill risk estimates

Failure to use other well accepted risk models such as the US OSRA model

SFU reports that Enbridge provides separate estimates of the likelihood of spills for each of the three major components of the project:

tanker operations,
terminal operations,
the oil and condensate pipelines.

The SFU scholars say Enbridge does not combine the separate estimates to provide an overall estimate of the probability of spills for the entire project and therefore does not provide sufficient information to determine the likelihood of adverse environmental effects……

It notes that “forecasting spill risk is challenging due to the many variables impacting risk and the uncertainties in forecasting future developments affecting risk. To improve the accuracy of risk assessment, international best practices have been developed.”

Part of the problem for Enbridge may be that when the company appeared before the Joint Review Panel it has repeatedly said that will complete studies long after approval (if the project is approved), leaving large gaps in any risk analysis.

The SFU study may have one example of this when it says Enbridge did not complete any sensitivity analysis for condensate spills at Kitimat Terminal or the condensate pipeline.

Enbridge response

Enbridge responded by saying

Our experts have identified a number of omissions, flawed assumptions and modeling errors in the study and have serious concerns with its conclusions:
The spill probability numbers are inflated: The author uses oil throughput volumes that are nearly 40 per cent higher than those applied for in this project which also inflates the number of tanker transits using these inflated volumes
The pipeline failure frequency methodology adopted by Mr. Gunton is flawed, and does not approximate what would be deemed a best practices approach to the scientific risk analysis of a modern pipeline system
Mr. Gunton based his failure frequency analysis on a small subset of historical failure incident data. Why would he limit the source of his data to two pipelines with incidents not reflective of the industry experience and not reflective of the new technology proposed for Northern Gateway?
The study results are not borne out by real world tanker spill statistics. Based on Mr. Gunton’s estimates we should expect 21 to 77 large tanker spills every year worldwide while in reality after 2000 it has been below 3 per year and in 2012 there were zero.

Most of Enbridge’s rebuttal is a personal attack on Gunton, noting

We are very concerned about the misleading report released by Mr. Gunton, who was a witness for the Coastal First Nations organization during the Northern Gateway Joint Review Panel process.
Mr. Gunton should have made his study available to the JRP process, the most thorough review of a pipeline that’s ever taken place in Canada. All of Northern Gateway’s conclusions have been subject to peer review, information requests and questioning by intervenors and the Joint Review Panel.

In response, Gunton told the Globe and Mail “the report took over a year to complete and it was not ready in time to be submitted as evidence before the federal Joint Review Panel which is now examining the proposed pipeline.”

Enbridge’s statement also ignores the fact under the arcane rules of evidence, any study such as the one from Simon Fraser had to be submitted to the JRP early in the process, while evidence was still being submitted.

The recent ruling by the JRP for closing arguments also precludes anyone using material that was not entered into evidence during the actual hearings.

That means that the SFU study will be ignored in the final round of the Joint Review Panel, which can only increase the disillusionment and distrust of the process that is already common throughout northwest British Columbia.

Avian malaria found in Alaskan birds, another indication of climate change

A form of malaria that infects birds has been found in parts of Alaska, and scientists say the discovery is another indication of climate change in the north.

The spread could prove devastating to arctic bird species that have never encountered the disease and thus have no resistance to it, said San Francisco State University Associate Professor of Biology Ravinder Sehgal, one of the study’s co-authors. The study was published Wednesday, Sept. 19, 2012 in the journal PloS One.

The avian malaria parasite is related to the human form and so the bird study could help scientists track how climate change is affecting human malaria.

Researchers examined blood samples from both resident and migratory birds collected at four sites from 61°N to 67°N, with Anchorage as a southern point, Denali and Fairbanks as middle points. Coldfoot was the northern point, roughly 960 kilometres north of Anchorage. They found infected birds in Anchorage and Fairbanks as far north as 64°N, but not in Coldfoot

In migratory birds, samples were taken from both adults and hatchlings to see if the infection had occurred locally or during migration.

