overview of environmental design, fire and explosion hazards and oil spill contingency plans of the Northern Tier Pipeline project in Clallam County, Washington

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TJ
930 HATFIELD
H37 CONSULTANTS LTD
1980 environmental and pollution management
tml ri

201 1571 Bellevue Avenue, WEST VANCOUVER, B.C., CANADA V7V 3R6
Telephone: (604) 926-3261; Telex: 04-352798

"The preparation of this report was
financially aided through a grant
from the Washington State Department
of Ecology with funds obtained from
the National Oceanic and Atmospheric
Administration, and appropriated for
Section 308(b) of the Coastal Zone
Management Act of 1972."

AN OVERVIEW OF ENVIROTZENTAL
DESIGN, FIRE AND EXPLOSION
HAZARDS AND OIL SPILL
CONTINGENCY PLANS OF THE
NORTHERN TIER PIPELINE
PROJECT IN CLALL41
COUNTY, WASHINGTON

Prope-rty cf

P-repared for:
The City of Port Angeles
[)Ep@@P.T@AiENT OF COMMERCF NOAP and-Clallam County
Washington State
COA,@TA( SERVICES CENTER
1zf-q1jH. H(,)BSON AVENUE
CHARLLSTION -SC 29405-2413

Prepared by:
HATFIELD CONSULTANTS LIMITED
201-1S71 Bellevue Avenue
WEST VANCOUVER B.C.
V7V 3R6

September 1980

-7-

ABSTRACT

The Northern Tier Pipeline Companyapplication for site certification,
submitted to the State of Washington Energy Facility Site Evaluation
Council was reviewed and evaluated. Supplementary documents, including
background studies sponsored by the Northern Tier Pipeline Company and
expert witness testimony available at the time of review were also examined.
The review and evaluation dealt with environmental design, fire and explosion
hazards and oil spill contingency plans of the proposed project in the City
of Port Angeles and Clallam County.

Major topics for consideration were identified within the general areas
of review,,arid deficiencies and weaknesses were assessed under each major
topic. The following inadequacies were determined for the project as
proposed: insufficient submarine pipeline studies with respect to local
current and 'sea bottom conditions, and susceptibility to anchor damage;
the maneuvering and anchoring of large oil tankers in Port Angeles Harbor;
the data base used for fire and explosion hazard conclusions; the implica-
tion that inert gas systems are reliable mechanisms to remove explosion
risk.

TABLE OF CONTENTS

PAGE

ABSTRACT

TABLE OF CONTENTS

I INTRODUCTION

II REVIEW,METHODS 2

III GENERAL MENTS 4

IV SPECIFIC,TOPICS 7

A. ENGINEERING AND ENVIRONMENTAL DESIGN 7

1. SUBMARINE PIPELINE AND RIVER CROSSINGS 7

1.1 SUBMARINE PIPELINE CROSSINGS 7

Al) Construction and Operation Designs 7
and Procedures Proposed

A.2) Anchor Damage Potential 13

A3) Potential Enviromental Impacts 16

1.2 RIVER CROSSINGS 21

A.4) Assessment of Construction and Operation 21
Designs Proposed

AS) Potential Envirorniental Impacts 23

2. TERMINAL FACILITIES 26

2.1 SUBJECT: TANKER DESIGN AND OFFLOADING 26
OPERATIONS

A6) Assessment of Risk and Sources of Oil 26
Spills in Port Angeles Harbor and
Strait of Juan de Fuca

A7) Design of the.Proposed Surge Relief Tank 32

A8) Butler "Marine Terminal Simulator" 33

A9) Vessel Crew Unloading Monitoring and 35
Oil Spill Response:Capability

A10) Overview of Proposed Tank Farm 36

TABLE OF CONTENTS

PAGE

2.2 TRANSIT'AND MANEUVERING OF VESSELS 38

All) Terminal Facility Interaction with 38
Navigational Hazards and Port Angeles
Harbor Traffic ,

A12) Safe Anchorage Sites 43

A13) Review of Operating Procedures of 4S
Tankers in the Strait of Juan de Fuca
and Port Angeles Harbor

A14) Non-English Speaking Crew Mishap so
Relationships

A15) In-transit Vessel Assistance Procedures 51

B. FIRE AND EX PLOSION HAZARDS 53

1. VESSEL HAZARDS 53

Bl) Causes of Recent Vessel Fires and Explosions 53
B2) The Effectiveness of Vessel Inert Gas Systems 64

2. HAZARDS SPECIFIC TO PORT ANGELES HARBOR 67

B3) The Impacts of a large Tanker Ex-Plosion and 67
Fire on the Port Angeles Hospital and
Downtown Core

B4) Enviromental Effects and Health Concerns 7S
of a Release of Stored Chemicals

BS) Effectiveness of Port Fire Fighting Systems 76

3. TANK FARM HAZARDS 79

B6), Recent Tank Farm Fires and Explosions 79

C; QIL SPILL CONTAINMENT AND CLEANUP 82

Cl) Critical Review of Contingency Plans 82,

C2) Detection of Night-time Spills at Berth or 87
in the Strait of Juan de Fuca

(iv)

TABLE OF CONTENTS

PAGE

C3) Capability of Existing Equipment for 89
Use at River Crossings in Clallam County

C4) Evaluation of Electronic and Human Surveillance 90
of Proposed Leak Detection System

CS) Potential Impacts on Groundwater 93

C6) Improvements for Prevention, Response and 96
Cleanup Capabilities

V BIBLIOGRAPHY 98

I INTRODUCTION

Northern Tier Pipeline Corporation (NTPQ have prepared an application
to the State of Washington Energy Facilities Site Evaluation Council
(EFSEC) for a port and pipeline system to transport Alaskan and offshore
im 4-
oil from Port Angeles to the U.S. mid-west. Hatfield Consultants L iled
(HCL) were contracted by Clallam County and the City of Port Angeles to
carry out an environmental assessment of three broad areas of the applica-
tion:. Engineering and Environmental Design; Fire and Explosion Hazards-
and Oil Spill Containment and Clean-up. Specific technical subjects to be
addressed were agreed upon in a work plan developed with a county/city
committee. The geographical area included in the review aspects of the
proposed project within Clallam County, and a brief review of submarine.
pipeline cros'sings at the eastern end of the Strait of Juan de Fuca and
Saratoga Passage.

The results of the assessment are intended for use by the county and
city in ensuring their.interests are protected at the Energy Facility Site
Evaluation Council Hearings, on the application, which are taking place in
1979-1980. This report contains an outline of relevant statements made
in the NTPC application, NTPC witness prefiled testimony, backup consultants
reports, and HCL's assessment of them. It has been organized by issue under
general subject heading in order that the material could be readily used
in the hearing process.

The assessment was made within the constraints of a very short (7-week)
review period and a very limited budget. Because of this, the reviewers
were forced to deal only briefly with some subjects. However, the
reviewers believe that the assessment has identified the major information
gaps and deficiencies in the application as it has been presented up to
the submission date of this report.

II REVIEW METHODS

Assessment of the NTPC documentation was carried out during the period
April 1 - May 21, 1980.

Project Reviewers Included:

1. Mr. C. Hatfield, Mr. J. Villamere and Mr. M. Winsby - HCL staff;

2. Mr. G. Morgan Thurber Consultants Ltd.;

3. Mr. J Bennett Bennett Envirormental Consultants Ltd.;

4. Capt. R. W. Lumsden - Marine Consultant.

Assessment Procedures Included:

1. a one-day site reconnaissance of the port and tank farm site;

2. a two-day reconnaissance of the tanker route from Cape Flattery;

3. review of relevant sections of the NTPC documentation as provided
by county personnel;

4. a one week visit to shipping specialists and organizations in
London, England. During this visit, the following people were
interviewed:

Capt. M. L. M. Jolivet, Navigation and Safety
Shell International Marine Limited

Capt. R. W. Lumsden, Marine Consultant

Mr. A. E. Fischer, Managing Director
Marine Pollution Compensation Services Limited

Ms. F. Holland, Marketing Executive
H. P. Drewry (Shipping Consultants) Ltd.

Dr. D. S. Aldwinckle, Senior Ship Surveyor
Lloyd's Register of Shipping

Cdr. T. M. Hayes, Inter-Region'al Consultant
Maritime Pollution Technical Cooperation Division, U.N.

CaDt. E. 0. Jones
Shell Tankers (U.K.) Limited

Mr. R. Brown, Regional Liaison
Shell International Marine Co. Ltd.

Mr. J. A. Nichols
International Tanker Owners Pollution Federation Limited

Mr. D. Scarfe
International Tanker Owners Pollution Federation Limited

Mr. A. E. Findlater, Maintenance and Machinery Operation
Shell Tankers (U.K.) Limited

Dr. J. W6nham, Marine Pollution Advisor
Inter-Governmental Maritime Consultative Organization, U.N.

S. personal interviews with.the following individuals:

Mr. J. Wiechert, Manager
Clean Sound Oil Spill Cooperative, Seattle, Wa.

Capt. W. Stuart, Director
Canadian Coast Guard (retired)
Otta@va, Canada

t1r. T. MacDonald, Fire Chief
Mr. D. Jordan, Deputy Fire Chief
Nanaimo Fire Department
Nanaimo, B.C.

Mr. W. Wolferstanl
Environmental and Land Use Committee
Victoria., B.C.

6. review of relevant reports from HCL and sub- consultants' libraries;

7. judgments of HLC staff and sub-consultants based on experience
with the subject areas.

Since documentation for the T)roject was continually changed by new
hearing testimony and the filing of supplementary documents up to
the due date for this report, some of the issues were dealt with more
fully than others. For the same reasons, some aspects of the assess-
ment may only be current as of the original due date (May 21, 1980).

III GENERAL COMMENTS

In assessing the NTPC documentation and backup consultants' reports,
a consensus developed among HCL reviewers on general impressions of the
proposal presentation. There were some subject areas which stand out in
the proposal as being major data gaps, deficiencies or simply misinformation.
The overall conclusions of the reviewers are presented below. The assess-
ment of specific subject areas should be carried out with these overall
conclusions in mind.

1. A critical deficiency in the NTPC application is a lack of good
technical information

With some exceptions, backup consultants' reports generally
appear to be carried out by competent personnel and are professionally
presented.. However, the NTPC application itself is one of the poorest
documents the reviewers have seen.

The reviewers .point out that in applications of this type, the
proponent is making commitments to carry out public safety and environ-
mental measures as stated in the application. These commitments can be
modified by witnesses appearing at the hearing who clearly have the
authority to make commitments on NTPC policy matters or by supplemental
filing of application amendments or volumes. It should be emphasized
hoi veVer, that consultants' reports) unless their entire contents are
clearly endorsed by NTPC application statements, do not constitute
commitments on behalf of NTPC.

A general lack of good specific technical material or even
adequate use of that presented in consultants@? reports made the
application difficult to assess. It is recognized that the project
is not at a final engineering design phase nor did the reviewers
expect such information at this stage. However,, for the subject
areas assessed in this report, NTPC did a poor job in presenting
enough technical material to make the proposal credible even at this
conceptual stage.

2. The mlication contains incorrect statements and numerous errors

NT?C documentation contains completely wrong statements in some
critical subject,areas such as safety record of inert gas systems,
practical possibility of tankers using low sulfur fuel in port and
VLCC anchoring capacities of Port Angeles Harbor, etc. It also has
numerous errors in figures and calculations as pointed out in evidence
by witnesses at the hearing. This results in misleading impressions of
the safety and environmental impacts of the project and ultimately
reflects badly on parts which may be adequately done.

3. During the -assessment period a continuous flow of new information
was filed, promised documents were filed late, and some reports
were filed in draft. This made the task of assessing specific
issues of the project more difficult than necessary

Evidence in chief.presented by NTPC witnesses and new documents
filed at the hearing often contained information differing,substantially
from original plans in the application. Reviewers of the material,
therefore, had to continuously keep up to date on the new ideas and
revised plans being presented by NTPC. Crucial documents such as
Volume II of the contingency plan were only received a few days before
the end of the HCL assessment, even though the document had been
promised by NTPC much earlier. It was even then only in draft.
Operating in this way may be good hearing strategy from the point of
view of NTPC since it makes a thorough review of the application by
intervenors extremely difficult. However, it leads the reviewers to
believe the project contains substantial areas of "back of an envelope"
planning.

4. There is a lack of firm agreements with outside parties concerning
critical parameters of the project

The reviewers understand that no firm intent or contractual agreements
exist concerning such things as a supply hook-up to existing Puget
Sound refineries, membership in the Clean Sound Spill Cooperative and
supply of low sulfur bunker fuel. Whether or not such agreements are
successfully negotiated has orders of magnitude effects on such things
as air quality projections,, shipping accident risk analyses and assess-
ment of the adequacy of contingency plans.

S. NTPC has had poor advice and appears to have little in-house expertise
on shipping matters

Statements made in the application on.tanker inert gas systems,
low sulfur fuel burning capabilities in port, anchoring space, etc -
arIe naive. Since such points are of crucial importance to the safety
and viability of the project, reviewers found it surprising that NTPC
did not make use of the large body of international expertise available
on VLCC shipping matters.

6. Accident and safety risk analyses are inadequate for the project

Analyses of accidents occurring and the consequences of such accidents
rely heavily on mathematical calculations based on theoretical or local
data.. They appear to have been made by people unfamiliar with shipping
operations, worldwide real incident statistics, case history literature
and incident witness information. As such the consultant analvses on
.such critical factors are inadequate. Conclusions about public safety
and probable environmental imDact contained in the .1,TMC application are
misleading and bear little relation to real life major oil port problems.

7. Scenario techniques for analysing effects of accidents and mitigative
success were not used extensively enough in the documentation

Projected oil spill movement in-U.S. and Canadian waters, the
projected success of clean-up operations and.projected damage such
spills would cause was not done in the application. Fire and explosion
scenarios were only touched on superficially. Detailed scenarios on
these subjects would permit reviewers and hearing commissioners to
have a better real life idea of the possible impacts of the project
if there were an accident.

8. The documentation contains little discussion on the projected success
of proposed mitigative techniques for dealing with such things as fire
and pollution emergencies

Sections in the documentation describe the fire fighting and spill
clean-up equipment which will be on hand to deal with emergencies.
Plans are presented in different degrees of detail on how this equip-
ment would be used to deal with an emergency situation. The impression
is given that if this equipment is available and if it is used it will
mitigate the problem. For fire and explosions, this is not necessarily
so. For oil spills at sea, this is totally inaccurate, because of a
lack of technology to contain and pick up oil at sea even in relatively
sheltered waters. This has never been done successfully in any major
oil spill.

9. Engineering for the project is generally very preliminary

A review of the references supplied has indicated that the
engineering studies that have been carried out to date on the pipe-
line are generally in a very preliminary stage. In some cases the
applicant has recognized considerable uncertainty and has carried out
more detailed studies. Examples of this are the R.J. Brown reports
dealing with the Port Angeles harbor submarine pipeline crossings.
The overall application is thus currently out of balance. It is also
out of balance geographically in that relatively little stud), has been
made of that portion of the underwater pipeline route outside of Port
Angeles harbor.

10. Where detailed studies have been carried out substantial changes in
the study parameters have resulted

Because of the preliminary state of the engineering studies, the
apparent lack of precedent in certain areas, and the environmental and
economic consequences of an underwater pipeline.failure, the reviewers
would recommend that, if the project is approved, an independent
review board of competent experts be formed for reviewing all engineering
aspects of this part of the project as they are developed from design
through to construction.

A. ENGINEERING AND ENVIRONMENTAL DESIGN
1. SUBMARINE PIPELINE AND RIVER CROSSINGS
1.1 SUBMARINE PIPELINE CROSSINGS

Al) The Construction and Operation Designs and Procedures Proposed

EXPLANATION:

The methods used to construct and place submarine pipelines must be
appropriate for.local conditions, such as water depths, bottom soil and
seismic-conditions, tidal and wave induced currents and.bottom countpurs.

BACKGROUND NTPC APPLICATION: SOURCE

Submarine.pipelines are proposed for three separate
areas: Port Angeles Harbor, Strait of Juan de Fuca
(Admiralty Inlet), and Saratoga Passage.

Port Angeles Harbor Crossing:

"The two submarine pipelines will connect the onshore Vol. II
Ediz Hook pipelines,to the onshore storage facilities p.6-16
approximately 5.2 miles away at Green Point. These
lines, in conjunction with the onshore lines, booster
pumper and other elements-of the unloading system will
be designed to provide a maximum flow rate of 100,,000
bph through each line... Preliminary hydraulic and
economic studies indicate that the pipelines will be
either 48-inches or 52-inches in diameter... Prelim-
inary design studies indicate that the wall thickness
for 48-inch and 52-inch pipelines will be approximately
0.7S inches and 0.87S inches, respectively. High den-
sity, concrete, weight coating will be applied to the
pipe to produce the design submerged weight, which will
be determined following route selection, evaluation of
bottom currents, investigation of bottom soils, and se-
lection of the construction method."

Strait of Juan de Fuca and Saratoga Passage Crossings:

"The pipe will be 42-inch diameter, the same as the Vol. II
land portion of the system in Washington. However, p.6-74
because of possible pipe laying barge capability to
limitations ' it may be necessary to reduce the diameter p.6-76
to 36-inches for about 6 miles through the deeper part
of the Strait of Juan de Fuca crossing ... the prelimi-
nary design studies indicate that the.pipe wall,thick-
ness will be 0.750 and 0.625 inches for the Strait of
Juan de Fuca and Saratoga Passage crossings, respect-
ively"..."the Preliminary design studies indicate that
the thickness of the concrete weight coating will be
approximately 2.6 inches and 3.1 inches resnectively
for the Strait of Juan de Fuca and Saratoga Passage
crossings."

DISCUSSION:

In reviewing the R.J. Brown and Assoc. Report (1979a, 1979b, 1979c)
the following unanswered questions arise:

1. What is the experience,with installing large 42-inch diameter
pipelines-and operating them in waters with significant tidal
- currents? Are we pressing the limit of our experience?

Because the required negative bouyancy varies with the square
of the design currents from both tides and waves, it is
important to reliably determine the magnitude of the currents
that are likely to affect the pipeline, both during the operating
period and during the installation period. It affects the methods
used in installing the pipeline. B.C. Hydro ( 1979) states -
that the design current velocities over the operating life of a
submerged pipeline should be of the order of 100 year maximum
conditions.* It goes on to state that possibly the S year maximum
condition could be acceDtable for design for installa'tion conditions.
Thus in order to reliabiy determine the currents to be taken into
account, one must have surveys of currents continuously carried
out over an extensive period. B.C. Hydro ( 1979 ).states that
the minimum period should be 6 months to a year On page 2-19
of R.J. Brown and Associates ( 1979a ) it is implied that
100 year design current velocities are to be taken into account
for the operating condition (although here they are referring to
wave generated currents only). However, on page 2-17, they imply
that they are going to use a 1 year design velocity for designing
for the installation condition.

When one compares Table 2.1 in R.J. Brown and Associates
1979a with Table 2.1 in R. J. Brown and Associates
1979c I there is a substantial. increase in the design
tidal currents particularly in the sections of the pipeline off
Ediz Hook where velocities up to 3.9 ft/sec were measured.
The reason for this increase is that a current measurement
survey was undertaken during the period January 29, 1979 and
March 1, 1979 in Port Angeles Harbor. This shows the necessity
of taking site measurements. However, is this one month long
period of measurements long enou h in the light of the above
comment from B.C. Hydro ( 1979 %. J. Brown and Associates
( 19.79c ) page 2-3, describe an attempt to establish
a design current by making a correlation between the measured
currents and tidal data. The results were not too encouraging
which is to be expected. Most experienced boaters in Juan de
Fuca Strait are aware that the relationship between tidal
levels and tidal currents at any particular location varies
appreciably depending upon the magnitude of tidal level change
and prior weather conditions (eg. wind generated seiche),
The proponent states that he is taking a "conservative" approach
by increasing the maximum measured current taken during the
period by 10% and using this value as the design tidal current.
Clearlv this is no substitute for taking an extended program
of rea@ings. We really do not know if 10% is conservative or

not. It is furth er noted in R.J. Brown and Associates (1979b),
page 3-S, that to date, no detailed survey of underwater
currents has been conducted on the remainder of the submerged
pipeline route outside of Port Angeles harbor. The R.J. Brown
design tidal current, a maximum of five feet per second for
the Strait of Juan de Fuca, does not appear to be conservative
in view of design currents used by earlier studies for- NTPC.
Mr. Peebles during his testimony did not know whether the
R.J. Brown' design was feasible above currents of S feet per
second, which is well below 10.68 feet per second identified
by McDermott-Hudson (1977).

2. Why wasn't more on-site investigation conducted at this stage
of the study? More on-site investigation should have been
conducted which might have prevented the inaccuracies and
inconsistencies found in the NTIPC reports.

3. What factors of safety are used in selecting submerged weights
for a pipeline? Note 2 on Dwg. 1-209 and the equation at the
top of page 2-14 indicate that no factor of safety has been used.

Dwg. 1-209 of R.J. Brown and Associates (1979a) provides the
results of wind tunnel tests which indicate that the no ditch
case is not the worst case. A small ditch with 1 on 2 side
slopes (case No. 1 required higher submerged weights to with-
stand a given current velocity. Is it possible to make matters
worst by trenching?

The following aspects of submarine pipeline installation are considered
below: floatation of the pipeline due to liquefaction; the problem
of a potential break in'the line; shoreline regression at the land-
fall site; projected cost estimates; and tidal scour.

