Oil Spill Response Gap and Response Capacity Analysis

(A43220)
(A43220)
(A43220)
Northern Gateway Pipelines Inc.

Section 52 of the National Energy Board Act Application for
Enbridge Northern Gateway Project
NEB File OF-Fac-Oil-N304-2010-01 01
Filed 27 May 2010
OH-4-2011
NOTICE OF MOTION OF THE HAISLA NATION
SEEKING LEAVE TO FILE LATE EVIDENCE
INTRODUCTION
1.
The Haisla Nation is an intervenor in the Joint Review Panels review of the Northern
Gateway Pipeline Project. The deadline for intervenors to file written evidence in these
proceedings has passed. The Haisla Nation hereby seeks leave to file additional written
evidence.
2.
The additional written evidence the Haisla Nation seeks to file is a report titled Oil Spill
Response Gap and Response Capacity Analysis for Proposed Northern Gateway
Tanker Oil Spills in Open Water and Protected Water Operating Environments,
prepared by the Nuka Research and Planning Group, LLC (the NUKA Response Gap
and Response Capacity Analysis) and is attached as Attachment 1 to this motion.
3.
Haisla Nation brings this motion pursuant to Hearing Order OH-4-2011 and Amended
Hearing Order AO-011-OH04-2011 (the Hearing Order) and section 35 of the National
Energy Board Rules of Practice and Procedure, 1995, SOR/95-208, for an order that
the Haisla Nation is granted leave to file the NUKA Response Gap and Response
Capacity Analysis as written evidence.
FACTS
4.
On May 5, 2011, the Joint Review Panel [the Panel or JRP] issued Hearing Order
OH-4-2011, which set various deadlines for the filing of evidence and information
requests in these proceedings.
5.
The Haisla Nation has, in its various submissions to the Panel, identified its concerns
relating to the ability of Northern Gateway to respond to a spill in the marine
environment, including concerns relating to the effects of environmental conditions on
spill response capability.
6.
On October 28, 2011, the Haisla Nation filed a Notice of Motion, seeking an order that
Northern Gateway be directed to respond to a number of the questions in Haisla Nation
Information Request (IR) No. 1 to which Northern Gateway had, in the view of the
Haisla Nation, not provided adequate responses (A34832).
7.
On November 3, 2011, the Haisla Nation filed its IR No. 2 to Northern Gateway
(A2H2E3).
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HAISLA NATION MOTION

August 1, 2012
8.
In IR No. 2.29a), the Haisla Nation asked:

Please explain how quickly the proposed spill response infrastructure could respond to
contain a spill and whether that would limit the extent and degree of spills in the Kitimat
River Valley and in Kitimat Arm. Please include a discussion of how response efforts will
be deployed in remote locations in the Kitimat Valley and all locations west of the coast
mountains during poor weather conditions (high winds, high waves, for, low cloud, poor
visibility, heavy rain, heavy snow, etc.)
9.
On November 24, 2011, Northern Gateway filed its responses to Haisla Nation IR No. 2
(A2I8V1). Its response to Haisla Nation IR No. 2.29a) was:
Northern Gateway acknowledges the importance of the Kitimat River Valley and the
need for careful engineering design and thorough emergency preparedness and
operational response planning for that area. For details regarding response time to an
oil spill in the Kitimat River, please refer to Northern Gateways response to Haisla
Nation IR 1.54c).
10.
Northern Gateways response to Haisla Nation IR No. 1.54c) (A2E8Y0) did not address
the issue of how response efforts could be deployed during poor weather conditions.
Nor did it provide any information about how response travel times to an oil spill in the
Kitimat River might be affected by poor weather.
11.
In IR No. 2.29g), the Haisla Nation asked:

Please discuss the limitations and effectiveness of the methods and technologies
identified for oil spill containment and clean-up. Please provide actual percentages of oil
recovered under varying conditions (wind, waves, currents, tides, other weather
conditions, etc.).
12.
Northern Gateway issued the following reply to Haisla Nation IR No. 2.29g):
Please refer to Northern Gateways response to Coastal FN IR 1.19g) regarding the
limitations on response techniques that may be associated with stormy weather
conditions.
Please refer to Northern Gateways response to Coastal FN IR 1.21d), which describes
why it is not possible to provide a percentage estimate of oil which may be recovered
following a spill incident.
13.
In its IR No. 1.19g), Coastal First Nations asked (A2C2S9):

Please include in [a discussion of various scenarios] the percentage of time a credible
response operation would not be possible at various times of the year because of typical
sea conditions and the effectiveness of boom, skimmers and the other types of spill
response equipment during suboptimal operating conditions.
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August 1, 2012
14.
In its response to Coastal FN IR No. 1.19g) (A2E4Q5), Northern Gateway did not
provide the requested percentages in its response. Its response stated:
A response limitation would depend on the operating environment and the type of
equipment deployed.
In general, as wave heights and wind speeds increase, natural dispersion and
degradation typically also increases. Figure 8-2 in the General Oil Spill Response Plan
(GOSRP) identifies wave heights above 3 m (10ft) as the threshold beyond which
monitoring of natural dispersal and degradation of unsheltered spills is generally
considered the most appropriate response option.
15.
In its IR No. 1.21a), Coastal First Nation asked:

Please provide a response gap analysis to determine the time periods whereby sea and
weather conditions in the CCAA and the OWA would preclude safe or effective
deployment of spill response, in order that the effectiveness of the response capability
can be determined.
16.
In response to Coastal First Nation IR No. 1.21a), Northern Gateway stated: Please
refer to Northern Gateways response to Coastal FN IR 1.19g).
17.
In its IR No. 1.21d), Coastal First Nations sought details about the effectiveness of oil
spill cleanup attempts.
18.
In its response to Coastal First Nations IR No. 1.21d), Northern Gateway provided
information relating to the percentage of oil dissolved, dispersed, burned or recovered,
but also wrote:
It is not possible to provide a standard estimate of the percentage of recovery from an oil
spill incident. The amount of oil recovered from an oil spill is primarily a function of the
size of the spill, the oil type (persistence) and the environmental conditions at the time of
the incident.
The effectiveness of response measures used elsewhere in the world for responding to
large spills is not different than in the BC environment as the same response measures
are used everywhere in the world and their effectiveness is a function of incident-specific
factors rather than geographic factors.
19.
The Haisla Nation does not view Northern Gateways response to Haisla Nation IR No.
2.29a) as responsive. Similarly, the Haisla Nation does not view Northern Gateways
responses to Coastal First Nations IR Nos. 1.19g) and 1.21d) as responsive to Haisla
Nation IR No. 2.29g). Finally, the Haisla Nation also does not view Northern Gateways
response to Coastal First Nation IR No. 1.19g) as responsive to Coastal First Nation IR
No. 1.21a).
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August 1, 2012
20.
On January 27, 2012, the Panel issued its ruling on the October 28, 2011 Haisla Nation
Motion and on motions filed by a number of other interveners seeking an order
compelling Northern Gateway to respond to round 1 IRs. The Panel largely declined to
issue an order compelling Northern Gateway to respond to the IRs identified in the
October 28, 2011 Haisla Nation Motion as incomplete or lacking. In its ruling, however,
the Panel provided the following specific direction on IRs regarding marine shipping and
marine accidents and malfunctions:
The following IRs or portions thereof:
[Coastal First Nations IRs 1.20(a) Gitxaala Nation IRs 1.7.2.1 1.7.2.10,
1.7.2.14 1.11.5 ...]
involve technical questions regarding marine shipping and marine accidents and
malfunctions. Considering information already provided by Northern Gateway in
response to these questions, and the forthcoming TERMPOL Technical Review
Committee report to be completed in February 2012, the Panel is not persuaded that the
additional information sought is required, at this time.
As the TERMPOL report has not yet been filed by Northern Gateway, parties may
request permission to submit further evidence, or take any other procedural step
deemed necessary in response, once this information is filed. The Panel notes that this
evidence may also be tested by questioning Northern Gateway at the final hearings
(Panel Ruling 16, A2L5S7, p. 6).
21.
Coastal First Nations IR No. 1.20(a) and Gitxaala Nation IRs 1.7.2.1, 1.7.2.10, 1.7.2.14,
and 1.11.5 (A2C4H0) sought specific information relating to spill response capacity.
22.
Transport Canada filed the TERMPOL Technical Review Committee Report on

February 23, 2012. The Report states that it specifically excludes an analysis of oil
pollution response planning and preparedness (A2Q4A7, p. 4).
23.
Northern Gateways responses to IRs from the Haisla Nation, Coastal First Nations, and
other intervenors made it clear that Northern Gateway had no intention of submitting
information to the Panel that assessed the impacts of environmental conditions on the
ability of Northern Gateway or any other party to respond effectively to a spill in the
marine environment (see for example Northern Gateway response to Haisla Nation IR
No. 2.27d), e) and f), 2.29a) and g), and Coastal First Nation 1.19g) and 1.21a).
24.
The Haisla Nation therefore commissioned the Nuka Research and Planning Group,
LLC to conduct such an assessment on its behalf.
25.
Further, given its concerns relating to the logistics of responding to a significant spill of
diluted bitumen or synthetic crude in Kitimat Arm or Douglas Channel, the Haisla Nation
commissioned Nuka Research and Planning Group, LLC to conduct an analysis of
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August 1, 2012
response capacity for available mechanical oil spill recovery systems to contain and
recover marine oil spills.
26.
The information and evidence filed by Northern Gateway to date does not include this
type of study or analysis.
27.
The Nuka Research and Planning Group, LLC has prepared the NUKA Response Gap
and Response Capacity Analysis, which analyzes both the percentage of time during
which it will not be possible to respond to an oil spill on open water due to
environmental conditions, and the response equipment capacity that would be required
to respond to an oil spill on open water in a meaningful way.
28.
The Haisla Nation is seeking leave to file NUKA Response Gap and Response Capacity
Analysis as late written evidence.
GROUNDS FOR MOTION

29.
30.
This Motion is brought pursuant to the National Energy Board Rules of Practice and
Procedure, 1995, SOR/95-208, ss. 4, 35, and Hearing Order OH-4-2011, s. 4, seeking
relief on the basis of:
a.
The Agreement Between the National Energy Board and the Minister of
Environment Concerning the Joint Review of the Northern Gateway Pipeline
Project, ss. 6.2 to 6.4, and Appendix Terms of Reference;
b.
Hearing Order OH-4-2011, s. 4; and
c.
principles of natural justice and procedural fairness.
The Hearing Order identifies the following factors as relevant to whether the Panel will
approve the submission of late evidence:
how the proposed Project will impact the participant;

the reason why the deadline was not met;
whether the submission is likely to assist the Panel;
whether similar submissions have been, or could be, made by others;
how other parties could be disadvantaged as a result of the late submission; and
any other relevant considerations (OH-4-2011, s. 4, p. 5).
How the proposed project will impact the Haisla Nation

31.
Haisla Nation Territory is centred in and around Kitimat, Kitimat Arm and Douglas
Channel. The Haisla Nation depends heavily on the lands, waters and resources of its
Territory, and claims aboriginal title to its Territory and exercises aboriginal rights
throughout its Territory.
(A43220)

August 1, 2012
32.
Haisla Nation members depend extensively on marine resources for sustenance and
cultural purposes. Haisla Nation culture relies on Haisla Nation resources in the
transmission of Haisla cultural identity from one generation to the next. The Haisla
Nation has filed written evidence documenting its use of and reliance on its lands,
waters and resources.
33.
The Haisla Nation has set out in detail in its responses to IR No. 1 from the Panel and
IR No. 1 from Northern Gateway how it stands to be impacted by the proposed project
(A2U4X9 and A2U2U3).
34.
All three aspects of the proposed project will be situated in Haisla Nation Territory. The
proposed pipeline will parallel the Kitimat River Valley, which runs into Kitimat Arm. The
marine terminal is proposed for the west side of upper Kitimat Arm, directly across
Kitimat Arm from the Haisla Nation residential reserve, Kitamaat IR No. 2. The
proposed tanker traffic will ply the waters of Kitimat Arm and Douglas Channel.
35.
The Haisla Nation has never ceded, surrendered or abandoned its Territory, and
continues to govern and act as stewards to the lands, waters and resources of Haisla
Nation Territory. The project proposes to use Haisla Nation aboriginal title land in a way
that is inconsistent with Haisla Nation stewardship of its lands, waters and resources
and with the Haisla Nations own aspirations for the use of this land. Since aboriginal
title is a constitutionally protected right to use the aboriginal title land for the purposes
the Haisla Nation sees fit, this adverse use would fundamentally infringe the aboriginal
title of the Haisla Nation.
36.
The proposed pipeline and marine terminal will have significant footprint impacts on
Haisla Nation lands, waters and resources. In addition, the pipeline, the marine terminal
and the tankers carry with them the risk of an accident or malfunction that could result in
a spill of condensate, diluted bitumen or synthetic crude onto the lands and into the
waters of Haisla Nation Territory. These are waters from which the Haisla Nation
sustains itself, waters which nourish Haisla Nation members and Haisla Nation culture
and cultural heritage.
The reason why the deadline was not met