The study notes that the infected birds at 64°N were above the Arctic Circle commonly known to people across the region as “north of 60”)

Using satellite imagery and other data, researchers were able to predict how environments will change due to global warming — and where malaria parasites will be able to survive in the future. They found that by 2080, the disease will have spread north to Coldfoot and beyond.

“Right now, there’s no avian malaria above latitude 64 degrees, but in the future, with global warming, that will certainly change,” Sehgal said. The northerly spread is alarming, he added, because there are species in the North American arctic that have never been exposed to the disease and may be highly susceptible to it.

“For example, penguins in zoos die when they get malaria, because far southern birds have not been exposed to malaria and thus have not developed any resistance to it,” he said. “There are birds in the north, such as snowy owls or gyrfalcons, that could experience the same thing.”

Researchers are still unsure how the disease is being spread in Alaska and are currently collecting additional data to determine which mosquito species are transmitting the Plasmodium parasites that cause malaria.

The data may also indicate if and how malaria in humans will spread northward.

Modern medicine makes it difficult to track the natural spread of the disease, Sehgal said, but monitoring birds may provide clues as to how global climate change may effect the spread of human malaria.

The study is the fact that the malaria parasites were able to complete their transmission cycle in the North American Arctic” provides “empirical evidence that local hosts in the north of Alaska may be exposed to new parasites with impending global warming,” especially if there is increased variation of both day/night and season temperature changes. Rainfall is also a factor.

Both Anchorage and Fairbanks are likely to have suitable conditions for the avian malaria parasite “completion, other areas with high annual precipitation but mild precipitation and temperature seasonality would be predicted to also be suitable” for the parasite.

One form of the avian malaria parasite has been previously in four bird species: the Common Rosefinch (Carpodacus erythrinus) in South Korea, the Greater Scaup (Aythya marila), the Pacific Golden Plover (Pluvialis fulva) and the Common Yellowthroat (Geothlypis trichas) in the United States, and in six migratory species, meaning that form can tolerate cold temperatures.

The book Birds of British Columbia says the Greater Scaup is a common migrant on the BC coast and may winter in BC, and an abundant migrant in the BC interior in both spring and fall, and often winters in the Okanagan. The Pacific Golden Plover is rare in BC, because its migration route takes it toward the east coast. It is usually spotted in the Peace River region but has been seen occasionally near Massett and Boundary Bay. The Common Yellowthroat can be found through the BC mainland in the summer but is rare on Vancouver Island and Haida Gwaii.

A study in New Brunswick has shown that one form of mosquito that tolerates cold infects birds in that province. Although that mosquito is “rare” in Alaska, a close relative is common in the state and although the scientists were unable to find the source of the infection, that Alaskan mosquito could be a prime suspect.

Geological Survey of Canada identifies tsunami hazard, possible fault line on Douglas Channel

Fault zone map Douglas Chanel — A map from the Geological Survey of Canada showing the line of a possible seismic fault on Douglas Channel (Geological Survey of Canada)

Updates with statement from Natural Resources Canada, new filings by Enbridge Northern Gateway and the Attorney General of Canada (in box below)

The Geological Survey of Canada has identified a tsunami hazard and a possible seismic fault in Douglas Channel near Kitimat. A scientific paper by the Geological Survey and the Department of Fisheries and Oceans says there were once two giant landslides on Douglas Channel that triggered major tsunamis and that the landslides were possibly caused by an earthquake on the fault line.

Kitimat is the proposed site of the Enbridge Northern Gateway project and at least three liquified natural gas projects.

If the projects go ahead, hundreds of supertankers with either bitumen or LNG will be sailing in the channel for years to come.

A filing by the Attorney General of Canada with the Northern Gateway Joint Review Panel is asking the JRP for leave to file late written evidence long after the original deadline of December 2011. The Attorney General’s motion was filed on August 17, but went unnoticed until the Kitimat environmental group Douglas Channel Watch brought the matter up with District of Kitimat Council tonight (Sept. 17).