Floatation of Pipeline due to Liquefaction:

Our major comment here concerns the quality and extent of study which
has been given to this topic. Assuming that liquefaction occurs, it
should have been.a relatively simple matter to determine whether or not
the pipeline would float. Yet on page 5-1 of R.J. Brown and Associates
(1979c) which is a revision to earlier documents, the conclusion is
reached that the pipeline will be negatively bouyant (i.e. will sink)
in liquified Type A soil. Only 4 months later in Butler and Associates
(1980) it is concluded that floatation rather than sink-ing of the
pipe will be the predominant case. Unlike the anchor penetration
problem orthe liquefaction problem per se, there is really nothing
difficult about this analysis. It is in fact an error that should
never have occurred since it reflects upon the credibility of the study.
However, it did occur and one is led to the conclusion that some
aspects of the project must be in the very -preliminary stage of
engineering design and that some of the checking leaves much to be
desired.

The Problem of a Potential Break in the Line

A break in the line resulting in an oil sT)ill could be both costiv and
time consuming to fix. The application does not adequately address how.
difficult it would be to repair the line if broken. In the Department
of Ecology Questions and Answers, response to question H-lS, the applicant
does acknowledge, however, that repairs would be difficult to accomplish.

Other studies concerning proposed large diameter pipelines that are to
be submerged by reservoirs state that location and examination of the
failure of a submerged pipe could require several weeks before temp-
orary repair could be initiated. Service could be disrupted for
several months in a worst case type of situation. B.C. Hydro (1979),
on p.24 states that "Pipeline failure ... would (result in) a long
pipeline shutdown during the repair period". With regard to the Northern
Tier Pipeline the worst-type of situation would be severing of the pipe-
line due to, say, a large submerged slide which would affect a signif-
icant portion of the pipeline. The cost of repairing the worst case
would amount to several millions of dollars. However, by comparison
the costs of an interruption in the oil supply caused by a.breakage
would probably be very high.

The applicant has identified two potential causes of a break in the
pipeline - liquefaction of sediments on the sea bed (possibly causing
slides); and penetration of the pipeline by ships' anchors (eg..in Port
Angeles harbor). Anchor damage risk will be discussed in Section A2.

Liquefaction:

In R.J. Brown and Associates (1979c), page 5-2, concern is
expressed over the possibility of sea bottom instability
on the Ediz Hook Slope in Port Angeles harbor. Here the
sea bottom is at an angle of 24 degrees and investigations
have shown what appears to be a slide or flow zone. The
Applicant proposes to mitigate the effect of further
possible slides by installing the pipe in Type B soil
below the loose Type A soil and to align the route so that
it is perpendicular to the contours. But is is practicable
to excavate to Type B soils bearing in mind the expressed
difficultv in R.J. Brown and Associates (1979c) of excavating
the sand @oxer (refer to later discussion on floatation of
pipeline)9

In the Washinaton State Department of Ecology Questions and
Answers, page 4, it is stated that no borings have been
done on the submarine crossings on the Strait of Juan de
Fuca or Saratoga Passage, nor are any borings planned at
these crossings. On the other hand it is pointed out
0
that Type A deposits probably reach their thickest depths
in Saratoga Passage. Iffiat then is the possibility of
0
liquefaction induced slides on shallow slopes but of a
magnitude that could sever the -pipe outside of Port Angeles
harbor?

Because of the consequences of a break in the submerged portion of
the line and the difficulty in repairing a break, the submerged
line should be conservatively located, designed and.constructed.
The applicant should be required to demonstrate that he had in fact
adopted this philosphy. It is difficult to.obtain assurance that
he has done so from the documents at hand. We feel that.the
approach towards the design and construction of an underwater pipe-
line as described in the B.C. Hydro (1979) report portrays a
typically conservative approach. Some aspects like the intent not
to install block valves along the submerged portion of the line and
not to investigate by drilling the sea bed conditions along the portion
of the line outside of Port Angeles harbor (M. Veatch, prefiled
testimony, p.4) should be further explored. Shannon and.Wilson
(1979a), page 5, states that SS samples total were taken along the
two studied routes across the Strait of Juan de Fuca and Saratoga
Passage to determine bottom soil conditions. Figure 2 shows that
the spacing of the location of the samples ranged approximately
between 4000 and 8000 ft. This is a very preliminary sampling
program. Recommendations are made in Shannon and Wilson (1979a),
page 4, for further exploratory work which the Applicant should
carry out prior to final design. Conditions could vary from those
indicated by Shannon and Wilson (1979a). In particular, we feel
that not enough stress has been placed on the possibility of dense
soils or rocky material occurring at or close to the ocean bed.
The marine charts for this area indicate rocky bottom conditions
north of Dallas Bank and south of Partridge Bank. A sharp change
from a yielding foundation soil to a non-yielding foundation soil
may result in stress problems in the pipe.

It is also not clear how the applicant will monitor the performance
of the submerged portion ofthe pipeline. The response io question
13 in the Washington State Department of Ecology Questions and
Answers does not really address this. Does the Applicant intend to
use smart pigs to monitor on a regular basis the condition of the
pipe? Will these smart pigs be able to detect deformations that
have occurred in the pipe as a result of ground movement or float-
ation?

Shoreline Regression at Landfall Site

It-is noticed (Shannon and Wilson, 1979c), that the investigations
for the landfall sites were carried.out at a reconnaissance level
with no drilling or detailed surveys. Some of these landfall
sites are undergoing re gression by wave erosion. The rate of
shoreline regression is not known. On page 7 of (M. Veatch, pre-
filed testimony), Mr. Veatch is reported stating that the erosion
rate for Green Point bluffs is somewhere between 8 to 12 in. per
year. The USGS have been reported as stating that the erosion rate
for the bluff is 20 to 40 in. per year. Assuming the life of the
project to be 20 years (what is the life of the project?) the
shoreline regression at Green Point can vary from 20 to-70 feet in
the vicinity of the landfall. Do the proposed measures for existing
erosion at the landfall sites take into account this magnitude of
erosion in adjoining areas?

Tidal Scour

Tidal scour may well be a problem at Ediz Hook. Currents up to 3.9
ft/sec. have been measured at this location. Shannon and Wilson,
1979b, (fig. 7) shows thAt at these velocities erosion of fine
silty sands can readily occur. Indeed erosion can start to occur
at velocities as low as 1 ft/sec. Figure 2 (Shannon and Wilson,
1919b) shows.the bottom contours between Ediz Hook and Green Point
and it is noted that there is a depression as deep as 20 ft. off the
end of Ediz Hook which would be compatible with tidal scour at this
location. It would thus be important that the pipe be buried to
such a depth as to allow for scour. We can find no indication that
these studies have been carried out or are to be initiated.

The reviewers also strongly feel that the approach to design and the
construction methods and control for the underwater section be more
conservative than is customary in pipeline engineering practice.
In particular the applicant should prepare environmental and
engineering contingency plans to cover a wide range of project
conditions that may arise during the construction and operation of
the pipeline.

The applicant should, before construction, obtain as much site data
on such thingsas water, ocean bed and sub-ocean bed conditions
as can be economically and environmentally justified, although it
is inevitable that much important information will be discovered
only during construction. In fact, it is therefore particulary
important that the applicant establish a workable liaison between
those responsiblefor construction. The applicant should be
required to demonstrate to the review board that all the engineering
and environmental implications of the design are being carried
through into construction.

A2) Anchor Damage Potential

EXPLANATION:

All of the submarine pipelines, including the unloading pipelines
will be in areas of marine vessel traffic. The Port Angeles Harbor
and the Juan de Fuca Strait crossing areas have particularly high
numbers of marine traffic transits. Vessels could drop anchors
in any of the submarine pipeline crossing areas for anchorage or in
emergencies. The vulnerability of pipelines to anchor damage
therefore requires thorough examination.

BACKGROUND - NTPC APPLICATION: SOURCE

"Those factors primarily responsible for leaks and Vol. III
ruptures in submarine pipelines include dropping or p.2.11-80
dragging anchors damaging lines, internal and external
corrosion., structural defects., bottom trawls, hooking
lines, and natural causes (USGS 1978).11

For the unloading submarine pipeline (Port Angeles
Harbor),"typical burial depths (coverage over the pipe) Vol. II
of large diameter pipelines vary from 3 feet minimum to p.6-17
approximately 15 feet maximum, depending on the bottom
.,soil characteristics."

For the Strait of Juan de Fuca and Saratoga Passage Vol. II
submarine pipelines trench depths are shown to be 7 p.6-173 &
to 10 feet, respectively. Mechanical backfill of the p.6-176
submarine pipelines will take place in the surf and (Port
shallow water zones. Backfilling for the remaining Angeles
submarine pipeline portions will rely on bottom Harbor)
currents to move sufficient deposition of bottom Vol. II
material over the lines. p.6-154
(Strait of
Juan de Fuca)
Vol. III
p.6-172
(Saratoga
Passage)
Vol. II
p.6-177

DISCUSSION:

Anchor Penetration Studies:

Initial analysis (R.J. Brown Associates, 1979a p. 2-41) indicated
that an anchor could penetrate to a maximum depth of 29 feet in Type A
material. Subsequent to the issue of this report it was realized that
excavation to such depths in loose sands would be difficult to accom-
plish. A more detailed analysis was carried out and more importantly,
the results were calibrated to fit actual experience as reported in
some 71 references. As a result, the maximum depth of penetration
was reduced to 11 feet (R.J. Brown & Associates, 1979c, p. 6-3). At
the same time, it was acknowledged (R. J. Brown & Associates, 1979c
p. 1-5) that it is currently beyond the capability of normal marine
dredging equipment and pipeline trenching equipment to excavate a
depth of 11 feet, over the deeper portion of the harbor and that it
would be necessary to modify or specially design dredging equipment or
mobilize equipment from the Gulf Coast. Presumably because of this it
was stated (p. 1-6) that if 11 feet of cover is not achievable then a
minimum cover of 4 feet would be.accepted for which the-risk of anchor
contact was estimated to be 1 in 500 years. Our review of the second
phase of the studies indicates that the study has made extensive use of
available data. However., on p. 6-14, it is stated that "there is not a
great deal of data available on the maximum fluke tip penetration of
dragging anchors. Also, the data which is available is sometimes con-
flicting." The report goes on to describe some of this conflicting
evidence, yet fails toexamine the recent anchor and chain marks on the
bottom of Port Angeles Harbor described in the Shannan & Wilson reports.
Furthermore, it assumes natural sediment burial of'the pipe will be ade-
quate. The National Transportation Safety Board has identified a number
of anchor caused pipeline mishaps in the Gulf of Mexico. Recently, a
natural gas transmission line in the Gulf of Mexico was ruptured by the
grappling hook from an anchor handling boat (National Transportation
Safety Board, 1979). During their investigation the Safetv Board re-
viewed U.S. Geological survey records, and found that 42 sim"ilar accidents
occurred over 12 years in the same area.

There appears to be a theme of rationalization in the reasoning for the
extension to the R.J. Brown studies and the results that were obtained.
In view of the significance of the findings, it seems very advisable
that a commitment be obtained from the applicant to carry out full-scale
site-specific tests of anchor penetration in Port Angeles Harbor prior
to final design and proceeding with the project. Having established
anchor penetration by these field tests, a thorough study should.be made
of the capabilities of trenching and dredging equipment (modified or
otherwise) which is available for use on the project. Again, this study
should preferably include field tests. In any case, the applicant should
p.rovide greaterassurance than he has done of his ability to bury the
pipeline to.the required depths.

Although the entrance to Port Angeles Harbor could be designated as a non-
anchoring location, often ship's anchors aredropped in emergencies and
a vessel's master must always consider the ship's safety first. The traffic

in the harbor has been reported as approximately 3SOO visits per year
(NTPC Application) indicating that the possibility of emergency anchor
drops will always exist.

A3) Potential Environmental Impacts

EXPLANATION:

A submarine pipeline rupture or leak could result in contamination
of sensitive areas near Port Angeles Harbour, Dungeness Bay,
Sequim Bay and the Skagit delta.

BACKGROUND - NTPC APPLIC ATION: SOURCE

Likelihood of Rupture:

Table 111-6-1 indicates that a submarine pipeline spill Vol. III
(all casualties). frequency would be 1 in Sl years for p.6-17
the Strait of Juan de Fuca and Saratoga Passage. The
size of the spill is described as 19 bpy average. Such
a spill is expected to cause moderate ecological damage.
Table 111-6-1 further indicates that a submarine oil
spill from the pipeline under Port Angeles Harbour Vol. III
is expected once in 11S years with spill size described p.6-16
as 6.S bpy. The effect of such a spill is described
as negligible. Elsewhere in the application, "the Vol. III
mean spill size in the event of rupture is S,895 and p.2.11-46
1,336 barrels per spill because of the static
(drainage) and dynamic.losses, respectively.-

Impact on Water:

The NTPC Application indicates that, in water systems, Vol. III
a major pipeline rupture could have significant short- p.3-4
term impacts on biological systems and "recovery from
a major spill could-take two or more years." Released Vol. III
oil could form conglomerates with silt and sediment p.2.3-30
and remain in bottom areas. The application indicates
that "chronic water quality degradation in the embay-
ments could result.."
Submarine pipel.ine ruptures in Port Angeles'Harbour
are not directly addressed in relation to water
quality.

Impact on Flora:

The effects of oil spilled from a submarine pipeline Vol. III
rupture in Port Angeles Harbour again are not p.2.4-6
directly addressed. However, for ruptures of other
submarine pipelines "the salt marsh habitat at the Vol. III
mouth of the Dungeness River, near Dungeness Bay, p.2.4-18

Skagit delta area, and Stillaquamish delta area) could
be damaged extensively by oil introduced by currents
and tides."

Significant damage to aquatic plant communities is Vol. III
outlined as "community parameters such as organism p.3-S
abundance, biomass, and species richness, may remain
altered for two or more years after exposure to and
clean-up from an oil spill ... The Dungeness to Sequim
and Northern Saratoga Passage to Skagit Bay areas are
the most important areas potentially affected by the
pipeline.'r

Impact on Fauna:

The application indicates that in terms of the faunal Vol. III
environment that "the lack of detailed site-specific p.2.S.2
information" allows only general oil impact predic-
tions to be made.

"Marin e ma'mmals are highly mobile and will probably Vol. III
avoid areas of oil spills or areas of high disturb- p.2.S-4
ance;" the primary species (harbour seal and Vol. III
northern sea lion) affected "are primarily fish p.2.5-3
eaters (see 'Fish and Ichthyoplankton' for impacts
,on fish). In general, losses of food for marine
mammals would be too small to be significant; however,
these mammals may feed in other areas temporarily
until food and other habitat conditions normalize."

For birds "the most critical periods are wintering Vol. III
and migration periods... Spring 1978 data indicate p.2.S-7
that at the,peak of migration at least 1,100 diving
birds might be exposed to an oil spill in Port
Angeles Harbour and at least 350 in the Morse Creek
to Green Point critical area" while "a catastrophic
spill contaminating Dungeness Bay could involve over
73,000 birds by coating birds and destroying habitat
(MSN 1977).tv

For fish in Port Angeles Harbour "impacts on fish Vol. III
from operation of the tanker.unloading facilities P-2.5-9
could result from tanker casualty .oil spills, from
transfer oil spills, from bunker'fuel oil spills,
or from miscellaneous contaminants." Also, in Port Vol. III
Angeles Harbour "as with other marine animals, the p.2.S-13
onlNTmajor source of impact on zooplanktons during

operation of the proposed facilities would be accidental
oil spillage."

Macroinvertebrate impacts are not addressed directly Vol. III
because "the possible sources of HC introduction into p.2.5-16
the marine environment in order of decreasing
probability include transfer spills of crude oil or
bunker fuel at the tanker berths,, crude oil spills
associated with tanker accidents and crude oil
spillage arising from unloading pipeline accidents."

"Oil spills will create significant adverse effects if Vol. III
a major tanker or pipeline rupture occurs." Long- p.3-6
term effects are not described directly but "a major
pipeline rupture could severely damage fish eggs and
larvae, macroinvertebrates, and possibly adult fish
in nearby streams., lakes and estuaries."

DISCUSSION:

In general, the NTPC Application recognizes the areas and species
which would be affected by a major oil spill. In sections of the
application discussing net ecological effects, "bpy" units are used
to describe spill sizes. The use of such quantities to describe
spill sizes is highly misleading when describing spill frequencies
of 1 in 11S years (i.e. a 6.S bpy average spill size for the Port
Angeles Harbour pipeline) and 1 i 51 years (i.e. a 19 bpy average
spill size for the Strait of Juan de Fuca and Saratoga Passage
pipelines). If frequent, minor spills are expected it should be
clearly stated because Table 111-6-1 in the NTPC Application
implies that the described ecological effect is based on minor
yearly spill size figures. However, the following statement is
underlined in the application: ."Therefore, the total probability
of an oil s 11 1 in the submarine pipeline crossiiig-sin7ashington
Tc-6-n-siTe-ring ot major and min-or spills) is 0.01 1-6 Fei---year
7 ff
(once every 51 years), ig-iT -a predicted s@-ill vol Fe o -1-9-6-b'PY.
(WIT Application Vol. TM, P.T.-11-94). Note thaft-"Fo-T major-
and minor spills are considered in this determination.

If the spill size figures used in Table 111-6-1 of the NTPC
Application are meant to describe spills at infrequent intervals,
the sizes are then in contradiction with spill size figures used
elsewhere in the application. Whereas for the Port Angeles
Harbour unloading pipeline, 6.5 bpy x 115 years = 748 barrels;
mean spill size losses are described also as 5,895 (static)
+ 1,336 (dynamic) = 7,231 (NTPC Application Vol. III, p.2.11-46).
And whereas,for the Strait of Juan de Fuca and Saratoga Passage

pipelines, 196 bpy x Sl years 969, "the maximum estimated spill
is 21,000 barrels for the Strait and 17,000 barrels for Saratoga
Passage." (NTPC Application Vol. III, p.2.11-97). The later
statement further detracts from a personal communication from
ERT to OIW ( 1979a )where off Port Williams "at this
location,, a worst case scenariocould potentially spill approx-
imately 25,000 bbls (ERT 1979)."
Clearly", as shown above, net ecological impact conclusions are
based on the assumption that worst case spi lls will not occur,
rather than on the possibility that they might. Various sections
of the application indicate the potentially serious effect oil
spills could have on certain biological groups in the Port
Angeles Harbour area, Admiralty Inlet, Strait of Juan de Fuca
area, and.Saratoga Passage area. The potential effects of
submarine pipeline spills (as opposed to surface spills) however,
are played down by.use of the statistics above.

In particular,,the environmental severity of submarine pipeline
related oil spills in the Port Angeles Harbour area is not
addressed directly, or for other submarine pipeline sections,
is given cursory treatment because such oil spills are dismissed
as being unlikely causes of pollution when compared to other
oil spill sources (such as transfer spills of crude oil).

As well., discussion on environmental impact severity resulting
from a large rupture generally seems to place-great reliance
on the leak detection system proposed. A response time of
approximately 5 minutes is anticipated for the.unloading pipe-
lines and approximately 2 minutes1for the other submarine
pipelines for ruptures involving leaks at O.S% of throughput
(NTPC Application Vol. III, p.2.11-46 and p.2.11-9S). However,
leaks below this limit would continue at a rate of 4,66S bpd
(for the ultimate systems throughput) or less until detected
visibly on the water's surface... As part of the NTPC oil
surveillance program an aerial patrol will traverse the strait
following the pipeline route a minimum of once every two weeks
to detect visually any small leak that might occur." (NTPC
Application Vol. III p.2.11-95).. Therefore if a submarine
leak below the detection limit occurred between two aerial
surveys and remained undetected at the surface for 3 days,
then 3 days x 4,66S bpd = 13,99S barrels. Spills of this size
could be very significant for the critical species and areas
identified for the area (ERT, 1979).

Much of the discussion on the effects of crude oil, relies on
comparison of an oil spill in the Santa Barbara Channel with

the effects in the Port Angeles Harbour/Puget/Sound area. Comparisons
such as these are subject to qualification. Firstly, a sufficient pre-
spill data base was not available to allow detailed pre-and-post spill
effects to be made (Straughan, 1971). Secondly, Straughan and Hadley
(1978) show that comparisons of oil spills between marine areas should
be treated with caution because of differences in effect caused by
differences in temperature, crude oil.type and species within that area.
A further geographical difference should be noted; Port Angeles and
Puget Sound shoreline differs from the exposed Santa Barbara coastline.
The Port Angelesand Puget Sound area bears more geographic similarity to
the biologically and economically sensitive Japanese Seto Sea, where a
50,000 barrel oil spill occurred in December, 1979. Major long-term
effects were avoided in the Seto Sea largely as a result of a massive
(357,000 workers) and costly (approximately $200 million) clean-up
operation (Hiyama, 1979).

Because the oil spill impact from a submarine pipeline is largely ignored
for Port Angeles Harbour, the potential short and long-term impact on
several biological groups has been insufficiently addressed. Marine.
bivalves (such as clams) reproductive capability can be affected by
crude toxicity (Renzoni, 1975) and both survival and growth can be
impaired on oil spill sites (Sow, 197S). This could be critical for
the shellfish resources off Ediz Hook and Port Angeles. As well, a
fuel oil spill in West Fallmouth, @Iass. in 1969 resulted in both severe
short-term impact to a saltmarsh habitat (Sanders et al, 1972) and
longer term population impact on some species, such as crabs (Krebs
and Burns, 1978). Further studies should be conducted in the Ediz
Hook to Dungeness Spit area to assess in detail the biological effects
of a submarine pipeline rupture.

1.2 RIVER CROSSINGS
A4) Assessment.df Construction and 0
peration Designs proposed

EXPLANATION:

Stream crossings present special difficulties for overland pipelines.
The methods used for construction and operation must take into
consideration the size and physical features of the streams crossed.

