Arctic Standards Recommendations on Oil Spill Prevention, Response, and Safety in the U.S

A report from Sept 2013 Arctic Standards Recommendations on Oil Spill Prevention, Response, and Safety in the U.S. Arctic Ocean Contents 1 Overview What are Arctic standards? 3 Principles to guide Arctic policy and management decisions 3 Ensure that local communities have a meaningful voice in decision-making 4 Safeguard ecosystem health and a subsistence way of life 4 Require that science guide decision-making 5 6 The Arctic Ocean Challenging conditions 6 Sea ice 8 Freezing temperatures 8 Wind and waves 8 Fog and seasonal daylight 8 Oil spill response gap 9 Limited infrastructure 9 11 Oil and gas leasing and exploration on the U.S. Arctic OCS 12 Arctic oil spill prevention recommendations summary 13 Arctic seasonal drilling limits 16 Arctic drilling design and operation standards Performance standards for Arctic OCS drilling rigs 16 Arctic OCS BOP standards 17 Arctic well cementing practices 18 20 Arctic facilities design and operation Arctic OCS production facility and transportation performance standards 20 Arctic OCS pipeline performance standards 21 Arctic OCS tank performance standards 23 25 Arctic vessel and logistical support 28 Arctic pollution prevention operating standards Arctic OCS Critical Operations Curtailment Procedures 28 Arctic OCS exploration and production expertise, experience, capacity, competencies, and qualifications 29 Arctic air pollution prevention controls 29 Arctic pollution prevention: Zero discharge of drilling muds, drill cuttings, produced water, and sanitary and other industrial wastes 30 31 Arctic oil spill response recommendations summary 32 Arctic standards for oil spill response planning Arctic oil spill trajectory analyses and mapping standards 32 Arctic oil spill recovery calculations and minimum equipment requirements 33 35 Arctic well blowout source control Arctic well capping and containment system performance standards 35 Arctic relief well rig performance standards 36 Arctic emergency well control plans 36 Arctic well control expert contracts 37 38 Arctic oil spill response equipment and personnel Polar Class support vessel requirements for responding to an Arctic oil spill 38 Arctic mechanical response equipment and training standards 38 Arctic oil spill removal organization standards 39 Arctic oil recovery storage standards 39 41 Arctic oil spill response equipment testing and verification Arctic offshore field tests to verify spill response tactics and strategies prior to operation 41 Protection of Arctic resources of special economic, cultural, or environmental importance 41 43 Public participation and transparency in Arctic drilling plans and operations Public and joint agency review process for Arctic oil spill response plans 43 Public access to Arctic exploration and production facility inspections and audits 44 45 Endnotes 49 Appendix I 103 Appendix II Acknowledgments The Pew Charitable Trusts wishes to thank the many people who helped make this report possible: Pew’s U.S. Arctic program staff who helped write and develop the report and recommendations: Raychelle Daniel, Stephen Ganey, Marilyn Heiman, Eleanor Huffines, Ellie Humphries, Henry Huntington, Larissa Nipper, and Melissa Prior-Parks. Pew colleagues who helped with editing, graphics, design, and communications: Dan Benderly, Ryan Chauvin, Ned Drummond, Mary Engel, Kymberly Escobar, Sara Flood, Justin Kenney, Edward Paisley, Andrew Qualls, Jerry Tyson, Liz Visser, and Brennen Wysong. And for providing technical support and advice: Susan Harvey, Harvey Consulting LLC. External reviewers Stephen K. Lewis, S2Lewis Technical LLC Roy M. Robertson, Project manager/preparedness monitor, Prince William Sound Regional Citizens’ Advisory Council Mr. Lewis and Mr. Robertson were asked to review the draft because of their diverse perspectives and technical expertise. The purpose of this independent review was to provide candid and critical comments on the analysis and reasoning contained in the report so as to assist The Pew Charitable Trusts in making it as sound as possible. Although the reviewers provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations. For more information about Pew’s Arctic work, please see www.pewenvironment/arctic. 