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CH HAPTER 5 Strateg for Re gies esponse an Mitigat nd tion PRE-SP PILL STRA ATEGIES FOR OIL AN GAS EX F ND XPLORATI ION AND P PRODUCTI ION Essentially al pre-spill st E ll trategies, wh hether in the Arctic or els sewhere, emmphasize preventio as the key oil spill–related activity Preventio n is based on understand on y y. n ding the scie ence and techn nologies assoociated with oil explorat h tion and prod duction and applying tha understan at nding to the speecific enviro onment in wh any acti hich ivity is takin place (US ng SGAO, 2012 with the g 2), goal of manag ging risk throoughout an operation. With a high le o W evel of knowwledge, many potentially y y high-risk activities ca be anticip k an pated and ma be mitigat For exa ay ated. ample, when oil wells aree properly designed for the range of anticipated risk, establ r o d lished proceedures are fo ollowed, equipmen is properly inspected and maintain and trai nt y ned, ining is prov vided, well c control event are ts likely to be managed more safely (ExxonMo d y obil, 2013). WWhen accide occur, th causes an ents he nd outcomes can be analyzed so tha new inform s at mation can b incorporat in future plans. be ted In general, a tiered respon system (Figure 5.1) r n t nse represents th standard w he worldwide approach to evaluatin risks and resource nee (e.g., Ex h ng eds xxonMobil, 2 2013). Tier 1 is exempliffied by a sma oil spill th can be ha all hat andled quick at the loca level. If w kly al weather, such as high win h nds or seas, becomes a fa b actor, this co ould be eleva to a Tier 2 response, and rapid r ated r response andd control may not be possible for a variety of reasons, inclu m r uding conce for respo erns onders’ safetty. As previo ously mentio oned in Chap 4, region resource could also be limited i Arctic pter nal es o in locations In the case of a large sp a Tier 3 classificatio could occ quite rap s. e pill, on cur pidly to makee sure that needed reso ources are pu into play as quickly as possible. T potential for resource ut a s The e limitation in a specific region— instance, the Arctic— identifie in conting ns —for —is ed gency plans. Figure 5.1 Example of a tiered respons system. Sour ExxonMob 2013. 1 se rce: bil, The oil and gas companie that work in the Arctic belong to t major Ti 3 oil spill T es c the ier l removal organization (OSROs), as well as more regiona focused OSROs that have signif ns , m ally t ficant cold-regi response capability and experien A comm strategy of Arctic an temperate spill ion e a nce. mon nd e response involves ma aking sure th all possib counterm hat ble measure tools are availab for use as s ble s condition permit (e.g., Owens Coastal Cons ns C sultants, 199 8; Dickins a Buist, 19 and 999; Brekne et al., 2004; ADEC, 2010b). 127 PREPUB BLICATION C OPY

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128 Responding to Oil Spills in the U.S. Arctic Marine Environment Scenario 5 Break in Subsea Pipeline from Nearshore Production A break in a subsea pipeline at locations such as North Star, Oooguruk, or Nikaitchuq would lead to oil spilling into the nearshore environment and possibly moving out into the offshore region. An alternative scenario is a chronic, long-term-duration pipeline leak below detectable limits. Main Considerations The failure of a pipeline could potentially lead to a large-scale oil spill, with the possibility of oil spilled in the nearshore to move offshore or onshore. However, there could also be only limited oil spill release due to automatic valve closures. There may be long-term human and ecosystem risks posed by chronic low-level leaks. Standard Response Responsible party assumes leadership role for cleanup; Unified Command is activated. Response Needs Environmental benchmark and monitoring data, a multiuse Arctic observing network, high-resolution aerial mapping, and adequate training and exercises for local responders working with the Unified Command and pipeline personnel, possibly over winter or in adverse weather are needed. Industry Activities Post–Deepwater Horizon In addition to ongoing development and review of specific oil spill prevention and response plans in support of exploration operations, a number of response-related activities took place immediately following the Deepwater Horizon oil spill. Industry task forces were created to review options associated with containing oil spills at their source, especially subsea releases. While the focus has been on the Gulf of Mexico, well containment technologies could be used in other exploration areas including the Arctic (USGAO, 2012). The U.S.-based Joint Industry Task Force80 (JITF) created task forces to examine offshore operating procedures, offshore equipment, subsea well control and containment, and spill preparedness and response.81 The International Association of Oil & Gas Producers created a Global Industry Response Group82 (GIRG) to ensure that the lessons learned from recent wellhead blowouts and other accidents are applied around the world. The Subsea Well Response Project83 was organized around four tasks: designing a subsea well-capping toolbox, designing hardware for subsea dispersant injection, assessing the need for and feasibility of a containment system suitable for international use, and evaluating potential approaches for equipment deployment. Each group made recommendations, mostly focused on well containment and intervention; oil collection, processing, and storage; and relief wells. Several multiyear projects have been initiated in efforts such as good practice guides for spill response, research programs to enhance spill response options, and outreach activities to assist decision makers, communities, 80 Members of the JITF include the American Petroleum Institute, International Association of Drilling Contractors, Independent Petroleum Association of America, National Ocean Industries Association, and United States Oil and Gas Association. 81 See http://www.spillprevention.org/jitf-overview.html, accessed October 24.2013. 82 See http://www.ogp.org.uk/publications/management-committee/capping-and-containment-global-industry- response-group-recommendations-japanese-translation/. 83 See http://subseawellresponse.com/. PREPUBLICATION COPY

