Saturday, May 22, 2010

Making an energy extraction disaster worse

Extracting energy from natural resources often carries hazards that are not well known. Because of the April, 2010, explosion at the Upper Big Branch mine in West Virginia, some hazards of coal mining are once again widely publicized, [1] although coal mine disasters have been common for near two centuries. [2] But other coal mining hazards, including stream disturbance from subsidence, methane discharges, underground fires and the vast destruction of environment from surface mining, remain little known to most of the public. [3]

When disasters occur while extracting energy from natural resources, human errors can make them worse. April of 2010 has been a cruel month. Several incidents during the Macondo 1 well blowout in the Gulf of Mexico, including origins of the blowout itself, appear to come from human errors that should have been preventable. [4] Few of the many errors are more vexing than acts of U.S. government agencies trying to respond to that disaster.

Evidence from news reports suggests little or no U.S. Coast Guard planning and coordination for responses to the immense fire. Water, sprayed from several vessels on the fire, entered pontoons of the semi-submersible Deepwater Horizon platform, causing it to capsize and sink after about a day and a half. [5] The huge volumes of natural gas and oil discharges continued to burn at the sea surface, but water sprays were then used to extinguish the fire. As previous ocean oil disasters showed, like the 1979 Ixtoc 1 well blowout in the southern Gulf of Mexico, sea surface fires can burn more than half of blowout discharges, reducing environmental impacts. [6] Through mid-May, 2010, the Coast Guard had provided no detailed public explanation of its actions.

The U.S. Environmental Protection Agency issued instructions allowing the U.S. Air Force and BP, owner of the Macondo 1 well, to apply hundreds of thousands of gallons of dispersant chemicals, both on the sea surface and on the sea floor in the vicinity of discharges from the Macondo 1 well. [7] Short-term effects of dispersant chemicals on marine environments are only partly known, and long-term effects are often unknown.

There have been controversies over the use of dispersants in ocean oil disasters ever since their first major application, following the 1967 Torrey Canyon disaster off the southwest coast of England. Studies suggest long-term hazards, leaving treated coastal environments more disturbed than environments where no cleanup was attempted. [8] The EPA has had decades to evaluate dispersants, but its research has been meager, leaving the agency unprepared in emergencies to respond on the basis of thorough scientific knowledge. In an apparent attempt to mitigate hazards of dispersants being used for the Macondo 1 well blowout, EPA issued supplementary instructions to BP on May 20, 2010. [9] A simultaneous press release said that EPA intended to require use of "less toxic" chemicals. [10]

EPA maintains short-term acute toxicity information for dispersants. [11] Two marine species are used to rate "50 percent lethal concentration" (LC50) in parts per million for approved dispersants: the inland silverside (Menidia beryllina), an estuary fish, after 96 hours exposure, and the oppossum shrimp (Mysidopsis bahia), also an estuary dweller, after 48 hours exposure. In addition, there are "effectiveness" ratings for two crude oils, "Prudhoe Bay Crude" and "South Louisiana Crude." EPA has published testing procedures for the ratings. [12]

As of mid-May, 2010, the EPA-maintained National Contingency Plan Product Schedule included fifteen dispersant products, three of them under multiple trade names. [13] They are listed here in the order of least toxic to most toxic, by 96-hour exposure LC50 ratings in parts per million for Menidia beryllina:

DispersantToxicity LC50, ppmToxicity LC50, ppmEffectiveness
  ProductMenidia beryllinaMysidopsis bahiaSo. La. Crude
MARE CLEAN 2001996    96-hr938    48-hr84.1%
JD-2000407.00 96-hr90.50 48-hr77.8%
NEOS AB300091.1   96-hr33.0   48-hr89.8%
NOKOMIS 3-AA34.22 96-hr20.16 48-hr65.7%
ZI-40031.76 96-hr20.96 48-hr89.8%
SEA BRAT #430.00 96-hr14.00 48-hr60.6%
NOKOMIS 3-F429.80 96-hr32.20 48-hr64.9%
SAF-RON GOLD29.43 96-hr63.00 48-hr53.8%
COREXIT EC9500A25.20 96-hr32.23 48-hr54.7%
SPILLCLEAN24.30 96-hr10.00 48-hrN/A
COREXIT EC9527A14.57 96-hr24.14 48-hr63.4%
BIODISPERS13.46 96-hr78.90 48-hr63.0%
FINASOL OSR 5211.66 96-hr9.37 48-hr71.6%
DISPERSIT SPC 10003.5   96-hr16.6 48-hr105   %
JD-1091.90 96-hr1.18 48-hr91   %

In the May 20, 2010, EPA instructions to BP the key sentence reads, "...BP shall identify...dispersant products from the National Contingency Plan Product Schedule that...have a toxicity value less than or equal to 23.00 ppm LC50 toxicity value for Menidia or 18.00 ppm LC50 for Mysidopsis...." News reports indicated BP was following EPA instructions literally, [14] saying BP had been using Corexit EC9500A, rated at 96-hour LC50 of 25.2 parts per million for Menidia beryllina, but after the May 20 EPA instructions was ordering Dispersit SPC 1000, rated at 96-hour LC50 of 3.5 parts per million for Menidia beryllina.

EPA has provided no rationale for the specific criteria in its May 20 instructions. Their obvious effect is to allow use of the dispersant products Finasol OSR 52, Dispersit SPC 100 and JD-109. It is not clear whether Spillclean would qualify; it has LC50 for Mysidopsis less than 18 but LC50 for Menidia greater than 23, and it lacks an "effectiveness" rating. It is also not clear whether Corexit EC9527A or Biodispers would qualify; they have LC50 for Menidia less than 23 but LC50 for Mysidopsis greater than 18. The instructions say "or" as to LC50 ratings but have ambiguous grammar.