Appended to the Attorney General’s motion is a copy of a scientific paper from the Geological Survey “Submarine slope failures and tsunami hazards in coast British Columbia: Douglas Channel and Kitimat Arm” by Kim W Conway, J.V. Barrie of the Geological Survey and Richard E. Thomson of the Department of Fisheries and Oceans.

The report says the scientists discovered “evidence of large submarine slope failures in southern Douglas Channel.”

It goes on to say: “The failures comprise blocks of bedrock and related materials that appear to have been detached directly from the near shore off Hawkesbury Island.” Hawkesbury Island and many of the other islands in Douglas Channel are built up with material left over from the ice age glaciers and thus are vulnerable to displacement and landslides.

The research identified two slides, one estimated at 32 million cubic metres and a second of 31 million cubic metres. The report goes on to say that the discovery of an “apparently active fault presents the possibility that they may have been triggered by ground motion or surface rupture of the fault during past earthquake events.”

The slope failure landslides are covered with thick layers of mud, and that, the scientists say, could mean that the failures could be ancient, possibly occurring 5.000 to 10,000 years ago. Further research is needed to confirm the date of the giant slides.

What is worrying about the discovery is that fact that there were two recent submarine slope failures on the Kitimat Arm of Douglas Channel. both creating tsunamis. The first slope failure occurred on October 17, 1974, triggering a 2.4 metre tsunami at low tide. Then on April 27, 1975 there was a second slope failure near low tide on the northeast slope of the Kitimat Arm that generated an 8.2 metre tsunami. The 1975 tsunami destroyed the Northland Navigation dock near Kitimat and damaged the Haisla First Nation docks at Kitamaat Village.

The paper says that “Additional geological research is required to better delineate the age of the submarine failures, their triggers, and their mechanisms of emplacement.”

Urgent new research is underway and the filing by the Attorney General says when the Department of Justice requested leave to file late evidence says it anticipates that the further research by DFO is expected to be completed by November 1. The Natural Resources Canada Earth Sciences Sector began a national assessment of submarine slope failures in Canada in late 2011 and completion of the Pacific portion of this assessment is targeted for December of 2012.

The Attorney General’s filing says that DFO is now modelling “potential wave heights and speeds that may have resulted from the two previously unrecognized submarine slope failures in the Douglas Channel.” The model will use high resolution scans of the Douglas Channel seafloor to create the models.

The survey of Douglas Channel in 2010 suggests the possible existence of a fault immediately to the south of the second ancient slide on Hawkesbury Island.

The GSC paper says that evidence for a continuous fault was observed by aligned stream beds and fractures on the south end of Hawkesbury Island, about four kilometers from the site of the second ancient slide. The possible fault then appears to terminate far to the south near Aristazabal Island on the Inside Passage. The Geological Survey says that eleven small earthquakes, all less than magnitude three, have appeared with 20 kilometres of the suspected fault over the past 25 years.

The paper says that the scientists conclude that the slides appear to have left very steep slopes at or near the shoreline that could be susceptible to future failure events.

A large potential slope failure has been identified near one of the ancient slides….

in the absence of additional evidence, the fault must be considered a potential trigger for the submarine failure events….the triggers for the failures have not been defined; however, their proximity to a potentially active fault represents one potential source. The failures probably generated tsunamis during emplacement and conditions exist for similar failures and associated tsunamis to occur along this segment of Douglas Channel in the future.

The scientists say that detailed tsunami modelling is underway to

provide an improved understanding of the generation, propagation, attenuation, and likely coastal inundation of tsunami waves that would have been created by slides… or that could be generated from similar future events. Only through the development and application of this type of tsunami modelling will it be possible to gauge the level of hazard posed by the identified submarine slope failures to shore installations and infrastructure, or to devise ways to effectively mitigate the impacts of future such events.

The filing by the Attorney General offers to bring the scientists to the Joint Review Panel to appear as witnesses sometime during the final hearings.