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Strategies for Response and Mitigation 129 and researchers to better understand oil spill prevention, preparedness, and response (API, 2012). GIRG’s recommendations centered around prevention as a way to achieve the most effective outcomes.84 In addition to these industry-wide efforts, there has been a focus on creating new technologies for well containment and spill response. Several organizations can provide access to significant response tools as well as knowledge and skills to build capacity. The members of the Marine Well Containment Company85 have drilled approximately 70% of the U.S. Gulf of Mexico deepwater wells from 2007 to 2009. Helix Well Containment Group86 is a consortium of 24 operators that represent approximately 80% of the deepwater operators in the Gulf of Mexico. It was created around the well containment capabilities used in the Deepwater Horizon response. The Subsea Well Intervention Service87 has an integrated intervention system which includes well capping and dispersant equipment that can be deployed internationally in the event of a subsea well control incident. The United Kingdom–based Oil Spill Prevention and Response Advisory Group88focuses on technical issues, including first response for protection of personnel, oil spill response capability and remediation, and regulations and response mechanisms. They have a well-capping device that enhances the United Kingdom's capability to respond to a major oil spill. Independent oil companies also have capping stacks that can be designed for specific areas of deployment—for example, extreme cold and ice for Arctic environments—or may be transportable to other areas by vessel or large aircraft. While the ability to transport equipment by air enhances response capabilities outside of the Gulf of Mexico, it may not be very feasible. The capping stacks would have to be disassembled (because they are so large), loaded on multiple aircraft, reassembled on the other end, and tested to ensure integrity. Transport by vessel may be more likely, since there are multiple capping stack locations around the world. In general, these organizations have significant experience with deepwater drilling operations and response needs. RESPONSE STRATEGIES FOR IMPACTED WILDLIFE In the event of an oil spill, wildlife, including birds and marine mammals, could be impacted. Impacts could be due to contact with oil or disturbance from spill response activities. Annex G of the Unified Plan guides any responses to wildlife that are threatened or impacted by a spill event in Alaska (ADEC, 2002a). Wildlife response strategies are categorized as primary, secondary, and tertiary. The primary strategy is to control oil release and spread at the source through mechanical containment and recovery, protective booming, in situ burning and/or dispersants. The secondary strategy is to deter wildlife from entering the oiled areas through techniques such as passive visual methods and active auditory methods (e.g., propane cannons, bird-scare buoys). Preemptive capture and moving of unoiled wildlife is included in the secondary strategy. Only trained and authorized personnel are allowed to conduct active deterrence and capture activities. The tertiary strategy is to capture and rehabilitate oiled wildlife 84 See http://www.ogp.org.uk/downloads/GirgBrochure.pdf. 85 See http://marinewellcontainment.com/. 86 See http://www.hwcg.org/. 87 See http://www.oilspillresponse.com/services-landing/well-incident-intervention/subsea-well-response-project. 88 See http://www.oilandgasuk.co.uk/knowledgecentre/OSPRAG.cfm. PREPUBLICATION COPY

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130 Responding to Oil Spills in the U.S. Arctic Marine Environment for possible release back to the environment. Rehabilitation and release of wildlife will likely be a key component of oil spill response in the Arctic. Those types of activities are complicated in the Arctic because of logistical issues, the likely remoteness of a spill, the use of many wildlife species for subsistence purposes by local communities, and the size and type of wildlife that might need to be responded to, such as polar bears and walruses. There are also legal issues that would need to be considered for some species, such as adherence to the Marine Mammal Protection Act or the Endangered Species Act. For many species, federal agencies co-manage with Alaska partners. Rehabilitation and release of wildlife in the event of a spill would need to be accomplished in close association with subsistence hunters and marine mammal co-management organizations, such as the Ice Seal Committee. The Ice Seal Committee has requested that sick or injured ice seals not be