BACKGROUND - NTPC APPLICATION:
SOURCE
"As required by DOT regulations, the cover over the
pipeline will be a minimum of 48 inches below the Vol. II
100-yeAr flood level scour depth at waterway cross- p.6-64
ings unless rock excavation is encountered, where
the cover may be reduced to 18 inches. At all major
stream crossings,, the wall thickness of the pipe
will be increased by 20% to provide an additional
safety factor at the crossing; additional thickness
of corrosion preventive coating will be provided;
and either continuous concrete coating or individual
concrete weights will be applied to provide the
negative buoyancy required to keep the pipeline
buried beneath the stream bed."

Table 11-6.3-4 shows the major and minor stream Vol. II
and river crossings found within Clallam County; p.6-67
Dungeness River, Siebert Creek, McDonald Creek,
Matriotti Creek, Cassalery Creek, Gierin Creek,
and five irrigation ditches and unnamed creeks.

Mainline valves will be installed' "'on each side Vol. II
of a.water crossing that is more than 100 feet p.6-84
wide from high-water mark- to high-water mark;"

"Stream flow control measures and channelization Vol. II
will be avoided in all areas of pipeline crossings. p.6-108
The current or natural flow character of the streams
will be undisturbed by the pipeline."
"The method of excavation and construction of the
crossina will be dependent on the characteristics
of the w:aterway. Excavation of the underwater
trench will be accomplished by the use of backhoes,
.draglines, or clamshells. In shallow waters, this
equipment can work in a normal manner, resting on
the bottom. For deep water excavation, the equip-
ment will be mounted on barges, equipped with power
winches, and stabilized by anchors to the stream
bottom or by cables to the banks. As,excavation
of the trench progresses, the barge is repositioned
by operation of the winches. The excavated material
will be placed on thestream. bottom adjacent to
the ditch to be used as backfill after the pipeline

is in place. If the crossing permit requires that
the excavated material be replaced with select
material, then it will be loaded on barges as
excavation progresses and carried to shore for
disposal.
Streams with sand bottoms and flowing surface water
will be wet excavated by means of a dredge or drag-
line. Sand bottom streams carrying subsurface
water will be de-watered with well points and dry
excavated with a dragline.
Crossings of drainage ditches and irrigation
canals that cannot be open cut will be constructed
by boring beneath or spanning overhead as may be
required by the agency with jurisdiction.".

DISCUSSION:

Construction and installation of the 1)ipeline over stream crossings
in Clallam County does not appear tb be an important issue. The-
major concern of burial depth has been consideredY and procedures
appear consistent with basic design criteria, subject to final stage
details. Stream crossing pipeline engineering is generally a well
developed field..

AS) Po tential Environmental Impacts

EXPLANMON:

Oil pipeline crossings of streams can have impacts upon the associated
environment during both the construction and operational phases.
The degree of impact will depend upon a number of factors.

BACKGROUND - NTPC APPLICATION: SOURCE

"Streams crossed in the Olympic foothills are in the Vol. III
Dungeness River drainage; these streams are classified p.1.3-18
as being excellent quality by the State of Washington
(1977). Irrigation withdrawals affect stream flows in
this drainage, and agricultural, muncipal, and logging
activities cause some degradation of water quality,
mostly by increasing levels of suspended solids and
organic loads. Flows in the Dungeness River average
about 470 cfs, with low flows of about 100 cfs and
high flows of about 1,300 cfs."

"Suspended sediment levels are expected to vary Vol. III
widely during excavation, and maximum instantaneous p.2.3-26
values of several hundred mg/l are expected to occur
just downstream from the dredging operation.
Assuming that downstream transport of suspended
sediment is dependent only on current speed
and settling velocity, turbid sediment could
be carried about 5 miles downstream before settling
to the stream bottom... The crossing of the
Dungeness River is about 5 miles from its mouth,
and some of the disturbed sediment is expected
to reach Dungeness Bay."

"Any oil spills or leaks from the proposed pipe- Vol. III
line into streams in the Puget Sound region of p.2.3-32
Washington will be of special significance. 'Most
of the streams are classified AA (extraordinary
quality), and a portion of any oil released to
thesestreams will probably be transported
downstream into embayments in the Strait of
Juan de Fuca or Puget Sound... In the Dungeness
River, a spill at the river crossing would reach
Dungeness Bay in about one to two hours."

"Leaks that are less than O..S% of the pipeline Vol. III
capacity could go undetected by the automatic p.2.3-31
detection system (see Section 11-6.3). Based on
a maximum volume of 933,000 bpd, leaks of up to

4,665 bpd could go undetected by this system and
remain undetected until visually sighted by aerial
line patrols, ground patrols, or third party
observers."

For the Puget Sound Region, "In all stream types Vol. III
.the suspended sediment should not greatly increase P-2.S-32
the existing sediment loads; thus, effects of
sediments and deposition on salmon spawning should
not be significant."

DISCUSSION:

The proximity of the proposed pipeline route to the Clallam County
coastline, exposes both streams crossed and the associated marine
habitat (particularly the Dungeness estuary) to the effects of
construction and operational mishaps. These effects include
sedimentation, flow rate changes, blasting contus@;ion damage, migration
and accidental contamination of fish through construction
related activities and operational spills..

Sedimentation can result from clearing, grading, ditching, and back-
filling activities on land, in-stream construction activities, and
the operation of transportation and construction equipment on
disturbed areas.. Adult fish are not usually directly affected by
suspended sediments unless concentrations are so high that they cause
abrasions to gills and clogging of gas exchange mechanisms (Phillips,
1971). When suspended sediment settles out on the stream bed, it
can blanket spawning beds and substrates containing invertebrate
organisms (Cordone and Kelley, 1961; Dryden and Stein, 197S). As
indicated in the application (Vol. III, p.2.3-26), Dungeness Bay
could also be affected by sediment loads.

Temporary flow rate changes are likely from the possible extraction
of pipeline test water from the Dungeness River. The principal
freshwater issues associated with water withdrawal are the biological
effects of altered stream flows and aquatic organisms being drawn.into,
intakes. If withdrawal occurs during periods of upstream salmon
spawning migrations low flows could result in impeded passage.

if explosives are used to excavate a pipeline trench in stream beds
containing bedrock or large boulders, acoustic waves can cause damage
to the tissues and organs of fish; the swim bladder is particularly
vulnerable to damage (Tyler, 1960). The strength of the shock waves
from blasting depends upon distance from the blast, water depth,
strength of charge, substrate type and position of charge. The radius
of shock waves is much shorter in shallow water than in deep water
because of absorption of shock waves striking the bottom (Busbee,
1963). The principle fisheries concern associated with blasting is
the possible effect on populations of spawning, rearing, migrating
or overwintering fish.

Obstructions to fish passage can occur from vegetation removed from
banks during in-stream construction activities and by the accumulation
of construction associated solid waste material. Removed vegetation
can collect downstream (eg. at culverts) to prevent fish movement.
The placement of excavated material on the beds of small shallow
streams may cause a weir effect and impair fish passage by increasing
stream velocity. Discarded waste material (eg. pieces of construction
material) could impede fish movement by collecting downstream.

Construction related spills might involve liquids such as diesel
fuel and gasoline as well as propane, lubricants and hydraulic
fluid and solvents. Diesel fuel spilledin a stream in California
caused fish mortality (Bury, 1972). Gasoline is also toxic to fish
and spills of gasoline can cause measurable damage to invertebrate
communities for a period of several months (McKee and Wolfe, 1963).
Kavanaugh-and Townsend (1977) indicate that construction related oil
spills were common occurences along the Trans-Alaskan Pipeline, and
that reporting and clean-up procedures were often not followed.

Operational oil spills could occur and based on the 933,000 bpd
through-put, leaks of 4,665 bpd could go undetected by the described
automatic detection system (NTPC Application, Vol. III p2.3-31).
.Both downstream fish and invertebrate habitat and Dungeness Bay
eelgrass beds would be exposed to such a spill. ImDingement of oil
on the eelgrass beds would have significant repercussions on the
surrounding ecosystem (Thayer and Phillips, 1977).

2. TERMINAL FACILITIES
2.1 TANKER DESIGN AND OFFLOADING OPERATIONS
A6) A-
,sessment of Risk and Sources of Oil Spills in Port Angeles HaYbor
ang Straii of -Aian de Fuca

EXPLANATION:

Oil spills in harbors frequently occur during transfer operations,
and transfer terminals can provide a source of chronic oil
pollution. Risk analysis conclusions can be misleading due to
ihe data base being inap ropriate.
lp

BACKGROUND - NTPC APPLICATION: SOURCE

"Four unloading arms will be installed on a steel- Vol. II
framed structure on each service platform to provide p.6-11
a maximum,unloading rate of 100,000 gph, with accept-
able pressure drop and flow velocity."

"All piping, valves, fittings, and connections will be Vol. II
designed to withstand stresses resulting from opera- p.6-11
ting and transient pressures, as well as stresses
resulting from the support system, external loads and
temperature changes."

"The arm ends will be provided with hydraulic actuated Vol. II
couplers designed to withstand safely internal p.6-12
pressures and mechanical loadings."

"The terminal dispatcher will open and close the Vol. II
proper tank manifold valves to-the onshore storage p.6-202
facilities and when all is ready will give clearance
to commence unloading by activating permissive circuits
that will allow the dock supervisor to open the marine
unloading arm isolating valves. The tanker crew will
then be advised to start the ship's pumps."

"After cargo has been unloaded and all pumps have Vol. II
@stopped, the unloading arm and tank manifold valves will p.6-202
C,
be closed. The unloading arms will then be cleared of
oil and disconnected from the ship's manifold."

"Oil spill probabilities are estimated for both opera- Vol. III
tional and casualty-related spills based on statistics p.2.11-4
from the 1971-1972 world tanker fleet data base. To
account for possible variations from site-specific
factors, environmental conditions (fog, waves, and so
forth), operating conditions (navigation controls,
traffic levels), and geographic conditions (configu-
ration of the Strait of Juan de Fuca and Port Angeles

harbor) are analyzed. Similarly, the risks are anal-
yzed using different assumptions in the data base. The
results of theseanalyses confirm that use of the 1971-
1972 data base provides the most conservative risk
analysis, even accounting for site-specific factors."

'Turing 1971 and 1972, the USCG reported a nationwide Vol. III
total of 624 vessel-related harbor spills of crude oil p.2.11-5
and refined products, includiilg a nationwide total of
1,000 barrels or less.of crude oil.."

"A USCG study of oil cargo transfers from tankers and Vol. III
barges (Leaotta and Taylor 1973) found that the quantity p.2.11-6
of oil transferred has little bearing on the probability
of an accidental discharge because it is during hookup
and disconnection that most discharges occur. Operational
spills are more accurately related to transfer operations
or vessel calls-than to volume of oil handled on this
basis. "

For Port Angeles harbor and its approaches:

"Environmental factors most likely to influence 1101. 111
accident statistics are incidence and extent of fog, p.2.11-21
severe storms, and extreme wind and wave conditions.
Other influencing factors include hazards from
military operations and collisions with fishing
vessels or nets. Where appropriate, an attempt is
made to identify those mitigating measures or
counterposing influences-that might lessen the
risks.

DISCUSSION:

Loading arms and other equipment associated with tanker-to-pipeline
oil transfer should not be a source of large oil spills. The
specifications of piping, valves, and connections to be used for
the unloadina arms and the anticipated stresses on them are not
provided and a review of the design of these-items cannot be made
until they are provided. However, the reviewers assume that NTTPC
will apply API standards and other safety standards to their
engineering designs. A description of the communication pattern
to be established between ship and dock (specifically ship's crew
operating ship's pumps) is not provided. The propose@d communica-
tion standards should be addressed by NTPC.

The likelihood of oil escape during vessel unloading operations
has been adequately considered in the NTPC Application. NTPC
proposes continuous enclosement of the area around the unloading
-platform with oil containment booms during oil transfer operations.

A major spill in the harbor due to collision, could result in
serious environmental and property damage. The capability of
cleaning up oil spills by mechanical means is essential, as it is
unlikely that permission would be given to use chemical dispersants
and natural flushing of the harbor is slow.

There are a few areas in the world where nature takes care of
pollution problems in oil ports. One of these is at Milford Haven
in Wales. This is a major deep-water port and is often quoted by
the oil industry as being a good example of a lack of environmental
damage from oil spills along a major enclosed waterway subjected
to heavy tanker traffic. The Haven which is the approaching
waterway to Milford Haven is very deep water with 25 ft. tides
(Dicks, 197S). Due to this flushing action and to the general
acceptance of dispersants in the U.K., chemicals are used widely.
The dilution effect of the large water body and the tidal movement
results in little concentration of oil that could cause environ-
mental damage. However, Port Angeles Harbor is not a comparable
situation.

The data base for the NTPC risk analvsis is the historic record of
oil spills in the Puget Sound (1969-197S, Fig. A6-2) area and
world tanker fleet losses in U.S.A. waters for 1971-72. The
reviewers conclude that use of the Puget Sound data is not really
relevant since few larger tankers entered the area during the time
the figures were obtained (Re: Fig. A6-3), and that the latter
world figures are out of date. Much more recent tanker casualty
figures involving world tanker fleet data on a global
scale, indicate an increase in the number of incidents involving
large tankers (Lloyds accident Bulletin, 1977-79).

The reviewers recommend that NTPC carry out a much more compre-
hensive spill risk analysis than has been computed to date.
Such a review should use the latest world shipping accident data
available and take into account at.least the eleven factors listed
by a group known as the Oil Companies Tnternational Marine ForLun.
This group is made up of world shipping representatives with wide
operational tanker experience. (O.C.T.M,.F., 1979)

These factors.were concluded by this group as having the main
influence on an evaluation of the risk of an incident along

TANKER CASUALTIES vs. DISTANCE TRAVELED
FOR, EIGHT PORT SYSTEMS 1969-1975
210- Tankers@>5,000 Gross Tons; Pori'Calls>118 IDraft
r*= o.785 AU
x = 0.000115
AU= 0.000195
ALC 0.000035

180-
*Adjusted for small sample size

New York

150-
Gulf Coast

120-

Delaware.

Cr
UJI go-

LL.
0
I= 60-
W San
Francisco
Chasa a 0
D
Z Greater
Puget
30 .- Los Z
Angeles

Bost

0
200,000 400.000 600,000 800,000 1.000.000 1,200,000 1.400,000
DISTANCE TRAVELED IN NAUTICAL MILES 0 1 W
Fig. A6- 2

Fig. A6-3

CRUDE TANKER ARRIVALS-PLUS DEPARTURES
THROUGH STRAIT OF JUAN BE FUCA AND SOUTHERN
ROSARIO STRAIT
SOURCE: SEATTLE CHANIBER OF CO@f--IERCE; SHIPPING

500 SMALL TANKERS - OCW ESTIMATE

400

cc
LARGE TANKERS - BASIS
300:-
ANNOUNCED PLANS

D
_j
CL

200

cc 21 YEAR AVERAGE
< 1954 TO 197
ui
@e - - - - - - - - - - -
z
100

NOTE
(E) ESTIMATED FROM FIRST
t 8 MONTHS OF 1975
0
1950 1955 1960 1965 1970 1975 1980
YEAR

11/10/75

world tanker routes. They are:

1) Traffic density
2) Crossing traffic
3) Width of navigable area
4) Varying visibility and weather
S) Navigational constraints (shoal waters, rocks, islands, etc.)
6) Routing Systems/Traffic Advisory Systems
7) Rounding of headlands
8) Navigational Aids (human)
9) Navigational data
10) Hydrographic data
11) Nature of bottom

Such an as sessment should also consider the following factors more
site-specific to Port Angeles:

Negative Factors

1) Bad weather conditions relative to visibility, frequent fog
along southly in bound traffic lane.
2) No mandatory traffic control at present.
3) No pilot untilvessel reaches Port Angeles.
4) Narrow shipping lanes.
5) Rocky shores would damage grounded vessel.
6) No salvage tugs available capable of refloating grounded VLCC.
7) Single screw vessels.
8) High tides and currents.
9) Approximately 50% foreign flag vessels.
10) Oil spill clean-up on water extremely difficult.
11) Earthquake and tidal wave area.
12.) Sensitive biological environment.

Positive Factors

1) Relatively low traffic concentration (cf. English Channel, Thames
River, Europort (Rotterdam)).
2) Radar surveillance.
3) Deep water.
4) Relatively protected waters from heavy storms .
S) Hydrographic data good.
6) No islands or other obstructions near to shipping lane.

In conclusion, it is of interest to note that that the statistics shown
in the publication (O.C.I.M.F., 1979) indicate that tanker accident
probabilities in the United States are greater than the world average,
and that 92% of all accidents occur in port. The reviewers' concern
is not with the small spills from transfer operations or small tankers,
but the fact that Port Angeles will be the first port in the U.S.A.
to receive VLCCs if the NTTPC proposal is accepted. Other sections
of this report point out the difficulties in handling such vessels
within the port area which compounds the probability of a collision
or grounding resulting in a major oil spill.

A7) Design of the Proposed Surge Relief Tank

EXPIANATION:

The surge reli 'ef tank plays an important role in preventing oil spills
during vessel unloading operations.

BACKGROUND - NTPC APPLICATION: SOURCE

"The system will consist of a fast-acting relief valve Vol. II
on each unloading line set to relieve at pressures p.--.6-15
slightly greater than normal operating'pressures and
a tank for receiving crude oil diverted.through the
relief valves. The tank capacity will be designed to
contain six minutes of ships' discharge at the rate of
100,000 bph (10,000 barrels) and will be located at
distances from adjacent facilities in accordance with
applicable code requirements."

DISCUSSION:

The following statement has been taken from the testimony of Mr. N.
Tilden: "The surge (relief) tank may be larger than necessary, but we
have not yet done an analysis by computer to determine this." The
important design criteria for the surge relief tank are not discussed
in the documentation or the testimony reviewed. In fact, it appears
that the surge relief tank sizing was based on the space available
for it. The experience at other oil ports with surge relief tanks,
i.e. sizing, design, frequency of utilization, problems encountered,
etc., is not discussed. The surge relief tank design criteria
requires better explanation. This is an issue which can be easily
resolved by engineering design.

@The following points are worthy of consideration:

1. Procedures are not outlined for action to be taken if surge
discharge exceeds 6 minutes in length (i.e. where would excess
crude oil be directed);

2. The basis for the 6 minute retentiondesign parameter is not
clear;

3. The specifications of the "fast-acting relief valve" are not
provided nor are the anticipated surge pressures. The capability
of the relief valve will depend on the peak pressures to which
it will be subjected;

4@ If the "applicable code requirements" are known and understood,
the distances of the relief tank from the proposed facilities
should be defined.

A8) The "Butler Marine Terminal Simulator"

EXPLANATION:

The operation of a marine terminal requires a coordinated scheme
capable of.integrating ship and shore activities, without significant
operational delays. The scheme should be versatile to contend with
unforeseen delays.

BACKGROUND - NTPC APPLICATION:
"The purpose of the program is to enable the user SOURCE
to make informed design judgments; the program Butler Marine
itself makes no such judgments, but merely reports Terminal Simulator
the effects of different design and operating (version II)
assumptions on terminal performance."
P.1
"At the time of this writing the use is limited to p.3
a maximum of:

1) four berths
2) four liquid types
3) ten tanks per liquid type
4) one pipeline

"An inbound tanker will advise the terminal by Vol. II
ship to shore radio link of its estimated time of p.6-201
arrival 24 to 36 hours from port."

DISCUSSION:

It is important to note that the simulator does not indicate consequences
to tanker traffic of prolonged or unforeseen delays. The model user
must estimate harbor and other delays which might affect terminal
operation and presumably must recommend arrival patterns for in-bound
traffic. Consequently, the user will have no model by which he can
guage the impact on shipping lanes or anchorage sites for the
recommended arrival pattern change.

The Marine Terminal Simulator (Version II) paper is extremely
general and therefore open to numerous questions of both a specific
and general nature. For example, it is not apparent whether the
Butler Marine Terminal Simulator has been used at other oil ports and,
if so, how effective the program was in predicting important port
operating criteria. In the text that follows,.statements taken from
the Marine Terminal Simulator, Version II are presented; questions,
with respect to each of these statements are provided:

Statement 1: "The purpose of the program is to enable the user
to make informed design judgments; the program itself
makes no such judgments but merely reports the
effects of different design and operating assumptions
on termi nal performance."

Comment: The human element involved in design
ju-dgment is evident. The qualifications and
experience of the person or persons making the
judgment is very iinportant and should be
questioned.

statement 2: "Ships arrive according to a pattern specified in
advance by the user."

Comment: How does user arrive at the pattern? What
@F @es of delays are taken into account in the program?

'Statement 3: "When a ship is cleared for berthing and berthing
delay is allowed to pass before the ship begins to
unload."

Comment: What are the critical factors involved in
@Fe-termining what aberthing delay consists of? How
is this berthing delay incorporated into the simulator
program? Other potential delays such as terminal
equ.roment failure or emergencies, weather extremes or
labo@ disruption do not appear part of the simulator
model at its present stage of development.

Statement 4: Program Output:

Under the "Program Output" heading a list of "Input
Items" is presented. Input Items 2 and 4 are note-
worthy. Item 2 stipulates initial pipeline start-up
delay; Item 4, berthing and deberthing delay times by
liquid type. These so-called "input items" are
difficult variables to come to grips with. Since these
input variables are subject to the judgment of the user,
the output from the program is subject to questioning.