The filing notes that the current evidence tendered to the JRP by Enbridge, and other parties does demonstrate the potential for marine geohazards and associated tsunami events. Enbridge’s design of the proposed Northern Gateway marine terminal and its operational plans took into consideration the current state of knowledge of geohazards including earthquakes and tsunamis at the time of filing. Enbridge has said it would undertake further geological survey during the detailed design phase for the terminal.

At the time Natural Resources Canada noted that the information provided for the Environmental Review was sufficient at that time, now the Attorney General says:

the geographic scope for potential landslide induced tsunami hazards is now better understood to extend beyond the Kitimat Arm. NRCan and DFO seek by this motion to ensure that this Panel, and the Parties before the Panel, have the most up to date information on geohazards in the Douglas Channel.

Updates: DFO report in October will clarify the tsunamis in Douglas Channel.

Statement from Natural Resources Canada

Natural Resources Canada sent this statement to Northwest Coast Energy News on September 20, 2012.

In reference to the opening paragraph of your September 18th editorial entitled Geological Survey of Canada identifies tsunami hazard: Possible fault line on Douglas Channel, we would like to clarify the following. Although the ancient large submarine slope failures which our scientists have identified may have caused tsunamis, this is not a certainty. It is important to note that Fisheries and Oceans Canada is currently studying this information to model potential wave heights and speeds.

As our report states, only through the development and application of this type of tsunami modelling will it be possible to gauge the level of hazard posed by the identified submarine slope failures to shore installations and infrastructure, or to devise ways to effectively mitigate the impacts of future such events.

Northern Gateway response filed on August 31, 2012

Enbridge Northern Gateway filed this response to the Attorney General’s motion on August 31.

This motion of the Federal Government Participants requests permission to file late evidence consisting of a report entitled “Submarine Slope Failures and
Tsunami Hazard in Coastal British Columbia: Douglas Channel and Kitimat Arm” regarding tsunami hazard and additional modelling work based on that report.

Northern Gateway does not object to the filing of this late intervenor evidence.
It may be relevant and Northern Gateway accepts that theevidence could not be filed earlier. However, Northern Gateway would like the opportunity to conductits own additional modelling work which it would be prepared to provide to DFO for comment prior to the filing of any modelling work by DFO in this proceeding.

Attorney General response to Enbridge on September 10, 2012.

The Attorney General of Canada responded to Enbridge by saying:

Attorney General responds DFo is prepared to await filing its subseqent modelling work in these proceedings until such time as it has received, reviewed and commented upon additional modelling work as proposed by NGP Inc.

DFO nots howeverand wishes to alert the JRP that the NGP INc proposed may occasion a delay in the filing of the DFO moedling work which is now proposed for filing on or about October 31, 2012. Delivery of DFO comments as requested will depend on when DFO received the NGP Inc modelling work, the time and resources required by DFO to study and provide comments on the NGP modelling work and unforeseen factors which may have an impact upon completion the commentary. As such,

DFO is prepared to file its modeling work on or about October 31, 2012, but subject to any further direction or request by the panel.

Map of Douglas Channel — Geological Survey of Canada map of Douglas Channel showing the area surveyed which discovered the landslides and possible fault line. (Geological Survey of Canada)

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Map of slides at Kitimat — Map from the Geological Survey of Canada showing the landslides on the Kitimat Arm which triggered tsunamis in 1974 and 1975 (Geological Survey of Canada)

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Slide at Hawkesbury Island — Map from the Geological Survey of Canada showing the giant slide on the southern tip of Hawkesbury Island. (Geological Survey of Canada)

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Hawkesbury Island slide map — Map from the Geological Survey of Canada showing the second giant slide on the coast of Hawkesbury Island on Douglas Channel (Geological Survey of Canada)

Department_of_Justice Notice of Motion of the Attorney General of Canada Seeking to Tender Supplementary Written Evidence (pdf)

Submarine Slope Failures and Tsunami Hazard in Coastal British Columbia Douglas Channel and Kitimat Arm PDF

New US report slams Enbridge for spill record, as scientific investigation opens into diluted bitumen

A new US report is slamming Enbridge for its record on oil spills, just as the BC government set out strict new conditions for building pipelines and tanker traffic in the province.