rehabilitated and released because of concerns about possibly introducing diseases into the wild population, but it is not clear what the policy would be in the event of a spill. Historically, Annex G has not utilized traditional knowledge in its response plans; National Oceanic and Atmospheric Administration (NOAA) and other agencies are attempting to include this in the future (presentation by Brad Smith, NOAA, March 2013). Response methods for birds affected by an oil spill are generally well established (e.g., USFWS, 2003), and deterrent techniques, equipment, and trained personnel are readily available. Alaska Clean Seas owns and maintains a mobile Bird Capture and Stabilization Center and contracts with International Bird Rescue89 for personnel support. International Bird Rescue also owns a rehabilitation facility in Anchorage. The U.S. Fish and Wildlife Services (USFWS) is currently updating its 1999 Oil Spill Response Plan for Polar Bears in Alaska (USFWS, 1999; USFWS and USDOI, 2013), which will provide more specific information and guidance for polar bear response. USFWS has been attempting to improve coordination between response partners and has been studying how to best clean oiled polar bear fur (USFWS and USDOI, 2013). Equipment for oiled polar bear response is maintained by Alaska Clean Seas and supplemented by USFWS equipment. However, there is a minimal amount of equipment, with capacity to respond to up to five oiled bears. NOAA’s National Marine Fisheries Service (NMFS) is finalizing revisions to its Marine Mammal Oil Spill Response Guidelines, last revised in 2006.90 After completion of the revised national guidelines, regional guidelines will be developed, with Alaska as one of the first to be addressed. Deterrence methods for marine mammals have been considered for use during spill drills in Alaska, including air guns or other noisemaking devices. However, no techniques have been tested or are formally approved at this time. This may be of greatest concern for whales and walruses, because there are no approved deterrence methods. There is, however, literature on bowhead whales’ avoidance of seismic air guns and other sounds. NOAA faces a number of issues regarding deterrence and rehabilitation of wildlife—a lack of scientific study and developed protocols regarding hazing of marine mammals, working within the existing legal framework, and a lack of consensus with native co-managers. There are presently no facilities in Alaska with capacity to receive and rehabilitate any significant numbers of marine mammals (presentation from Brad Smith, NOAA, March 2013). Over the past few years Alaska Clean Seas has sponsored an informal North Slope Marine Mammal Response Working Group consisting of the resource agencies (NMFS, 89 See http://www.bird-rescue.org/about/our-bird-rescue-centers/alaska-wildlife-response-center.aspx; accessed November 11, 2013. 90 See http://www.nmfs.noaa.gov/pr/pdfs/health/eis_appendixl.pdf. PREPUBLICATION COPY

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Strategies for Response and Mitigation 131 USFWS, Alaska Fish and Game), Alaska Zoo, Alaska SeaLife Center, and member company representatives to develop procedures and identify needs for marine mammal response on the north slope of Alaska. Working relationships and procedures are improving, but additional resources are needed to increase capabilities. The Alaska SeaLife Center has developed protocols for the care of oil-affected phocid seals and has reviewed equipment on hand for polar bear response and determined the additional equipment necessary for seal response. They have also designed, constructed, and tested a Mobile Treatment and Rehabilitation Enclosure for seals for Alaska Clean Seas. One positive aspect of response activities in the Arctic is that, unlike other regions, many of the Arctic animals do not need much water for stabilization. Fish totes can be used for most initial activities and a facility with large holding tanks is not necessary. Planning for marine mammal response in northern Alaska is under way but still in its infancy, with significant logistical challenges. Space, water, power, and personnel support facilities are in short supply, although small portable capabilities are under consideration. Alaska has an extensive stranding network which could assist during a spill event, but trained and authorized live animal capture and handling personnel are in short supply. The Alaska SeaLife Center holds the only NOAA/NMFS permit in Alaska to respond to marine mammal and bird strandings. Support for wildlife response (e.g., boats, personnel, and facilities) is not well defined in contingency plans. Expectations for marine mammal response could be better defined—for example, how to respond to large marine mammals, which are difficult to approach unless they are incapacitated; tactics if an oil spill impacts a haulout; and the consequences of attempting to deter or move an animal versus no response. It does not appear that recent oil spills such as the Deepwater Horizon have led to new or different methods of deterrence. RESPONSE STRATEGIES FOR COASTAL ENVIRONMENTS A primary goal of a spill response is to keep oil off the coast, in order to minimize impacts to sensitive habitats. The basic oil spill response strategies used in temperate regions are generally applicable to Arctic marine and shoreline environments. Specific differences are likely to relate to the remoteness of Arctic environments and an expectation of challenging working