Overall Conclusions:

Based on the very limited information presented, it is impossible to
determine the value,of the Butler Marine Terminal Simulator. It
is most important to have Northern Tier address the previous
situations during which the Simulator was used, and to relate the
situations involved to the proposed development of the Port Angeles
harbor. It. appears that the Butler Marine Terminal Simulator can
best be classified as an indicator of port activities during a period
when all activities are occurring as planned; the ability to
,accomodate unforeseen delays does not appear to have been allowed
for in the simulator sketA provided.

A9) Vessel Crew Unl2ading N1onitoring and Oil Spill Response Capability

EXPLANATION:

During unloading operations, trained crew members should be on duty
to help monitor operations and provide on-board support as required.
Oil spills resulting from unloading operations can be attended to
most quickly by vessel crews. The capabilities and preparedness of
tanker crews will vary.

BACKGROUND - NTPC APPLICATION:
SOURCE
During unloading operations and upon clearance
by the terminal dispatcher to commence unloading Vol. II
"the 'tanker crew will then be advised to start the p.6-202
ships' pumps".
"After cargo has been unloaded and all pumps have Vol. II
stopped, the unloading arm and tank manifold valves p.6-202
will be closed. The unloading arms will then be
cleared of oil and disconnected from the ships'
manifold. Concurrently, the final gmaging and
checking of ship's tanks will be accomplished".

DISCUSSION:

The crew of the vessel unloading oil could play a significant
role.i-n the early detection of a spill and responding to the
spill in an appropriate manner. In the NTPC documentation, no
indication is given with respect to the role of the crews in
monitoring unloading activities and responding to oil spill
situations. This subject should be.addressed. In addition, the
corflmunication system between the tanker and shore based personnel
should be described.

International tankers do not carry oil spill equipment on board
and crews are generally not trained with respect to their roles
during an oil spill. There is no indication in the documentation
that the Port Angeles terminal facilities would have more stringent
requirements with respect to the subjects discussed 'above.

A10) Overview of Proposed Tank Farm.

EXPLANATION:

Tank farm design must conform to standards necessary for adequate
public safety-and acceptable environmental impact risk.

BACKGROUND - NTPC APPLICATION:
SOURCE
The onshore storage facilities "will be constructed Vol. II
on a site approximately 6 miles east of Port Angeles p.6-32
near Green Point. The facilities will include the
storage tanks and appurtenances, piping systems,
oil-water seperators, oil measurement facilities,
a control building, environmental controls, support.
facilities, and services".

"Storage tanks will be constructed in phases to Vol. II
accommodate the anticipated growth in terminal p.6-35
volumes and to provide gross storage capacity
approximately equal to ten days of average daily
volume. Tanks and appurtenances will be designed,
fabricated and tested in conformance with the
requirements of applicable standards and codes."

"The proposed storage tanks each will be 28S feet Vol. II
indiameter with a shell height of 56 feet. The p.6-35
tanks will be equipped with floating roofs having
primary and secondary seals ...

"The filling lines and manifolds will be designed Vol, II
for the maximum tanker unloading rate of 100,000 p.6-37
bph rate with acceptable pressure draft."

"The design, material fabrication, and erection of, Vol. II
the storage tanks will be performed by a tank p.6-143
contracting specialist. Material fabrication,
forming, and cutting the steel plates will be per-
formed by the tank contractor at a fabrication plant
prior to delivery."

"'Facilities to be constructed or installed by the Vol. II
mechanical and electrical contractors will include p.6-145
oil water separators, fire fighting equipment,
utilities, power supply, communications system,
controls, and instrumentation."

"The marine terminal operations will be controlled Vol. II
and monitored from the main control center located p.6-197
at the onshore facilities near Green Point-.
Terminal dispatchers will be in charge of the tanker
unloading and onshore storage facilities."

DISCUSSION:

The basic design and construction plans if carried out to API and
other applicable standards, represent an acceptable engineering
risk. Foundational designs are well within the precedents that
have been established. The interglacial soils at the site do not
appear to be a problem as foundation material.

Although accidents do happen at tank farms (Section-M) resulting
in fires, explosions and/or oil spills, tank farms in general
have a good operating record.

2.2 TRANSIT AND MANEUVERING OF VESSELS

All) Terminal Facility Interaction with Navigational Hazards and Port
Angeles Harbor Traffic

EXPLANATION:

Existing navigational hazards and harbor traffic accident risks will
be compounded by the placement of an in-h,arbor terminal facility and
by associated terminal tanker traffic.

BACKGROUND NTPC APPLICATION: SOURCE

"The harbor is approximately 3 miles long by over 1 Vol. II
mile 'Wide at its entrance. Its deepest water, shown in p.6-3
Figure 11-6.1-1 is adjacent Ediz Hook, where depths up
to 100 feet occur within 600 to 700 feet off the
southern shore of Ediz Hook and extend 2,,000 to 3,000
feet across the harbor area.."

"According to the COE, approximately 3,500 vessels with NTPC
a maximum draft of 39 feet entered and departed Port Vol. III
Angeles Harbor in 1976." p.1.14-9

Total traffic recorded by the U.S. Coast Guard VTS in Vol. III
1977 was 1S,,216 "which represents about 95% of the p.1.14-15
estimated traffic in the Strait (Butler Associates Inc.,
1978).11 This figure represents the number of vessel Vol. III
movements not number of vessels. p.1.14-14
EFSEC
P-2-132

Vessel types recorded by the VTS include Vol. III
"Freighter", "Tanker", 'TTug", "Goverment" "Ferry", p.1.14-lS
7%iisc.11; sepcific reference is not made to fishing
v,essels. However, in reference to the same figures,
the EFSEC Draft Environmental Statement states:
"In addition,, there is an unknown number of transits EFSEC
by private craft and commercial fishing, boats which p.2-102
are not recorded as part of VTS." In reference to
log carriers, "because of the seasonal nature of log Vol. III
shipments, periods of considerable congestion and p.1.14-14
ship queuing have occurred when volumes are on the
order of 100,000 tons per year."
Projected design capacity tanker calls I-1w ill Vol. 'III
generate 433 port calls per year, (395 crude P-2.14-18
oil and 38 fuel oil tankers)" and "service Vol. III
times for this level of tanker calls will incrase p.2.14-18
average waiting time to 40% of service times "or
approximately 12 hours".

"At least one line handling launch will be provided Prefiled
by Northern Tier. Others, when needed, will be Testimony #1
available, on a contract basis. Tug service will be Tilden p.10
provided by others; however, before beginning
operations Northern Tier will insure that a sufficient
number of properly sized tugs are available."

."I expect that a fleet of three to four tugs will Prefiled
be required and they would be likely based in Port Testimony
Angeles Harbor." Bader p.3

"On a daily basis the Northern Tier project would add Prefiled
about 2 or 3 vessel movements to the existing traffic Testimony
and thus increase vessel traffic to about 53 or 54 Bader p.3
vessels (based on 1978 statistics)."

DISCUSSION:

1. No indication is made of a marker system (buoys, or guidance
lights) for the entry of and/or maneuvering and anchorage of
VLCCs. The absence of a marker system will leave the place-
ment of tankers in the maneuvering and anchorage areas up to
pilot knowledge of the area and depth soundings. However, the
placement of buoy marker systems (as opposed to guidance lights)
could create hazards for smaller vessels trafficking in the
area.

2. The possible influence of tidal currents on anchoring and
maneuvering of tankers has not been addressed. The harbor is
described as having complex pattern of tidal currents, and
westerly winds which "tend to drive floatable materials east-
ward and southward toward shore." (NOAA,.1978).

3. U.S. chart 18468 shows sand in portions of the proposed
anchorage area. Very fine, loose silty sand areas have been
identified in the NTPC Application (Vol. II, p.6-133) as
occurring off Ediz Hook. Vessels anchored in sand could drift
eastward and southward during strong northwesterly wind
conditions.

4. Anchorage by VLCCs in the harbor as described in the NTPC
proposal is difficult to accomplish without a double anchor
system. This problem has not been sufficiently researched
by NTPC. A possible double anchoring system is shown in
Figure All-1, note that tide changes would cause vessel rotation
around both anchor cables in this diagram.

A vessel of some 300,000 DIT and having a length of 1,113 feet
will require at least a minimum length of cable of 900 feet.
(equal to 10 shackles or "shots") to lie securely at anchor.
The diameter of the swinging circle required would therefore
be a minimum of some 2,000 feet.

PROPOSED MANEUVERING
AND ANCHORAGE AREAS

MANEUVERING AND ANCHORAGE
ZONE (LOWER PROBABILITY)

PORT
ANGELES

FIGURE All-I DOUBLE ANCHORING SYSTEM, PORT
ANGELES HARBOUR.WITHIN N.T.RC.
MANEUVERING AND ANCHORAGE AREAS

600 600 1800 3000 4200
!!Niiia
0 1200 2400 3600
SCALE IN FEET

Allowance must be made for vessels berthing or unberthing from
the oil docks and for vessles 1-ying alongside atthe docks
ja 300,000 MIT oil tanker has a beam of some 175 feet).

Figure 11-6.1-1 "Tanker Unloading.Facilities in Port Angeles
Harbor" in the NTPC Application shows a berth area of some
1,300 feet width, giving sufficient width for vessels maneuvering
into or out of the berths. This plan also shows a '!most probable
tanker maneuvering and anchorage area" and a "tanker maneuvering
and anchorage zone (lower probability)" of a total approximate
width of 3,000 feet.

Half of Port Angeles Harbor (U.S. Nautical Chart 18468) is less
than 13 fathoms (78 feet). Depths in the lower zone are 11 to
13 fathoms (66 to 78 feet). A 300,000 DIff.oil tanker draws 82
feet, therefore the lower zone is unavailable to larger vessels.
From these facts, it would appear that a safe swinging circle
of 2,000 feet is difficult to obtain unless the vessel anchors
well to the north in the anchorage area. A large vessel might
,then swing dangerously close to the oil berths and any vessels
which happen to be alongside them.

Since the space is so limited, this would call for very precise
placing of the anchor by,the pilot of any large vessel proceeding
into the anchorage. This would be very difficult if not impossible
for the pilot to accomplish noting that the bridge of a vessel is
situated well aft and a long way from the anchor. The vessel is
very difficult to maneuver and the vessel direction will be affected.
by.local harbor currents.

Other features of the harbor which might inTede docking procedures
should be noted. Port Angeles is a busy harbor with considerable
ferry and other traffic. Log booms in the vicinity are relatively
unmaneuverable and move at very slow speeds when towed.

S. A large vessel anchoring or maneuvering within the narrow confines
of the harbor would severely restrict the maneuvering room.avail-
able to other vessels. Such a problem would be compounded in the
event of poor visibility; the Application acknowledges that fog is
a frequent occurrence inthe Port A Ingeles area, particularly during
s=ier -.ionths. A Devanney et. al., 1979 review of marine collisions
has found visibility to be -crit7l-cal and that statistics show low
visibility collision occurrences to be 1,000 times greater than high
visibility collision occurrences; such collisions are noted to
occur even after radar detection has been made.

Oil transfer lines are proposed to the storage facility at Green
Point.. Restriction on the use of anchors is likely to be imposed
in this area. This could inhibit large vessels which have problems
Z@
of machinery or steering gear failure on entry in the harbor.

6. a). References are made in the NTPC Application to anchorage
sites outside of the harbor. G. Bader, in his testimony
for Northern Tier states.that "although Port Angeles harbor
could be used as an anchorage, it appears more likely to me
that regulatory agencies would designate an anchorage area
outside of Port Angeles harbor for the Northern Tier tankers".
However, under cross-examination, Bader indicated that no
analysis of alternate anchorage sites has been conducted or
is under consideration. The following questions should be
addressed by,NTPC to clarify this situation:

i) what areas outside Port Angeles will be used for
alternate anchorage sites, if congestion in the
harbor requires vessels to move elsewhere?

ii) if tankers use alternate sites, how will they
anchor and what kind of assistance would they
require in the event of break-down and/or anchor
dragging?

iii) what penalty system would be imposed if vessels
anchoring to the east of Port Angeles harbor
inadvertently anchor in or drag over the sub-
marine unloading pipeline?

iv) where will Puget Sound refinery tankers lighter
in the event that they are required to anchor
outside.Port Angeles harbor?

b) For tankers anchored in the harbor, the anchoring system
used should be described, i.e. how many anchors, deployed
in what configuration.. The possibility of successive arrivals
of log ships, NTPC tankers and Puget Sound refinery tankers
has not been addressed nor has an overall traffic management
scheme been suggested.. As well, the type of communication
link between the terminal disDatchers and VTS personnel is
not presented.

Northern Tier should be definitive in its use of Port
Angeles harbor as an anchorage site, to prevent confusion
by incoming vessels as to whether their occupation of
harbor deep water areas will be condoned in emergencies
and/or accepted as an habitual occurrence.

7. Given existing traffic patternsidentified. by NTPC and potential
hazards created by VLCC tanker movements in the harbor area, the
design and implementation of a master harbor management scheme
should be considered. With such a plan, scheduling of harbor
use by other concerns could be made in regard to seasonal and
daily use by NTPC and NIITPC could gauge its' harbor activities
to the use of Port Angeles harbor waterways by other vessels.

A12) Safe Anchorage Sites

EXPLANATION:

During emergency situations, safe anchorage areas for vessels in
distress are critical. For VLCC1s which are limited to deep anchorage
locations, it is essential that the suitability of nearby safe
anchorages be known in advance of emergency situations.

BACKGROUND - NTPC APPLICATION:
SOURCE
"Alaskan crude will generally be transported in
.50@000 5fF to 165,000 DWT tankers. Persian Gulf Vol. II
crude will generally be carried by larger tankers, p.6-6
ranging in size from 200,000 9VT to 300,000 DWT11.

Based on DWT class characteristics described in the Vol. II
application "the water depth required for a loaded D.6-6
300,000 DWT class tanker is 90 feet.".

DISCUSSION:

A discussion of safe anchorage sites is not included in the NTPC
application. The testimony of Mr. G. Bader with respect to this
subject is relevant and is summarized below. Mr. Bader stated that:

1. no studies have been carried out by NTPC;

2. no studies are being planned by NTPC;

3. information on four sites, Neah Bay, Pillar Point, Clallam Bay
and Freshwater Bay, is available (these sites were considered
for the oil port and rejected due to proximity to shipping
lanes);

4. simulation of the Northern Tier operation may 8how a need for
anchorage.

It is important to emphasize that at some point in time, regardless
of how well tanker traffic can be progranned, tankers will be required
to drop anchor in or near Port Angeles harbor. The acceptability of
a parti'cular anchorage site will depend upon a number of-factors
including the draft of the tanker, capability of the ocean bottom of
holding an anchor, wind conditions, tidal and current conditions etc.
It is essential that NTPC develop a plan for the safe anchorage of
vessels under a number of operating variables. Potential anchorage
sites such as Clallam Bay, Pillar Point and Freshwater Bay may have
one or more of the following deficiencies:

1. do not have suitable bottoms at depths at which VLCC1s would
drop anchor;

2. are exposed to winds from the west, i.e. the prevailing winds;

3. ships at anchor would be in close proximity to the ship traffic
lanes.

With respect to item 1, it is possible that permanent anchorages
could be constructed. However, to date, N7PC have not addressed
this subject.

A13) A Review of Operating Procedures of Tankers in the Strait
ot Juan de Fuca and Fort Angeles Harbor

EXPLANATION:

Safe Operating and docking standards are essential for large
vessels such as VLCC1s in confined and often unfamiliar coastal
areas.

BACKGROUND - NTPC APPLICATION: SCURCE

"An inbound tanker will advise the terminal by ship-to- Vol III
shore radio link of its estimated time of arrival 24 to p.6-2
36 hours from port. Such notice will usually include
requests for bunkers, water, ship's stores, and tug
assistante and will provide any information regarding
the cargo or ship's condition that would affect the
berthing and unloading operations."

"A sufficient number of adequately sized launches will Vol. II
be made available on site. The launches, together with p.6-22
.the fireboat and separate oil spill -recovery vessel,
will be moored at a small dock constructed in the
vicinity of the tanker berths".

"The number and sizes of tugs required for berthing the Vol. II
tankers at the unloading facilities will be determined p.6-22
following discussions with prospective shippers' marine
departments".

'I expect a fleet of three to four tugs will be required prefiled
and they would likely be based in Port Angeles Harbor". testimony
of Gerald
"The harbor area is felt by the applicants to provide Bader p.3
"ample room for maneuvering and turning the largest
expected tankers, whether in ballast or fully loaded.- Vol. II
Figure 11-6.1-1 illustrates the probable harbor space p.6-3
to be used for tanker maneuvering and anchorage.".

DISCUSSION:

The application provides no details of procedures to be followed for
maneuvering and docking tankers. The numbers and sizes of tugboats
are left open to future consideration This could be important
if simultaneous berthing and deberthin*g operations occur, particularly
during inclement weather. To dock the larger vessels up to 327,000
MIT would require three 6000 horsepower tugs. These tugs would
pi-obabl), be required onlv once a day although they could be required
more ofien as throughput capacity is reached and successive arrivals
of crude and bunker tankers surpasses one a day.

It will be possible for large vessels to anchor or wait outside the
harbor and to enter when the berth becomes available. A large vessel
entering on a draft of 80 feet will be required to pass close to the
eastern point of Ediz Hook. To avoid too sharp a turn into the harbor,
the vessel would turn well offshore and approach the entrance on a
course of approximately 2300 True. After rounding the spit buoy, the
vessel would turn onto a course of 2700 and thence proceed to the berth.

During the maneuvering and while the vessel was picking up her tugs
and lining up for the berth, it would be necessary to apply traffic
movement limitations. This would avoid the risk of collision. Entry
and movement of tankers within the confines of the port should be
banned during times of poor visibility.

Problems of Entry

In the event of strong winds creating swell conditions outside the
harbor, it might be difficult for tugs to get alongside and secure
until the vessel was under the lee of Ediz Hook. In such weather
conditions, the vessel may have to keep up a minimum speed of say,
three knots, to maintain steerage. The average large tanker has
only a proportion of ahead power of roughly,30/40% for astern use.
Even with the help tugs, it would be difficult to slow and stop the
vessel and line up for the berths in the short distance available after
passing the spit buoy. Other vessels in the harbor area would be at
risk of collision.

A further point to consider during port entry would be the possibility
of sudden machinery or steering gear failure as the vessel was rounding
the spit. Provided tugs of adequate power were available, control of
the shi-D should be retained. However, it would be difficult to use
vessel astern power, if required, should vessel steering gear fail
because the rotation of the propellor would cause the vessel to proceed
in an arc.

Problems of Exit

In Section 6.1.6.3 Emission Control, of the NTPC Application, the
following is stated: "additional ballast beyond 20% of tanker DIVT
will be taken into cargo tanks only after the ship is clear of the
harbor and Port Angeles vicinity. Tankers without segregated ballast
will be limited to a maximum of 20% ballasting while in Port Angeles
harbor."

The restriction of 20% seems very small if due allowance has to be made
for maneuvering in moderate wind strengths. This gives a 300,000 DWT
vessel a ballast weight of only 60,000 tons and a probable mean draft
of approximately 30 feet. The ensuing free-board would thus be 75
feet, providing a huge sail area. Such a vessel would be difficult
to handle in winds of even moderate strength. This could cause problems
for the pilot, particularly if vessels are anchored within the proposed-
tanker anchorage zone.

Other points for consideratio n of vessel operating procedures are:

1. It is not indicated whether the tugs decided upon will be
capable of dealing with VLCC distress situations during
heavy seas in the Strait of Juan de Fuca.

2. It is not indicated whether some tug service will be reserved
for exclusive use by Northern Tier Tankers, or if tugs will
be in general use (specifically for assisting log carriers).
The financial arrangements for tug operation could influence
the tug availability.

3. The mandatory imposition of the vessel traffic management
scheme for Juan de Fuca Strait would be necessary to increase
tanker traffic passage to a safer level. The present traffic
separation scheme leading to Port Angeles Harbor,is shown
in Fig. A13-1. The location of major vessel collision and
groundings (1954 to 1973) near Port Angeles Harbor are shown
in Fig. A13-2. The critical significance of poor visibility
as a factor in marine accidents is discussed in Section All.

BONIL
POINT

SAN
JUAN
POINT

olp TORI
Of
SHERINGHAM
:POINT LIGHT
'c'JC.4
CA PE ALERT
HEAD
FLATTERY
ZOA.,
7.

KYDAKA
POINT CHURCH
POINT 4@,
00
S@p -LONE
=oNE
SLIP
POINT
LIG PILLAR
POINT

11,10 T
ANGELES

LEGEND Fig. A13-1 STRAIT OF JUAN DE FUCA TRAFFIC
LIGHTS & REPORTING POINTS SEPARATION SCHEME
ISource: Canadian Hydrographic Chart 3607
DIRECTION OF TRAFFIC SCALE 1: 52.5,000

15 MILES
PRECAUTIONARY AREA
0 5 10 15

-.7 --BRITISH COLUMBIA
WASHINGTON

AR CO & MOBIL

VANCOUVER
ISLAND

0
.71

'SHELL It TEXACO
op
.. rl
0 Of
0
0
0

PACIFIC
OCEAN

OLYMPIC
PENINSULA
PORT ANGELES'
(PILOT STATION)

LEGEND MAJOR COLLISIONS &GROUNDINGS IN NORTHERN
0 VESSEL COLLISIONS Fig. A13-2 PUGET SOUND - JAN/54 TO JUNE/73
Source': U.S. Coast Guard and Pilots Association
0 NOT RESEARCHED SCALE 1: 841,000
40 VESSEL GROUNDING
25 MILES

REFINERIES
0 5 10 15 20 25

A14) Non-English Speaking Crew Misha-D-Relationships

EXPLANATION:

The wide use of multinational crews has created communication
difficulties on a number of occasions. In North American waters,
English speaking capability is essential for the quick and clear
conveyance of important messages.

