' Kozloff Keith From Sent To Cc Subject Herman Chris@epamail epa gov Tuesday August 19 2003 3 02 PM keith kozloff@do treas gov rick williamson@exim gov Cotter Patrick@epamail epa gov Hill-Macon Cam@epamail epa gov Camisea Pipeline EIA-storms toxicity Keith and Rick-As they are useful I am forwarding Dr Brian Melzian's comments on yesterday's draft about potential effects of storm waves and toxicity of potential released materials I will revise and circulate this note to reflect Dr Melzian's and other comments Other comments have noted that physical effects smothering suffocation of diesel gasoline spills on aquatic systems can be immediately catastrophic--making their toxicity a relatively academic issue and the need to distinguish better between naphtha and naphthalene It seems that the description of what will be in the pipelines changes from document to document If you meet with Plus Petrol could you ask --whether contrary to the EIA the pipeline is to be trenched the entire distance to the terminal to what·depth --whether any wave spectra study has been done including during the winter --what is the latest version of what product diesel jet fuel gasoline naphtha propane butane--or all the above or others depending on market conditions will be exported Thanks Chris Forwarded by Chris Herman DC USEPA US on 08 19 2003 02 49 PM----Brian Melzian To Patrick Cotter DC USEPA US@EPA Chris 08 19 2003 02 26 PM Herman DC USEPA US@EPA cc Subject Some Comments Camisea Pipeline EIA Pat and Chris Unfortunately I need to work on some other very important and time-sensitive projects but please see my comments in bold found below Good Luck with all of this and when are we going to Peru - Brian NHEERL Atlantic Ecology Division 401 782-3188 ----- Forwarded by Brian Melzian NAR USEPA US on 08 19 03 01 23 PM Chris Herman Sent by Chris ·To Brian 1 Patrick Cotter DC USEPA US@EPA --------------------------- Herman -- -- Melzian NAR USEPA US@EPA _cc keith kozlo£f@do treas gov james mahoney@exim gov Subject Camisea Pipeline EIA 08 18 03 06 45 PM Based on discussions with EPA colleagues I have been reviewing the PlusPetrol ERM EIA report Alternative Subsea Piping with respect to two questions--pipeline whip risk and characterization of leaks resulting from pipeline rupture This note is a draft subject to correction and revision on technical matters--all errors are mine--intended to flag some possible concerns I wo ld welcome comments reactions Risk of Pipeline Whip NOTE THAT WAVES GENERALLY TOUCH BOTTOM AT APPROXIMATELY 1 2 THEIR WAVE LENGTH HENCE A WAVE ONLY 7 METERS IN LENGTH MEASURED FROM CREST_TO CREST WILL IMPACT THE BOTTOM BY THE WAY YOU CAN DETERMINE THE TYPES OF WAVES THAT HAVE IMPACTED THE COAST BY SIMPLY MEASURING THE GRAIN SIZE DISTRIBUTION OF THE SEDIMENTS WHERE THE PI-FELINE WILL BE BURIED IF THE SEDIMENTS ARE FINE AND MUDDY THEIR PROBABLY WILL NOT BE MUCH DISTURBANCE BY THE WAVES AT LEAST MOST OF THE TIME BECAUSE THESE WAVES WILL USUALLY BE SMALL AND THE OCEAN CURRENTS ARE WEAK IF THE SEDIMENTS ARE COARSE SAND OR GRAVEL THERE WILL BE MUCH WAVE AND LONGSHORE CURRENT-ACTION OVER TIME AS YOU MAY KNOW THE PACIFIC OCEAN OFTEN G NERATES WAVES WHICH ARE MUCH LONGER THAN 7 METERS ESPECIALLY IN THE WINTER HENCE PERHAPS SOMEONE SHOULD DEPLOY A SURFACE BUOY TO MEASURE THE WAVE SPECTRA OVER T-IME SOMEONE COULD MEASURE THE ONSHORE-OFFSHORE MOVEMENT OF THESE SEDIMENTS BY SIMPLY POUNDING LARGE METAL RODS INTO THE SEDIMENTS AT VARIOUS INTERVALS PERPENDICULAR FROM THE BEACH AFTER THIS rs DONE THE SCUBA DIVERS Pat COULD THEN GO _OUT AND SEE HOW MUCH SEDIMENTS AS MEASURED BY VERTICAL CHANGES NEAR THE RODS ARE MOVED OVER TIME THIS rs A FAIRLY STANDARD PRACTICE USED TO MEASURE THE EROSION AND ACCRETION OF BEACH SEDIMENTS According to the report Chapter 1 page 2 the pipeline approximately 4000 meters long will lie on the sea bed after a sea water depth of 3 5 meters has been reached ie about three quarters of its length Up to that point it will buried to a depth of two meters to protect them from the waves This raises the question what waves --normal waves-·or storm-produced waves Given the configuration of the Pacific coast it would appear that this design might protect the pipeline from normal waves but could well expose the pipeline to wave action and pipeline whip during storm events The report does not appear to address this latter source of rupture risk The report's brief discussion of pipeline rupture is limited to rupture due to a ship's anchor or an important earthquake Unlike other sealoading facilities the report does not claim that the pipeline has been designed to minimize risk of spill due to third parties damages earthquakes and tsunamis- Impacts of Rupture The report's brief discussion of the effects of pipeline rupture is limited to fire and explosion on the assumption that the 'worst' result of a spill would be an ignitable vapor cloud formed by butane propane or an ignitable diesel 'lake' ·on a brief review the potential for a pipeline-based fire to ignite the platform or a tanker--a horrendous scenario-- is not discussed except to say that the objective of the response action would be to control any migration of the ignited product chapter 4 page 27 2 - -- The_EIA