conditions (API, 2012). As a result, Arctic operations require an understanding of specific response techniques (e.g., mechanical recovery, dispersants, in situ burning), potential limitations associated with each technique, and knowledge of what works with conditions at sea, in ice, or on coastlines during different seasons (Polaris Applied Science, 2009). General shoreline cleanup approaches include physical removal, in situ techniques, and natural processes (Sergy et al., 2003; Prince et al., 2003a). Additionally, possible interaction between sediments in the shore zone and the oil need to be considered. While there is likely to be little tidal mixing energy, wave action in the surf zone could lead to significant oil-sediment interaction (Owens et al., 2003). Oiled sediments can be treated in different manners, including in situ treatment through dry or wet mixing as well as sediment relocation. The goal in these cases is to increase the exposure of oiled sediments to weathering processes, in order to accelerate natural degradation. In the cases where oil refloats during exposure to wave action or other energetic processes, it can be contained and collected (Polaris Applied Science, 2009). As with most oil spill responses, the Net Environmental Benefit Analysis (NEBA) process (described in the next section) is one approach to assess potential countermeasures, whether they are active (e.g., in situ burning, mechanical cleanup) or passive (monitoring of natural PREPUBLICATION COPY

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132 Responding to Oil Spills in the U.S. Arctic Marine Environment attenuation processes). It also helps to determine whether additional environmental damage could be caused as a result of specific response actions. In remote locations like the Arctic, where physical access may not be practical, using a biodegradation response may provide for less physical damage than would be incurred by the use of manual removal techniques. An additional consideration is avoiding the possibility of placing responders in hazardous situations to perform beach cleanup. The Arctic’s remote locations, limited infrastructure availability, and few possibilities for the transport and disposal of oiled waste require response techniques that minimize waste generation. Preferable techniques are in situ and natural attenuation processes, which lead to lower waste generation for shore zone operations. In the case of on-water treatment options, the use of oil/water separators could minimize oily water waste. Onboard incineration of collected oil and oily waste could provide another opportunity to reduce the volumes of contaminated material. New techniques that reduce waste, such as herding agents that allow for in situ burning without the use of fire-resistant boom, may also be of high value for Arctic spills (Buist et al., 2011). NEBA APPROACH Regardless of the response method or methods used, there will be some environment impacts due to an oil spill. Numerous factors must be considered for the selection of oil spill response procedures for use in contingency plans and emergency response operations. These factors include the probability of an oil spill, the possible volume and type of crude oil or refined product that might be spilled, environmental factors influencing the fate and behavior of the hydrocarbons that could be released, the sensitivity of the most valued ecosystem components (VECs) to oil pollution, the potential impacts from the application of oil spill countermeasures (e.g., dispersants, in situ burning), and the time needed for habitat recovery. The NEBA process became increasingly prominent following the Exxon Valdez oil spill. It provides decision makers a strategy for deciding what response options are appropriate at a specific spill location based on the analysis of environmental tradeoffs that may occur from the use of the various oil spill countermeasures available (Baker, 1995). From an ecological point of view, NEBA provides a protocol for weighing the advantages and disadvantages of various spill responses with regard to flora and fauna and their habitats within the specific area of concern, compared with no response (known as natural attenuation). A generic NEBA framework is outlined in the International Petroleum Industry Environmental Conservation Association publication “Choosing Spill Response Options to Minimize Damage: Net Environmental Benefit Analysis” (IPIECA, 2000). In addition to providing information for the selection of the best cleanup methods, the NEBA process also provides an assessment of long-term effects on an ecosystem, guidance on the intensity level and operational end points for cleanup operations, and estimates of likely recovery rates ( Potter et al., 2012; IMO, 2013). A decision process such as NEBA can be used to determine which countermeasures might be best to reduce detrimental effects to an already contaminated environment. PREPUBLICATION COPY