BACKGROUND NTPC APPLICATION:
SOURCE
"The composition of the tanker fleet arriving at
the tanker unloading facilities will largely depend Vol. II
on the origin of the crude cargoes." p.6-6

DISCUSSION:

There have been accidents involving ships where a foreign language
communication problem has contributed to the incident. Records of
such problems exist for ports in the Vancouver, B.C. area. However,
such incidents are usually related to oil transfer operations
between ship and shore. English is the international language of
shipping. Officers of all flag ships must pass an English profic-
iency examination as part of their certification. In the judgement
of ship's masters with long sea experience, language communication
is not a major problem (Captain R.W. Lumsden, MarineConsultant and
Captain M.L.M. Jolivet,, Navigation and Safety, Shell International
Marine Limited,, May 1980, pers. comm.). However, problems do occur.
Two recent incidents of communication failure between tanker vessel
crews and U.S. Coast Guard personnel have occurred in the Strait of
Juan de Fuca. In October, 1976, the White Peony was found using the
outbound traffic separation lanes while inbound. Correction of the
situation did not occur until hours had passed because of the inability
to communicate course instructions. One month later (November, 1976),
the Warbah was found in a similar si,tuation., managing to move inward
60 miles along the outbound traffic lane before being boarded by a
pilot in Port Angeles.

A15) In-Transit Vessel Assistance Procedures.

EXPLANATION:

The type and degree of assistance provided in-transit vessels is
related to the risk of mishap to which the vessels will be exposed.
The existence of traffic control systems, radar surveillance, the
use of pilots.and tugs etc. are relevant to this topic.

BACKGROUND NTPC APPLICATION:
SOURCE
"An inbound tanker will advise the terminal by ship-to
shore radio link of its estimated time of arrival 24 Vol. II
to, 36 hours from port. Such notice will usually p.6-201
include requests for bunkers, water, ship's stores,
and tug assistance and will provide any information
regarding the cargo or ship's condition that would
affect the berthing and unloading operations".

"The number and sizes of tugs required for berthing Vol. II
the tankers at the tanker unloading facilities will p.6-23
be determined following discussions with prospective
shippers' marine departments. The ordering and pay-
ment for tug services will be each ship's responsibil-
ity. Private companies presently service the Port
Angeles area. Requirements will be discussed with
these companies to ensure that adequate tug service
will be available when construction of the facilities
is completed."

"The theoretical average waiting time for initial Vol. III
tanker traffic will be 20% of the average service p.2.14-lS
time; that is, time to berth, unload, and deberth,
and ballast, or approximately five to six hours per
ship (Swan Wooster Engineering, Inc. 1978). (Ave-rage
service times,, by comparison, will be between 24 and
33 hours per tanker). However, most tankers will
occupy much of this theoretical waiting time by
slowing down as they approach Port Angeles rather
than anchoring in the harbor.",

"According to estimates for the future capacity of the Vol. III
tanker unloading facilities, 'service times for this p.2.14-18
level of tanker calls will increase average waiting
time.to 40% of service times,, and some impedance may
occur unless additional berthing facilities are
provided".

DISCUSSION:

It is the understanding of the reviewers, based on discussions with
the Canadian Ministry of Transport, that:

1. The U.S. Coast Guard are currently tracking ships between Cape
Flattery and Port Angeles using a radio connunication-chart
plotting (dead reckoning plot) system;

2. A comprehensive radar system will be in effect in this area
within one year or possibly even sooner;
3. 'At the present time, pilots board vessels heading for Puget
Sound ports at Port Angeles, pilots do not board the vessels
west of Port Angeles;

4. Marine traffic control lanes are plotted on marine charts of'
the Cape Flattery to Port Angeles area (see Fig. A13-1) ' but
are absent between the base of Ediz Hook and Dungeness Spit.

The radar system being installed will greatly improve marine traffic
control and eliminate a great deal of the risk of ships colliding
or grounding, although such installations should not be regarded
as failsafe guarantees that accidents will not occur. This system
will be installed before the Port Angeles terminal is scheduled for
operation.

In the NITPC documentation and expert witness testimony, vessel
assistance procedures, especially as they apply to the Cape Flattery
to the entrance to Port Angeles harbor, are not dealt with in any
%degree of detail. The role of pilots and tugs for this portion'of
the voyage is not addressed. The experience of local pilots and
tugboat operators in bringing a VLCC vessel from Cape Flattery to
the terminal is also not addressed. It is important to note that
a number of recent marine mishaps have been blamed on the pilots.
This portion of the documentation requires considerably more input
from the proponents (i.e. defining the existing traffic control
system and inninent changes and improvements the system will be
undergoing) before a thorough assessment can be undertaken.
Although detailed information is lacking, it is apparent that the
U.S. Coast Guard improvements (i.e. the installation of radar)
will certainly improve the marine traffic control situation and
serve to reduce the risk of a major marine accident. Figure A13-2
shows the location of major marine accidents occurring between
1954 and 1973.

B. FIRE AND EXPLOSION HAZARDS

I VESSEL HAZARDS

Bl) Causes of Recent Vessel Fires and Explosions

EXPLANATION:

It is relevant to the NTPC Application to have good recent data
on this issue.

BACKGROUND - NTPC APPLICATION: SOURCE

"world tanker fleet data for 1971-1972 tanker explo- Vol. I.II
sions and-fires are shown in Figures 111-2.11-9 and 10, p.2.11-67
respectively. The graphs indicate that about half of
all explosions and fires on tankers occur at piers or
in harbours ... The probabilities of explosions and/or
fires on tankers at piers and in harbours per thousand
tanker trips is 0.06 and 0.17, respectively. These
data are taken from the USCG information (J. J. Henry
Company 1973)." Refer to Figs. Bl-l and B1-2.

"Figure 111-2.11-11 shows the shipboard location of Vol. III
explosions from the 1971-1972 data. Those explosions p.2.11-67
occurring in locations outside the cargo tanks are
often non-catastrophic and usually do not result in
oil spills or damage outside the ship." Refer to Fig. B1-3.

DISCUSSION:

The data presented by NTPC for 1971-1972 is too old to be of
maximum relevance to the application. The Lloyd's List of
Casualties for tankers over 10,006 DIff, 1977 to 1979 (Pig.
Bl-4) shows a significant increase in fir I
e and explosion
casualties. Note that data for vessels smaller than 10,OOODIVT
are not indicated by this list. There have 'heen 5 tecent
explosions of.tankers to date in 1980. Fig. Bl-5 lists
total losses of large vessels from January 1. 1979, and
again, smaller vessel data is not reflect@d in this list.
The increase in explosion causes has been attributed in part
to badly trained crews (Lloyd's News, S/6/80), particularly
in connection with inert gas system maintenance (see
Section B-2).

Total Casualties.
Polluting Casualties
From: Henry Company, 19,73
40 (12)

(22)
30 -(20)
(8)

(15)
20 (6)

(5)
10)

12)
(0)
0 Li--
Piers Harbors Entrances Coastal Sea Unknown

Northern. Tier Pipeline Co.

figure 111-2.11.9 Tanker Casualties
from Explosions for
1971-1972

Fig., BI-I

70 Total Casualties
Polluting Casualties
(21) From: Henry Company, 1973
60

Wk 40

(20)
20
(6)
13) (13)
(4)
10
(2)

(0)
0
Piers Harbors Entrances Coastal Sea Unknown

Northern lier Pipeline Co.

Figure 111-2.11-10 Tanker Casualties from
Fires for 1971-1972

Fig. BI-2

70
(20) Total Casualties
60 Polluting Casualties
From: Henry Company, 1973

(29)
40

(14)
(13)
20 Al
(5)

(7) (3)
10
(2)

0
Cargo Tanks Engine Room Boiler Pump Room Unknown

Northern Tier Pipeline Co.

F i gure I 111- 2. 11 - 11 Shipboard Location
of Expl.osions for
1971-72
o
--]73
pany, 19

L 1

111 -3
L

Fig. B1-4
JIji@@,@ qNr)
, I " I TitL -Ak60 AREA
L@t--LUSIOIC IN I U
OF TANKERS ML% 10,000 DWT REPOhThl, IN LLOYDS LIST
1977-1979
(excluding new construct -ion, uwlei- repair, br-eakers yard & pump roomfires)
(Source: Lloyds LLst, r)vr ICS ("asuaity Bulletins)

CASUALTY SHIP
INITIATING DETAILS COMMENT
S DWT BUI LT CONDITION HULL DEAD,& EVENT
DATE PLACE NAME/MANAGEko TYPE IGS' FLAG/KNGT. DAMAGE MI L; SN!-; POLLUT10N

th Jan. At Sea MARY ANN 72,152 1969 Ballast Extenstv e Explosion while cleaning
(off E. USA) Global Bulk Carriers 00 Lib/USA 11storage tank"
@.it Jan At Sea EXOTIC 1@2,719 1970 Lial last !@Fjrioub h Explosion in Noo.7,8,9&10
(N. itlantic) Nereus !;hIpping 01ju llb/Grk
2: th Mar. At Sea CLAUDE CONWAY 45,946 1957 Ballast CTL 12 Yes Explosion hull split iia two
(off C. Year) Cosmopolitan Shipping T Pan/USA
q 1, Lh Apr. lnland Sea A:;Tfiv IZO 88,@43 1976 Loaded Serious - Yes Collision Struck i.w.o. Nos.3&4 by
lono Lines T Pan/USA Crude 4,349 dwt cargo ship; fire Lr
th June Set$ GUNNY 17,537 1951 Bal last TL 2 Yes (Undertow); explosion split
Algot Joharisson 11 Fin/Fin hull in two
Maracaibo MAN HA,rTAN IjUKE believed ins
t Aug. 62,279 1976 Ballast ';eriuu:i 1 Jetty Contact Lxplosion and fire Tank
,;kukko steamEllip T 16- 1;ing/jap
i t;d Nov. At Sea MATSUSHIMA MkkUN0 77,159 1964 Ballast CTL Explosion; IP ruptured
S. of Japan Nippor, !:ujan kaifitai 11 Jap/Jap VA burnt out; taken in tow
after 3 days
Till Nov. At Sea MCUDUKE B2,644 196? Ballast Minor 2 Welding Explosion in tank
Mosvold -1hipping T Nor/Nor
off Venezuela)
't-1h Dec. At Sea VEN 01 L 330,954 1973 Loaded @erious 2 Yes Collision n re ford
Shipping IGS Lib/USL 23,000t
(off S. Africa) luterocean S
C, ji Dec. At Sea VENPET 330,869 1973 ha I last Serious Yes Collision Struck i.w.o. aft tanks;
(off S. Africa) Iriteroceaj, Sliipping 11 %S LiVUSA after 3,000t accommodation gutted
Crude

CASUALTY SH I P
INITIATING
DWT BUILT H111.11 VEAD & EVENT DETAILS COMM .T
DATE PLACE NAM@,,MANA@IEK; COND ITI oN POLLUTION
1'Y1'E 1GL; @'I.AGiMNGT. 1,AMAGE ML@ING

178
,nd Feb 1973 Fire in accommodation and on
L. Maracaibo IIASSIOPEIA 27,871 lallast VL
kathymnis Kul,ukundiv Oil,'Chem 6 rk/G rk deck; turned back. Explosion
blew 2 holes in side; sank

th Feb. Khorranshalir CYS INTEGH1111Y 29,500 1977 Discharg- Mitior Deck fire
Islaud Navigation T Lib/HK i;Ag
Naphtha
-th July Tg. Priok WiMINA 1011 13,712 1974 loaded Minor Fire spread At anchor; fire spread from
Indonesian (;ovt. 11 Lib/Indo produc tLj from VIC bunker vessel alongside to
alongside NolS

I th Aug. At @'ea ftlflut)]C 65,964 196b Waded Major Explosion in No.2 upper void
Nereus L;hippitLg t;bo Grk/Grk space; continued on voyage
Mobile - Italy
til oct. Kwiila Bay FEOSQ SUN 20,824 1960 Liallast TL 27 Yes At anchor; boat alongside
Feoso Oil T Pan/HK after inspecting hull damage,
crude explosions, fire, sank
i1st Dec. At Sea ANDEOS PATHIA 21B,661:, 1970 Lzaded CTL 34 Yes Hull Heavy weather, full fracture, 00
(B. of Biscay) United Shipping & 11 6rk/Grk Grude 5o,ooot f1meture explosion in ballast tank
Trading amidships-, lightened S. of
Azores

CASULATY SI i I P
INITIATING DETAILS COMMENT
LIVE PLACE NAME"MANAGEM UWT BUI L T .11;11 HiLLUTTON EvEm
TYPE. T6.; KAG/KNGT. JAMA61i" MI. IN(:

.,f 19
th Jan. Bantry bay 1'.'1,4@O 1968 Its. I las t- 51 yes Hu I I Broke back, deck fire,
'le ld-tle led @'r / Fr Ing after fra,: ture explosion
I . t 1%) ; t!:l ('rude
tl Feb. At @ea @,Allyi Cnkis j4,567 19 0 7 Ballast -erious Gas freeing; explosion/fire in
E.N. Atlantic OW 1-ib/ Nos. 7-11; accommodation
damaged.
ith Kar. At ';ea 11 i,*:T 114,144 19"? 1 lift I It.!, t. MI flur I ank c leaning; No. I hatch
CarlbLeaj, I it te rria L ioiai 1 .,b(- Lib i;rk covers blown off

"perati-alis
11 Apr. I Ne..-.eLi 12V-02 1@'/4 1" 1 lust I 'T 1, Yes 1 igotlking Explosions wtd fire; main
J*:-'@,!@:s et T IG" fib/?'z- deck i.w.o. Nos. 2 & 3 blown
JeS off, rest distorted; sank
tit May _@etubal Al,!A;@ H IAN 212,'IiJ9 190 Ballast bischarging slops using air
InteroCeall 'Shipping 11 IGS Lib/Grk driven portable pump; deck
opened up over Nos. 3,4,& 5
t1l Awle Musi ilivur 6111CE IIINTAN 15,792 1971 Ilt. -eriouis Collision :.truck Mainheron; caught fire;
V ub/ ioaded grounded; explosion in No. 1C;
Crude gutted
;--Ith June Musi Rivur MAIilIIEAWN 19,965 1959 Ballast ;erious Collision "'truck by Bruce Bintan; caught
Vii,u,dri.9 Cruiaett Pan/Grk fire; grounded-, explaaiona in
Nos. 3P,4Pj4C & for'd P.R.;
accommodation gutted
th June At Sea AV 11.11., L; 154,096 1 I)W Pt. T L 12 Yes Itull Broke in 2. one section caught
Arkibiati ;,ea T Idb/ Loaded fracture? fire, both ends sank
ith July At Sea AE,.AL@4 -'APTAIN 210,2@7 i968 1,objed -'crijus I) yes Collision @:tmck Atlantic Empress in
ljff Tobago li,terit.,tiofial IGn I.ib/Grk Crude raiLL storm; fire in for'd
ccmpts. and on deck
It-t1i Aug. Cabii,aa u/,O)l :1)64 Loadeu 3 Yes At tBM. Explosion and fire,
111gelel, Ilippil,g T Grk/. G rk C r-ui e towed out; sauk 4th Sept.
after further explosions

CASUALTY SHIP CONSEQUENCES
INITIATING DETAILS COMMENT
EVENT
DATE PLACE NAME/MANAGERS DWT BUILT CONDITION HULL DEAD & POLLUTION
Type TON FLAG/MNGT DAMAGE MISSING

979 cont'd

19th AUG At Sea OGDEN OTTOWA 29732 1976 Ballast Serious Gas freeing; explodion i,w,o,
180' Off Ogden Marine T Lib/USA No. 1; 75% of deck i.w.o No. 1
Ecquador missing

10th AUG AT Sea CHERRY KING 29,299 1956 Ballast TL 6 Explosion and fire; sank
17' off Morse Management T Sing/Sang

1st SEPT Mississippi CHEVRON HAWAII 71339 1973 Discharg- UTL 3 Yes Lightning Struck for'd; explosions and
Chevron Shipping T USA/USA ing feed- 40,000t fire; gutted; bow severed;
stock sank, 4 barges caught fire

10th OCT At Sea TALAVERA 35,040 1960 Ballast TL 1 Welding? Explosions; deck lifted
Off Barbados Cie Espanola de T Sp./Sp. i.w.o. 5P, 6P, 9, 10, 11, 12

27th OCT Manaus GUNVOR MAERSK 32,056 1073 Pt. CTL Struck Struck i.w.o No.2P,
A.P. Moller T Dan/Dan Loaded explosions in 2 tanks; gutted

30th OCT At Sea SALLY I 17,749 1972 Ballast Explosion; 1 man blown over-
Off Senipah Ocean Patrol T Lib/HK board, later recovered

1st NOV At Sea BURMA AGATE 61,674 1963 Loanded TL 31 Yes Collision At anchor; struck by cargo
Off Galveston Kassos Maritime T Lib/Grk Nig. ship i.w.o No 6; immediate
Enterprises Crude explosion; gutted; aground

9th NOV At Sea BEMGE VANGA 223,965 1974 Loaded TL 36 Welding? COW retrofit workers on board;
S. Atlantic Sig. Bergesen d.y. O/O IGS Lib/Nor. Iron Ore no SOS; some debris recovered

15th NOV Bosphorus INDEPENDENTA 150,001 1978 Loaded TL 54 Yes Collision At anchor; struck by cargo
Romanian Govt T IGS RUs/Rus Cruse ship; grounded; split in 2

19th DEC At Sea ENERGY DETERMINATION 321,186 1976 Ballast TL 1 Accommodation Accomodation fire, spread ER
Off Goin Is. Island Navigation T IGS Lib/HK fire and then cargo tanks; taken
in tow, split in 2, aft
part sank
22nd DEC Chiba PRIMAROSA 254,276 1973 Discharg- Minor - No Back flow of
Sarda Gestioni Navali T IGS TTl./TTl. ing crude cargo gas in
IGS?

Fig. Bl-S
Total losses of large vessels from I January 1979

SIZE AND CLASSIFI- INERT GAS HLILL CARGO
VESSEL BUILT TYPE CATION SYSTEM VALUE VALUE LOST CASUALTY OWNER

Betelgeuse 1968 121,430 dwt BV No $12.6m $3.8m Explosion while discharging. Cie Navale des
(French) large tanker Bantry Bay, Ireland Petroles (Total
January Oil)

Seatiger 1974 123,692 dwt AB Yes $12m Struck by lightning'during International
(Liberian) storms as finished dis- Navigation Corpo-
charging Nederland, Texas ration, Monrovia,
April 19, 1979 Liberia

Atlas Titan 1969 212,759 dwt LR Yes $12.8m Explosion in cargo tanks Centurion Maritime
(Liberian) VLjCC followed by fire, during Co., Monrovia,
tank cleaning, Setubal, Liberia
Portugal, May 27, 1979

Aegean Captain 1968 210,257 dwt LR Yes $ 7m $55m Atlantic Empress and Aegean Quadrant Shipping
(Liberian) VLCC Captain collided off Tobago. Corp. Monrovia,
July 19, 1979. Aegean Liberia
'Captain sold and broken up;
Atlantic Empress 1974 292,666 dwt LR No $35m $40m Atlantic Impress, fire and Branco Shipping
(Greek) VLCC explosion, sank August 2 - Co., Chios, Greece

Stoic 1971 152,790 dwt AB No $12m $4.5m Ran aground August 19,1979. Southwind Shipping
(Liberian) Combination Disappeared off Sekibi Co., Monrovia,
Shoal, Japan, during Liberia
typhoon

Berge Vanga 1973 227,912 dwt W Yes $19m $Sm Presumed sunk after massive Sig. Bergesen
(Liberian) Combination explosion(s) north west of D.Y. and Co.
Tristan da Cunna, South Monrovia, Liberia
Atlantic. Last report
October 29, 1979

Total losses of large vessels from 1 January 1979

SIZE AND CLASSIFI- INERT GAS 'HULL CARGO
VESSEL BUILT TYPE CATION SYSTEM VALUE VALUE LOST CASUALTY OhNTER

Independenta 1978 150,000 dwt RNR No $40.2m $20m In collision.with general Navrom, Romania
(Romania) large tanker cargo carrier, outside
Istanbul Harbour, iNiovember
15, 1979

Energy Determination
(Liberian) 1976 321,186 dwt LR Yes $58m Fire and explosion in Strait United Overseas
ULCC of HDrmuz, Arab Gulf, Petroleum
December 12, 1979 Carriers,
Monrovia,
Liberia (C.Y.
Tung)

Salem 1969 213,928 dwt LIZ No $24m. $25.Sm* Sank off the coast of oxford Shipping
(Liberian) VLCC net Senegal, cause uncertain. Co., Monrovia
January 17, 1980 Liberia

Irenes Serenade 1965 99,688 dwt EV No $6m $22in Exploded, caught fire Maderic Marine
(Cyprus) large tanker Navarino Bay,.near Pylos, Co. Mg-r: Tsakos,
Greece, February 23, 1980 Shipping and
Trading,
Limassol, Cy
,prus
Maria Alejandra 1977 239,010 dwt IR Yes $20m Explosions, sank off the Mar Oil, Cadiz,
(Spanish), VLCC coast of Mauritania Spain
March 11, 1980

Albahan B 1971 239,410 dwt LR ? $24m Exploded, sank off the
(Liberian) VLCC coast of Tanzania, April
3, 1980

Total losses of large vessels from 1 January 1979

SIZE AND CLASSIFI- INERT GAS HULL CARGO
VESSEL BUILT TYPE CATION SYSTEM VALUE VALUE LOST CASUALTY ONNER.