37.
The Haisla Nation is of the view that NUKA Response Gap and Response Capacity
Analysis is evidence of a nature which Northern Gateway should have provided in its
application. The Haisla Nation has sought this information from the outset, as
evidenced in its September 7, 2010 submission on the adequacy of Northern Gateways
application (A1U3Z4). In addition, the Haisla Nation and a number of intervenors
submitted information requests relating to spill response capacity. Information requests
directed specifically at this issue were largely unanswered.
38.
Further, the Haisla Nation is also of the view that Northern Gateway should have
provided information of the nature that is provided in the NUKA Response Gap and
Response Capacity Analysis in response to information requests from intervenors.
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August 1, 2012
39.
Finally, the evidence the Haisla Nation is seeking to file pursuant to this motion
addresses a number of gaps in the information and evidence submitted by Northern
Gateway in support of its application.
40.
The Haisla Nation has conducted itself diligently in the Panels review process, but is
hampered by inadequate resources and by the onerous timelines imposed by the
Hearing Order.
41.
It did not become evident until Northern Gateway filed its responses to Haisla Nation IR
No. 2 that it had no intention of providing information of the nature that is provided in the
NUKA Response Gap and Response Capacity Analysis.
42.
The TERMPOL Report does not address this aspect of the proposed project.
43.
The preparation of the NUKA Response Gap and Response Capacity Analysis required
more comprehensive meteorological data than was available in the record of the review
of the proposed project. Once obtained, the raw data had to be compiled into a useful
data set. This work was undertaken by Mountain Weather Services. Once the
meteorological data set was available, Nuka Research and Planning Group LLC had to
perform further analysis and modelling to generate the information that supports the
NUKA Response Gap and Response Capacity Analysis. All this took time.
Whether the submission is likely to assist the Panel

44.
The Haisla Nation submits that the NUKA Response Gap and Response Capacity
Analysis will assist the Panel. It includes information that is critical to enable the Panel
to assess the extent to which Northern Gateways proposed oil spill response measures
are technologically and/or operationally feasible.
45.
The response gap analysis component of the NUKA Response Gap and Response
Capacity Analysis provides valuable information about the extent to which local
environmental conditions on open water will impact on spill response. This information
is critical to determining the extent to which Northern Gateways proposed oil spill
response measures can be effective in limiting the adverse impacts flowing from an
accident or malfunction that results in a spill.
46.
The response capacity analysis of the NUKA Response Gap and Response Capacity
Analysis examines response capacity for available mechanical oil spill recovery systems
and trained personnel to contain and recover marine oil spills. It identifies the level of
equipment and personnel required to respond realistically to a spill from the proposed
project. This information is also critical to determining the extent to which Northern
Gateways proposed mitigation measures can be effective in limiting the adverse
impacts flowing from an accident or malfunction that results in a spill. In addition, this
information will be required to guide a realistic formulation of conditions relating to spill
response capacity which may be required should a certificate be issued for the
proposed project.
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August 1, 2012
47.
Failure to admit this evidence, however, would impair the ability of other parties and the
Panel to fully understand the limitations of Northern Gateways proposed oil spill
response measures, and their ability to formulate potential conditions which may be
required should a certificate be issued for the proposed project.
Whether similar submissions have been, or could be, made by others

48.
The Haisla Nation submits that the information it is seeking to file pursuant to this
motion ought to have been provided by Northern Gateway to ensure an adequate
information base for the Panels review of the project and in response to specific
information requests.
49.
Both Haisla Nation IR No. 2.29a) and Coastal First Nation IR No. 1.21a) asked Northern
Gateway to provide the type of information that is provided in the NUKA Response Gap
and Response Capacity Analysis.
How other parties could be disadvantaged as a result of the late submission

50.
Other parties and the Panel will generally be assisted by this late submission, as it
provides additional information which is critical to assessing the extent and degree to
which the mitigation measures proposed by Northern Gateway can address the
significant adverse effects anticipated to result from oil spills from the project.
51.
The only party which may be disadvantaged by the late submission of this evidence is
Northern Gateway itself. Northern Gateway submitted its Reply Evidence on July 20,
2012, and has not had an opportunity to reply to the NUKA Response Gap and
Response Capacity Analysis. The JRP review process, however, accords Northern
Gateway the same rights as other parties with respect to obtaining leave to file
information beyond deadlines established in the Hearing Order.
Other relevant considerations

52.
Northern Gateway has consistently submitted evidence beyond its June 9, 2011
deadline for filing evidence, without obtaining leave from the Panel. The Hearing Order
only contemplated additional information being filed by Northern Gateway in section 8.1,
and imposed a deadline of June 9, 2011 for such additional evidence. Despite this
deadline, Northern Gateway has continued to file additional evidence in these
proceedings without seeking or obtaining leave from the Panel.
53.
Northern Gateway has declined the opportunity to augment its evidence and information
with the information that is now being presented to the Panel for consideration through
the NUKA Response Gap and Response Capacity Analysis.
54.
The NUKA Response Gap and Response Capacity Analysis contains an analysis which
Northern Gateway itself, in the Haisla Nations view, should have entered into the
record. Thus, any potential prejudice to Northern Gateway from this evidence being
admitted now will be, in part, the result of its own conduct.
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August 1, 2012
55.
The NUKA Response Gap and Response Capacity Analysis contains information which
is useful and relevant to the Panels mandate, as set out in the Agreement Between the
National Energy Board and the Minister of Environment Concerning the Joint Review of
the Northern Gateway Pipeline Project and the Terms of Reference. The Terms of
Reference specifically require an assessment of measures that are technically and
economically feasible and that would mitigate any significant adverse environmental
effects of the proposed project.
56.
Further, the Agreement requires the Panel to conduct the review in a careful and
precautionary manner, and in a manner which will facilitate the participation of the public
and Aboriginal peoples.
57.
The List of Issues identified in the Hearing Order and the Scope of the Factors
Northern Gateway Pipeline Project1 is broader than those for conventional National
Energy Board proceedings. They specifically include potential impacts on Aboriginal
interests, including asserted Aboriginal rights. The Panel has been tasked to receive
information from Aboriginal peoples related to the nature and scope of the potential or
established Aboriginal and treaty rights that may be affected by the project and the
impacts or infringements that the project may have on potential or established
Aboriginal or treaty rights.2 The Panel is required to reference, in its report, information
which is provided by Aboriginal peoples regarding the manner in which the Project may
affect, inter alia, Aboriginal rights.
58.
The project is proposed for an area to which the Haisla Nation has always claimed
Aboriginal rights and title. The Aboriginal Consultation Framework for the Northern
Gateway Pipeline Project states that:
The JRP process will be the primary mechanism for Aboriginal groups to learn about the
project and present their views to the federal government about inter alia the effects
any change in the environment resulting from the project may have on their current use
of land and resources for traditional purposes
And:
The federal government will rely on the JRP process, to the extent possible, to fulfil its
duty to consult with Aboriginal groups.
And:
The JRPs environmental assessment report and the record established through the JRP
process will be the primary source of information to support the federal governments
assessment of the projects potential impact on potential or established Aboriginal and
treaty rights.
1
2
Scope of the Factors Northern Gateway Pipeline Project, August, 2009.

Joint Review Panel Agreement, ss. 8.1 and 8.2.
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August 1, 2012
59.
In its response to Haisla Nation IR No. 1, the Government of Canada wrote: The Haisla
Nation have been directed to Northern Gateway as the first opportunity to have issues
addressed, as Northern Gateway has the ability to make changes to the project to
address concerns raised by Aboriginal groups and other stakeholders (A2U6I8, p. 5).
60.
Northern Gateways evidence is incomplete; as a result, the Haisla Nation seeks to

augment the information before the Panel with the NUKA Response Gap and Response
Capacity Analysis. This information is required in order to ensure a full and fair review
of the proposed Project.
61.
During the course of its review of the proposed project, the Panel is required to uphold
the principles of natural justice and procedural fairness. As a general common law
principle, the principle of procedural fairness applies to every public authority making an
administrative decision which is not of a legislative nature and which affects the rights,
privileges, or interests of an individual: Canada (Attorney General) v. Mavi, 2011 SCC
30, [2011] 2 SCR 504 at para. 38.
62.
The duty of procedural fairness is flexible and variable and depends on an appreciation
of the context of the particular statute governing the process at issue and the rights
which stand to be affected. The purpose of procedural fairness is to ensure that
administrative decisions are made using a fair and open procedure, appropriate to the
decision being made and its statutory, institutional and social context, with an
opportunity for those affected to put forward their views and evidence fully and have
them considered by the decision-maker: Baker v. Canada (Minister of Citizenship and
Immigration), [1999] 2 SCR 817 at para. 22 (Baker).
63.
Several factors are relevant to determining the content of the duty of fairness: (1) the
nature of the decision being made and process followed in making it; (2) the nature of
the statutory scheme and the terms of the statute pursuant to which the body operates;
(3) the importance of the decision to the individual or individuals affected; (4) the
legitimate expectations of the person challenging the decision; (5) the choices of
procedure made by the agency itself. This list is not exhaustive: Baker, supra, at paras.
21-28.
64.
The Haisla Nation believes that the proposed project has the potential to seriously affect
the Haisla Nations rights, privileges and interests. Principles of natural justice and
procedural fairness require that the process assessing the proposed project has
available to it enough information for an informed decision.
65.
Northern Gateway is proposing mitigation measures that are based on an incomplete

assessment of the technological and economic feasibility of the proposed mitigation
measures. The information contained in the NUKA Response Gap and Response
Capacity Analysis will add information that is necessary and required in the context of
such an assessment.
10
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Attachment 1 to August 1, 2012 Haisla Nation Motion

Oil Spill Response Gap and Response Capacity Analysis
for Proposed Northern Gateway Tanker Oil Spills in
Open Water and Protected Water Operating
Environments

Report to
Haisla Nation Council

Developed by
Nuka Research and Planning Group, LLC

July 2012
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Oil Spill Response Gap and Response Capacity Analysis for Northern Gateway Operations

Contents
Contents.................................................................................................................................................................... 1
List of Tables.......................................................................................................................................................... 2
List of Figures ........................................................................................................................................................ 2
Authors...................................................................................................................................................................... 4
Lead Authors and Primary Editors......................................................................................................................... 4
Contributing Authors and Analysts ....................................................................................................................... 4
Meteorological Data and Analysis......................................................................................................................... 4
Executive Summary................................................................................................................................................... 5
Overview ............................................................................................................................................................... 5
Response Gap Analysis.......................................................................................................................................... 5
Response Capacity Analysis................................................................................................................................... 5
Conclusion............................................................................................................................................................. 6
Part 1: Introduction................................................................................................................................................... 7
1.1 Background ..................................................................................................................................................... 7
1.1.1 Northern Gateway Project Proposal ........................................................................................................ 8
1.1.2 Representative Operating Environments................................................................................................. 8
1.2 Mechanical Recovery of Marine Oil Spills ....................................................................................................... 9
1.2.1 Mechanical Recovery Methods ................................................................................................................ 9
1.2.2 Northern Gateway Oils............................................................................................................................. 9
1.3 Shipping Routes......................................................................................................................................... 10
Part 2: Oil Spill Response Gap Analysis ................................................................................................................... 12
2.1 Overview ....................................................................................................................................................... 12
2.1.1 Scope and Approach of Analysis ............................................................................................................ 12
2.1.2 Environmental Factors ........................................................................................................................... 12
2.1.3 Assumptions........................................................................................................................................... 14
2.2 Methodology................................................................................................................................................. 16
2.2.1 Selected Operating Areas...................................................................................................................... 17
2.2.2 Datasets Assembled for Each Operating Area........................................................................................ 17
2.2.3 Response Operating Limits..................................................................................................................... 18
2.2.4 Response Gap Index ............................................................................................................................... 18
2.3 Analysis.......................................................................................................................................................... 19
2.3.1 Nanakwa Shoals ..................................................................................................................................... 19
2.3.2 Dixon Entrance ....................................................................................................................................... 25
2.4 Discussion...................................................................................................................................................... 30
2.4.1 Impact of Conservative Estimates to Response Gap Analysis ................................................................ 30
2.4.2 Comparison with 2011 Preliminary Response Gap Study ...................................................................... 30
2.4.3 Combining Response Gap Data for Multiple Locations Along Proposed Shipping Routes..................... 31
2.4.4 Implications of Response Gap to Oil Spill Mitigation from Northern Gateway Tankers ........................ 32
Part 3: Oil Spill Response Capacity Analysis ............................................................................................................ 33

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3.1 Overview of the Approach ............................................................................................................................ 33
3.1.1 Purpose and Scope of Analysis............................................................................................................... 33
3.1.2 Factors Considered in the Analysis......................................................................................................... 33
3.1.3 Assumptions........................................................................................................................................... 33
3.2 Methodology................................................................................................................................................. 34
3.2.1 Response Options Calculator ................................................................................................................. 34
3.2.2 Oil Spill Simulation Parameters .............................................................................................................. 34
3.2.3 Operational Planning Parameters .......................................................................................................... 36
3.2.4 Spill Response Systems .......................................................................................................................... 39
3.2.5 Equipment and Recovery Specifications ................................................................................................ 42
3.3 Outputs from Response Options Calculator Simulations .............................................................................. 44
3.3.1 72-hour Recovery Estimates.................................................................................................................. 44
3.3.2 Task Force Requirements to Recover 10,000 m3 spill in 72 hours ......................................................... 45
3.4 Detailed Simulation Discussion .................................................................................................................... 47
3.5 Adjustment of Recovery Capacity Estimates based on Transit Times........................................................... 51
Part 4. Conclusion .................................................................................................................................................. 53
Part 5. References ................................................................................................................................................... 55
Part 6. Appendices .................................................................................................................................................. 57
Appendix A: ROC Output Summaries (Mass Balance) for 16 Simulations........................................................... 57
Appendix B. Acronyms and Abbreviations .......................................................................................................... 59
Appendix C: Meteorological Data Summary ........................................................................................................... 61