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Strategies for Response and Mitigation 133 Identifying and Protecting Valued Ecosystem Components The optimal spill response technique is defined as the one that will minimize a spill's adverse impact on the habitat of the region and its biological resources. Case studies have conclusively shown that the application of aggressive cleanup operations may delay the rates of habitat recovery by causing additional damage beyond the oil spill itself (Baker, 1995). For example, in the aftermath of the Exxon Valdez incident, excavation and washing of rocks to remove surface and subsurface oil was shown not to offer a net environmental benefit because the procedures altered shore structure and delayed biological recovery (NOAA, 1990). In the event of a large oil spill, a single spill response strategy is unlikely to provide optimal protection for all environmental resources as more than one environmental compartment (i.e., water surface, water column, sediments, and shoreline) would likely be impacted. In fact, a response strategy that provides protection for one environmental resource (e.g., chemical dispersion of oil slicks to protect seabirds) may increase risks to another (e.g., toxicity of dispersed oil in the water column). Decision makers select the optimal response strategy based on the protection of priority environmental resources and the countermeasures which offer them the greatest protection. NEBA incorporates prioritization criteria for the protection of VECs that could be impacted by oiling, cleanup operations, or residual oil. These rare and valuable species of aquatic plants and animals have scientific, social, cultural, economic, historical, archaeological or aesthetic importance, determined on the basis of cultural ideals or scientific concern (Forbes, 2011). VECs identified for the Chukchi and Beaufort Seas include higher-trophic-level species such as polar bears, whales, and seals; prey species such as capelin and sculpin; and activities such as seal hunts (Lee et al., 2011b). The analysis will also consider seasonal variations of these valued ecosystem components (e.g., breeding grounds, migration routes) and the time frame of the restoration of items which may be impacted. Using NEBA in the Selection of Oil Spill Countermeasures There are several response countermeasures available for oil spill response on open water and in ice (physical recovery, dispersant applications, in situ burning, and monitoring natural recovery), as well as on shorelines (e.g., manual oil collection, flushing, cleaning agents, pressure washing, and bioremediation). There are clear differences in operational limits for each oil spill response strategy—advantages for some techniques can include speed, efficiency, or ease of use, while disadvantages can include burn residue or leftover oil due to low encounter rates. The value of a particular method will depend on the situation, including weather conditions, organisms and ecosystems that are impacted, the availability of response support, and the type of oil spilled. A NEBA process needs to include all identified factors in order to select the best response strategy. Planning a NEBA Strategy for the Arctic Concerns about accidental releases of oil have risen with the expansion of frontier oil and gas and marine shipping industries within the Arctic Circle (AMAP, 2010). To date, there has not been a large oil spill within Arctic marine waters. Small spills have been primarily associated with fishing activities (AMAP, 2010), although larger spills have occurred in ice-covered PREPUBLICATION COPY

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134 Responding to Oil Spills in the U.S. Arctic Marine Environment subarctic waters such as the Gulf of Finland (Runner 4) and the Gulf of St. Lawrence (Kurdistan, Arrow). However, with the expected increase in exploration and production operations in deeper offshore waters, and due to the Deepwater Horizon oil spill, there are major concerns over the possibility of a subsurface blowout under or in ice and the industry’s and government’s ability to respond. Scenario 6 A Well Blowout   An exploratory well in the offshore Chukchi Sea suffers a major blowout late in the drilling season. The shallow well was being drilled in about 45 meters of water within a targeted oil zone approximately 100 km from the coast of Alaska. As the blowout continues, the well releases nearly 60,000 bbls/day. The responsible party has abided by all necessary laws and regulations. This represents a low-probability, high-impact event that has potentially large environmental consequences due to the volume of oil released Main Considerations Issues include weather, visibility, ice impacts on response and rescue efforts, potential for needed personnel rescue/recovery and oil spill response, potential for a large volume of oil released, shoreline contamination in remote areas, and oil in ice with cleanup extending over the winter months. Other considerations include the logistics of reaching the well, rescuing personnel, and limiting spill impacts. Oil behavior and its effects are dependent on the season, and response strategies will need to be tailored to meteorological-ocean-ice conditions over a long-term cleanup period. Standard Response Responsible party assumes leadership role for cleanup, Unified Command is activated, and efforts are made to make responsible party’s response resources immediately available. Response Needs Knowledge of long-term behavior of oil in ice, on ice, and under ice; decision tools and processes for rapid and effective response to large-scale, remote, and logistically challenging Spills of National Significance; preposition of spill response equipment; resources to cover sociological and environmental damages and for long-term shoreline contamination cleanup; and training and exercises for local response personnel working with the Unified Command personnel, possibly over winter are needed. A decision process such as NEBA is likely to be an integral part of