Mycene 1976 238,889 dwt LR Yes $27.2m Exploded, sank off the Mycene Shipping
(Liberian) VLCC coast of Senegal, Co., Monrovia,
April 3, 1980 Liberia

Totals $309.8m $175.8m

AB - American Bureau; BV Bureau Veritas; IR Lloyd's Register; W Norske Veritas; RNR Registru Naval Roman.
Sources: Lloyd's Register, Lloyd's Intelligence

*Salem cargo was insured for $56 million. A payment of $30.5 million has been made by South Africa to the owners, Shell, leaving L25.S
million outstanding.

B2) The Effectiveness of Vessel Inert Gas Systems

EKPLANATION:

Vessel inert gas systems are regarded by some as totally
effective in eliminating the likelihood of tanker explosions.

BACKGROUND - NTPC APPLICATIONS: SOURCE

The number of tankers equipped with inert gas Vol. III
systems and segregated ballast systems is shown in p.2.11-71
Table 111-2.11-21 No ship equipped with an inert
gas system has ever had an explosion. The portion of
the worldwide tanker fleet with inert gas systems
has been increasing and is expected to continue in-
creasing as more of the larger crude carriers are
.built. This trend should lead to a reduction in the
risk of tanker explosions and should make the frequency
,of explosions and fires used here conservative (high)."
Table 111-2.1-21 is shown in Fig. B2-1.

DISCUSSION:

Design and Operation Problems

The experience of tanker fleet operators has been that I.G.S.'s
are difficult to operate and maintain and, in fact, could cause
more problems than they solve, unless they are operated correctly
and routinely inspected thoroughly.

1. An I.G.S. has a direct link from boiler exhaust to cargo
tanks. Human or mechanical failure can cause explosive
fumes to leak back to an ignition source while the I.G.S.
is not in use because of:

a) the water seal not being filled;
b)@ the pressure vacuum valve leaking due to a corroded seal;
c) corrosion in ducting;
c) The.Fan casing leaking fumes into fan room.

Note that the I.G.S. is related to the cargo tanks only, and
therefore will have no effect on fire and explosion sources
elsewhere on the vessel.

2. The balance of the inert gas fed to the cargo tank must be
correct during offloading. The precent oxygen in the gas
could be too high due to varying loads on ship's boiler in
port.

Fig. B2-1

TABLE 111-2.11-21

PERMANENT BALLAST AND INERT GAS SYSTEM CHARACTERISTICS

OF WORLDWIDE TANKER FLEET

Percent of Tankers
Number With In Size Class With
DWT Number of Permanent Permanent Inert Gas
Size Class Tankers Ballast Ballasl System

JONES ACT CRUDE TANKERS

By 1 June
1981
S0,000 6 1 17 100
62,000 .3 1 33 100
70 - 80,000 is 14 93 100
90,000 4 4 100 100
120 - 130,000 8 8 100 100
165,000 6 6 100 100
190,000 4 1 4 100 10L
TOTAL 46 38

FOREIGN CRUDE TANKERS

100 125,000 132 88 67 22
150 175,000 25 18 72 20
175 200#000 22 16 73 14
200 225,000 147 106 72 37
225- 250,000 160 118 74 59
300- 327,000 21 is 71

TOTAL S07 361

Source: Clarkson & Co. Ltd. 1976.

Rev. 2-6/79

Recorders of I.G.S. flow and oxygen are not mandatory.

3.. Cargo tanks have natural traps for fumes, because of their
internal structure,, that the I.G.S. might not replace., The
vent test would not indicate this. Static electricity
generated by cargo tank cleaning jets could ignite these fumes.

4. Retrofit I.G.S. equipment on old tankers often can -not keep
pace with oil cargo discharge rates.

Explosions on Vessels Equipped with I.G.S..

The NTPC.Statement: "No ship equipped with an inert gas system has
ever had an explosion" is incorrect.

There are 3,819 crude oil tankers in ser vice in the world; 380 are
fitted with I.G.S. In 1979, oil tanker explosions totalled 22.
L.G.S. were fitted on 7 of these vessels (See Summary of Fires and
Explosions, 1977 - 1979, Fig@ B1-4). Large vess6l total losses.
since January 1, 1979, (See Fig. Bl--S) total 14. Seven of these
were fitted with I.G.S.

These statistics show that an I.G.S. is no guarantee of safety and
could in fact be a partial cause of the explosions.

HAZARDS SPECIFIC TO PORT ANGELES HARBOR

B3) The Impacts of a Large Tanker Explosion and Fire on the Port Angeles
Hospital and Downtown Core.

EXPLANATION:

Noting the proximity of the proposed terminal to a major population
area, the potential impacts of a tanker explosion and fire must be addressed.

BACKGROUND NTPC APPLICATION: SOURCE

Excerpts quoted below contain corrections found in the
ERRATA sheet - Attachment B to the prefiled testimony
of Brian Murphy (2/26/80).

"Based on-reports of tanker explosions and supported Vol. III
by the analysis provided in Appendix B, an approximate p.2.11-74
1500-foot radius appears to be a conservative estimate
of the distance over which structural damage could
occur because of a tanker explosion. Therefore, the
full land width of the end of Ediz Hook near the tanker
unloading facilities would be at risk. In addition,
the personnel and property of the tanker unloading
facilities and the USCG station would be at risk.
Port Angeles is over 8,000 feet from the proposed
berthing site.@ According to the analysis in Appendix
B, windows are expected.to be broken to a distance of
2,880 feet following the explosion of a 130,000 DWT tanker."

"Impacts might occur in Port Angeles if a tanker Vol. III
exploded or caught fire and remained afloat in the p.2.11-74
vicinity of the Port Angeles waterfront. If
moorings were broken by explosion and if the burning
tanker were adrift, wind or currents could force it
toward the city. Along the western end of the
city, near the forest products industrial facilities,
a tanker with a draft of 7 fathoms (42 feet) or less
(approximately 70,000 DWT) could come very close to
shore before running aground. If the tanker came
within 300 to 500 feet of wooden structures on the
shore, the tanker fire could produce sufficient radiant
heat to ignite those structures. Most of the shore-
line along the city, however, is such that a tanker
would run aground well out (more than 1,500 feet for
a 70,000 DWT tanker) in the harbor and would not
endanger the city. Larger tankers could have a
larger fire, but would run aground further from
shore. Even in those areas where the tanker could.
get close enough to pose a threat, city firefighting
apparatus could wet down exposed buildings sufficiently
to reduce significantly the threat of fire.

Any tanker fire will result in large quantities of
black smoke, S02,.CO, and NOX being released into the
air. The impact of this large, short-term source of
air pollution could.range from a nuisance level to
a potential health hazard to people with respiratory
diseases."

"Downtown Port Angeles is about 9,000 feet from the Prefiled
proposed berthing site. Olympic Memorial Hospital testimony of
is located about the same distance from the tanker Brian Murphy
berth. According to our analysis, windows could be p.8
shattered following the total explosion of a 327,000
DWT tanker to a distance of 4,040 feet."

"Atmospheric factors, including focussing, could Prefiled
be important at low overpressures such as those testimony of
associated with window breakage, but should not be Brian Murphy
significant at high overpressures associated with P.10
more severe damage"... "A possible example is
represented by the 70,000 DIVT Liberian tanker
Sansinena which exploded in Los Angeles harbor in
1976. Scattered damage to windows occurred in a
westerly direction as far as 3-1/16 miles and in a
northerly direction as far as 2 miles away. (There
were a few reports of broken windows even further out
up to six miles or more) National Transportation
Safety Board Report NTSB-MAR-78-6, U.S. Coast Guard
Report 16732/71895."

... we considered a spill from one wing tank of an ibid. p.11
80,000 DWT tanker having a fire radius of 1,700
feet. Even for a very large wind speed of 34
miles per hour, the smoke plume was calculated to
rise 1.32 miles above theOlympic Memorial Hospital
roof. For a larger fire resulting from a 327,000
DWT tanker with a fire radius of 5700 feet, the plume
rise is even larger - the plume bottom was 2.40
miles above the Olympic Memorial Hospital roof."

"The hospital is a reinforced concrete building, Prefiled
and in the worst possible explosion, with the tanker testimony of
having drifted across the harbor before exploding, David L. Moore
it could sustain.broken and shattered windows and P.18
some structural damage. AnN , people near the windows
facing the harbor could be injured by flying glass
from shattered windows.

"However, there are several factors and circum- ibid. p.15
stances which could possibly result in these impacts
occurring at greater distances or which could
result in lesser impacts at smaller distances. For
example, isolated areas tens of miles from the
explosion source can receive focused blast waves due
to certain atmospheric effects, particularly low-
level temperature inversion.".

"The results of the structural damage analysis Vol. V
indicate that in'a.very unlikely circumstance that p.B-11-68
an entire 130,000 DWT tanker exploded, the largest
area impacted moderately would be 1,220 ft. (or
4 mile), severely 860 ft. (or 1/6 mile). If only
the center tank of a 70,000 DhT tanker exploded,
the figures would be approximately 460 ft and
320 ft.".

be seen in Table B-11-32, in the very Vol. V
unlikely event of the explosion of all tanks of P-B-11-77
a 130,000 DWT tanker, the maximu@i area with
glass shattering would be 2,880 feet (0.55 miles).
If only the center tank of a 70,000 D11T tanker
exploded, the area im-pacted would be 1,080 feet
(1/5 mile).".

"Shock waves in the atmosphere*from sonic booms, Vol. V
.for example, can be intensified or focused under p.B-11-77
some conditions. The conditions necessary for
this focusing could exist at the time of a tanker
explosion in Port Angeles and the effective glass
shattering range somewhat extended.".

DISCUSSION:

Very few VLCC ports are located within 6,500 feet of major population
centres such as NTPC are proposing for Port Angeles. Some older
terminals, eg. Shell Haven on the River Thames in England, are close
to populated areas but new terminals eg. Milford Haven in England
and Bantry Bay in Ireland, are normally located at significant distances
from populated areas. In fact, tanker movements in the Port Angeles
harbor will be such that a fire or explosion could occur at closer
distances such as 4,000 to S,000 feet-if a collision were to take
place. Northern Tier and its consultants have determined by statistical
analysis that the probability of a tanker explosion would be very low
and that the use primarily o@ tankers with inert gas systems will be an
additional safeguard (Volume III, Part 2, Environmental Studies,
p.2.11-71). NTPC have stated that "No ship equipped with an inert gas
system has ever had an explosion." As discussed in Section B-2 Of
this Report, seven explosions of the fourteen which have occur-red in
the last year and a half have occurred on tankers with inert gas systems.
Inert gas systems cannot be looked upon as a failsafe explosion
prevention method and may themselves lead to problems of fire and
explosion.

There are three issues with respect to tanker fire and explosion in
Port Angeles harbor that should be addressed. They are as follows:

1. range and type of damage due to explosion and fires;

2. air pollution resulting from a tanker fire;

3. smokeimpingement.,

With respect to item 1 above, studies by ERT and OIW indicate that
damages from tanker explosions at the terminal would be limited to
shattered and cracked windows in Port Angeles. Damage to the USCG
station would be extensive. Noting, Port Angeles is an active harbor,
the potential impact of an explosion and fire on other vessels (eg.
tugs, fishing boats, the ferry, etc.) using the harbor at the time
of the explosion should be addressed. In the documentation, the
explosions considered took place at the terminal with certain analyses
addressing the issue of fire damage originating from an explosion
when the tanker,, following the explosion, broke away from its moorings.
The issue of a tanker explosion occurring at other locations within
the harbor is included in the testimony of Mr. D. Moore. Figure 111-7
(Fig. B3-2) from Mr. Moorels testimony is included. Based on this
figure, an explosion is said to cause moderate damages to a wood frame
house (2600 feet away), a multi-storey brick apartment (2100 feet
away), a light steel frame industrial building (1000 feet away), etc.
The question arises as to the definition of moderate; the site-specific
susceptibility of buildings in the risk area-To-esnot appear to have
been considered. The question also arises as to the effect on
individuals present in the area,at the time of the explosion. These
subjects are not addressed in the detail warranted.

In Fe bruary, 1980, the tanker Irenes Serenade exploded in Navarino
Bay near Pylos, Greece. As a result of the explosion, oil spilled
from the ship forming a burning oil slick over a large area of
water around it. The explosion and fire took place 1200 meters
(approximately 3/4 of a mile) offshore. However, as a result of
the fire, the adjacent shoreline was also burned. (Photos B3-1 and
B3-2). The fire in the tanker burned for several days. The
reviewers believe that a similar situation would be a very difficult
emergency for NTPC and Port Angeles control resources to deal with.

The,re are several important parameters that should be considered
with respect to tanker fires in Port Angeles harbor. In the NTPC
documentation, it has been noted that a tanker fire occurring near
shore may require the wetting down of wood frame buildings by the
Port Angeles Fire Department. However, the capabilities of the
Fire Department in fulfilling this task when a number of buildings
are in jeopardy has not been.addressed. In addition, the capability
of all available fire fighting units and equipment in putting out
the tanker fire itself has not been adequately addressed. Tanker
fires such as the Irenes Serenade and the Betelgeuse in Bantry Bay
and others have burned for days or sometimes-weeks, illustrating
that modern fire fighting equipment is not adequate in dealing with
tanker fires. It could be desirable to be able to tow a burning
tanker from Port Angeles harbor to a safer location. The mechanics of
this activity and the proponent's (or others) capability in carrying it
out have not been addressed in the documentation. What would happen
if other tankers berthed or at anchor in the area also caught fire?

The reviewers believe that the fire and explosion risk posed by a
major oil terminal in Port Angeles has not been dealt with in warranted
detail in the present NTPC documentation. Serious accidents occur
at even the best run terminals. Case histories of recent

Figure 111-7
POTENTIAL STRUCTURAL DAMAGE FROM A WORST-CASE TANKER
EXPLOSION (327,000 DWT) ALONG SHORE

f
17

8
6 5 18'
_','Ground i ng',,','
contoUr'@
4 (30, f eet)

0 1 2 3 4
;CALIE 1" 1004 Of Fjj'V

Tanker
School A%
Hospital oft
Types of Damages and Distances 0 1 w
Moderate Damage to:
1 Typical Glass Failure (16,500 feet) 4 Wood Frame House (2600 feet)
2 Usual Glass Shattering (6300 feet)
3 General Light Structural Damage (3600 feet) 5 Multistory Brick Apartment (2100 feet)
6 - Light Steel Frame Industrial Bldg (1000 feet)
7 - Reinforced Concret-e Office Bldg. j750 feet)
8 - Steel Frame Office Bldg. (650 feet)

m m

Ail

Ink-

Photo B3-1 Fire following explosion of Irenes Serenade in Navarino,
Pylos, Greece,.February, 1980.

Source: Press Photograph

Photo B3-2 Scorched shoulder about 1200 metres (approximately 3/4 mi
Irenes Serenade

Source: Press Photograph

world tanker fire and ex-olosion incidents indicate the following:

I. that such incidents are increasing with and without inert
gas systems installed;

2. that causes of many of the incidents are uncertain and
therefore a breakthrough in reducing them in the near
future seems unlikely;

3. that suchzincidents often lead to an uncontrolled situation,
the results of which are unpredictable.

Since the present NTPC terminal is to be located in relative prox-
imity to the City of Port Angeles, the reviewers have concluded that
considerably more risk analyses, emergency scenario outlines and
hard fire-fighting capability information is required. from NTPC,
including the comparison with alternative-terminal sites, before
the acceptability of the risk can be fully assessed.

With respect to item 2,- in the documentation (Vol. III, Part 2) it
is stated that- "any tanker fire will result in large quantities of
black smoke, SO CO and ND being released into the air. The impact
of this large, ih'ort-term solurce of air pollution could range from
a nuisance level to a potential health hazard to people with
respiratory diseases.". It is important to note that CO and SO are
extremely hazardous pollutants to man and multiple deaths due t;
SO2 emissions1have been recorded. However, in this report,--the.
amount of these pollutants emitted has not been estimated nor has
their effect on ambient air quality been determined. Stating that
these pollutants could cause a nuisance or a potential health hazard
is quite possibly a major understatement., The definition of "short-
term source of air pollution" sh 'ould also be questioned noting that
the Burma-Agate tanker fire, S miles off shore from Galveston, Texas
burned, or was allowed to burn, for 61 days.

With respect to smoke impingement (item 3), Mr. B. Murphy in his
testimony stated that under certain circumstances (a small fire), a
smoke plume could reach the Olympic Memorial Hospital. Mr. Murphy's
example was: "the burning time for a fire of approximately 7S feet
in radius would'range from one to five minutes. For a 34 mile Iper
hour wind speed at C stability conditions (but not D stability,
for which the plume is narrowed), a fire of this sort could impinge
on Olympic Memorial Hospital." In the documentation and the
testimony, questions with respect to the probability of this occurring,
its effects on hospital patients, the need for hospital cv@@cuation,
overall contingency plans, etc. have not been addressed. Presumably,
if this fire can result in hospital smoke impingement, there must
be a*range of fire conditions during which smoke impingement would
occur. This range is not discussed.

B4) Environmental Effects- and Health Concerns of a Release of Stored
Chemicals

EXPLOSION:

The two major industries in Port Angeles at the present time are
pulp mills. Pulp mills store significant.quantities of environ-
mentally hazardous liquids such as oils, chemicals and process
solutions. Pulp mills also store large volumes of liquid chlorine,
a substance that, in the gaseous state, constitutes a major public
health concern.

BACKGROUND - NTPC APPLICATION:

The subject of secondary fire and explosion effects is not
discussed in the NTPC documentation, nor has it been discussed
in the testimony of the NTPC expert witnesses.

DISCUSSION:

The reason that NTPC has not addressed this subjectis probably
because their risk analyses show the risk of a tanker explosion
is small and that in the event of an explosion the on-shore
environmental damage will be minimal; however, the possibility
of such an explosion cannot be ignored and fires do not
necessarily require an explosion for ignition. In the NTPC
documentation (discussed in Section B3 of this report) there are
circumstances under which shore facilities could be severely damaged.
It is important to note that pulp mills (Port Angeles has two) often
store in large quantities of process chemcials such as liquid
chlorine, sodium chlorate solution, sodium hydroxide, sulfuric acid;
milling solutions.such as black liquor, green liquor and white
liquor and oil products such as bunker oil and lubricating oils.
.In the event of a major explosion that results in the rupture of.
the pulp mill storage tankes, significant environmental problems
could result. In addition, the rupture of the liquid chlorine
storage tank (generally a rail tank car) would result in signif-
icant health risk (Chlorine gas is extremely toxic) to workers and
possibly even to residents of the area. These potential problems
and measures to reduce environmental and health risks require
thorough consideration and discussion in the NTPC documentation.

BS) Effectiveness of Port Fire Fighting @Xstems

EXPLANATION:

A major fire and explosion at the proposed unloading facility
will require effective, well maintained equipment and thoroughly
trained personnel to deal with it.

BACKGROUND - NTPC APPLICATION: SOURCE

"Fire fighting design and procedures for the facilities Vol. II
will be developed in cooperation with the Port Angeles p.6-20
Fire Department, the USCG, and the Seattle Fire
Department.

A seawater fire protection system with foam capability
will be provided at the tanker unloading facilities.
Two diesel engine-driven fire pumps, each one capable
of delivering the design,volume of seawater, will be
installed.on a platform, with roadway trestle access
from shore. Fire mains will be installed along the
roadway and pipeway trestles to form a closed-loop
system. Fire hydrants will be located on the berth and
booster pump platforms, and at strategic locations on
the trestles. A remotely.controlled, high-capacity
water monitor for fire protection will be provided on
the access tower at each tanker berth. Foam monitors
will be located on each platform and on the roadway
trestles. Portable dry chemical units will be pro-
vided on the platforms to control electrical fires.

One fully equipped and manned fireboat will be in
service at all times during tanker unloading and bunk--
ering operations as an added safety measure for in-
creased fire protection capability at the tanker un-
loading facilities.

This 70 to 80 foot vessel will be equipped with fire
punTs capable of delivering a total of 6,000 gpm of
seawater to remote and manual controlled monitors, on-
board fire hose connections, and an articulated water
tower. The vessel will also be equipped with a foam
chemical system and various portable.firefighting and
first aid equipment.

Smoke and heat detectors will be located in all buil-
dings, including the booster pump control room and
berth operators' shelters. Reporting stations will be

located on the berthing and booster pump platforms and
also at the shore endslof the roadway trestles. These
stations will sound a general alarm and actuate a
warning signal in the main control center at the on-
shore storage facilities."

"The proposed fixed fire fighting equipment and spill Prefiled
containment equipment at the berths as proposed provides testimony
the ability to utilize large quantities of fire killing of G. Kirsop
foam on any leak or spill which might be ignited, or p.3
in the case of an unignited spill, to prevent ignition
during the clean-up phase. Similarly foam, plain
water or dry chemical extinguishing equipment will
be readily available for use on other fires which
may occur around the pier facility. Should a tanker
be on fiTe before reaching the berth, the fire boat
will be available to supplement the shipboard fire
fighting efforts.

The design also has automatic early warning fire
detection in the control room and other enclosed
areas, backed up by portable fire extinguishing
equipment. Sea water is currently proposed as the
fire protection water source. Many fire protection
systems of the type needed for facilities of this
kind are currently in operation and have proven
satisfactory."