List of Tables
Table 2.1 Impact of Environmental Factors on Spill Response Operations............................................................. 15
Table 2.2. Limits Used for the Northern Gateway Response Gap Analysis ............................................................. 16
Table 2.3. Applying the Response Gap Index .......................................................................................................... 18
Table 3.1. Environmental Conditions Applied for Summer and Winter Simulations at OWA and CCAA ............... 36
Table 3.2 Transit Times to Potential Spill Sites from Potential Oil Spill Response Hubs ........................................ 37
Table 3.3 Summary of equipment and recovery specifications used in ROC simulations ...................................... 44
Table 3.4. Summary of Recovery System Performance for All Simulations Based on ROC Outputs...................... 45
Table 3.5. Task Force Requirements for Sixteen Simulated Oil Spills (10,000 m3) Under Ideal Conditions as
Calculated using ROC .............................................................................................................................................. 47
Table 3.6 Recovery Performance of a single OWTF in CLB OWA Winter Simulation .............................................. 48
Table A.1: Recovery capacity of a single NSTF for CCAA Summer Conditions ........................................................ 57
Table A.2: Recovery capacity of a single NSTF for CCAA Winter Conditions........................................................... 57
Table A.3: Recovery capacity of a single OWTF for OWA Summer Conditions ....................................................... 58
Table A.4: Recovery capacity of a single OWTF for OWA Winter Conditions ......................................................... 58

List of Figures
Figure 1.1 Proposed Oil Tanker Routes to Kitimat Marine Terminal........................................................................ 7
Figure 1.2 Map Showing Open Water Area (OWA) and Confined Channel Access Area (CCAA) ............................. 8
Figure 2.1 Methodology for Calculating Response Gap .......................................................................................... 17
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Figure 2.2. Three Examples of Response Gap Index Application ............................................................................ 19
Figure 2.3. Results of response gap analysis for Nanakwa Shoals, year-round ...................................................... 20
Figure 2.4. Results of response gap analysis for Nanakwa Shoals, spring/summer................................................ 21
Figure 2.5. Results of response gap analysis for Nanakwa Shoals, fall/winter........................................................ 22
Figure 2.6. Time periods for which response was deemed possible or not possible based on applying the RGI to
environmental data at Nanakwa Shoals ................................................................................................................. 23
Figure 2.7. Scatter plot graphic showing wind, sea state (wave height and wave steepness), temperature, and
day/night with RGI at Nanakwa Shoals (2005)........................................................................................................ 24
Figure 2.8. Results of response gap analysis for Dixon Entrance, year-round ........................................................ 25
Figure 2.9. Results of response gap analysis for Dixon Entrance, spring/summer ................................................. 26
Figure 2.10. Results of response gap analysis for Dixon Entrance, fall/winter ....................................................... 27
environmental data at Dixon Entrance ................................................................................................................... 28
visibility with RGI at Dixon Entrance (2005) ............................................................................................................ 29
Figure 2.13. Preliminary Response Gap at Locations along Proposed Shipping Route, and Response Gap
Calculated Using RGI Methodology at Dixon Entrance and Nanakwa Shoals ......................................................... 31
Figure 2.14. Combined RGI throughout the year at both Nanakwa Shoals and Dixon Entrance. ........................... 32
Figure 3.1 Map Showing Location of Potential Spill Sites and Spill Response Hubs in Northern Gateway Tanker
Region ..................................................................................................................................................................... 37
Figure 3.2 Examples of Open Water Task Force Configuration and Equipment .................................................... 41
Figure 3.3. Calculations and conversions used to derive 72-hour task force needs from ROC outputs ................ 46
Figure 3.4 Recovery Mass Balance Estimate for CLB OWA Winter Simulation (For One OWTF) ............................ 48
Figure 3.5. 72-hour Oil Thickness Output from CLB OWA Winter Simulation Spill (10,000 m3) ............................ 49
Figure 3.6. 72-hour Water Content in Emulsion from CLB OWA Winter Simulation Spill (10,000 m3) .................. 50
Figure 3.7. 72-hour Oil Viscosity Output from CLB OWA Winter Simulation Spill (10,000 m3).............................. 50
Figure 3.8. 72-hour Oil Evaporation Output from CLB OWA Winter Simulation Spill (10,000 m3) ........................ 51
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Authors
This report was compiled by Nuka Research and Planning Group, LLC.
Lead Authors and Primary Editors

Elise DeCola
Sierra Fletcher
Contributing Authors and Analysts

Bretwood Higman, PhD
Andrew Mattox
Michael Popovich
Tim Robertson
Meteorological Data and Analysis

Uwe Gramann, P. Met.
Senior Meteorologist, Mountain Weather Services

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Executive Summary
Overview
The Haisla Nation Council commissioned this study to analyze capabilities and limitations related to mechanical
oil spill response along the vessel routes associated with the proposed Northern Gateway project. Nuka
Research and Planning Group, LLC analyzed the response gap and the response capacity for a spill response at
two areas along the shipping routes to and from Kitimat, BC. The response gap analysis estimates how often
environmental conditions will be so bad as to prevent the effective deployment of mechanical spill response
equipment. The response capacity analysis estimates the quantity of forces that would be required to achieve
a given on-water mechanical recovery goal. Combined, these two analytical approaches illustrate what is
possible and what is required to respond effectively to a spill that could result from shipping oil along the
Northern Gateway tanker routes.
Response Gap Analysis

The response gap analysis applied an established methodology to compare historical data on wind speed, wave
steepness, temperature, and daylight with established limits at which mechanical response is not
possible/effective. Historical data (January 1996 - February 2012) were gathered for both Dixon Entrance (open
water) and Nanakwa Shoals (protected water). The analysis considered individual factors along with the
interactions among environmental factors; for example, waves of a certain height are much more limiting in the
presence of a strong wind or in times of low visibility. The response gap analysis resulted in estimates that the
four environmental conditions measured for the study would prevent the deployment of an effective response
at Dixon Entrance 45% of the time on average over the year. (During the more severe conditions from October
March, a response would not be possible approximately 68% of the time, while in the milder months from April
September, a response would not be possible 24% of the time.) By contrast, the environmental factors
measured would prevent an effective response at Nanakwa Shoals 7% of the time on average over the year.
However, data for Nanakwa Shoals indicated that response gap periods those times when no response was
feasible often spanned several consecutive days, likely due to storm events.
Response Capacity Analysis

The response capacity analysis was performed using the Response Options Calculator (ROC) model to calculate
the equipment, vessels, and personnel that would be required to contain and recover a 10,000 m3 oil spill in a
generic open water location and a generic channel location in different seasons and with different spilled
product. The model also estimates total oil recovery (Genwest Systems Inc. 2012). Based on the ROC model
outputs for the 16 simulations run, the number of task forces required to contain and recover a 10,000 m3 spill
under idealized conditions within 72 hours is between 8 and 20. The low estimate 8 task forces would
require 8 oil spill response vessels with 8-16 work boats, 1600m of ocean boom, and more than 300 personnel
to be on-scene and recovering the oil within 8 to 12 hours of the spill (depending upon location). This estimate
presumes that sufficient barge capacity would be available to support offloading of recovered oil and water
from the primary skimming vessel to the barge.
Bulk recovery rates across the sixteen 10,000 m3 spill simulations ranged from 503 m3 to 2120 m3 depending on
the location, type of oil spilled, and season. In general, more forces are required for an open water spill than for
a confined channel area spill, due in part to the longer transit time for resources to arrive on-scene. Likewise,
winter spills require additional task forces to achieve the necessary recovery rates because they have shorter
operating periods due to reduced daylight. The response capacity estimates for the 16 spill simulations look only
at initial on-water recovery and do not factor in the additional response resources that would be associated with
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concurrent response operations, such as nearshore recovery, sensitive area protection, wildlife response,
shoreline cleanup and assessment, or spill surveillance.
Conclusion
Conservative estimates were used throughout the analysis, so that the results represent best case scenarios.
For the response gap analysis, the only environmental factors measured were those for which reliable, hourly
data existed to develop the hindcast. It did not incorporate currents; ice; or visibility limitations due to fog,
clouds, or precipitation. For the response capacity analysis, logistical factors, mechanical failures, human error,
and the impact of on-scene conditions to the overall response are not reflected in the ROC outputs. The
response resource estimates developed in the RCA address only on-water recovery of floating oil. A full-fledged
oil spill response system would also incorporate nearshore recovery, sensitive area protection, wildlife response,
shoreline cleanup and assessment, and surveillance/reconnaissance.
The results of the two analyses conducted in this study provide a necessary basis for planning for effective
response for spills to water along the shipping routes to and from Kitimat, BC. These results indicate that there
are significant periods of time sometimes several days in a row during which a response would be prevented
by environmental conditions even in the protected waters of Nanakwa Shoals. Even in the best conditions,
significant numbers of vessels, equipment, and personnel will be needed in order to mount an effective
response. Deploying these resources within 72 hours of a spill is critical to ensure the most effective response
possible, but also requires significant planning, adequate training, and the deliberate placement of equipment to
reduce transit times to potential spill sites. Additionally, the response gap analysis can be used to inform spill
prevention planning to minimize the chances of a spill occurring when that 72 hour response window will be one
of high winds, steep waves, cold temperatures, and/or long hours of darkness.
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Part 1: Introduction

1.1 Background
The Haisla Nation Council commissioned this study to analyze the capabilities and limitations to mechanical oil
spill response (containment, recovery and removal of oil) in two areas along the potential vessel routes
associated with the Northern Gateway project. The purpose of this study was to provide additional information
as part of the regulatory review of the proposed Northern Gateway project.
This report overlays two related analyses. The first, a Response Gap Analysis (RGA) applies an established
methodology to estimate the overall window-of-opportunity to respond to an oil spill from a Northern Gateway
tanker in two representative locations. The RGA provides an estimate of how often mechanical oil spill response
would be possible at the two selected locations. The second component, a Response Capacity Analysis (RCA)
uses a simulation model to estimate the scale of a spill response (type and quantity of resources) that would be
required to contain and recover a marine oil spill during the critical 72-hour time period when on-water spill
response technologies are most effective. Taken together, these two analyses provide a basic framework for
what is possible and what is required to effectively respond to an oil spill along the Northern Gateway tanker
routes (Figure 1.1).
Figure 1.1 Proposed Oil Tanker Routes to Kitimat Marine Terminal
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1.1.1 Northern Gateway Project Proposal
The proposed Northern Gateway project will transport diluted bitumen, synthetic crude, condensate, and other
hydrocarbons via pipeline across Alberta and British Columbia. The project includes construction of a major oil
terminal in Kitimat, BC to serve as the western terminus of the pipeline and serve as the hub for import and
export of petroleum products, via oil tanker, to and from the Northern Gateway pipeline. An estimated 220
tankers per year will call on the Kitimat Marine Terminal, resulting in an estimated 440 transits to and from
Kitimat. Inbound laden tankers will carry condensate and synthetic crude oil, and outbound laden tankers will
carry diluted bitumen. Oil spill risks exist along the entire portion of the proposed primary and alternate tanker
routes (DNV 2010).
1.1.2 Representative Operating Environments
Both analyses included in this study focus on operating environment as a key component of oil spill response
operations. For the purpose of this study, we have applied two generalized operating environments to the
proposed tanker routes. These correspond to the distinctions made by Enbridge in Northern Gateway planning
documents by dividing the tanker routes into two general categories: Open Water Area (OWA) and Confined
Channel Access Area (CCAA). Within each area, a representative site was chosen for both analyses. In the
OWA, the Dixon Entrance weather buoy was selected for the RGA open water and the same site used for spill
location and weather condition inputs for the RCA. Within the CCAA, the Nanakwa Shoals weather buoy was
selected as the RGA protected water site and was also used to input into the RCA model. These two locations
were chosen because they are broadly representative of the operating environment classifications applied by
the American Society for Testing and Materials and commonly utilized in oil spill reference guides (ASTM 2003;
Potter 2004). These sites were also chosen because there were sufficient environmental datasets available for
both locations to allow for meaningful analysis, particularly for the RGA which requires a continuous set of
weather observations.
Figure 1.2 Map Showing Open Water Area (OWA) and Confined Channel Access Area (CCAA)

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1.2 Mechanical Recovery of Marine Oil Spills

Oil spill response methods are generally divided into three main categories: mechanical recovery, where oil is
contained in an area using boom or natural containment and removed using skimmers and pumps; non-
mechanical recovery where chemical countermeasures, burning, or bioremediation are used to degrade or
disperse an oil slick; and manual recovery, where oil is removed using simple hand tools and techniques such as
pails, shovels, or nets. Mechanical recovery had been identified as the primary oil spill cleanup method to be
used for spills from Northern Gateway tankers.
1.2.1 Mechanical Recovery Methods
The objective of mechanical recovery is to concentrate oil to a thickness that will permit recovery. Mechanical
recovery systems involve two major components: containment barriers and recovery systems. The containment
barrier is used to corral oil, and a skimming system is used to recover the oil that floats at the waters surface.
On-water recovery picks up water as well as oil, both incorporated into the oil (forming what is known as an oil-
water emulsion)1 and as free water. Therefore, oil recovery systems recover a much higher volume of fluids
than the actual spill volume. Sufficient storage must be available to hold the volume of recovered oil and water.
Once the oil has been recovered, free water must be decanted (separated from the emulsified oil) and the
remaining oil must be transferred using pumps and hoses to temporary storage until it can be properly disposed.
Mechanical recovery systems require additional equipment and resources such as vessels, pumps, anchors,
decanting systems, and trained personnel with the ability to safely operate these systems. Ultimately, all
recovered wastes must be properly disposed of according to applicable regulations.
Effective mechanical recovery operations require surveillance and spill tracking to identify the location,
spreading, and condition of the spilled oil in order to select and apply the appropriate response equipment and
tactics. They also require logistical support to transport equipment and trained personnel to the spill site, deploy
and operate the equipment, and decontaminate the equipment when response operations are complete. Spill
responders must be able to safely access the spill site in order to deploy the equipment. Accessing the spill site
is often one of the biggest challenges, particularly in remote areas.
Response time is critical to the success of on-water mechanical recovery. As soon as oil is spilled to water, it
begins to spread, evaporate, and emulsify. As time passes, it becomes more difficult to track, contain, and
recover or treat spilled oil. Therefore, the quick mobilization and deployment of response equipment and
trained personnel is important to the overall response effectiveness. However, like all on-water operations,
marine spill response is vulnerable to limitations posed by weather and environmental conditions. Mechanical
recovery is not safe or effective above certain weather and environmental thresholds. Extended periods of
adverse weather can significantly impact oil spill recovery operations.
1.2.2 Northern Gateway Oils
The type of oil spilled can have a major impact on the selection of oil spill response techniques, and on their
ultimate effectiveness. Planning documents for Northern Gateway tanker operations specify several different
types of oils that could be transported. These include diluted bitumen, synthetic crude oil, and natural gas
condensate. Each substance will behave differently when spilled to water, and the effectiveness of traditional