future contingency plans, because post-spill decisions are best and most quickly made in light of pre-spill analyses, consultations, and agreements involving all of the appropriate organizations and parties. Use of NEBA in contingency planning offers several advantages—extended time frame for analysis, consideration of spill scenarios covering a wide range of environmental factors (e.g., seasonal changes in species diversity and ice cover), time for identification and collection of scientific data, and stakeholder involvement. NEBA can cover a range of oil spill scenarios from small accidental releases associated with routine operations to the “worst case” in terms of oil volume, sensitive species, and environmental factors. Other important considerations include the logistical constraints that are likely to be encountered during Arctic oil spill response operations, which will influence the efficacy of current countermeasure strategies. For an Arctic NEBA, the process needs to include not only regulators, resource managers, health authorities, technical specialists in oil spill response technologies, and the scientific community, but also regional representatives to ensure that local and traditional knowledge is incorporated. PREPUBLICATION COPY

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Strategies for Response and Mitigation 135 Scenario 7 Structural Failure of an Oil Storage Tank   A land-based diesel oil storage tank suffers structural failure in a winter storm. The oil overruns the berm and flows over the ice and into the offshore environment. Main Considerations Response on land, nearshore, and offshore may require different teams, expertise, and coordination (particularly in the offshore area) to account for offshore, shoreline, groundwater, and surface water contamination and contaminant cleanup. Oil in ice and on ice will require cleanup extending over the winter months, with impacts from weather, low visibility, and ice on response efforts. There will be community integration into the response for several reasons: depletion of oil reserves in the winter, without the possibility of restoring reserves until the following spring and long-term health and environmental risks posed by a tank spill. Standard Response Responsible party assumes leadership role for cleanup, Unified Command is activated, and local entities assume leadership within the Unified Command. Response Needs Adequate prepositioned response equipment, integrated and simultaneous response on land, nearshore, and offshore, which will need training and exercises for local response personnel working with the Unified Command personnel; provision for fuel and oil replenishment in case of an oil tank leak and/or rupture; wildlife response techniques; and logistical and manpower support for large events are needed. The use of NEBA is helpful for regional spill contingency plans, since some response options have a limited window of opportunity. Contingency planning can identify such areas of potential conflict and attempt to resolve them through consultation among all interested organizations before any spill occurs. While oil spill response protocols have been developed for the Arctic, there is a need to understand the effectiveness and consequences of the technologies such as oil spill treatment agents. NEBA analysis factors in the logistical challenges associated with deploying and supporting oil spill response resources in the Arctic that influence their success. For example, the effectiveness of mechanical oil recovery by skimmers may be highly limited by the presence of ice, while the same ice presence may support in situ burning operations by preventing the spreading of oil. Conducting a NEBA Traditional NEBAs involve the following elements (IPIECA, 2000) in the process of collecting information regarding the physical features, ecology, and human resource use in the relevant area. These are to: 1. Review previous spills and experimental results that are relevant to the area and to possible countermeasures; 2. On the basis of prior experience, anticipate likely environmental outcomes if the proposed countermeasure is implemented compared to outcomes if the area is left to recover naturally; and 3. Compare and weigh advantages and disadvantages of various potential responses with those of natural cleanup. PREPUBLICATION COPY

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136 Responding to Oil Spills in the U.S. Arctic Marine Environment The NEBA process can be used to establish the most important resources at risk in an oil spill, based, for example, on their status as a protected species, ecosystem relevance, or human use. This set of priorities will depend on the preparation of a list of local environments at risk; the results of predictive oil fate, behavior, and trajectory models; and observational and remote sensing data. It takes into account the nature of the spilled oil and changes it may undergo during weathering, which may influence the level of biological effects. Additional information may be available in species vulnerability and environmental sensitivity maps, showing the distribution of natural resources and important human use areas. As discussed briefly in Chapter 3, a “no response” or natural attenuation option is an operational oil spill response strategy. Such an approach is often employed during a spill response because monitoring and evaluation of a situation are basic steps before taking physical cleanup action. NEBA can then be used to