does not discuss the environmental impacts of rupture-induced fire or explosion or pollution of coasts and beaches it does not even mention the possibility of aquatic ecosystem impacts in the Reserve or elsewhere THIS COULD BE A MAJOR-PROBLEM It simply-and in a wholly conclusory fashion--states that the assessment of impacts which might derive on a potential basis from these contingencies have been assessed as slight on the rest of the resources analyzed chapter 5 p 32 It claims that the maximum volume spilled would be 5400 barrels propane butane 4100 barrels gasoline 700 barrels diesel Chapter 4 page 26 IF THIS IS A REMOTE AREA AND NO ONE IS AROUND TO IMMEDIATELY RESPOND THESE TYPES OF SPILLS COULD END UP BEING MUCH LARGER WORSE EVEN THOUGH THESE AMOUNTS ARE NOT AS LARGE AS WHAT WOULD-OCCUR FROM AN OIL TANKER SPILL THEY ARE STILL QUITE LARGE This sounds low given the initial 113 m3 hour subsequent 350 m3 hour production capacity of the plant · The butane and propane pipes are both 20 inch diameter insulated while the gasoline pipe is 24 inch and the diesel pipe is 10 inch diameter Only the 20 inch pipes will have fiber optic cable to monitor damage to the insulation The report's estimate is based on activation of a blockage valve 1 kilo on shore within 30 seconds by pressure loss sensors and on trapping half of the product ·within the pipe The basis for the assessment that impacts would be slight is unclear It appears to assume that the contingencies plan is completely effective to prevent incidents or reduce the effect of a fire explosion to a minimal level chapter 5 p 32 Yet the relevant chapter Chapter 6 makes clear the that purpose of the contingency planning is to optimize resppnse and to minimize damage i e that it assumes a 'contingency' and does not address prevention The Chapter does not of course actually contain a contingency plan The report seems to consistently underst·ate or relati vize the environmental impacts of a spil of propane butane gasoline jet fuel and diesel IF THIS IS TRUE AND BASED ON THE OIL TOXICITY INFORMATION THAT I SENT TO YOU FOLKS THIS MAY BE A MAJOR WEAKNESS OF THE EIA Propane butane While these would as the report notes ordinarily gasify there is potential--not described in the report--for these toxic compounds not to be immediately released but instead to be dissolved by storm processes into the water column YES BUT THESE COMPOUNDS SHOULD BREAK DOWN RAPIDLY AND OR RAPIDLY VOLATILIZE BY THE WAY ARE THERE ANY LARGE BIRD AND MARINE MAMMAL COLONIES CLOSE TO WHERE THIS PIPELINE WILL BE INSTALLED IF YES BE CAREFUL Gasoline Jet Fuel Effects of a spill of gasoline jet fuel from the gasoline pipeline are not discussed in the report According to technical experts while these would volatilize in 1-2_days they contain high concentrations of toxic soluble compounds which result in localized severe impact to water column and intertidal resources ANY SPILL OF THESE PETROLEUM PRODUCTS COULD DEVASTATE THE LOCAL MARINE ENVIRONMENT AND PERHAPS OTHER AREAS UPSTREAM Upshore OR DOWNSTREAM Downshore FROM THE SPILL' THE POTENTIAL TOXICITY OF THESE PRODUCTS SHOULD NOT BE UNDERESTIMATED ESPECIALLY IF THEY END UP N THE SEDIMENTS OR IF THEY IMPACT NEARBY WETLANDS MANGROVE FOREST ETC THESE PETROLEUM COMPOUNDS ARE ALSO ACUTELY TOXIC TO MANY MOST JUVENILE AND LARVAL FORMS OF MARINE LIFE Naphtha According to the report ni iphtha is hardly soluble in water and relatively volatile •' chapter 6 p 34 According to technical experts however naphthalenes are the most water soluble of the higher polyaromatic hidrocarbons and notwithstanding relatively low solubility have moderate acute toxicity and moderate potential for b1oaccumulat1on and chronic tox1city Tnese medium weight components pose the greatest environmental risks to organisms because the compounds are more persistent they are biologically available and the PAHs have · high toxicities AGREED ANp AROMATIC COMPOUND WHICH CONTAIN MORE THAN_9' E BENZENE RING e g NAPHTHALENE TEND TO BIOCONCENTRATE MORE READILY THAN SINGLE RING COMPOUNDS BENZOaPYREN A USPECTED CARCINOGEN IS ALSO MULTI-RING COMPOUND FOUND IN ALMOST ALL PETROLEUM OILS 3 rLYAcc rding to he report eL • • ' significa t o ubHity in ter NOT · TOTALL i T-RUE SINCE UNDER THE PROPER E ONDITIONS IT CAN READILY ACCOMMODATE INTO THE wATER 2 oLUMN and volatility relatively low compared with naphtha or gasoline TRUE Bl IT IS STILL VERY VOLATILE The report recognizes that diesel leakage represents a major risk oncerning water-and environment impact to the littoral when compared with propane butane and naphtha leakage requiring removal AGREED chapter 6 page 35 italics added This characterization of solubility toxicity and comparative risk seems at best incomplete According to technical experts diesel is moderately volatile and contains mc derate concentrations of toxic soluble compounds will 'oil intertidal resources witr - 1ong-term contamination potential and has rotential £or subtidal i pacts DIESEL IS VERY SIMILAR TO No 2 FUEL 0IL AND BOTH CAN BE EXTREMELY TOXIC TO MARINE ORGANISMS WHETHER THEY ARE FOUND IN THE WATER COLUMN BOTTOM SEDIMENTS ROCKY INTERTIDAL AREAS SALT MARSHES OR ANY OTHER PORTIC OF THE MARINE ENVIRONMENT bdm 8 19 03 1425 4