1
Emulsification occurs as a part of the overall weathering of oil when it is spilled to water. The oil properties change and
water-in-oil emulsion ratios typically increase over time. Emulsion studies of the project oils have shown that some oils
3
may emulsify as much as 60-70% within the first 24 hours of the spill. If a mechanical recovery system removed 100m of
3
oil that was a 60% water-in-oil emulsion, only 40 m of the recovered product would actually be spilled oil. Emulsification is
a significant consideration for spill planning, because the volume of storage required to hold recovered oil will be much
higher than the actual volume spilled.
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mechanical recovery systems and equipment to a Northern Gateway spill may be significantly impacted based
on the type of oil.
For the purpose of this analysis, two types of oil are considered diluted bitumen and synthetic crude oil.
Condensate is not included because its properties are not necessarily appropriate for on-water mechanical
recovery methods.2 Condensate spills would initially form a slick similar to a crude oil spill, however due to its
chemical and physical properties, a condensate spill would quickly evaporate and dissipate into the water
column, rendering on-water containment and recovery ineffective (Moffatt and Nichol, 2007). Even if a
response could be mounted before the slick dispersed, on-water booming of condensate would creates a safety
risk, due to the high volatility and potential for ignition or explosion.
Synthetic crude oil has properties similar to some naturally occurring crude oils, and while there has been
limited real-world experience with synthetic crude oil spills, it is reasonable to expect that traditional mechanical
recovery methods and equipment could be applied to a synthetic crude oil spill.3 Diluted bitumen is heavier and
more viscous than most crude oils, and it is characterized as a heavy oil (IMO, 2005). The characteristics of the
spilled oil are not considered at all in the Response Gap Analysis, because that analysis focuses simply on
identifying whether oil spill response would be feasible to undertake. The Response Capacity Analysis does
consider oil characteristics as they relate to oil recovery rates under ideal conditions. However, the subject oils
used in the RCA were derived from Enbridge submission documents, and may not be fully representative of the
range of oils that could be transported along the tanker routes. For example, the two diluted bitumen blends
used in the RCA are considerably less dense than the diluted bitumen that spilled from another Enbridge
pipeline in Michigan in 2010 (USEPA, 2011). The difference in oil properties would impact the potential
effectiveness of skimming operations because the oil could more readily become submerged. Oil spill
simulations for heavier diluted bitumen blends should be considered once subject oil properties have been
established.
1.3 Shipping Routes
Throughout this report, the Northern Gateway (NG) system is compared to Prince William Sound (PWS), because
the PWS system provides a working model of how a major marine oil terminal in the North Pacific manages oil
tanker spill response planning. However, the Northern Gateway shipping routes are complex and extensive, in
comparison to Prince William Sound. Northern Gateways routes:
Incorporate multiple enclosed waterway routes, which are not accessible from potential staging areas
for major marine or air-based access via direct vectors.
Diverge in the open water area.
Have a combined length of more than 800 km before clearing the OWA and all terrestrial hazards.4
Condensate is derived during natural gas production. It is highly volatile and acutely toxic. In the event of a condensate
spill, the majority of condensate is modeled to evaporate or dissipate within 24 hours, making on-water recovery unlikely.
A condensate spill may have adverse impacts, as the product itself is toxic to many organisms.
3
A variety of syncrudes may be transported by the Northern Gateway project. Synthetic crude oil is derived from oil sands
or oil shale. It is so-named because, although it is analogous to crude oil in its general behavior and commodity use, it is
actually product refined from the original source. Synthetic crude oil is not a homogenous product. It is a family of
hydrocarbons, much like true crude oil. Within a spill context, synthetic crude oil is assumed to behave similar to crude oil.
The synthetic crude oil tested by SL Ross may or may not be representative.
4
The PWS tanker route from Valdez out of Hinchinbrook Entrance is approximately 120 km long, and consists of a single
route. The Northern Gateway tanker route, until all land-hazard areas are cleared, contains roughly 800-900 km of routes.

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The proposed tanker routes are shown in Figure 1.1. While the operating environment along the proposed
tanker routes is highly variable, we have selected two representative locations along the proposed route to
represent two functionally different operating environments with regards to spill response.
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Part 2: Oil Spill Response Gap Analysis

2.1 Overview
Despite decades of improvements to the technology and procedures used to mount a spill response on water,
there are still times when environmental conditions hinder or preclude an effective response. This response gap
analysis (RGA) considers the potential impact of four environmental factors (wind, sea state, temperature, and
daylight/darkness) on response operations based on published literature and input from spill response experts
(SL Ross, 2011; Nuka Research 2007). It also considers the potential impact of combinations of these factors on a
response.
2.1.1 Scope and Approach of Analysis
The analytical approach applied here originated in a 2007 analysis for Prince William Sound (Nuka Research,
2007).5 Subsequently, SL Ross applied a similar approach, for the Canadian Beaufort Sea (2011), and the Living
Oceans Society conducted a partial analysis (focusing on wave height only) for the proposed shipping route
associated with the Northern Gateway project in 2011. This study therefore draws on previously established
understanding of which environmental factors impact response, the metrics and data typically available for each
environmental factor, the four priority factors, the typical limitations on response due to different
environmental factors, and the impact of interactions among environmental factors (Nuka Research, 2007).
The following steps were taken to complete this analysis:
1. Identify two weather stations representative of both protected and open-water operating areas along
the proposed shipping route to and from Kitimat, BC.
2. Establish operational limits for four environmental factors based on previous studies and best
professional judgment.
3. Apply the operational limits to the weather station datasets determining how each of the four would
influence response for each weather observation period.
4. Establish a rule to estimate whether the interaction among all the environmental factors for a single
observational period would allow or prohibit response.
5. Apply the response gap rule to the datasets determining which observational periods had weather that
would prohibit response, and characterize those results with summary statistics.
2.1.2 Environmental Factors
The purpose of this response gap analysis is to determine the frequency of the response gap in two areas of
potential vessel operations associated with the proposed Northern Gateway project. The environmental factors
of wind, sea state, visibility, and temperature all impact mechanical containment and recovery equipment
differently (Nuka Research, 2007). Table 2.1 summarizes the impact of environmental factors on spill response.
Wind
Wind alone6 can impede or prevent mechanical response operations in the following ways:
Vessels unable to keep on station,

Crew unable to work on deck,
Equipment and workboat deployment and retrieval impeded, and

5
6
The methodology used for Nuka Researchs 2007 analysis was initially proposed for review in 2006. (Nuka Research, 2006)
Wind is also the primary driver of ocean waves, but sea state will be considered as a separate factor.
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Boom failure.

Sea State
Sea state refers to both wave height and wave period (frequency). When wave height is small, wave period has
little effect on response operations. As wave height increases, waves of a short period have greater effect on
response operations than waves of a longer period. Short, choppy waves have a more significant effect than
long, ocean swells. Waves can impede or prevent mechanical response operations in the following ways:
Boom failure,
Skimmer failure,
Crew unable to work on deck,
Equipment and workboat deployment and retrieval impeded,
Oil becoming submerged and thus not available to recovery, and
Inability to track and encounter oil.

Visibility
Factors that may hamper visibility include darkness, fog, snow, heavy precipitation, or low clouds. Visibility can
impede or prevent spill response operations in the following ways:
Inability to track and encounter oil, and

Vessels unable to keep on station.
This study only considered the impact of daylight on visibility, though at times fog or other factors would also
impair visibility.
Temperature
High and low temperature extremes can adversely affect oil spill response operations, but in British Columbia
low temperatures are more likely to cause problems. Low temperature can impede or prevent response
operations in the following ways:
Crew unable to work on deck due to ice or hypothermia,

Mechanical equipment failure due to icing, and
Vessel instability due to icing.

Currents
Currents can signicantly impact oil spill response operations. In rivers or narrow embayments, the entire
response system is captured in the current and there is little or no relative movement between the various
components of the response system. However, currents can cause problems in areas where eddies or tide rips
occur and when the current sets the response system into shoal waters. Currents can impede or prevent
response operations in the following ways:
Boom failure,
Oil becoming submerged and thus not available to recovery, and
Vessels unable to keep on station.
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Because only ocean currents are likely to be encountered by the open- water response systems considered for
this study, and there is no way to measure local currents such as tide rips, currents were not considered for the
purposes of this study. Both Nanakwa Shoals and Dixon Entrance are relatively protected from currents, as
compared to other areas along the shipping routes. Data on currents is not included in this analysis.
Ice
Ice can impede or prevent response operations in the following ways:
Failure of skimming systems,

Boom failure, and
Inability to track and encounter oil.
Ice is not considered for this phase of this study, because ice is not a common phenomenon in the selected
operating areas and reliable data on the presence of ice are not available.
2.1.3 Assumptions

Interactions Among Environmental Factors
Interactions between environmental factors have a major effect on response operating limits. For example, low
temperatures and strong winds cause freezing spray that can impede or prevent response operations much
sooner than either temperature or wind alone. Likewise, waves of a certain height are much more limiting in
the presence of a strong wind or in times of low visibility. We accounted for these interactions by developing a
simple set of rules to combine observed weather conditions and determine whether response was possible for
each observational period. (Nuka Research, 2007)
Response Capacity Degradation due to Environmental Factors
The degradation of response does not occur at a single point, nor is it necessarily linear in nature. For instance,
response efficiency does not go from 100% to 0% as wind increases from 10 to 11 m/s. Likewise, a wind of 8
m/s does not indicate that the response efficiency is half that at 16 m/s. The degradation curve is probably
different for each environmental factor. This further complicated the task of setting discrete operational limits.
We accounted for capability degradation by establishing categories of limitations for each environmental factor.
(Nuka Research, 2007)
Mechanical Response Equipment
Although Enbridge has not provided specific information about the quantity and type of equipment that would
be used for the Northern Gateway project, Nuka Research applied limits based on the assumption that the
equipment will represent standard available technology and be comparable to the offshore oil spill response
equipment maintained by major U.S. oil spill response organizations. With this basic assumption, the limits can
be applied to the historical environmental factor data in the targeted areas to calculate a response gap even
without knowing the exact quantity or configuration of vessels and other equipment that may end up being put
in place: if the weather conditions preclude the effective deployment of one skimmer, for example, those same
conditions would preclude the effective deployment of 12 skimmers.
Applicability of Traditional Crude Oil Response Systems to Subject Oils
The equipment operating limits applied in this study are derived from earlier work in Prince William Sound,
Alaska. The Prince William Sound system was developed for spills of Alaska North Slope crude oil, which differs
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from the subject oils (synthetic crude oil and diluted bitumen) that will be transported by Northern Gateway.
Since there is no commercially available response equipment designed specifically for diluted bitumen spills, the
application of conventional crude oil technologies was necessary. While this study is not meant to imply that
Prince William Sound mechanical recovery technologies would necessarily be effective on the Northern Gateway
oils, operating limits for on-water mechanical recovery systems are generally independent of the type of oil
transported. However, if novel spill recovery technologies were developed for the subject oils, additional
response gap analyses may be appropriate. For the purpose of the RGA, the key question is whether or not
mechanical recovery equipment could be safely and effectively deployed under the given conditions. The
effectiveness of the equipment in actually recovering the subject oils is discussed in greater detail in the RCA
section of this report (Part 3).
Table 2.1 Impact of Environmental Factors on Spill Response Operations
FACTOR
CONDITIONS THAT COULD PRECLUDE A RESPONSE
Wind
Winds > 15 to 20 m/s, but depending on other variables.