provide an estimate of the potential impact on VECs from the spill if no countermeasures were used, based on oil spill trajectory and fate models; oil toxicity for various resource groups, such as coastal marshes, marine mammals, marine birds, and fishes; seasonal and/or spatial distribution and specific characteristics of VECs, such as breeding conditions, habitat, and migration routes; and estimates of impacts to populations and communities of living resources. For the application of active spill response methodologies, NEBA can determine potential recovery rates for each countermeasure option and can be used to identify possible limits on their practical use. It can also be used to establish which environmental or operational conditions could improve particular response efficiencies. For each type of countermeasure, NEBA ascertains the degree to which environmental impact on each resource could be lessened if the countermeasure was deployed by itself or in combination with others. By considering the reductions in spill impact that could result from each countermeasure, including the time needed to achieve acceptable levels of habitat recovery, the NEBA can be used to select the response options that can offer the best protection to VECs, as well as the greatest overall reduction in harmful environmental consequences. A decision process such as NEBA can be used to select the intensity of the response countermeasure, as well as the determination of when to conclude the response. Decisions are typically based on potential environmental and socioeconomic impacts of the spill, the potential impact of the cleanup operation, and whether the environment will be able to naturally recover from oil spill impacts. The American Petroleum Institute’s (API’s) 2012 report, Spill Response in the Arctic Offshore, provides a range of cleanup intensities and conditions where each might be appropriate. They note that the most intense efforts to remove all oil are appropriate in areas where there is an abundance of human or environmental activity, the risk from oil is high, and intense cleanup measures pose little risk. By contrast, monitoring may be sufficient in situations where the oil poses little risk, the potential for natural oil degradation and natural recovery are high, and the risks posed by cleanup efforts are also high. These examples represent end members of cleanup effort. Some situations call for more moderate levels of effort. Another example from their report shows that where areas adjacent to the oiled area are highly sensitive to oil, and where the oiled area is only moderately sensitive to cleaning, the appropriate cleanup efforts may include removing most of the visible oil but allowing traces of oil to remain (API, 2012). PREPUBLICATION COPY

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Strategies for Response and Mitigation 137 Data Gaps and Research Needs to Improve the Application of NEBA in the Arctic Prediction of the fate and effects of oil under various spill scenarios is largely accomplished by the use of spill trajectory models and applicable case histories. The precision and accuracy of these models is based on ocean current data, knowledge of the physical and chemical characteristics of the spilled oil, weather data, and species sensitivity data. In comparison to temperate regions, the database for this information in the Arctic is limited. For example, reliable oil spill trajectory models for oil fate and behavior under sea ice conditions have not been established. Considering its extreme weather conditions, seasonal ice cover, extended periods of darkness, and the possibility of enhanced species sensitivity to oil, the Arctic presents a challenge for the application of NEBA. Developing standardized protocols for toxicity testing would benefit comparative efforts and support future natural resource damage assessment procedures. For example, risk assessments will require a toxicity database for VECs. There is a need to conduct assessments of native populations and habitat characteristics to establish benchmark conditions at sites slated for future exploration and production and in areas that might be affected by a marine oil spill from shipping. A shift from acute effects to sublethal effects on key polar species is needed, including at sensitive life stages. The integration of toxicity data and predictive risk assessment models is essential in future NEBA analysis. The Arctic environment adds additional levels of uncertainty in the interpretation of toxicity data. Several steps to potentially reduce this uncertainty could be further study of the effects of temperature on the metabolism and biochemical responses of various cold-blooded organisms and studies on the life histories of Arctic organisms to determine seasonal differences in their sensitivity to oil. The results of toxicity studies for temperate species of zooplankton have often been used to infer the response of Arctic species in terms of sensitivity to oil. However, such direct links cannot be drawn. For example, Arctic zooplankton typically have longer life spans, which can lead to increased duration of oil exposure. They also contain higher lipid concentrations, which allow them to survive longer without food and to attain higher concentrations of residual hydrocarbons. There is a need to better understand the impact of oil spills on productivity, the food web, and trophic-level dynamics. Arctic oil spill case studies have been focused on small response