Drilling for Oil in Alaska… if EPA can decide when drilling ships become stationary

Royal Dutch Shell has spent billions of dollars over six years preparing to drill for new oil in Alaska. Some twenty-five billion barrels of oil are estimated to be deep under the Beaufort and Chukchi seas. Not surprisingly, drilling for oil in Alaska is complicated and expensive.

Part of the complexity is the short summer exploration and drilling window. The other part is caused by drifty U.S. federal regulations of marine natural resource exploration and development.

Drilling delays caused in part of arbitrary EPA regulations led to a late departure of Shell’s drill ships, which were then partially damaged in transit to warmer waters. (The assertion that EPA regulations were partly to blame is discussed below.)

The New York Times reports (“With 2 Ships Damaged, Shell Suspends Arctic Drilling,” February 27, 2013 ), that Shell has suspended drilling operations in the Arctic for 2013. Shell hasn’t given up, it just needs time to repair its ships. Various U.S. government agencies will be passing judgement on past and potential future Shell drilling in the Arctic:

The Interior Department, the Coast Guard and the Justice Department are reviewing Shell’s operations, which have included groundings, environmental and safety violations, weather delays, the collapse of its spill-containment equipment and other failures.

“…Shell has had numerous serious problems in getting to and from the Arctic, as well as problems operating in the Arctic,” said Lois N. Epstein, Arctic program director for the Wilderness Society and a member of an Interior Department offshore drilling safety advisory panel.

“Shell’s managers have not been straight with the American public, and possibly even with its own investors, on how difficult its Arctic Ocean operations have been this past year,” she said. 

Well, maybe so, but this is an assertion by a program director at an environmental advocacy group, also chosen to advise the Interior Department.

You can gain insight on the advice received from this Wilderness Society program director from their webpage  “Save the Arctic from Oil Drilling” page (shown at right). Here is another Wilderness Society story or fund-raising blurb, titled: “On the brink of catastrophe: Help protect Arctic animals from devastating oil spill“.

I don’t wish for Alaska wildlife a “devastating” oil spill. Royal Dutch Shell is a very large company with extensive expertise in drilling for oil in difficult places deep underwater. Deep ocean oil drilling technology has advanced dramatically over the last twenty years. The average depth of the Beaufort sea is 1,000 meters. Deep water oil drilling offshore in Brazil is 2,000 meters down (Economist story). Shell’s drilling in the Arctic is about 20 miles offshore and in  water about 120 feet deep according to this 2013 Dept. of Interior “REVIEW OF SHELL’S 2012 ALASKA OFFSHORE OIL AND GAS EXPLORATION PROGRAM” (pdf) (So the Shell operation in the Arctic is not deep-water drilling, just offshore drilling.)

This September 2012 article in The Telegraph notes:

The US Department of Interior’s Bureau of Safety and Environmental Enforcement granted Shell a permit to drill to shallow depths at the Beaufort well, which follows approval three weeks ago for similar preliminary drilling in the Chukchi, Reuters reports.

Environmentalists criticized the decision, even though the Beaufort permit will not allow Shell to penetrate any oil- or gas-bearing zones. 

The restrictions are similar to those imposed in the Chukchi, where Shell was granted approval to drill down to only about 1,400 feet because it was unable to bring required oil-spill equipment to the site, the agency said.

 The government “has set the bar high for exploration activities in the Arctic, and any approved operations must meet those standards,” Jim Watson, the agency’s director, said in a statement. (Source)

This July 17 (updated September 14, 2012) Popular Mechanic article surveys the technology issues for Shell’s offshore Arctic drilling work. The article is titled: “Everything You Need to Know About Shell Oil and Arctic Offshore Drilling in Alaska” but could as easily be titled: “Everything You Need to Know About Why Shell Oil Arctic Offshore Drilling in Alaska is Really Risky.”

The website introduction to the article provides background:

After years of arguments over drilling in the Arctic National Wildlife Refuge (ANWR), the debate about Arctic oil exploration has moved offshore, into the waters of the Chukchi and Beaufort seas. 