The negative impact of winds on the effectiveness of a response is realized when winds approach a
range of 15 to 20 m/s or greater. Temperature, sea state, visibility, and precipitation may vary the
effect of a specific wind speed. In some circumstances, a response may be possible in 15- to 20- m/s
winds, while in other circumstances a response may not be effective in winds less than 10 m/s.
Sea State
Seas greater than 3 m (10 feet) with strong tides and currents.
A rule-of-thumb operating limit for wave height is 3 m(10 feet). This limitation may be affected by
ambient temperature, visibility, and precipitation. The impact of tides and currents can only be
determined on a case-by-case basis.
Visibility
Depending on other environmental factors, the visibility limitation may be <0.9 km for vessels
tracking oil.
If wind, sea state, temperature, visibility and/or precipitation cause the response to be inefficient, the
additional factor of darkness may actually impede a response.
Limitations for flight surveillance operations, based on visual flight rules for rotary- and fixed-wing
aircraft are:
-500 foot ceiling and 3.7 km visibility if in sight of land, or
-500 foot ceiling and 35.5 km visibility if over open-water and land is not in sight.
For booming and skimming vessels, the visibility limitation varies between 0.2 km (200 meters) and
1.5 km (800 meters), depending on temperature, sea state, wind, and precipitation. Visibility limits
affect response vessels differently depending on whether they are already engaged in oil recovery or
seeking oil to recover. For vessels actively booming and skimming in oil, the master of the vessel
would set limits based on safety and operational efficiency. For vessels not in oil and which may
require aircraft surveillance, the limitations would likely be determined by those of the aircraft as
described above.
Temperature
Long-term temperatures below freezing combined with high winds could preclude a response.
Sustained temperatures below freezing, in conjunction with high winds, severe sea states, poor
visibility, and/or heavy precipitation, will significantly reduce the effectiveness of the response. At
temperatures below -9C and winds of 24 to 28 knots, wind chill becomes a factor in response
operations.

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2.2 Methodology
To quantify the response gap for two locations in British Columbia, this study began by assembling historical
datasets of the environmental factors known to affect open-water mechanical response systems. Each dataset
contained observations related to the following environmental factors: wind speed, wave steepness,
temperature, and visibility (limited to daylight and darkness). These datasets were used to evaluate how often
environmental conditions exceed the maximum response operating limits for each representative environment.
(The limits are established in Table 2.2).
A response gap index (RGI) was calculated to incorporate the interactions between environmental factors and
response efficiency losses based on the established response limits (Table 2.2). Once the RGI was computed for
each observational period, the Response Gap was estimated by summing up the RGI over a set of observations.
The response gap is expressed as the percentage of time that a response is not possible. Figure 2.1 shows how
the RG was calculated from the RGI.

Table 2.2. Limits Used for the Northern Gateway Response Gap Analysis
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Figure 2.1 Methodology for Calculating Response Gap

2.2.1 Selected Operating Areas
This study focused on two areas along the tanker route proposed for Northern Gateway operations. Dixon
Entrance was chosen to illustrate the potential response gap for open water areas, while Nanakwa Shoals was
chosen as representative of protected waters along the route (see Figure 1.1).
Nanakwa Shoals is the site of the only Department of Fisheries and Oceans (DFO) buoy within the protected
waters on the proposed tanker route. Though protected, this area is also subject to sudden and severe
conditions due to strong winds from the arctic during high pressure in the winter. These arctic outflows can
create winds of up to 60 knots. (NAV CANADA, 2001) The DFO weather buoy at Dixon Entrance had a relatively
complete observation data set when compared to other open water locations.
2.2.2 Datasets Assembled for Each Operating Area
The data for wind, sea state, and temperature are all from the automated buoys at Dixon Entrance (Buoy #
46145) and Nanakwa Shoals (Buoy #46181) (DFO, 2012). The datasets were culled of any buoy data flagged as
doubtful, erroneous, or off-position, and any duplicate records were deleted. Observations were
considered to be valid for no more than one hour; if a subsequent observation was recorded in less than one
hour, the validity of the previous observation ended at the time of the new observation. In general, observations
were taken hourly with occasional interruptions (Gramann, 2012, included as Appendix C to this report).
For the purposes of this study, visibility has been measured strictly based on daylight/darkness using civil
twilight tables based on Terrace Airport in 1975 (National Research Council Canada, 2012). While there is some
data available from the airport or lighthouses describing the visibility related to cloud cover, fog, or
precipitation, these are not available on an hourly basis and do not necessarily reflect the conditions along the
shipping routes. This extremely conservative approach will therefore not account for times during the day when
visibility is hindered due to fog or precipitation, which are particularly common from September through
February (Terhune, 2011).
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Prior to the analysis, the datasets were reviewed and any outliers removed.7 A total of 103,364 observations
were taken at Nanakwa from January 1996 - February 2012. At Dixon Entrance, 125,185 observations were
applied in the analysis over the same time period.
There are some gaps in the datasets resulting from periods of hours, weeks, or months when the automated
buoys were not functioning properly. There are a number of possible reasons for buoys to malfunction, including
vandalism, heavy weather, freezing spray, maintenance, or funding limits. In the case of freezing spray or other
impacts from heavy weather, this could result in a moderate bias towards under-reporting bad weather (See
Appendix C for further discussion).
2.2.3 Response Operating Limits
Nuka Research established basic operating limits for mechanical response equipment used in Prince William
Sound in 2007. The same limits are used in this study (converted to metric). These were based on the authors
best professional judgment and a literature review, including review of both published and unpublished reports
included in an annotated bibliography in 2006 (Nuka Research 2006). Reports included after-action reports from
oil spill drills, exercises, trainings, and actual responses. Information about system operations in real world
environments was more relevant than laboratory tests of any single component.
Subsequent to the 2007 study for Prince William Sound, the Living Oceans Society conducted a preliminary
response gap analysis for the proposed shipping route associated with the Northern Gateway project. This study
focused only on wave height, and included the same limits used by Nuka Research in 2007 with variations only in
the way that the values were converted to metric. (Terhune, 2011) Limits used by S.L. Ross for a 2011 response
gap analysis for the Canadian Beaufort Sea are also consistent with the limits applied by Nuka Research in both
2007 and this analysis, with only minor variations (e.g., for wind speed, SL Ross uses any speed greater than 15
m/s as the upper limit for effective response, while Nuka Research uses any speed equal to or greater than 15
m/s for the same.) (S.L. Ross, 2011)
For each of the four environmental factors considered, Nuka Research established a range at which response is
not impaired (green), possibly prevented (yellow), and not possible/effective (red). These limits, shown in Table
2.2, were then applied in the analysis to estimate the amount of time that response is not impaired, possibly
prevented, or not possible/effective based on historical data for wind, sea state, visibility, and temperature at
two chosen locations along the proposed shipping route for the Northern Gateway project.
2.2.4 Response Gap Index
A response gap index (RGI) was created to reflect the interactions among environmental factors (Table 2.3).
Even if no single environmental factor is ruled red (response not possible or not effective), the challenge of
dealing with yellow (response possibly prevented) conditions for two or more factors at the same time will
likely make effective response impossible. Figure 2.2 shows how this rule might be applied to three different
observational periods.
Table 2.3. Applying the Response Gap Index
If
Then the RGI is
any environmental factor is ruled RED
Red (response not possible)
all environmental factors are ruled GREEN
Green (response possible)
only one environmental factor is YELLOW and the rest are GREEN
Green (response possible)
two or more factors are ruled YELLOW
Red (response not possible)

7
For example, the data for Nanakwa Shoals displayed extreme sea temperatures on a few days of -20 C; these were
removed.
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Figure 2.2. Three Examples of Response Gap Index Application
2.3 Analysis
Data for each location were analyzed for the following factors: wind, sea state (wave steepness), visibility, and
temperature. For each operating area the response gap was calculated for each environmental factor
separately, then the RGI. The sections below present this information for summer and winter separately, as well
as the year-round average. The RGI at each location from January 1996 February 2012 is plotted and
presented along with a more detailed presentation of the RGI at each location for January December 2005.
This year represented one of the most complete data sets at both locations.
2.3.1 Nanakwa Shoals
Year-Round
In Nanakwa Shoals, the data related to wind, sea state, temperature, and visibility were compiled for a total of
103,664 observations between January 1996 and February 2012. The limits in Table 2.2 were applied to each
observational period, resulting in an determination for each observational period that the response would have
been unimpaired, impaired, or prevented by each of the weather conditions considered. The RGI was applied to
estimate the combined impact of the environmental factors. All values are rounded, and presented in Figure 2.3.
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Figure 2.3. Results of response gap analysis for Nanakwa Shoals, year-round

Seasonal
Figures 2.4 and 2.5 show the seasonal variability in the ability to mount a response at Nanakwa Shoals. For the
purpose of this analysis, the dates of March 26 October 7 were used to describe spring/summer conditions,
and the dates of October 8 March 25 for fall/winter conditions. Not surprisingly, an effective response is
more likely to be prevented by environmental conditions between October and March than during the
spring/summer.
Figure 2.6 shows the frequency with which the RGI was calculated to be green and red, and also illustrates the
time periods from January 1006 February 2012 for which data were not available.

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Figure 2.4. Results of response gap analysis for Nanakwa Shoals, spring/summer
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Figure 2.5. Results of response gap analysis for Nanakwa Shoals, fall/winter
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environmental data at Nanakwa Shoals
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Detailed Review of Single Year Data (2005)
For a more detailed look at one year (2005),8 Figure 2.7 describes the impact of the different factors, along with
red and green dots indicating the number of observational periods deemed to be red and green according to the
RGI methodology. In the protected waters of Nanakwa Shoals, waves are almost always below 1 m. It does get
quite cold for sustained periods of time, however, and arctic outflow winds may occur during periods of
sustained cold hence, many of the red conditions result from the fact that both temperature and wind are
rated yellow.
day/night with RGI at Nanakwa Shoals (2005)
This year was chosen because it provided one of the most complete data sets for both Nanakwa Shoals and Dixon
Entrance.
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2.3.2 Dixon Entrance
Year-Round
At Dixon Entrance, the data related to wind, sea state, temperature, and visibility were compiled for a total of
123,185 observations between January 1996 and February 2012. The limits in Table 2.2 were applied to each
observational period, resulting in an determination for each observational period that the response would have
been possible, possibly prevented, or not possible. The RGI was applied to estimate the combined impact of the
environmental factors. All values are rounded, as presented in Figure 2.8.
Figure 2.8. Results of response gap analysis for Dixon Entrance, year-round

Seasonal
Figures 2.9 and 2.10 show the seasonal variability in the ability to mount a response at Dixon Entrance. For the
purpose of this analysis, the months of March 26 October 7 were used to describe spring/summer
conditions, and the months of October 8 March 25 for fall/winter conditions.
Figure 2.11 shows the frequency with which the RGI was calculated to be green and red at Dixon Entrance, and
also illustrates the time periods from January 1006 February 2012 for which data were not available.

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Figure 2.9. Results of response gap analysis for Dixon Entrance, spring/summer
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Figure 2.10. Results of response gap analysis for Dixon Entrance, fall/winter

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Figure 2.11. Time periods for which response was deemed possible or not possible based on applying the RGI
to environmental data at Dixon Entrance

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Detailed Review of Single Year Data (2005)
For a more detailed look at one year (2005),9 Figure 2.12 describes the impact of the different factors, along
with red and green dots indicating the number of observational periods deemed to be red and green according
to the RGI methodology. In daytime, conditions rarely exceed response capabilities by very much. At night,
response is only possible if wave heights stay low enough to fall in the green category. Thus, the combination
of wave height and darkness has the most frequent impact on a potential response.
Figure 2.12. Scatter plot graphic showing wind, sea state (wave height and wave steepness), temperature,
and visibility with RGI at Dixon Entrance (2005)
2005 was chosen because it provided one of the most complete data sets for both Nanakwa Shoals and Dixon Entrance.
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2.4 Discussion
2.4.1 Impact of Conservative Estimates to Response Gap Analysis
Conservative estimates were applied throughout the Response Gap Analysis, so that the resulting estimate
represents best case limits; therefore the response gap estimates may be low. It is possible that other factors
not accounted for in this analysis, such as fog or precipitation, would preclude response for a higher percentage
of the time. Similarly, conditions that do not preclude a response (green RGA conditions) may still impair or
degrade the effectiveness of response operations.
An RGA estimate does not mean that an effective response will occur when conditions are amenable, only that
the environmental conditions themselves should not prevent it. Careful planning, adequate resources, and the
right number of personnel with the appropriate qualifications will still need to be in place.
2.4.2 Comparison with 2011 Preliminary Response Gap Study
The preliminary RGA conducted by the Living Oceans Society in 2011 found response gaps based on wave height
of 0.12% at Nanakwa Shoals and 18% at Dixon Entrance (Terhune, 2011). When wind, wave steepness,
temperature, and visibility (in terms of daylight/darkness only) were added to the analysis and combined using
the RGI methodology, the response gaps at these locations jumped to 7% at Nanakwa Shoals and 45% at Dixon
Entrance. The impacts of fog and precipitation were omitted due to a lack of reliable data; if included, these
additional factors related to visibility would likely increase the RGI at both locations.
Since the inclusion of additional environmental factors in the RGA increased the response gaps so significantly at
Dixon Entrance and Nanakwa Shoals, there is no reason why similar increases would not happen at other
locations on the shipping routes to and from Kitimat, BC. In fact, based on a review of the preliminary response
gap assessment for Northern Gateway (Terhune, 2011), which used wave height data only, Dixon Entrance
represents a conservative example of an open-water location along the shipping routes associated with the
proposed Northern Gateway project. Ships passing by Dixon Entrance (buoy #C46145, also used in this study)
will also pass near West Dixon Entrance (buoy # C46205), where the response was estimated to be not possible
or impaired much more frequently even based just on wave height (48.25% of the time at West Dixon Entrance,
compared to 18.49% at Dixon Entrance). Additionally, vessels taking the southerly route will pass near East
Dellwood (buoy #C46207), where wave height data indicates a response that is impaired or not possible 50.3%
of the time. (Terhune, 2011) While it is not possible to apply a linear model to predict the extent to which the
response gap estimates would increase at these other locations with the addition of wind, wave steepness, and
temperature data, the increase is likely to be meaningful. For example, daylight/darkness was show to have a
significant additive effect to the overall response gap calculated for the two buoys in this study. Additional
consideration of just that one factor for the other response gap sites in the Living Oceans study would likely
increase their estimates considerably, particularly during winter months.
Figure 2.13 compares the response gap estimates based on wave height throughout the region (based on
Terhune 2011) with those calculated using the RGI for Nanakwa Shoals and Dixon Entrance.
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Figure 2.13. Preliminary Response Gap at Locations along Proposed Shipping Route, and Response Gap
Calculated Using RGI Methodology at Dixon Entrance and Nanakwa Shoals

2.4.3 Combining Response Gap Data for Multiple Locations Along Proposed Shipping Routes
The length of the transit route between Kitimat and the OWA creates the potential that a response gap may
exist along parts of the shipping route, meaning that even if the conditions are favorable for a response at the
spill location, a response gap may exist in areas where the spill may migrate. The full shipping route (or
combination of available routes) must be considered in order to anticipate the potential impact of
environmental conditions on a spill response associated with the Northern Gateway project. Figure 2.14
portrays the times during which wind, sea state, temperature, and visibility (day/night) would be conducive to a
response in the protected waters of Nanakwa Shoals, but, at the same time, preclude a response at Dixon
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Entrance. The times during which a response is likely to be impossible at both sites (shown in red, below) are
almost entirely limited to the months of October - March.