Well known to environmental workers, "a lower LC50 means the substance is more toxic," such as effects of metal ions in fish ponds. [15] Whoever wrote and whoever approved the May 20 EPA instructions apparently did not know that lower LC50 means higher toxicity. Whoever generated specific criteria for dispersants seems to have been choosing products to endorse rather than applying environmental knowledge. Superior products in EPA listings, on the basis of their LC50 toxicity ratings, include Mare Clean 200 and JD-2000. However, those products would not satisfy the misguided EPA criteria.

Adverse consequences in this situation were avoided. BP cancelled its order for Dispersit SPC 100 and responded to EPA that it could not find a qualifying dispersant "in sufficiently large quantities to be useful at the time of the spill." EPA rescinded the erroneous instructions, saying it would issue new ones. [16] It is likely that someone at BP saw through the mistake and realized its potential to make an energy extraction disaster worse. Major news media never told and therefore most of the public never learned about gross incompetence shown by the government during this incident.

[1] Jerry Markon, David A. Fahrenthold and Kimberly Kindy, Mine company faulted on safety issues, Washington Post, April 8, 2010, available at

[2] H. B. Humphrey, Historical summary of coal mine explosions in the United States, Bulletin 586, U.S. Bureau of Mines, U.S. Government Printing Office (1960). United States Mine Rescue Association, Historical data on mine disasters in the United States, available at U.S. Mine Safety and Health Administration, Coal fatalities, 1900-2009, available at

[3] Pennsylvania Department of Environmental Protection, The Effects of Subsidence Resulting from Underground Bituminous Coal Mining on Surface Structures and Features and Water Resources (2005), 25 files, available at Robert R. Seal II, Environmental processes that affect mineral deposits in the eastern United States, U.S. Geological Survey, U.S. Department of the Interior (1999), available at Evironment: The price of strip mining, Time 97(12), March 22, 1971, available at,9171,904921,00.html. Davie Rennie, How China's scramble for 'black gold' is causing a green disaster, London Telegraph, February 1, 2002, available at

[4] Janet McConnaughey and Holbrook Mohr, Associated Press, Oil rig reported explosion 3 hours before fire, WFMJ, Youngstown, OH, April 22, 2010, available at "James," Deepwater Horizon: A firsthand account, Mark Levin Show, WABC, New York City, April 30, 2010, transcription available at

[5] Campbell Robertson, Search continues after oil rig blast, New York Times, April 22, 2010, available at Russell Gold, Safety device questioned in 2004, Wall Street Journal, May 3, 2010, available at Les Blumenthal, McClatchy, Blowout preventers often fail, report says, Tacoma, WA, News Tribune, May 1, 2010, available at Michael Kunzelman and Richard T. Pienciak, Associated Press, Feds let BP avoid filing blowout plan for Gulf rig, WTOP, May 6, 2010, available at Susan Saulny, Finger-pointing, but few answers at hearings on drilling, New York Times, May 12, 2010, available at Scott Pelley, interviewer, Blowout: The Deepwater Horizon disaster, 60 Minutes, CBS News, May 16, 2010, available at

[6] Energy Resources Co., Ixtoc oil spill assessment, final report, Bureau of Land Management, U.S. Department of the Interior (1982), available at

[7] Jason Dearen and Ray Henry, Associated Press, Chemicals used to fight Gulf of Mexico oil spill a trade-off, New Orleans Times-Picayune, May 5, 2010, available at Ted Jackovics, Air Force C-130s spray chemical to help break up oil spill, Tampa Tribune, May 10, 2010, available at U.S. Environmental Protection Agency, Dispersant monitoring and assessment directive for subsurface dispersant application, May 10, 2010, available at

[8] Committee on Effectiveness of Oil Spill Dispersants, Marine Board, National Research Council, Using Oil Spill Dispersants on the Sea, National Academies Press (1989), Appendix B, Torrey Canyon, pp. 317-318, available at Robert J. Fiocco and Alun Lewis, Oil spill dispersants, in Pure and Applied Chemistry 71(1), 1999, special issue on oil spill countermeasures, pp. 27-42, available at

[9] U.S. Environmental Protection Agency, Dispersant monitoring and assessment directive, Addendum 2, May 20, 2010, available at

[10] U.S. Environmental Protection Agency, EPA: BP must use less toxic dispersant, May 20, 2010, available at!OpenDocument.

[11] U.S. Environmental Protection Agency, FSOC dispersant pre-approval guidelines and checklist (1995), Table 1, LC50 toxicities and toxicity indices of crude oils for marine organisms, p. A-10.

[12] U.S. Environmental Protection Agency, Methods for measuring the acute toxicity of effluents and receiving waters to freshwater and marine organisms, at U.S Environmental Protection Agency, Swirling flask dispersant effectiveness test, 40 CFR 300, Appendix C (1997), pp. 224-246, available at

[13] U.S. Environmental Protection Agency, National Contingency Plan Product Schedule, for Category select Dispersant, at

[14] Campbell Robertson and Elisabeth Rosenthal, Agency orders use of a less toxic chemical in Gulf, New York Times, May 21, 2010, available at

[15] Tim Gilbert, Copper in fish ponds, Koi Fish Ponds, Denver, Colorado, at

[16] Paul Purpura, BP can continue using controversial dispersant, New Orleans Times-Picayune, May 24, 2010, available at

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