operations, and the Arctic spill response community has limited first-hand experience and thus little information to predict the environmental outcomes of various oil spill countermeasures. Information on the long-term effects of oil and its environmental persistence within the Arctic is limited. Depending on the situation, habitat recovery rates following a spill can be slow. As a result, monitoring habitat recovery with a view toward restoration to pre-spill conditions may not be a valid or achievable end point. Climate change presents an additional confounding factor in the long term. It is also important to note that there are a number of emerging oil spill countermeasure technologies (e.g., chemical herders, facilitation of oil mineral aggregate formations) that have not been fully validated in the field. Until sufficient information is available on the population dynamics of VECs, the fate and environmental effects of oil, and the efficacy of various response technologies, Arctic NEBAs will be subject to a wider range of response effectiveness and uncertainty in outcomes. The Arctic Oil Spill Response Joint Industry Program has undertaken a PREPUBLICATION COPY

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138 Responding to Oil Spills in the U.S. Arctic Marine Environment project (Environmental Impacts from Arctic Oil Spills and Oil Spill Response Technologies) with a goal to provide information to improve and advance NEBA effectiveness.91 While the living resources in the Arctic have high ecological, socioeconomic, and cultural value, the potential loss of ecosystem services, which are the benefits to humankind from resources and processes that are supplied by ecosystems, is another important consideration in the NEBA process. If ecosystem services are lost or damaged within the Arctic, there is a need to determine the value of lost services, their recovery time, and whether they can be replaced by other means. Socioeconomic and Ecological Considerations in NEBA There are no response methods that are completely effective or risk free. NEBA considers the advantages and disadvantages of different spill response options, including no response. Prioritizing spill response options usually involves making tradeoffs between environmental resources that have been chosen to receive priority protection. However, socioeconomic factors will play an important part in decisions about spill response, so an optimal technique will minimize a spill's adverse impact on a region's environment, its economy, and the well-being of its people. In all cases, compromises are made during spill response operations. For an area containing both birds and fish, dispersant applications might be the best way to reduce the threat to birds but could increase the potential exposure level of fish in the area. This could lead to a different set of priorities in the Arctic, where subsistence hunting and fishing are extremely important to the indigenous people. CHAPTER CONCLUSIONS AND RECOMMENDATIONS Conclusion: An ongoing effort is needed to determine appropriate wildlife response techniques. In some cases, the “no response” option may be preferable for large marine mammals, such as hauled-out walruses. Wildlife response plans will need to include key indicators of environmental health, and prioritize response strategies. Recommendation: The U.S. Fish and Wildlife Service, NOAA’s National Marine Fisheries Service, the Alaska Department of Fish and Game, co-management organizations, and local government and communities are the trustees for wildlife deterrence and rehabilitation. As appropriate, these agencies and groups should work together with industry to explore and improve deterrence and rehabilitation methods for wildlife. Additional research and development for improved methods could benefit from the involvement of universities, non-governmental organizations, and others. Priorities should be set and regularly updated by the trustees for oil spill response based on the type of wildlife threatened, the season, other factors related to a spill, and updated research and methodology. 91 See http://www.arcticresponsetechnology.org/research-projects/environmental-impacts-from-arctic-oil-spills-and- arctic-oil-spill-response-technologies. PREPUBLICATION COPY

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Strategies for Response and Mitigation 139 Conclusion: An Arctic NEBA process requires prioritization of valuable ecosystem components, including seasonal distribution and cultural importance of wildlife, fish, and other resources; information on the transport, fate, and potential effect of the spilled oil; knowledge of operational limits, advantages, and disadvantages of each oil spill response countermeasure for the natural resources at risk; and consideration of logistical constraints and cleanup intensity. Recommendation: A decision process such as NEBA should be used to select the response options that offer the greatest overall reduction of adverse environmental impacts. In the Arctic, areas of cultural and subsistence importance should be among the priority ecosystem components. In light of concerns regarding detrimental effects on ecosystems, further study should focus on the impact of oil spills on Arctic food webs and dynamics at different trophic levels. The process should involve regulators, resource managers, health authorities, technical specialists, scientific experts, and local experts PREPUBLICATION COPY

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