Figure 2.14. Combined RGI throughout the year at both Nanakwa Shoals and Dixon Entrance.

2.4.4 Implications of Response Gap to Oil Spill Mitigation from Northern Gateway Tankers
Proposing specific mitigation measures is outside the scope of this study, but the results of this analysis provide
additional detail about the potential for unmitigated oil spill risks from vessel operations. It is clear that there
will be times when the proposed Northern Gateway pipeline is operating, necessitating the movement of diluted
bitumen and condensate onboard tankers to and from the Kitimat Marine Terminal, when the weather
conditions will preclude an effective spill response should a tanker spill occur. Mitigation measures should
consider the existence of a response gap along the tanker routes by enhancing tanker safety or prevention
measures during times when a response gap exists.
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Part 3: Oil Spill Response Capacity Analysis

3.1 Overview of the Approach
3.1.1 Purpose and Scope of Analysis
A response capacity analysis (RCA) was performed for on-water oil spill response operations in two
representative operating environments along the proposed vessel routes for Northern Gateway (NG) tankers.
The purpose of this analysis is to provide a semi-quantitative assessment of the capability of oil spill response
forces to mechanically contain and recover a marine oil spill from Northern Gateway tanker operations. The
basic research question posed was:
What is the capacity for available mechanical oil spill recovery systems to contain and recover marine oil spills in
two representative operating environments (open water and protected water)?
The RCA estimates generalized oil spill response capacity in the Project area, under favorable conditions, using
on-water mechanical recovery systems similar to those utilized by major U.S. oil spill response organizations.
The outputs of the RCA show the minimum amount of on-water mechanical recovery equipment that would be
required to address a model spill (10,000 m3). The results of the RCA provide a starting point for further
simulation analysis, which should factor in other conditions that may impact spill response effectiveness.
3.1.2 Factors Considered in the Analysis
In order to estimate response capacity, it was first necessary to define oil spill recovery systems. Since the
Northern Gateway submission documents have not explicitly defined the spill response equipment that will be
purchased or contracted if the project is approved, this study presumes that Northern Gateway will have best
available technology available to support clean-up operations. This analysis assumed a plausible recovery force
modeled on the Oil Spill Response Vessel (OSRV)-based open water recovery system utilized by the Marine Spill
Response Corporation (MSRC) during the 2010 Deepwater Horizon spill and other major on-water spill
responses.
This study applies the OSRV-based oil spill recovery systems to hypothetical spills of 10,000 m3 (approximately
2,640,000 gallons) at two representative locations in the project area. These environments are generally
representative of the types of conditions that would be encountered if cleaning up a spill in the open water area
(OWA) and confined channel assessment area (CCAA) as described in Northern Gateway submissions (DNV,
2010). This study utilizes the Response Options Calculator (ROC) to calculate the response resources that would
be required to contain and recover a 10,000 m3 oil spill at each location, and provides estimates of total oil
recovery (Genwest Systems Inc., 2012). This approach provides insight into the type and amount of resources
that would make up a best available technology spill response system for Northern Gateway operations, while
also providing a quantitative estimate of spill response efficiency under favorable conditions.
3.1.3 Assumptions
Modeling is necessarily dependent upon a serious of assumptions. Wherever possible, established models and
assumptions are applied. Assumptions and models inherent to ROC are described in the ROC Technical
Document (Genwest Systems Inc., 2012). All assumptions applied during the RCA are duly qualified or noted in
this report. Basic assumptions include: the operation of all equipment without malfunction or failure; the
absence of spill-related mishaps or other accidents that could hinder the response; effective logistics, command,
and communication; and effective reconnaissance and mapping of the spill.
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When applying the RCA findings to potential real-world spills, the estimated recovery capacities should be
considered the best possible cases. Assumptions in this analysis are favorable towards effective spill response,
creating a systematic positive bias.
3.2 Methodology
3.2.1 Response Options Calculator
The Response Options Calculator (ROC) computer model was used to estimate bulk oil recovery capabilities.
ROC is a publicly available computer model developed for the U.S. National Oceanographic and Atmospheric
Agency (NOAA) with industry support. The ROC was developed specifically to evaluate mechanical and non-
mechanical response options to oil spills by estimating the volume of oil that could be recovered by various
systems under a range of conditions. The model simulates oil weathering, spreading, and recovery by advancing
skimming systems (mechanical recovery).10 Spill behavior and weathering in ROC is based on updated versions
of the algorithms of the Automated Data Inquiry for Oil Spills (ADIOS) model, also developed for NOAA (NOAA,
2012), which are combined with new algorithms for slick spreading (Genwest Systems Inc., 2012). Like the
overlying ROC program, ADIOS was developed specifically to model oil fate and spreading to support oil spill
response planning.
ROC is not a trajectory model. It simulates the spread of the oil slick, but does not include influences from tides,
current, land, ice, debris, or complex weather conditions. Oil spread and spill response occur without any
influence from land or shallow water. ROC assumes that the mass balance of oil on the water is always available
for recovery, with no oil stranding on shorelines, and utilizes the average thickness of the total calculated slick to
project recovery rate.11 This analysis used ROC standard oil weathering. ROC weathering is not a
comprehensive fate model, and does not account does not account for such complex influences as water
salinity, particulates, or the compositional complexity of diluted bitumen. It does not account for possible oil
submergence.12
Within the ROC, modeled response systems are applied to oil spill scenarios. Response options performance is
calculated using an algorithm that applies specific response systems at one-hour time intervals to a simulated oil
spill, concurrent with the spreading and weathering of the spill.
3.2.2 Oil Spill Simulation Parameters
Spill Location and Dates
A series of oil spill simulations were run through the ROC. All simulations presumed a 10,000 m3 oil spills. Spill
locations and dates varied as follows:
Open Water Area (Open water operating environment):

o Dixon Entrance weather information, winter (January 1)
o Dixon Entrance weather information, summer (July 1)

10
The ROC can also be used to model non-mechanical response options such as dispersants or in-situ burning, but non-
mechanical response was not included in this analysis.
11
Detailed technical specifications on ROC and its underlying algorithms and function may be found in the technical
documentation produced by Genwest Systems, Inc. and available online at www.genwest.com
12
Recovery estimates in ROC assume that all non-evaporated, non-dispersed oil will remain floating throughout the 72-hour
recovery period. In reality, the density curves for the diluted bitumens (SL Ross 2010a and 2010b) show the oils
approaching neutral buoyancy as early as 24 hours into a response. Oil that becomes neutrally or negatively buoyant may
submerge below the sea surface, making it difficult to track and rendering traditional skimming systems ineffective.
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Confined Channel Assessment Area (Protected water operating environment):

o Nanakwa Shoals weather information, winter (January 1)
o Nanakwa Shoals weather information, summer (July 1)
Oil Properties
Each of the 4 basic spill scenarios was run in ROC with 4 different oils, for a total of 16 basic simulations. Three
of the oils were taken from Technical Data Reports (TDR) submitted by Enbridge (SL Ross, 2010a and SL Ross,
2010b) and the ROC database:
Cold Lake Bitumen (CLB) diluted with condensate
Mackay Heavy Bitumen (MKH) diluted with light synthetic oil13
Syncrude, (SYN)

The fourth oil, Alberta Sweet Mixed Blend (ASMB), was chosen from the ROC database of oils as a second
synthetic crude oil, which might plausibly be transported be transported by the Project, but which SL Ross
had not tested.
Oil properties used in the ROC were:
American Petroleum Institute gravity (API gravity or API):

API = (141.5 / SG) - 131.5
where
API = Degrees API Gravity
SG = Specific Gravity (at 60F / 15C)
Viscosity: Kinematic viscosity values for 1C and 15C were used, depending upon whichever
temperature was closer to the simulation water temperature.
Distillation cutoffs were used as determined by SL Ross 2010a and 2010b.
Alberta Sweet Mixed Blend properties were drawn directly from the ROC database.
Spill Size
For this analysis, a 10,000 m3 instantaneous release of oil is used for all simulations. This spill size is consistent
with the oil spill simulations provided by Northern Gateway for 4 of 6 locations along the tanker route (Hayco,
2011). While a 10,000 m3 spill represents a major oil spill, a catastrophic spill from a very large crude carrier
(VLCC) could be in excess of 50,000 m3, or 13.2 million gallons (Hayco, 2011).14

13
Both diluted bitumen formulas analyzed in the project documents are on the less dense end of the spectrum for diluted
bitumen. Once the project oils are better defined and their properties understood, additional modeling would be useful for
higher density diluted bitumen formals.
14
The three classes of oil tankers anticipated to service Kitimat Terminal are Aframax, Suezmax, and Very Large Crude
Carriers (VLCCs). A VLCC carries in excess of 318,000 m3. If a single VLCC foundered and completely voided its tanks, the
resulting spill would approach 50% of the estimated size to the Deepwater Horizon spill. The worst possible spill would be a
collision of a VLCC and another laden tanker, causing one or both vessels to founder. However, the probability of such a
spill is very small compared to less serious spill. Applying the U.S. Coast Guard measurement that the worst probable spill is
10% of the worst possible spill, the worst probable Northern Gateway spill is considerably in excess of 31,800 m3. The
3
smaller 10,000 m spill was selected to represent a more probable spill size, while still being large enough to illustrate the
scale of response required for a major marine oil spill.

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Environmental Conditions
Table 3.1 summarizes the environmental conditions that were applied, based on the observation data compiled
and described in the Response Gap Analysis portion of this report. These wind speed estimates represent
averages for the warmest and coldest sea surface temperature months at weather buoys for the two
representative locations (Nanakwa Shoals for CCAA/protected water and Dixon Entrance for OWA/open water).
Wind variability is not accounted for in the ROC; all wind speeds are presumed to be constant. Sea surface
temperatures were chosen to simulate realistic extremes for very warm and very cold sea surface
temperatures. They were derived from data for peak high and low sea surface temperatures from 1991 to 2012
(Gramann, 2012 and Appendix C to this report).
Table 3.1. Environmental Conditions Applied for Summer and Winter Simulations at OWA and CCAA
Environmental
Conditions
CCAA Summer
CCAA Winter
OWA Summer
OWA Winter
Winds
8 kph (2.22 m/s)
8 kph (2.22 m/s)
11 kph (3.05 m/s)
11 kph (3.05 m/s)
Sea Surface
Temperature

17C
3C
15C
6C
3.2.3 Operational Planning Parameters

Deployment and Mobilization Times
The simulation presumes that all oil spill response resources arrive on-scene simultaneously. Transit times of 8
hours for the CCAA and 12 hours for OWA are used. These times incorporate spill notification, dispatch,
mobilization and transport equipment and personnel to staging areas (spill response hubs), transit to spill the
area, and on-scene equipment set-up for recovery operations. This is an optimistic assumption. The average
transit speed for OSRV is 16.7 kph (9 knots), and the maximum speed is 22.2 kph (12 knots). Transit distances
from major ports where spill response resources might be located to potential spill sites may very long,
approaching 500km (See Table 3.2 and Figure 3.1).
Our analysis assumes that a full complement of spill response equipment, vessels, and personnel would be at
ready status near enough to each of the representative spill sites to facilitate rapid mobilization and
deployment. Additional time would be required to recall crew and prepare equipment, for non-dedicated
forces.
US Coast Guard planning parameters for mobilizing response resources, used for these assumptions, are:
1 hour for owned,15 dedicated16 resources in ready state17

2 hours for owned, dedicated resources in callback state18
1.5 hours for contracted,19 dedicated resources in ready state
2.5 hours for contracted, dedicated resources in callback state

15
Equipment owned by and personnel employed by operator.

Equipment and personnel can be immediately released to spill, not employed or used in other operating capacity.
17
Equipment or personnel stored/housed onsite at spill response hub and ready for immediate deployment.
18
Equipment or personnel on notification or standby status.
19
Dedicated contractual access to equipment and personnel.
16
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2.5 hour for owned,20 non-dedicated21 resources in ready state22

3.5 hours for owned, non-dedicated resources in callback state23
3 hours for contracted, non-dedicated resources in ready state
4 hours for contracted, non-dedicated resources in callback state

Table 3.2 Transit Times to Potential Spill Sites from Potential Oil Spill Response Hubs
Potential Spill Site
Approximate Distance (km) from