The United States National Wildlife Association issued a report today called Importing Disaster, The Anatomy of Once and Future Oil Spills. (pdf of report at the bottom of this page)

At the same time, the US Academy of Sciences has opened a new investigation into diluted bitumen.

A letter critical of Enbridge, previously overlooked by the US media is getting new traction, as the anniversary of the Marshall, Michigan, Kalamazoo River spill approaches on July 25.

Enbridge, so far, has not responded to the National Wildlife Federation report.

The environmental group opens the report by saying:

As the biggest transporter of Canadian tarsands oil into the U.S., Enbridge has aresponsibility to the American public to manage their operations in a manner that protects our comm unities and natural resources. But tarsands oil is a very different beast than conventional crude oil, and it is difficult to transport the former safely through pipelines that were designed for the latter. That’s because tarsands oil is more corrosive(due to its chemical mixture)and abrasive(due to high-gritminerals), weakening the pipes to the point that they are more susceptible t oleaks and ruptures. Remarkably, there are no standards in place to ensure that new pipelines are built, maintained and operated with this fact in mind.

The National Wildlife Association goes on to say:

fossil fuel companies have a ‘stranglehold’ on our political establishment, preventing even modest initiatives that could make our energy safer and cleaner. That lobby strategy keeps in place a system that’s led to 804 spills by Enbridge alone in the last decade, and a total of 6,781,950 gallons of oil spilled in the U.S. and Canada.

“Rather than focus on safety and cleanup, Enbridge is recklessly moving ahead with plans to expand their pipeline network in the Great Lakes region and the Northeast, and to double down on high carbon fuel that is proving nearly impossible to clean from Michigan’s waters,” said Beth Wallace, NWF’s Great Lakes outreach advisor.

NWF’s report recommends comprehensive reforms to break the cycle of spills and pollution that continue to threaten communities and speed global warming. Among them, the report calls for stronger safety standards that account for increased dangers associated with heavy tar sands oil, increasing investment in clean energy and efficiency, and campaign and lobbying reforms that would put impacted citizens on a level playing field with Big Oil in the halls of Congress.

The NWF report then says:

The Kalamazoo spill may have been a poster child for corporate negligence but it is far from the company’s only black mark. According to Enbridge’s own reports, between 1999 and 2010, they have been responsible for at least 800 spills that have released close to seven million gallons of heavy crude oil into the environment — or approximately half the amount of oil that spilled from the Exxon Valdez in 1989.

Canada has seen its own share of Enbridge heartache, including a 61,000 gallon spill earlier this summer near Elk Point, Alberta.

The National Wildlife Federation report is calling for stronger pipeline safety standards that account for the dangers of transporting bitumen sands oil from Canada amd wants more rigorous reviews of all pipeline projects. The report calls bitumen sands oil “the planet’s dirtiest oil.”

US media covering the National Wildlife release and looking to the anniversary of the Kalamazoo disaster, are now quoting an overlooked letter from the US advocacy group Public Citizen issued on June 25.

Concerned about Keystone XL pipeline, the advocacy group sent a letter to the Texas House of Representatives, recommending that the state should not wait for US federal rules to prevent tar sands pipeline spills. Public Citizen called the industry’s track record “troubled” and asked the committee to take up legislation that would give Texas broader authority over pipelines.

The committee will examine state regulations governing oil and gas well construction and integrity, as well as pipeline safety and construction, to determine what changes should be made to ensure that the regulations adequately protect the public. Public Citizen will testify in support of stronger rules for the Seaway pipeline (an existing line repurposed to carry tar sands instead of crude oil), the Keystone pipeline (whose southern leg is not yet built) and proposed future tar sands pipelines.

“These companies keep calling it petroleum, but it’s not – these are pipelines of poison,” said Tom “Smitty” Smith, director of Public Citizen’s Texas office.