The Popular Mechanics article discusses the EPA clean air permitting dispute:

Offshore oil rigs are more like factories than conventional ships and must acquire emissions permits from the Environmental Protection Agency under the Clean Air Act before they can operate. Shell’s permits have been a point of contention and the subject of lawsuits for years. On June 28, Shell asked the EPA to revise its permit for drilling in the Chukchi, saying in part that generators on the Noble Discoverer drillship could not meet emissions requirements for nitrogen oxides (NOx) and ammonia. The company also asked for several other changes to the original document, officially called a Prevention of Significant Deterioration (PSD) permit. 

Environmental groups weren’t happy with the original pollution levels allowed, or with Shell’s request to pollute more. Again from the Popular Mechanics article:

Essentially, Shell said that the technology cited in its original applications hadn’t worked as planned under real-world testing. However, environmental groups have argued that the even the existing limits were too lenient. The permits allowed the Discoverer and its support vessels to emit 336 tons of NOx, 154 tons of carbon monoxide, and 43 tons of particulate matter, or soot, during the summer drilling season. Those are roughly the same emissions generated by a fleet of 300,000 cars operating for a full year. In a detailed letter sent to the EPA on July 19, environmental groups wrote, “Shell is unable to comply with its current permit or the Act this drilling season and its permit application likewise offers no basis for lawful operations. EPA, therefore, must exercise its authority to prevent Shell from operating until a new or modified permit is issued.” 

Some 900,000 cars are on Seattle roads every day, so three times the emissions are emitted near me. Why is that okay? Shell drilling ships would emit one-third as much during their short drilling season. You can read why NOx emissions are bad on this EPA page which says: “At ground level, ozone is a harmful pollutant.” And here is how this harmful ozone is produced:

Ground-level or “bad” ozone is not emitted directly into the air, but is created by chemical reactions between oxides of nitrogen (NOx) and

volatile organic compounds (VOC) in the presence of sunlight. Emissions from industrial facilities and electric utilities, motor vehicle exhaust, gasoline vapors, and chemical solvents are some of the major sources of NOx and VOC.

Clean Air Act regulations limit NOx and VOC emissions to reduce ozone that is harmful to people (and presumably polar bears). So EPA must be concerned that in the Arctic local volatile organic compounds (VOCs) will mix with the NOx released by the Shell drilling ships to create harmful Arctic ozone. Really? You can see from the EPA image the VOCs emission sources (they don’t include “killer trees” from the Smokey Mountains for some reason. Research here, and NASA “Volatile Trees” article here.) In the Arctic, not many trees, motor vehicles, consumer solvents, or industrial commercial processes.

Maybe there is some other harm caused by NOx emissions from a factory-like drilling ship twenty miles offshore in the Arctic. But whether people or polar bears can be harmed by these emissions doesn’t really matter to the EPA regulations. Clean Air regulations become a tool for special interests to pressure government regulators to slow or stop projects they deem dangerous or environmentally immoral.

This online editorial from the Fairbanks Daily News-Miner suggests the federal marine natural resource permitting process is a bureaucratic mess:

Environmental and North Slope community groups appealed the permits to an internal EPA review board. The board decided in late December that two issues needed better analysis from the EPA.

 The objections that stopped the permits were neither new nor substantive. That didn’t prevent them from provoking bureaucratic fussing of the highest order. 

The first stumbling block was an argument about how to define the precise moment when a drilling rig becomes “stationary.” Air quality rules are different for mobile and stationary sources, so it’s obviously an important definition. The appeals board, made up entirely of former EPA attorneys, said agency personnel didn’t explain their decision well enough. After decades of such work in other U.S. offshore waters, how could such an essential question still be in play?

Source

 Second, the board said, the agency failed to analyze the potential health effects of the hour-to-hour variations in nitrogen oxide levels that exploratory drilling equipment would cause in the air breathed by North Slope residents. The agency analyzed the annual effects and found them insignificant. But a new requirement for hourly analysis came down the regulatory pipeline about the same time. So, the board said, the agency should have reviewed the emissions’ effects in an hourly time frame. It’s a good bet the conclusion would be the same, but no matter — it’s back to the drawing board. (Source)

So… there is lots more oil in Alaska. Whether it is safe to drill there, and Shell should be allowed access to a reasonable Federal permitting process, or whether Arctic oil reserves should be left untapped due to harsh winters, difficult logistics, and risks of oil spills, well, that’s a matter for students to debate.