Spill Response Hub
Transit time (hrs) at 16.7 kph
Transit time (hrs) at 22.2 kph
Kitimat
Prince
Rupert
Shear-
water
Kitimat
Prince
Rupert
Shear-
water
Kitimat
Prince
Rupert
Shear-
water
Kitimat Terminal
215
245
12.9
14.7
9.7
11.0
Wright Sound Nexus
105
155
175
6.3
9.3
10.5
4.7
7.0
7.9
Browning Entrance
205
140
290
12.3
8.4
17.4
9.2
6.3
13.1
Camano Entrance
155
205
160
9.3
12.3
9.6
7.0
9.2
7.2
Learmonth Bank
425
190
490
25.5
11.4
29.4
19.1
8.6
22.1
Forrester Island
460
225
525
27.6
13.5
31.5
20.7
10.1
23.6
Haida Tip
295
330
200
17.7
19.8
12.0
13.3
14.9
9.0
Far South Rocks
375
460
200
22.5
27.6
12.0
16.9
20.7
9.0

Figure 3.1 Map Showing Location of Potential Spill Sites and Spill Response Hubs in Northern Gateway Tanker
Region

20
Equipment owned by and personnel employed by operator.

Equipment or personnel may be employed/used in other operational function that would need to be suspended in order
to deploy to spill.
22
Equipment or personnel stored/housed onsite at spill response hub and ready for immediate deployment.
23
Equipment or personnel on notification or standby status.
21
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Work Day
Operational periods for each simulation were adjusted based on the duration of daylight expected in summer
and winter.
For winter simulations, the winter daylight period is 7:23. This is rounded to 7:30, and one hour is
added to account for civil twilight periods. The total operations period is 8 hours 30 minutes.
For summer simulations, the summer daylight period is 17:06. This is rounded to 17:00, and one hour is
added to account for civil twilight. The total operations period is 18 hours.
Spill occurrence times and work periods are adjusted so that recovery forces arrive and begin recovering oil at
civil twilight (pre-dawn), giving them the entire first daytime work period to recover oil. No penalties for low
visibility are applied to civil twilight recovery operations.
Each simulation is run for 72 hours from the time of spill occurrence. Therefore, response forces impact the first
72 hours of the spill. This is intended to coincide with the critical 72-hour response window, during which
recovery is usually highest. Functionally, this results in a series of spill simulations that contain a transit period
(8 or 12 hours) followed by 2-3 daytime working periods, separated by night periods, during which no recovery
occurs.
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3.2.4 Spill Response Systems
The spill response systems used in the ROC simulations is based on an open water task force24 (OWTF) as
defined in various standard oil spill response manuals. Open water task forces (OWTF) are assumed to able to
operate in both spill environments (OWA and CCAA), but have limited access to near-shore shallow areas. While
the OWA and CCAA spill sites represent different operating limits, the type of on-water recovery equipment
commonly used for open water response can be applied in either environment, because the CCAA has sufficient
water depth to support open water response vessels.
Each system is comprised of equipment and vessels considered to be standard available technology based on
the authors experience in oil spill planning and response and a review of standard oil spill response manuals
(SERVS 2011, ADEC 2006). While four different general oil types are proposed for transport through the NG
system, the open-water task force elements were developed based on the need for high viscosity oil recovery
capability, to provide the ability to recover diluted bitumen.25 Skimming resources with high-viscosity recovery
capability can be easily modified to recover the less viscous oil products, which would also be transported.
3.2.4.1 Vessels
The open water task force used for this simulation is modeled on the Marine Spill Response Corporation
(MSRC)26 Oil Spill Response Vessel (OSRV). OSRVs are purpose-built vessels capable of acting as self-contained
oil recovery task forces. A typical OSRV is over 60m in length, and draws approximately 5m of water, limiting its
ability to operate in shallow areas. OSRVs are equipped with high-volume internal storage (635 m3 or 4,000 bbl)
and skimming equipment, and carry an on-board workboat, which acts as a boom-handling boat. OSRVs are
equipped for long-term recovery operations, have large crews (30+ people), have potential aviation support
capability (helipads), and represent standard, available technology for oil spill response. MSRC OSRVs have a
cruising speed of 8-9 knots (4-4.6 m/s) and top speed of 12 knots (6.1 m/s). OSRVs typically use a J-
configuration with their open water boom and workboat, to collect oil (See Figure 3.2). Although the
simulations in this study rely on an OSRV-based force, other task force configurations, not based on purpose-
built vessels, could be substituted. Substitution of vessels of opportunity or retrofitted vessels could impact
efficiency estimates.
3.2.4.2 Skimmers
The simulated OWTFs use the FRAMO Transrec 150 skimming system.27 The Transrec 150 system is a complete,
self-contained unit that could be deployed from an OSRV, and requires a single dedicated operator to run the
skimming system. This skimmer has three types of skimmers: a weir head, a high viscosity oil recovery head,
and a brush recovery head intended for arctic response where sea ice is present (Figure 3.2).

24
A Task Force (TF) is a typical building block for on-water oil spill tactical response. The term task force, when used in the
context of oil spill response, refers to a group of resources with common communications and a leader assembled for a
specific mission.
25
There is very little field or laboratory data regarding skimmer recovery rates for diluted bitumen projects. This is an area
that would benefit from further study.
26
MSRC is a major U.S. oil spill response organization with a significant on-water cleanup capacity. http://www.msrc.org/
27
While the typical MSRC OSRV utilizes a FRAMO TransRec 350 high capacity skimming system, The FRAMO TransRec 150 is
recommend for application in this area due to the availability of the HiVisc 150 Skimmer, which is designed to recover
higher viscosity oils (>10,000 cST) than the TransRec 350 is capable of recovering. An annular water injection system is also
included in this system to aid in high viscosity oil flow through the system during skimming operations.
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The weir head is designed to recover low to medium viscosity oils (up to 15,000 cST). The high viscosity (HiVisc)
oil recovery head is intended for heavier oils, with a viscosity range from 10,000 cST to 1,000,000 cST.
Performance can be expected to vary depending on oil properties.
MKH, CLB, and other diluted bitumen blends are expected to reach very high viscosities during a spill. According
to NG submission documents, one of the tested project oils (Mackay Heavy Bitumen) may reach viscosities of
15,000 cST (15,000 cP) within 24 hours of a marine spill and exceed 52,000 cST within 48 hours (SL Ross 2010a
and 2010b). For at least the first 48 hours of a projected diluted bitumen spill, the HiVisc skimmer head would
likely be an appropriate recovery technology. Longer timeframes or more viscious initial oils could result in oil-
water emulsions with viscosities exceeding 100,000 cST, the most viscous oil the HiVisc head is rated to skim.
The weir skimmer head would not be appropriate for the diluted bitumen blends, but would likely be more
appropriate technology for a synthetic crude oil.
3.4.2.3 Oil Containment Boom
Open water recovery systems typically rely on ocean boom. The MSRC OSRV system utilized Sea Sentry II boom,
and the same boom was applied to this simulation. Sea Sentry II boom is approximately 170cm in total height,
with approximately 58cm freeboard (boom floating above the water surface) and 112 cm skirt (boom hanging
below the water surface). This type of ocean boom is inflatable, and part of the system includes a power pack
and air blower to inflate the boom as it comes off the reel where it is stored. Each modeled OSRV is equipped
with a total of 201m of boom onboard, stored in 6 sections of 33.5m each. Each 33.5m section weighs
approximately 425kg.
3.4.2.4 Other Equipment
Pumps and other auxiliary equipment required to support OWTF operations were assumed to be industry
standard. Pumps were selected provide sufficient size and capacity to support skimmer nameplate recovery
capacity and aggressive free water decanting. High capacity offloading pumps were selected to achieve a four
hour target for offloading oil and water to secondary storage, including setup and breakdown.

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Figure 3.2 Examples of Open Water Task Force Configuration and Equipment

Example of OSRV recovering oil (Source: MSRC)
J-booming configuration (Source: ADEC, 2007)

TransRec 150 Skimmer (Source: FRAMO, 2012)

MSRC OSRV towing Sea Sentry II boom (Source: MSRC,
2012)

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3.2.5 Equipment and Recovery Specifications

Numerical specifications were applied to simulated OWTFs, to establish how the task forces would operate on-
water. The following assumptions were applied based on the authors best professional judgment,
manufacturer specifications, and experience with actual on-water oil spill recovery operations.
Speed
Vessel speed over water was set to 0.33 m/s (0.75 mph) for oil recovery operations. This speed is used because
once vessels advance at speeds higher than 0.44 m/s (1.0 mph), oil will begin to entrain under booms. The
chosen speed (0.33 m/s) is a credible speed for a response vessel to maintain during on-water recovery
operations.
Decanting
On-water skimming does not recovers 100% oil. In the environment, water and oil mix together to form what is
known as an oil-water emulsion.28 The proportions of oil and water which form the emulsion vary with oil type,
environemental conditions, and time. The emulsion cannot be separated into oil and water components by
response forces, and must be stored as-is.
Additional water is unintentionally skimmed along with the oil-water emulsion. This water, known as free
water, is not bound with the oil. Decanting systems selectively remove this free water from storage tanks and
return it to the environment, liberating more storage capacity for oil-water emulsion. The decant system
consists of a pump and a plumbing system which uptakes free water from the storage tank(s) and pours it
overboard.
Percentage decanted is set to 80% for the simulated OWTFs, meaning that 80% of the free water recovered by
the skimmer is successfully decanted out of the vessels storage tanks and returned to the environment. 20% of
the free water is not decanted, and must be transferred to secondary storage with the recovered oil and oil-
water emulsion. This is to reflect that fact that in real operations, not all free water is successfully decanted
from primary storage.
Decant pump rate controls the speed of decanting in ROC. The decant pump rate is set to 340 m3/hr, which is
80% of the nameplate rate for the skimmer. This rate allows the decant pump to keep pace with the skimmer in
the simulation, decanting free water as fast as it is recovered.
Swath width
Swath width is the width of area with the containment boom along which floating oil is swept. A standard
convention for calculating oil spill recovery efficiency is to assign swath width as 1/3 of the total boom length.
Therefore, for the OSRV-based OWTF, which carries 201m (660 ft) of boom, swath width would be 36.5m (120
ft). Swath width is sometimes also called boom sweep or sweep width. Based on past recovery operations,
36.5m is a reasonable swath width to maintain under favorable conditions.
Onboard Storage
Onboard storage refers to the quantity of recovered liquids that can be stored aboard the recovery vessel. The
OWTF has 635 m3 (4,000 bbl) onboard storage. Once this tank becomes full, recovered oil must be offloaded

28
Throughout this document, on-water recovery of oil is referred to. Technically, much of the oil encountered and
recovered is in the form of an oil-water emulsion. Oil is used as a abbreviated term for both on-water oil and on-water
oil-water emulsion.
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into another storage device, such as a barge or shore tank. Onboard storage is also sometimes referred to as
primary storage.
Nameplate Capacity
The nameplate skimmer recovery rate, or nameplate capacity, describes the maximum rate at which the
skimmer can theoretically skim oil. This is the maximum possible rate for the TransRec 150 weir head, identified
by the manufacturer. For late-stage skimming on synthetic crude spills and all skimming on diluted bitumen
spills, the TransRec 150s high viscosity recovery head will be necessary. The HiVisc head is expected to have a
substantially reduced nameplate rate, due the mechanical complexity of its viscous oil-cutting operation.
However, the manufacturer does not provide a nameplate rate. For this reason, the nameplate rate of the weir
head (400 m3 /hr) is applied to the HiVisc head for the open water simulations.
Discharge Pump Rate
The simulated OWTF is equipped with a very high capacity discharge pump capable of moving 1000 m3/hr for
offloading of recovered fluid to secondary storage.
Offload Time
Offloading time is the amount of time OWTFs must spend offloading their recovered fluids to secondary storage.
During offloading, the task force cannot engage in oil recovery operations. No oil is recovered during these
offloading periods. Oil spill response operations frequently have more recovery task forces than they have
secondary storage vessels, and must stagger their offloading periods to minimize recovery losses which result
from being serviced by a limited number of secondary storage vessels. In this simulation, unlimited secondary
storage is assigned to each OWTF, so there is no staggering of offloading periods. A 4-hour offload time is
achieved, which is credible based on the high-capacity pumps that are presumed to be in place for oil recovery
vessels. Offload rate can be calculated as (onboard storage volume)/(pump rate) + (1 hr for protected waters)
or (2 hours for open waters) (Washington State OSAC 2009).
Transit Time
Transit time captures the amount of time needed for a recovery vessel to rendezvous with a secondary storage
vessel or facility in order to offload recovered product. A barge and tugboat are assumed to shadow each
OWTF, providing dedicated on-scene storage, which results in a transit time value of zero. This is an optimistic
assumption and will require a sufficient number of empty barges to be available to support each on-water task
force. All barges (and associated tugboats) required to support offloading are presumed to be on-scene before
OSRV primary storage fills, so that there is no delay in secondary storage availability.
Throughput Efficiency
Throughput efficiency indicates the amount of oil recovered, versus the amount of oil encountered. Throughput
efficiency represents the fact that oil skimming equipment cannot recover 100% of the oil it encounters due to a
variety of limitations, the most significant being (1) loss of oil by the containment system, and (2) variations in
the thickness and concentration of the oil slick. ROC utilizes a user-set value as a baseline for throughput
efficiency, but modifies it if the model indicates the recovery system is encountering more oil than it is capable
of recovering. Throughput efficiency was set to 75% for all simulations, which means that of the total volume of
oil encountered by the on-water recovery system (boom and skimming system), 75% is removed.
Recovery Efficiency
ROC de-rates the nameplate efficiency of skimmer systems according to a recovery efficiency value, to reflect
the fact that most skimmers recover large volumes of free water along with oil-water emulsion. Recovery
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efficiency for the HiVisc and wier skimmer heads is set to 20% in the simulations. This is a realistic recovery rate
for weir-type skimmers.
Table 3.3 summarizes all equipment and recovery specifications applied to the simulation.
Table 3.3 Summary of equipment and recovery specifications used in ROC simulations
Specification
OWTF
Vessel(s)
1-63m OSRV; 1-10m support boat
Skimmer(s)
1-TransRec 150 skimmer
Speed
0.33 m/s (0.75 mph)
Decant Efficiency
80%
Boom type and amount
Sea Sentry II (170cm) 201 m
Swath width
36.5m (120 ft)
Onboard Storage
635 m3
Nameplate Capacity
400 m3/hr
Decanting Rate
340 m3/hr
Discharge Pump Rate
1000 m3/hr
Offload Time
4 hours (with 0 hours for offload transits)
Start/End Times and