The media reports on the NWF release are pointing to a new investigation by the US National Academy of Sciences on the safety of diluted bitmenl safety in the United States, that will be part of a report to the US Congress

An ad hoc committee will analyze whether transportation of diluted bitumen (dilbit) by transmission pipeline has an increased risk of release compared with pipeline transportation of other liquid petroleum products. Should the committee determine that increased risk exists, it will complete a comprehensive review of federal hazardous liquid pipeline facility regulations to determine whether they are sufficient to mitigate the increased risk.

On June 25, the committee added three industry experts to the panel as there is growing scrutiny over dilbit in the US, which could become an issue in the presidential race.

NWF Enbridge Oil Spill (PDF)

Tiny amounts of copper in rivers endanger salmon by affecting sense of smell

Tiny amounts of copper in a river affect a salmon’s sense of smell, making it harder to avoid predators, according to a study at Washington State University.

Jenifer McIntyre says the copper means that a salmon can’t detect another compound that ordinarily alerts them to be still and wary.

The minute amounts of copper can come from mines and even the brake linings of cars.

“A copper-exposed fish is not getting the information it needs to make good decisions,” says McIntyre, a postdoctoral research associate in WSU’s Puyallup Research and Extension Center, whose study built on earlier work that showed that copper can affect a salmon’s sense of smell and thus changing its behavour.

McIntyre put the two together, exposing juvenile coho salmon to varying amounts of copper and placing them in tanks with cutthroat trout, a common predator.

Healthy salmon can smell compounds in the water that are released when another fish is damaged. That substance, called Schreckstoff, German meaning “scary stuff,” alerts fish to nearby predators.

In her experiments, conducted in a four-foot-diameter tank, fish that weren’t exposed to copper would freeze in the presence of Schreckstoff, making it harder for motion-sensitive predators to detect them. On average, half a minute would go by before they were attacked.

But salmon in water with just five parts of copper per billion failed to detect the Schreckstoff and kept swimming. They were attacked in about five seconds.

“It’s very simply and obviously because predators can see them more easily,” says McIntyre. “They’re not in lockdown mode.”

The unwary exposed fish were also more likely to be killed in the attack, being captured 30 percent of the time on the first strike. Unexposed fish managed to escape the first strike nearly nine times out of ten, most likely because they were already wary and poised to take evasive action.

McIntyre also noticed that the behavior of predators was the same whether or not they had been exposed to copper.

Copper finds its way into streams and marine waters from a variety of sources, including motor vehicle brake linings, pesticides, building materials and protective boat coatings. Actual amounts will vary from undetectable in rural or forested areas to elevated in urban areas, especially when runoff from a storm washes roads of accumulated brake dust and other contaminants.

With testimony from McIntyre’s NOAA colleagues and others, the Washington State legislature in 2010 started phasing out copper brake pads and linings over the next 15 to 20 years. According to the state Department of Ecology, brake pads are the source of up to half the copper in the state’s urban waterways.

McIntyre used concentrations of between 5 and 20 parts per billion but has sampled highway runoff with 60 times as much copper. Copper’s effect is mediated by organic matter, which can make the metal unavailable to living things.

“My scenarios are potentially more like a hard-rock copper mining situation than storm water runoff, which typically carries dissolved organic matter along with the copper and other contaminants,” McIntyre says.

A number of large copper mining projects are proposed for the northwest region including, the controversial Taseko’s Prosperity copper mine near Williams Lake which was stopped after the local First Nations and environmental groups opposed the use of one lake for a tailings pond. Taseko is now trying to revive the project. There area also a number of copper mine proposals for the both the northwest BC coast and the Sacred Headwaters region, source of the major salmon rivers, the Skeena, Nass and Stikine. There is also a proposed copper mine Pebble Mine, at Bristol Bay, Alaska, another prime area for sockeye salmon.

Environmental impact of the Canadian copper mine projects are likely to be affected by the provisions of Bill C-38 which speed up environmental assessment and essentially gut habitat protection for fisheries.

Her research, conducted for a University of Washington doctorate with colleagues at UW and the National Oceanic and Atmospheric Administration, appears in the latest issue of the journal Ecological Applications.