DISCUSSION

Serious in-port tanker explosions and fires which have occurred
recently such as the "Betelgeuse" at a Gulf terminal in Bantry Bay,
Ireland, the "Independenta" in Istanbul harbor in November, 1979,
or the Burmah Agate near Galveston, Texas, have proved beyond the
capability of port or larger fire departments to put out. The
response in these cases was to let the fire burn its course
(the Burmah Agate burned for 61 days) and take one's chances with
further explosions. The "Independenta" burned for a number of days
causing flaming debris to fall on surrounding harbor facilities and
buildings with each further explosion. The 120,000 ton "Betelgeuse"
incident was the subject of a thorough inquiry by the Irish govern-
metn the conclusions of which are not yet public. It took place
at a large Gulf oil terminal built in the late 1960s. Some early
findings as outlined in a National Oil Week Magazine article of
March 14, 1980, were as follows:

1. "On the night, the alarm siren.was not working, foam extinguishers
were broken, all the jetty staff were casual workers and'all but
one of the escape ladders to the sea had been removed 'for
security reasons'.

2. There was no plan for emergency evacuation. Safety re-
quirements stipulated by architects had been ignored, creating,
in one building on the oil jetty, a tinder box condition.

3. A fire-fighting truck and three Land-Rovers commandeered by
rescuers failed to start.

4. The last fire-fighting exercise had taken place three years
earlier.

A number of conclusions were drawn by the reviewers concerning the
topic of port fire fighting capability. They are as follows:

a.. Equipment required for fire fighting at oil terminals must be
continuously checked and maintained.

b. Terminal personnel who would be involved in fire emergencies
require extensive training, and regular hands on fire fighting
exercises.

C. Present fire fighting capability is limited to relatively
small fires.

d. In large fire situations triggered by or resulting in large
explosions, historic incidents to date suggest that fire
fighting capability is limited to cooling surrounding struc-
tures and quelling smaller fires started by flaming debris.

The application also does not address fire fighting design and
procedures to be implemented with respect to the. surge relief tank
which is to be placed in the unloading facility area.

3. TANK FARM HAZARDS

B6) Recent Tank. Farm Fires and ExDlosions

EXPLANATION:

It is important for reviewers to be aware of the causes of recent
tank farm explosions and firesP the methods used to fight these
fires and the problems encountered in extinguishing these fires.

BACKGROUND - NTPC APPLICATION: SOURCE.

"Oil tank fires generally can be attributed to elec- Vol. III
trical storms and over-filling of the tanks. Elec- p.2.11-76
trical ignition of a floating roof tank is confined
to the seal space between the roof sealand the shell
where an explosive vapor mixture may occur (1) because
of the lack of contact of the seal with the shell.or
(2) during rapid tank discharge when a flammable mixture
may collect the seal.

The frequency of fires in tank farms during 1974 and
1975 was approximately 2.5 fires per 100 tank farms
(API 1976). This data leads to an estimate of one
fire every 40 years for a given tank farm based on fire
statistics from all tank farms."

DISCUSSION:

The causes and circumstances involved in three recent tank farm ex-
g
losions and fires were investigated by the reviewers. The*
etails are outlined below:

1. Nanaimo, B.C., Canada) September, 1977

The fire was caused by vandalism. It started in a Shell Oil
products tank farm and spread to the adjacent Chevron tank
farm (neither facility includes an oil refinery), both of
which had.fixed'roof tanks. The duration of the fire was
15 hours. Use of foam trucked in from Victoria, approximately
7S miles away finally put out the fire.

Difficulties encountered by Nanaimo Fire Department during
the fighting of the fire:

1) personnel - scheduling of rest periods, refreshment and
meal breaks;

41
water supply - an interruption in flow'would have allowed
heat to build up again;

3) dykes and pollution while the fire was still active,
too much water in the dyke area would cause burning
I
fuel to overflow the dykes;

4) traffic control - ensuring that observers did not inter-
fere with the arrival of support vehicles and fire
fighters;

S) disposal of remaining produc ts - the disposal of the
products remaining required caution, was time consuming,
and had potential environmental consequences.

Fite protection regulation deficiencies noted in the investi-
gation were a lack of security at the tank farm,the unaccepta-
bility of non-lined earthen containment dykes, and the lack of
a requirement that enough foam be on hand to deal with a fire
.emergency.

Damage to tank farms was more than 2.2 million dollars.

The costs to Nanaimo Fire Department, $42,000. There were
two fatalities.

2. Clark Oil Co., Taylor, Michigan, December, 1979

At a products tank farm pipeline terminal, a 29,000 barrel,
gasoline storage tank with an internal floating roof overflowed.
Released vapors ignited.

The fire lasted 32 hours with no fatalities resulting.

Local fire departments were responsible for putting out the
fire and, since the fire., level alarms have been placed onall
tanks.

3. Nbbil Oil Refinery, Torrence, California, October, 1979.

At the oil refinery, the incident involved an 80,000 barrel
gasoline storage tank which had an external floating roof.

A blending operation occurred at too high a temperature and
vapors escaped from a tank that was only 2S% full at the time,
and was ignited by a passing motorist.

The fire lasted 3 days and 3 fatalities (2 foremen and a
passing motorist) resulted.

During the fire,damage to other tanks in the area occurred and
nearby residents were evacuated for 2 days.

it is apparent that the utilization of floating roof tanks does
not ensure that tank farm fires'will not occur. The human element
(sabotage, vandalism, and error) cannot be ignored as important
concerns with respect to the occurrence of tank farm fires. The
burden placed on the local fire department is also important to
note. In two of the examples presented it appears that the
facilities of the local fire department were extended to their
limit, eliminating their ability to respond to another fire of a
residential or commercial nature. The NTPC proposal has not
assessed the ability of local fire departments (Port Angeles and
Fire District No. 3) to deal with a major tank farm fire; and
the response capability of local units cannot be addressed until
such information is furnished.

The Norther Tier documentation fails to address in the detail
warranted the following issues:

1. details of the fire fighting training program that Northern
Tier staff will undertake;

2. the interaction of the Port Angeles and regional fire-
fighting staff with NTPC staff in the event of a fire;

3. the effects of a major explosion and fire in the tank farm,
i.e. worst possible case effects on workers,, local residents,
the environment, the continued operation of the facilities-.

4. the methods being utilized to prevent sabotage caused by
either an employee or a non-employee of NTFPC (the Nanaimo
tank farm fire in 1977 that resulted in two deaths was the
result of vandalism);

S. other issues with respect to potential causes of fires,
eg. earthquakes, lightning, plane crashes, etc., are
touched upon in the documentation@but not dealt with in any
degree of detail.

NTPC should be required to address the risks to life and property
under the conditions of the worst possible fire and explosion at
the tank farm site.

C. OIL SPILL CONTAINMENT AND CLEAN-UP
Cl) Critical Review-of Contingency Plan

EXPLANATION:

An oil spill contingency plan must provide sufficient site-specific
detail to initiate immediate mobilization of available resources
for the containment and clean-up of an oil spill.

BACKGROUND - NTPC APPLICATION: SOURCE

"Prior to operation, NTPC will formulate a detailed and Vol. II
comprehensive Oil Spill Contingency Plan in accordance p.6-211
with the requirements of the DOT"... "The Oil Spill
Contingency Plan for the marine terminal will be deve-
loped in conjunction with the C.S.C. and other
appropriate organizations and goverment agencies to
provide rapid response and mobilization of personnel,
equipment, and materials to cope effectively with all
minor and major spills and other emergency situations
and conditions."

"Spills are detected by unexplained pressure and flow Vol. II
deviations, and. air patrol, employee, or public p.6-213
reports Since minor spills generally cause minimal
impacts, this discussion concerns primarily major
spills. Typical responses to a spill along the pipe-
line route on land and water, together with an outline
for the proposed Oil Spill Contingency Plan for NTPC,
are presented."

DISCUSSION:

The draft "Oil Spill Contingency Plan" Volume I and II filed by NTPC
to date represents a comprehens ive compilation of existing literature
on the subject. The proponent and their consultant deserve
commendation for the effort to date. As such it is a aood start in
writing a spill problem solving action plan. The reviewers have
the following comments on the plan:

General

1. The plan as submitted appears to contain man .y sections and
approaches used in a similar plan done for the Alveska Pipeline
Project in Alaska, and Oil Spill Cooperatives in Southern
California with which the reviewers are familiar. Although
there is nothing wrong with including information from other
plans - in fact many techniques can be used universally - the
.plans presented for NTPC have not been made site-specific
enough to accomplish a spill control and clean-up task in the

difficult marine situations in Juan de Fuca Strait and Puget
Sound.

The Plan presented is not an action plan that could be of
imediate.use to an on-scene commander but rather an outline
of the requirements of a plan.

2. The main deficiency in contingency planning as presented in
the draft plan documents or in the application is the lack of a
full discussion on the probable real life success of spill
control plans. The sheer volume of detail in the draft volume
documents could give the impression to an inexperienced eye
that most spill problems are mitigatable to acceptable levels
if the plan is put into operation. For terrestrial spills
this is usually the case, providing there is no groundwater
contamination problem. However, for river and open water
marine spills, case histories show spill control techniques
to be very ineffectual and beach clean-up is the rule. The
application contingency descriptions and draft plans therefore,
do not seriously consider the logistics of such a massive
beach cl.ean-up.

3. NTPC spill contingency plans do not contain any detailed
description of procedures to be followed when oil crosses
into Canadian waters and/or pollutes Canadian beaches. Spill
trajectories in three'reports predict that this could happen
if oil is spilled in Juan de Fuca (Paish, 1972; Stewart, 1978
and O.I.W., 1979b).

4. Discussion of costs for clean-up and damage compensation is
not adequate in the application and draft contingency plans.

Shoreline clean-up is extremely expensive. It demands
considerable equipment and manpower, which often have to be
provided by municipalities, state goverments, armed forces
and private contractors. The inland sea spill in Japan cost
200 million dollars to clean up. The AMOCO Cadiz tanker
clean-up off Brittany cost in excess of 200 million dollars.
Many other examples exist of how counties, municipalities,
states and federal governments are left to carry the-major
cost of clean-up. The whole area of compensation for clean-
up and property damage is very vague, and there is no
comitment from Northern Tier to cover these costs.
The NTPC Application should be specific in their own clean-
up cost and damage commitments, and contain a full discussion
of TOVOLOP, CHRISTAL, Canadian Maritime Pollution Claims
Fund etc.

S. The draft contingency plans are not clearly organized and would
be difficult to use in an emergency situation. Background material
is interspersed with the operational plan and it appears no con-
sideration has been given to brief field manuals for quick reference
in an emergency. The reviewers know of no incidents where the use
of a contingency plan presented in the NTPC format has been used
successfully to control a significant spill.

6. No firm agreement exists between NTPC and the Clean Sound Co-
operative; a firm commitment between the two parties is necessary
before NTPC can state they are to use the CSC equipment and know-
how.

Specifics
1. Personnel

History has shown that terminal personnel can take care of small
spills at the terminal, but are not trained or available to control
or take part in major clean-up efforts such as a tanker grounding
along the Juan de Fuca Straits. The oil industry in all areas
around North America have formed cooperatives such as the Clean
Sound organization, and they rely on stand-by contractors to clean
up oil spills. These contractors are trained with the equipment
and, as they cover a large area such as.the Puget Sound, usually
have a lot of practice. The plan implies that there is going to
be some arrangement with Clean Sound to call for their assistance.
This is very vague, and if it is only an agreement to be called in
from Seattle at the time of a major accident, then they will arrive
too late for any w'aterborne oil spill clean-up, but will only be
useful for organizing clean-up of the beaches. The nearest Clean
Sound equipment is located in.Bellinaham, whichlis a minimum of 12
hours steaming from Port Angeles. Personnel from Seattle could be
flown in, but as they will be bringing a lot of heavy equipment, it
is more likely that they will come by road, which will take a
minimum of four hours provided that the ferries are operating. The
NTPC -plan requires clarification on just how this manpower and
equipment will be mobilized to a point along Juan de Fuca Strait.

2. Equipment Selection

The NTPC draft contingency plan lists the specific models of
equipment that they would locate in Port Angeles, Green Point
and Arlington. The Green Point/Arlington equipment would only
be useful for spills within the harbour area or, on occasions,
in the Straits on a very calm day.

There is no equipment developed to date which has been capable
of containing and collecting oil in sea state 2 and 3 conditions.
(Tsahalis, 1979; Bright, 1979; Meade and Anderson, 1979; Fricke,
1979; Mathews, 1979; White, Nichols.and Garnett, 1979) NTPC state
that containment and recovery of oil is possible up to sea state 3
and I - 1.5 knots current. This has yet to be demonstrated. How-
ever, the author of the equipment list (Woodward, Clyde Consultants

Vol. II) is not aware of current.performance data on the types
of equipment which are recommended for this purpose, and has
recommended equipment which would not be suitable for even sea
state 1 to 2 conditions in the Straits.

Examples of this are Marco Type 4'and 7 skimmers. This type of
skimmer is not suitable for crude oils or any light fuels, only
heavy bunker fuels. (Beak Consultants, Canguard Consulting,
Associated Engineering, 1978). "Foam belt skiming units are
not suitable for recovery of light fuels or crude oils other than.
heavy bunkers or heavy crudes." (John Weichert; Manager, Clean
Sound Cooperative; pers. comm.)

The VIKM Seapack is an air inflated boom of 1600 ft. in length
which is heavily reliant upon the operation of air fans, pumps,
diesels, etc. Due to their unreliability in performing when
needed, the reputation of this equipment is poor. It also has
one inherent problem in that it does not have any top or bottom
tension member and this results in the loss of oil underneath the
boom even in calm seas with a half 'knot current. The author of
the equipment list recognizes the need for top and bottom tension
cables in oil booms, as he specifies it in other types. However,
the fact that the VIKOMA does not have these tension members is
ignored. (Bennett Environmental Consultants, 1980).

3. Beach Clean-Up

This is a major component of the Straits Contingency Plan, and any
grounding or accident to the tanker along the Straits will usually
result in shoreline pollution.

The present NTPC draft contingency plan does not indicate which
beaches could be used as sacrificial beaches in the event that oil
containment booms were to arrive on site in sufficient time to at
least direct oil to a specific area. There is no plan for clean-
up on the Canadian side of the Strait. Although Appendix C of
Volume II contains natural resource's inventory tables, this infor-
mation should be mapped to indicate all sensitive areas for fish,
shellfish, mammals, birds, tourists, etc. The plan does not ad-
dress the problems of access to beaches or the logistics of supply-
ing teams of workers in remote locations. Feeding and accommodating
the clean-up crews is always a major problem in an extended oil spill
clean-up. There are no large town-sites along the Straits which
could accommodate a sudden influx of personnel such as was required
in the Santa Barbara clean-up which took some nine months and em-
ployed an average of 200 workers per day. The traffic congestion,
resulting from movements of men and materials to clean-up sites and
recovered wastes to dump sites, particularly during the summer
vacation period,is very disrupting and has some long-term effects
on the tourist.industry. Santa Barbara is often quoted as being
unaffected by the Union Oil oil spill in 1969, and tourism was not
down. This is misleading, as during that year all hotels, restaurants,
etc., were busy due to the influx of clean-up teams, news media,

salesmen and other interested personnel in the oil spill. Also,
the natural scouring and highenergy in the intertidal zone in
the Santa Barbara Channel resulted-in rapid natural clean-up. This
high energy and scouring effect by sand does not exist along the
Straits.

For NTPC to demonstrate that they are aware of all these problems,
they should have included in their Contingency Plan some scenarios,
detailing what specific action they would take in some typical spill
situations. In scenarios, means of dealing with problems such as
the above could be 'detailed

C2) Detection of Night-Time Spills at Berth or in the Strait of Juan de Fuca

EXPLANATION:

The early detection of oil spills is critical for adequate containment
-and clean-up.

BACKGROLJND - NTPC APPLICATION:
SOURCE
"The submarine,portion of the unloading pipeline route
will also-be patrolled twice daily by a small launch Vol. II
operated by a competent observer. Relatively small p.6-30
amounts of oil will produce a sheen on the water
surface that can be detected visually. The launch
will be equipped with an infrared scanning device,
designed to detect the presence of oil on water not
discernible to the human eye."

The Marine Terminal Oil Spill Contingency Plan
outlined in the NTPC Application includes the follow-,
ing "Definition of procedures to be followed and Vol. II
lists of personnel, equipment and materials to be p.6-212
mobilized for each type of emergency situation
including:

minor operational spills at the tanker berths
during transfer of crude oil or bunker fuel;

minor accidental spills in the harbor or in
the strait;

minor and major spills resulting from leaks or
ruptures in the unloading pipelines, tanker,and
bunker berth piping, trestle piping, and booster
pumps piping."

DISCUSSION:

This is a problem which has not been adequately addressed by NTPC
and is a difficult problem to solve. There are a number of oil
spill detectors available on the market. They include designs
incorporating hard-wire systems, radio beacons, and infra-red
scanners. They all have their inherent problems. The in-water
buoy type usually relies on the differing conductivity of oil and
water and the direct contact of the spill with the buoy. The
problems with this type are that the buoy mightnot necessarily
be in contact with the spill due to current or wind directing the
spill away.fr6m the buoy, or a very small spill will set off the
alarm. As this is a busy port where small quantities of oil will
be on the water surface regularly, false alarms would soon result
in the misuse of the detector. These detectors require replace-
ment of the element or sensing device ea--ch time an alarm is given.

The infrared scanners are more reliable, but still need an experi-
enced eye to identify a spill, and the screen will be confusing to

a casual user of the system. Anything other than water shows on
the screen with only a difference in intensity visable. The move-
ment or flow of the object is also an indicator that it is oil.
A major problem with this type of device is that significant spills
are infrequent and operators become complacent about the use of the
equipment.

The best detector of an oil spill at night is a watchman's nose.
To be effective, regular inspections of all operations are required
during both day and night.

A spill from a tanker underway in the Juan de Fuca Straits at
night would be extremely difficult to detect even if each vessel
were fitted with its own infrared scanner, as the oil accumulation
on the surface astern of the vessel would be too slow to be ident-
ified on the scanning system.

C3) Capability of Existing quipment for use at River Crossings in
Clallam County.

EXPLANATION:

For use at river crossings, oil spill containment must be at
staging sites for immediate use, and must be capable of operating
under a variety of topographical and stream flow conditions.

BACKGROUND - NTPC APPLICATION:
"Containment would include using earthen dams SOURCE
across ravines and ditches, straw dams and under- Vol. II
flow dams across small streams, and floating p.6-214
booms across larger waterways" ... "As much oil as to
possible would be picked up by tank truck and p.6-21S
hauled to an approved disposal site or to the
nearest station for reinjectioninto the pipeline
system" ... "Along water coursesl work boats would
,use a water jet from a utility pump and hose to
wash down the banks and move the oil to a convenient
location for pick-up. Oil slicks on lakes could be
contained and moved by two work boats and a boom.
The oil-water mixture would be pumped out, skimmed
with a floating skimmer, or skimmed in a pit and
hauled away. A:boom. installed at an angle to the
bank would serve as a collection trap" "After
all possible oil had been recovered, a final water
clean-up would be made with sorbent pillows and
straw.".

DISCUSSION:

The equipment stored at Green Point would be the closest equipment
to river or stream crossings in Clallam. County. Because most
streams are crossed at their lower ends, it is unlikely that this
equipment could reach a river or stream crossing oil spill in time
to be of any effective use. The oil will have reached salt water
and probably be in an emulsified form. This emulsion could be
trapped in bays or along beaches. Light booms could be used to pool
the emulsified oil and the oil mop skimmer has proven to be effect-
ive in recovering oil in these conditions. However, for most
streams in Clallam County, there would be little that could be done
to get equipment to the spill site before the oil had moved down-
stream and the toxic effects to biological life had taken place.

C4) An Evaluation of the Electronic and Human Surveillance of the
Proposed Leak.Detection System

EXPLANATION:

The difficulty in containing and cleaning up an oil spill and the
degree of environmental impact of the spill will usually be
related to the size of the spill. The size of the spill in turn
will be related to the sensitivity of the various detection
systems.

BACKGROUND - NTPC APPLICATION: SOURCE

"For the inactive condition, static line pressure will Vol. II
be monitored at the booster pump platform"... p.6-29
to
"The quantitative sensitivity of this method will p.6-30
depend on the accuracy of the instrumentation and the
temperature compensation computer'program associated
with the monitoring system and the slope of the pipe-
line terminations at Green Point. Preliminary studies
indicate that leaks as small as 50 to 100 barrels or
0.07% to 0.14%, respectively, of the contents of one
line can be detected"...

"For the active or operating condition, a different
type of monitoring and leak detection system will be
used. For this condition, state-of-the-art sonic
flow meters (as discussed in Section 11-6.3.7) are
planned for installation at the tanker unloading
facilities and at the Green Point pipeline termi-
nations. This system will continuously monitor the
flow by computer at the booster pump platform and
the receiving point at Green Point. This leak
detection system will have a comparative measurement
accuracy of 0.5% of the pipeline throughput. A
second, though less accurate leak detection system
for the active condition will consist of the contin-
uous simultaneous monitoring by computer of the
quantities indicated by the turbine meters installed
on the booster pump platform and the quantities
indicated by the automatic tank guages installed on
the Green Point storage'tanks"...

"The submarine portion of the unloading pipeline
route will also be patrolled twice daily by a small
launch operated by a competent observer. kelatively
.small amounts of oil will produce a sheen on the

water surface that can be detected visually. The
launch will be equipped with an infrared scanning
device, designed to detect the presence of oil on
water not discernible to the human eye."

"Aerial and on-the-ground pipeline surveillance for Vol. II
possible leaks or other difficulties will be part p.6-111
of the routine operational procedures. Small leaks
and other.potential pipeline hazards will be de-
tected before they become serious."