1 Cover photos: 2 3 4 1. U.S. Fish and Wildlife Service 2. Rich Reid/National Geographic Creative 3 and 4. Kate Stafford Overview The search for oil is reaching into ever more remote corners of the world, including the U.S. Arctic Ocean. Diminishing sea ice is opening Arctic waters to increased industrial activities such as shipping and oil and gas development. Yet industrial development in these waters brings a new set of challenges and a larger set of risks than in other oceans because, in the Arctic, people and machinery will be working in some of the most remote and harshest conditions on the planet. The Arctic Ocean is ice-covered for eight to nine months of the year, with almost complete darkness for nearly three of those months. Even during the summer when the ice pack has mostly receded, the Arctic still experiences high seas, wind, freezing temperatures, dense fog, and floating ice hazards. Anyone doing business in the Arctic needs to be prepared for self-rescue. Inadequate infrastructure and punishing weather could seriously delay the arrival of additional vessels, equipment, people, or other help. Major highways, airports, and ports that most Americans take for granted do not exist in the Arctic. The nearest U.S. Coast Guard air base is in Kodiak, AK, more than 950 air miles away. The nearest major port is in Dutch Harbor, AK, which is over 1,000 miles from the Arctic Ocean. Sailing from Dutch Harbor to Barrow, AK (the point between the Chukchi and Beaufort seas in the Arctic Ocean), would be similar to transiting the entire West Coast of the United States. Oil spilled in Arctic waters would be particularly difficult to remove. Current technology has not been proved to effectively clean up oil when mixed with ice or when trapped under ice. An oil spill would have a profoundly adverse impact on the rich and complex ecosystem found nowhere else in the United States. The Arctic Ocean is home to bowhead, beluga, and gray whales; walruses; polar bears; and other magnificent marine mammals, as well as millions of migratory birds. A healthy ocean is important for these species and integral to the continuation of hunting and fishing traditions practiced by Alaska Native communities for thousands of years. The Outer Continental Shelf, or OCS, of the U.S. Arctic Ocean, which includes the Chukchi and Beaufort seas off the northern and northwestern coast of Alaska and extends from 3 to 200 nautical miles offshore, contains oil and gas resources managed by the U.S. Department of the Interior. (State and local governments manage offshore resources from the shoreline to 3 nautical miles offshore. This report does not address oil and gas exploration, development, or production in onshore areas of the Arctic or the nearshore state waters.) Within the OCS, the Interior Department is responsible for: • Developing and implementing an oil and gas leasing program. • Completing environmental impact statements and environmental assessments on proposed oil and gas projects. • Approving and providing oversight of exploration, development, and production plans for oil and gas projects. In short, the Interior Department is obligated to examine the potential environmental impact of its leasing program, ensure approved plans are executed safely and in the best interest of the United States, and balance the benefits and risks of oil and gas development. (See Figure 1, a flow chart showing the basic exploration, development, and production process.) A majority of the OCS offshore oil and gas exploration, development, and production in the United States takes place in the Gulf of Mexico. As a result, most of the drilling and extraction technology is developed for and tested in temperate waters. In the wake of the 2010 Deepwater Horizon blowout in the Gulf of Mexico, however, the United States and 1 Figure 11 The Offshore Oil and Gas Exploration, Development, and Production Process The flow chart shows a simplified view of the process, with each step requiring a set of additional permits and approvals Development Facility and Oil and/or Exploration Exploration Delineation and Production Pipeline Gas to Plan Drilling Drilling Production Well Drilling Installation Market Plan Source: U.S. Department of the Interior © 2013 The Pew Charitable Trusts other Arctic countries such as Canada and Greenland examined whether regulatory standards for Arctic oil and gas exploration, development, and production were sufficient to prevent a similar disaster and whether there was capability to respond to a major oil spill in ice-infested waters. The United States chartered a committee, the Ocean Energy Safety Advisory Committee, to examine U.S. regulations for OCS oil and gas operations and to make recommendations. In August 2012, the committee concluded that there is a need to modernize U.S. regulations to include Arctic-specific standards to prevent oil spills, contain them, and respond to them quickly and effectively.2 On March 14, 2013, Secretary of the Interior Ken Salazar released a formal review of Shell’s 2012 Alaska offshore oil and gas exploration program.3 The Interior Department’s findings reinforce the importance of taking a regionally specific approach to offshore oil and gas exploration in the Arctic. The report concluded that the federal government

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