"As part of the NTPC oil spill surveillance program Vol. III
an aerial patrol will traverse the strait following p.2.11-9S
the pipeline route a minimum of once every two weeks
to detect-visually any small leak that might occur."

DISCUSSION:

Ediz Hook to Green Point Pipeline capacity is 100,000 barrels per
hour. A maximum undetected leak could be O.S% of flow or SOO
barrels per hour during tanker offloading. NTPC intend surveying
the line twice per day. Therefore a leak could go undetected for at
least 12 hours. Approximately 6,000 barrels of oil could leak into
the harbour undetected during this period.

The maximum throughput for the rest of the pipeline is 933,000
barrels per day. Therefore a maximum undetected leak could be
0.5% of this flow or 4,1500 barrels per day which could continue
for up to two weeks between aerial surveillance flights in a worst
case situation assuming the leak was observed during the next
flight.

If an undetected leak occurred from either situation, it is evident
that the amounts involved could be significant and as the NTPC
Application reviews in Volume III, p.2.3-24 to 2.3-32; 2.4-19 to
2.S-32; 3-4 to 3-6; 4-2; 6-6; 6-8; 6-10 and 6-11, the introduction
of oil into the freshwater and marine environments along the .
route could have serious impact on water quality, flora and fauna
over time periods measured in years.

In the experience of the reviewers, it appears that NTPC is using
the best state-of-the-art leak detection system that is available.
Therefore, the projected environmental impacts from undetected
spills would be non-mitigatable residual impacts. For the
terrestrial and standard river and stream crossings part of the
pipeline, the environmental risks as demonstrated by history of
breaks on other existing pipelines is probably acceptable, at
least for the projected life of this pipeline. However, the degree

of environmental sensitivity for specific watercrossings (see Section
AS) might make the risk locally unacceptable. Environmental risk for
the submarine portions of the line may not be acceptable, since as
pointed out in other sections of this report the applicant will be
utilizing new technology for dealing with site-specific problems at
each of the three submarine crossing locations. Therefore,, any
calculation of undetected leak frequency occurrence for these sections
of the pipeline is highly speculative and would be unsubstantiated by
historical experience.

CS) Potential Impacts on Groundwater

EXPUNATION:

During the pipeline operations phase in particular, the contamination
of groundwater with oil is a significant concern. The clean-up of
oil contaminated groundwater is a difficult task.

BACKGROUND - NTPC APPLICATION: SOURCE

"The impact on groundwater of an operational oil spill Vol. III
at the onshore storage is anticipated to be very small p.2.3-14
because of the low permeability of the glacial tills
to both water and crude oil. Perched groundwater
conditions indicate that an oil spill or leak will
not reach the regional groundwater table, and only
very local contamination of perched water could occur,
since the groundwater itself would have to be dis-
placed by the less dense oil to penetrate any perched
aquifer zones."

"Construction activities will not have a potential for
contaminating or degrading public water supplies
because no municipalvater supply sources are located
near the onshore storage facilities."

"Oil spilled at Green Point will not affect public
water supplies because no public water supply sources
are located near the onshore storage facilities."

"Any.oil spills or leaks from the proposed pipeline Vol. III
will have varying effects on groundwater. Local p.2.3-34
contamination will occur if spills or leaks occur in
shallow aquifers. Since oil is less dense than
water, any.spilled oil will remain near the ground-
water surface and could expand laterally at a rela-
tively slow rate. Geological characteristics of the
C,
area where the spill or leak occurs will influence
the magnitude of oil impact to groundwater. If the
spill or leak occurs near an aquifer or recharge
area where confining rock layers are absent, con-
tamination of groundwater resources will be more
severe than if a spill occurs where the aquifer is
relatively deep and confining rock beds retard
movement of the oil. Leak detection systems and
block and check valves will mitigate the amount of
oil that could be lost from a pipeline rupture."

With respect to the pipeline during the inactive
phase:

"Preliminary studies indicate that leaks as amall as Vol. 11
So to 100 barrels or 0.07% to 0.14%, respectively p.6-29
of the contents of one line can be detected."

For the active or operating condition:

"This leak detection system will have a comparative
measurement accuracy of 0.5% of the pipeline
throughput.,,

"The potential for groundwater contamination because Vol.; III
of pipeline construction is small." p.2.3-36

DISCUSSION

It is important to note that oil contamination of groundwater during
the construction of the tank farm and pipeline should not be con-
sidered a major concern. Although oil contamination is possible, the
volumes involved are small and the resultant spill contamination
would be both local and small. The amount of contamination during
construction will depend on the type of aquifer affected, and the manner
in which spills are controlled or responded to. The contamination of
groundwater with oil is, however, a major concern during the opera-
tional phase of this proposed development. The risks of damage and
the magnitude of the potential problem are greatest for the terrestrial
portion of the pipeline. The discussion that follows pertains
primarily to the terrestrial pipeline.

Minor oil spills could result from leaking valves or gauges and small
leaks. Major spills could result from pipeline splits or ruptures
caused by defective pipe, imperfect welds, pipe corrosion, landslides,
vandalism,, sabotage, excavation equipment hitting the pipe, river scour,
earthquakes, and operational errors or accidents (Montana Department
of Natural Resources and Conservation, 1979). In this context, a minor.
spill is defined as 5,000 gallons or less and a major spill as tore than
5,000 gallons.

In.the NTPC documentation, it has been noted during the inactive phase
of the operational pipeline that leaks of 50 to loo barrels (presumably
per day) can be detected by instrumentation. This could amount to oil
losses of 3,500 to 4,500 barrels per day depending upon the pipeline
throughput. Losses of this magnitude are a major concern especially
noting that this loss will occur at one specific site along the pipeline
route.

Oil in the ground will, generally speaking, migrate through the soil and
form a pancake-shape layer on the groundwater surface (Concawe, 1977).
To a degree, oil and groundwater mixing will take place. Rainwater will
percolate through the soil an *d will dissolve certain oil components,
then enter and further contaminate the groundwater system. In that

groundwater flow patterns are very seldom understood, the clean-up
of the contaminated groundwater is a costly, difficult and time-
consuming process. If the groundwater is being used for water supply
purposes, an alternate water supply source will have to be found.
Considering the large clean-up time that would be involved, finding an
acceptable alternate water supply source may be a difficult and costly
problem in some areas traversed by the pipeline.

NTPC should address the following subjects in more detail:

1. 1mprovements that can be made to the pipeline leak detection
system;

2. the pipeline leak detection surveillance program;

3. specific procedures in case of a major oil leak and ground-
water contamination problem.

C6) Improvements for Oil Spill Prevention, Response, and Clean -Up
Capabilities

EXPLANATION:

The NTPC Oil Spill Contingency Plan should outline the best action
plan possible to protect the environmental resources of the Juan
de Fuca and Clallam County area.

BACKGROUND - NTPC APPLICATION: SOURCE

."The objective is to design, construct, operate and p.2-1
maintain the proposed facilities in the safest,'most
economical, and least environmentally damaging
manner possible."

DISCUSSION:

Collision in the Straits of Juan de Fuca is unlikely, but mandatory
traffic control would add a degree of safety. The most likely
causes of an accident, and oil spillage, are loss of power, loss of
the propellor, or loss of steering. A vessel which suffers any one
of these three problems.while in transit in the Strait will very
quickly run aground. Once aground on the type of shoreline which
borders the Strait, it is highly likely that the vessel will break
its back. The risk of this type of accident could be reduced if
each vessel was piloted by a suitable tug while in transit in the
Straits.

The Clean Sound Cooperative has had-considerable experience in
testing and use of oil spill clean-up equipment and should be fully
consulted regarding its selection. Training programs of oil spill
response teams should be specified and definitely committed to by
NTPC.

The information contained in the draft Volume Il Contingency Plan,
Appendix C, should be produced in a form.easier to read, preferably
on maps which would immediately indicate sensitive areas and also
predetermined sacrificial beaches. These sacrificial beaches are
found to be necessary in every major oil spill clean-up operation.
The two main factors in determining specifications for a sacrificial
beach are 1) its environmental sensitivity, and 2) its accessibility
and ease of clean-up.

The main area of the draft contingency plan that requires
considerable improvement is the section dealing with the tanker
traffic route Cape Flattery to Port Angeles.

It is well known that the present state-of-the-art oil spill
clean-up equipment on open water does not provide the clean-up
assurancesthat are reliable. If large tankers are going to
transit the Straits, then a more practical contingency plan is
required.

The logistics of cleaning up an oil spill have not been addressed
adequately and there is insufficient practical guidance to an
on-scene commander in the contingency plan. Pre-determined-
specific methods should be established for the total shore-line.
These methods would include the determination as to the availa-
bility of man-power and materials.

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H.P. Drewry,(Shipping Consultants) Limi ted. 1974. Crude oil pi@elines
and VLCC ports.H.P. Drewry (Shipping Consultants) Limited, London. 81 pp
H.P. Drewry (-Shipping Consilltants) Limited. 1978. Su@@orts and
S B M's for tankers.- H.P. Drewry (Shipping Consultants)
Limited, London. 63 pp.

H.P. Drewry (Shipping Consultants) Limited. 1978. U.S. oil imports
policies and tanker shipping. H.P. Drewry (Shipping Consultants)
Limited, Lond6n- -68pp.

Kavanaugh G.N. and A. Townsend. 1977. Construction related oil spills
along Trans- Alaska,pipeline. Joint State/Federal Fish and Wildlife
Advisory Team. special report No. 15. 16 pp.

Kirsop, R.G. prefiled testimony for applicant Northern Tier Pipeline
Company. Appearance #1 and Appi@arance #2.

Koloski, J. prefiled testimony for applicant Northern Tier Pipeline
Company.

Kramer, Chin, and Mayo, 1978. Letter dated May 2, 197.8 from Fu lton
G. Gale to Mr. Kenneth Walton, City Manager-, Port Angeles.

Krebs, C.T. and K.A. Burns. 1978. Long Term effects of an oil Spill
on populations of the salt marsh sr-a'F-.-P
@aa @u@@ax. @Ast@ract @ J. Fish.
Res. Board Can. 35: 648-649.

Lloyd's of London. 1980. Summary of fires and explosions in the cargo
area of tankers over 10,000 DIVT reported in Lloyq's List, 1977-1979.
Taken from: LloTd-F-s-list, ICS Casualty Bulletins. 4 pp.

Martell, H.G. prefiled testimony for applicant Northern Tier Pipeline
Company, Appearance #1 and Appearance #2.

Mathews, K.W., Lt. Coly. 1979. The Global Hope is aground- an incident
at Salem Sound. Proceedings 1979 oil Spill Conference, Los Angeles,
California p. 127

10.2

McDermott Hudson Engineering. 1977. Installation feasibility of a
crude oil pipeline crossing in the Strait of Juan de Fuca, WasFington.
Prepared for Northern Tier Pipeline Company. Project No. 660S.

MacDonald., T. n.d. Reflections of a blaze. Nanaiino FiTe.Department
Nanaimo, B.C. 16 pp.

McKee, J.E. and H.W. Wolf (ED)-1963. Water quality criteria,
Sacramento: California State Water Resources Control Board S 8 pp.

Meade, N. and R.G. Anderson. 1979.. Problems-and perspectives in measuring
the social costs of oil pollution. Proceedings 1979. Oil Spill Conference
Los Angeles, California. p S9.

Montana Department of Natural Resources Conservation,, Energy Di-vision,
1979. The effects of large underground pipelines on aquatic life and
habitants'with emphasis on the proposed Northern Tier Pipeline in
Montana.. Northern Tier Report 68 pp,

National Transportation Safety Board. -19SO. Safety-Information Report,
.SB 80-17/2868.

National Transportation Safety@Board 1980., Southern Natural Gas
Company rupture and fire of a-14 inch-gas transmission pipeline
southeast of New Orleans, Louisiana, July 1S, 1979F. Pipeline accident
report: NTSB-PAR-80-1

Nicol, C.W.1976. The Mizushima oil spill - a.tragedy for Japan and a
lesson for Canada.-@viromental Impact and Assessment Report, Report
T-
EPS-8-EC-76- . 2S pp.

Northern Tier Pipeline Company. 1979 a. Application for site
certification. Vol I, Vol II, Vol III Part 1, Vol III Part 2, Vol V
Part 1, Vol V Part 2. Submitted to State of Washington Energy
Facilities Site Evaluation Council Oly
.1 ympia Washington.

NOAA, 1978. Surface drifter movements observed in Port Angeles Harbor
and.vicinity, @ril 1978. C.C. Ebbesmeyer, J.M. Cox, J.M. Helseth. NOAA
Techinical Memorandum MESA-31.

National Oil Week Magazine 1980. Did the clock stop at Bantry Bay.
National Oil Week Magazine March 14, 1980. 6 pp.

Oceanographic Institute of Washington. 1980. Comparison of oil spill
risk in Greater Puget Sound, final report. Prepared for:
Environmental Research and Technology, Inc., Seattle, Wash. 120 pp.

Oceanographic Institute of Washington. 1978. LNG and LPG hazards
management in Washington state. Prepared for: Oceanographic
Commission of Washington. 2SO pp

Oceanographic Institute of Washington 1978b. Oil Spill risk
analysis. Prepared for:. Bureau of Land Management, Northern
Tier Pipeline Environmental Statement Office. 171 pp

103

Oceanographic Institute of Washington. 1978c. Existing and incremental
oil spill risk analysis for the federal Northern Tier Pipeline
environmental statement. Prepared for: Bureau of Land Management,
Northern Tier Pipeline environmental statement office. 113 pp.

Oceanographic Institute of Washington 1978d. Oil_Spill risk analysis
for the federal Northern Tier Pipeline environmental statement;
Appendices. FFe-p-a-rW-for: Bureau of Land Management. Northern Tier
Pipeline Environmental Statement Office. 134 pp.

Oceanographic Institute of Washington. 1979a. Behaviour and Fate of
underwater pipeline oil spills,final report. Prepared for:
Encironmental Research and Technology, Inc., Seattle Wash. 48 pp.

Oceanographic Institute of Washington. 1979b. Open water oil spill
trajectory analysis for the federal Northern Tier Pipeline
environmental statement. PreparR for: Bureau of Land Management,
Northern Tier Pipeline Environmental Statement office. 55pp.

Oceanographic Institute of Washington, 1979c. Fire and explosion hazards
Analysis and mitigation for the federal NortheE -Tier Pipeline
environmental statement; final r2port. Prepared for: Bureau of Land
Management, Northern Tier Pipeline office. 134 pp.

Oceanographic Institute of Washington. 1979d. Occurrence and
consequences of petroleum fires and explosion@_. Prepar@@�r
Enviromental Research and Technology Inc., Seattle, Wash. 94 pp/

Oil Companies International Marine Forum.-1979a. Higher risk sea areas,
a risk analysis. Witherby and Co. Ltd., London. 16 pp.

Oil Companies International Marine Form. 1979b. Higher risk sea areas,
a risk analysis; Annex 6 Risk Analysis Witherby anU Co., Lo-n-To-n. 5 pp.

Olender, W.K. prefiled testimony for applicant Northern Tier Pipeline
Company.

Peebles, E.E. prefiled testimony for applicant Northern Tier Pipeline
Company.

Petroleum Association for the conservation of the Canadian Environment.
1976. Offshore Marine oilspill contingency plan. PACE Report No.
.7510. 113 pp.

Phillips, R.W. 1971. Effects of sediment on the gravel environment
and fish production. Proceedings of a symposium of forest land u-ses
@-nd stream environment. Corvallis: Oregon State University Press.
p. 64-74.

Porricelli,J.D., V.F. Keith and R.L. storch 1971. Tankers and the
Ecology. Trans soc. Nav. Arch. Mar. Eng. 79: 169-221.

104

Renzori, A. 197S Toxicity of three oils to bivalve gametes and larvae,
Mar. Poll. Bull. 6: 12S-128.

R.J. Brown and Associates. 1979a. Preliminary Pipeline Design and
Review of Installation Methods for Port Angeles Harbor Crossing.
Prepar6J_fo_r_. Butler Associates Inc., February 1979.
R.J. Brown and Associates 1979b. Preliminary EngineeriLig Design for
for Submarine Pipeline Crossings of the Strait of Juan de Fu a and
Saratoga Passage. Prepared for: Northern Tier Pipeline Co., Aprii-1979

R.J. Brown and Associates 1979c. Revision of Preliminary Pipeline
for Port Angeles Harbor.Crossing.. Prepared for: Northern Tier Pipeline
Company, November 1979.

Roger Lowe Associates, Inc., 1980. Reportof river channel migration
studies, Clallom'Snohomish and King Counties, Washington. Prepared for:
Northern Tier Pipeline Company Sandemeyer, R., prefiled testimony for
applicant Northern Tier Pipelineompany.

Sanders, H.L., J.F. Grassle and G.R. Hampson. 1972 The West Falmouth
oilspill I. Biology WHOI-72-20. Prepared for: Environmental Protection
Agency. 47 pp.

Science Applications., Inc. 1978 Technical document Alternatives to the
proposed project, Northern Tier P@ipeline project, Chapter 8. Prepared.
for: Bureau of Land Mangement, Northern Tier Pipeline Project ElS,
Portland Ore. 179 pp.

Shannon and Wilson, Inc. 1978a. Geotechnical Investigation, Northern
Tier Pipeline Compa@y, Marine Terminal Facilities, Port Angeles,
Washington. Pre-Dared for: Swan Wooster Engineering Inc., July 1978

Shannon and Wilson Inc., 1979a,. Treliminary Geotechnical ExDlorations
and Stfidies for Submar-ine Pipeline'Cros sings' of the Strait of Juan de
Fuca and Saratoga Passage. Prepared for: Northern Tier Pipeline
I
Company., Apri11979.

Shannon and Wilson, Inc., 19 79b. @@pplemental Geotechnical Explorations
and Studies. Marine Terminal Facilities, Port Angeles, Washington.
Prepared for: Northern Tier Pi eline Company; April 1979.

Shannon and Wilson Inc... 1979c. Reconnaissance of Shore Approaches,
Northern Tier Pipeline, Strait of Juan De Fuca and Saratoga Passage
crossings. Prepared for: Northern Tier Pipeline Company, December 1979.

SRI International. 1978. Northern.Tier Pipeline Environmental Statement,
Technical Report, Chapter 8, project alternatives, Part 1, Port
Alternatives.14S pp.

los

State of California, Air Resources Board, 197 7. Air Pollution
consequences of the proposed SOHIO-BP crude oil transfer terminal
at Long Beach, California. Report No. 77-17-1, 61 pp.

Stewart R.J. 1978. Oil spill trajectory predictions for the straits of
Juan de Fuca and San Juan Islands. For the Bureau of Land Management's
review of the Northern Tier Pipeline Company's proposal;final draft.
45 pp.

_Straughan. D. 1971. What has taken the effect of the spill on the
on the ecology in the Santa Barbara channel? Biological and
Oceanographical survey of the Santa Barbara Channeloil spill 1969-70.
Biology and Bacteriology. D. Straugban(ed)

Straughan, D. and D.Hadley. 1978. Experiments with Littorina species
to determine the relevancy of oil spill data from southern California
to the Gulf of Alaska. Marine Environ. Res. 1:13S-163.

Swan Wooster Engineering, Inc. 1976 northern Tier Pipeline Company,
deepwater port study, marine facilities. Prepared for: Butler
Associates Inc., Tulsa, Okla. 60 pp.

Swan Wooster Engineering 1978.-Northern Tier Pipeline Co any,
alternative port sites. Prepared for: No rn Tier Pipeline
Company. 66 pp.

Swan Wooster Engineering 1979. Northern Tier Pipeline Company
tanker unloading facilities, Ediz Hook impacts. 71 pp.

Thayer, G.W. and R.C. Phillips. 1977. Importance of eelgrass beds in
Puget Sound. Mar. Fish Rev. 39:18-22.

Tilde-n,N.E. prefiled testimony for applicant Northern Tier Pipeline
Company; Appearances #1,#2,and#3.

Tsahalis, n.T. 1979. Contingency Planning for oil spills: Riverspill-
A river simulation mo I- proceedings 1979 Oil Spill Conference-,
Los Angeles, California p.27

Tyler R.W. 1960. Use of Dynamite to recover tagged salmon. Special
scientific Report-fisheries, No. 3S3. US Fish and Wildlife Service. 9 pp

U.S. Coast Guard: 19771 Marine board casualty report, SS Sansenina
(Liberian); Explosion and fire in Los Angeles Harbor, California on
December 17, 1976 with loss of life. DOT. Report No. USCG 17632/
7189S

Veatach,M., prefi led testimony for applicant Northern Tier Pipeline
Company. Appearances #1 and #2.

Washington Dept. of Fisheries 1979. Review of EFSEC application for site
certification for.northern T-ier Pipeline Company.

Whiteside, A.E. prefiled testimony for applicant Northern Tier Pi line
Com.pany. ph

106

White I.C. JA. Michaels and M.J. Garnett, 1979. Ten Year overview of
Clean-up at sea. Proceedings 1979 oil spill conference, Los Angeles,
California p.257.

Wilson, D.R. prefiled testimony for applicant Northern Tier Pipeline
Company.

Winegar, L.L. prefiled testimony for applicant Northern Tier
Pipeline Company.

Woodward-Clyde Consultants, 1979. Oil Spill contingency response plan
draft. Vol.I: General provisions, prepared for: Northern Tier Pipeline
Company. 212 pp.
Woodward-Clyde Consultants, 1979. Oil S@ill conting encX response
plan, draft. Vol II: Port Angeles district. Prepared tor: Northern
Tier Pipeline Company. 311 pp.

DATE DUE

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