Work Day Length
8 hrs 30 min (winter); 18 hrs (summer)
Throughput Efficiency
75%
Recovery Efficiency
20%
3.3 Outputs from Response Options Calculator Simulations

The oil spill recovery task force elements described in Section 3.2.3 were inputted into the Response Options
Calculator (ROC) and the outputs that the ROC yielded described the recovery capacity for a single task force at
each location for each season. The ROC output is expressed as the volume of oil recovered, evaporated, and
remaining in the environment at 24-hour intervals (24, 48, and 72 hours). Appendix A summarizes the recovery
capacity outputs (mass balance) for each simulation. Section 3.4 provides detailed ROC outputs for two example
scenarios.
3.3.1 72-hour Recovery Estimates
Table 3.4 summarizes recovery system performance for all 16 spill simulations, for a 72-hour period beginning at
the spill occurrence. Numbers are rounded to the nearest tenth. The column labeled % of 72 hrs identifies
the amount of time during the initial 72 hours of the spill response during which oil recovery operations actually
take place (no recovery happens during transit to the spill, darkness, or offloading periods). Summer and winter
day lengths are based on solstice periods (the longest and shortest day lengths, respectively). The Number of
Fills identifies the number of times the recovery vessel must offload to a secondary storage device.
Of the four subject oils modeled in the ROC, Syncrude was the most easily recovered oil, in terms of recovery
rate of oil as a fraction of remaining surface oil after 72 hours. The Syncrude characterized by SL Ross (2010 a
and 2010b) demonstrates a very high natural dispersion rate in the ROC simulation, substantially higher that
crude oils or the other modeled synthetic crude. This creates a high rate of recovery, as a percentage of surface
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oil, since an unusually large fraction of oil disperses naturally. SL Rosss report did not establish criteria for
sample selection.
Alberta SMB was selected for this study as a possible alternate light hydrocarbon to Syncrude, with different
characteristics. Alberta SMB does not exhibit the very high dispersion rate of the Syncrude.
Interpretation of diluted bitumen results is complicated by the potential for oil submergence, which ROC does
not account for, the recovery challenges of very high viscosity oil, and the generally poor characterization of
diluted bitumens both in terms of modeling properties and their real-world behavior when spilled.
Cold Lake Bitumen, MacKay Heavy Bitumen, and Alberta SMB all formed stable oil-water emulsions in the ROC
simulations. These three oils reached water percentages of 59% to 81% in all scenarios. These emulsion levels
were frequently achieved in less than 72 hours. Syncrude did not form stable emulsions with water in ROC,
which contributes to its high estimated rate of recovery. Maximum water content of the emulsions is listed in
Appendix A.
Bulk recovery rates across all 16 simulations vary by a factor of slightly more than 2, suggesting general
agreement.

Table 3.4. Summary of Recovery System Performance for All Simulations Based on ROC Outputs
Simulations
Time collecting
% of
72hrs
Oil Recovered
Emulsion Recovered
# of Fills
MHB OWA Summer
27.1 hours
38%
714 m3
2120 m3
MHB OWA Winter

MHB CCAA Summer
MHB CCAA Winter
CLB OWA Summer
CLB OWA Winter
CLB CCAA Summer
CLB CCAA Winter
ASMB OWA Summer
ASMB OWA Winter
ASMB CCAA Summer
ASMB CCAA Winter
SYN OWA Summer
SYN OWA Winter
SYN CCAA Summer
SYN CCAA Winter
13.8 hours
36 hours
19 hours
28 hours
14.6 hours
36 hours
19 hours
29.7 hours
17.2 hours
44 hours
21.5 hours
44 hours
21.5 hours
44.5 hours
24.4 hours
19%
50%
26%
39%
20%
50%
26%
41%
24%
61%
30%
61%
30%
62%
34%
457 m
3
810 m
3
570 m
3
731 m
3
461 m
3
810 m
3
523 m
3
675 m
3
492 m
3
461 m
3
387 m
3
695 m
3
421 m
3
802 m
3
537 m
4.5
1073 m
1581 m
3
985 m
2.8
5.9
4.5
2092 m
1073 m
1581 m
3
948 m
2.7
1778 m
1066 m
3
2.3
1.4
1.2
2.3
1.5
809 m
503 m
695 m
421 m
802 m
537 m
3.3.2 Task Force Requirements to Recover 10,000 m3 spill in 72 hours

Based on the ROC model outputs for the 16 simulations, the number of task forces required to contain and
recover a 10,000 m3 spill under idealized conditions within 72 hours is between 8 and 20. This extrapolation was
performed by comparing recovery performance of the modeled OWTF to the remaining surface oil after 72
hours, as calculated by ROC. Figure 3.3 summarizes the calculations used to derive these estimates. The
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number of task forces required is dependent upon spill location, season, and type of oil. In general, more forces
are required for an OWA spill than for a CCAA spill, due in part to the longer transits to the spill. Likewise, winter
spills require additional task forces to achieve the necessary recovery rates because they have shorter operating
periods due to reduced daylight.
These scenarios all presume sufficient oil storage barges (secondary storage) will be available to offload all task
forces, as needed, on demand and on-site. In reality, development and deployment of secondary storage
capacity will require significant resources. Oil storage barges range in size (oil storage capacity) from 19m3 micro
barges to those that can carry more than 7,950 m3. Common mid-range oil storage barges that can be utilized as
secondary storage include 1, 590 m3, 3,180 m3 and 4,770 m3. Larger storage barges require larger support tugs
and will be restricted to operating in deeper water due to increased draft. In order to meet the recovery
requirements for these 16 simulations, a 1:1 ratio of task force to storage barge would be required, meaning
that as many as 20 storage barges (of at least 500 m3 each) would need to be on stand-by to support the target
recovery rates (to support the MHB OWA winter simulation). The minimum number of storage barges needed
to support these simulations would be 8 (for the SYN CCAA summer simulation), but each barge would be
required to have a capacity of at least 1250 m3.29
Table 3.5 estimates the task forces required to respond to a 10,000 m3 spill of each of the four representative
oils at the two locations, in summer and winter. This estimate describes the minimum force to achieve the
projected response capacity.
Figure 3.3. Calculations and conversions used to derive 72-hour task force needs from ROC outputs
Estimated total OWTF required to collect spill =

Mass balance for 72 hrs (Total spill size evaporated amount amount recovered by 1 task
force)/(72-hour oil recovered by 1 OWTF) + 1

Example calculation: CLB OWA Winter Simulation
(10,000 m3 2020 m3 461 m3)/461 m3 + 1 =
7519 m3/461 m3 + 1 =
16.3 + 1 = 17.3
17.3 is rounded up to 18 because partial task forces do not exist.

29
Capacity calculated by dividing spill size (10,000 m3) by number of barges.
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Table 3.5. Task Force Requirements for Sixteen Simulated Oil Spills (10,000 m3) Under Ideal Conditions as
Calculated using ROC
Simulation
Number of
Open Water
Task Forces
(OWTF)
MHB OWA Summer
13
MHB OWA Winter
20
MHB CCAA Summer
11
MHB CCAA Winter
16
CLB OWA Summer
11
CLB OWA Winter
18
CLB CCAA Summer
10
CLB CCAA Winter
16
ASMB OWA Summer
11
ASMB OWA Winter
15
ASMB CCAA Summer
16
ASMB CCAA Winter
19
SYN OWA Summer
SYN OWA Winter
14
SYN CCAA Summer
SYN CCAA Winter
11

Note: Each OWTF
consists of:
*1 OSRV with
integrated high-
capacity skimming
system (400 m3/hr)
*crew of 30+ people
3
*635 m onboard
storage
*1-2 support vessels;
*201m of ocean
boom;
*discharge pump
capable of 1000
m3/hr;
*decanting pump
capable of 340 m3/hr

3.4 Detailed Simulation Discussion
Of the 16 simulations (10,000 m3 spills) run using the ROC, we have provided a more detailed discussion and
analysis of specific factors for one simulation: Cold Lake Bitumen, Dixon Entrance (OWA), winter. This spill
reflects one of the more challenging sets of conditions based on product, seasonality and geographic location.
Winter conditions in Dixon Entrance often preclude oil spill response operations altogether, as described in Part
2 (RGA). During times when a response would be feasible (approximately 32% of the time during fall/winter
months), as few as 8.5 hours of daylight and civil twilight are available for recovery operations. If a Dixon
Entrance spill were to occur at Learmonth Bank (Figure 3.1), the transit distance from Prince Rupert, the nearest
large sea and airport, is 190 km (See Table 3.2).
A Learmonth Bank spill scenario illustrates how the 12-hour deployment assumption applied to all simulations is
extremely optimistic. Given an average OSRV transit speed of 16.7 kph and assuming that a sufficient cache of
response resources was available in Prince Rupert, transit time alone for all of the required response resources
would be 11.3 hours. Adding in one hour each for mobilization and on-scene set-up, which presumes that forces
30
are owned by the operator, dedicated and in ready mode, the earliest timeframe for task forces to begin

30
See Section 3.2.3 for discussion of US Coast guard mobilization planning guidelines.
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collecting oil is roughly 13 hours. Pushing OSRV speeds towards maximum transit speeds (22.2 kph) makes the
12-hour goal possible, but only under ideal navigational conditions.
Figure 3.4 shows mass balance output from the ROC for a Cold Lake Bitumen spill at Dixon Entrance in Winter
for a single Open Water Task Force assuming optimal recovery conditions (12 hour deployment time and no
efficiency loss, with all other winter simulation assumptions in place). Table 3.8 summarizes recovery
operations for the single OWTF. Extrapolation of the ROC output in Table 3.6 shows that 18 OWTFs, plus
secondary storage and support assets, would be required to recover all surface oil for the 10,000 m3 spill in 72
hours.
Figure 3.4 Recovery Mass Balance Estimate for CLB OWA Winter Simulation (For One OWTF)

Table 3.6 Recovery Performance of a single OWTF in CLB OWA Winter Simulation
Time Recovering Oil, total:
14.63 hours
Oil Recovered:
461 m3
Oil/Water Emulsion Recovered:
1073 m3
Water Content (%) of the Emulsion at 24 hrs:
61%
Free Water Recovered
4293 m3
Free Water Retained
859 m3
Offloading Cycles
3.04
Area Covered
65 ha
Surface Oil Remaining
7519 m3
Evaporation
2020 m3

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Figure 3.5 shows the ROC slick thickness output for the CLB OWA winter simulation. The slick thickness for this
simulation attenuates according a pattern that we observed to be typical for most of the simulations, though it
is retarded by high viscosities. By 72 hours, the area of spill slick coverage is expected to exceed 40 square
kilometers. ADIOS predicts that slick thickness, at the thickest point, will be less than a quarter-centimeter,
inhibiting recovery efforts. It is possible given the very high viscosities of bitumens that the cohesion and
clumpiness of the oil is underestimated by the model.
Figure 3.6 shows the water content of the water-oil emulsion formed as the spill weathers. The oil rapidly
emulsifies. Within 24 hours, the oil forms an emulsion with 61% water content. ROC predicts this will be the
maximum water content, and the emulsion remains stable throughout the following 48 hours. Emulsions with
high water content have increased volume, requiring more storage than pure oil or emulsions with lower water-
to-oil ratios, and exhibit different behavioral properties than non-emulsified oil.
Figure 3.7 shows the viscosity changes. Within the simulation, oil viscosities exceed 80,000 cSt within a day, and
approach 115,000 cSt within 72 hours, exceeding the specified capabilities of the HiVisc skimmer head, and
possibly halting skimming operations. This is a steeper viscosity increase, with a slightly higher (extrapolated)
120 hour viscosity, than SL Ross predicted for an October spill of MKH in their analysis (2010a and 2010b).
The high viscosity of the CLB in this simulation supports earlier recommendations that on-water response
systems utilize high viscosity skimmer heads. For this simulation, the spill response equipment must be
sufficient to handle oil viscosities approaching or exceeding 100,000 cSt. Based upon the known oil properties,
adhesion will probably be high. If the spill were to impact shoreline areas, the oil would be expected to entrain
sediment and may achieve densities higher than seawater.
Figure 3.8 shows the evaporation curve. By 72 hours, the majority of volatiles have evaporated from the
simulated oil. Further evaporative loss will not be significant. Oil that remains in the environment would likely
be persistent, either stranding on shores, remaining at the water surface, or submerging.
Figure 3.5. 72-hour Oil Thickness Output from CLB OWA Winter Simulation Spill (10,000 m3)

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Figure 3.6. 72-hour Water Content in Emulsion from CLB OWA Winter Simulation Spill (10,000 m3)

Figure 3.7. 72-hour Oil Viscosity Output from CLB OWA Winter Simulation Spill (10,000 m3)

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Figure 3.8. 72-hour Oil Evaporation Output from CLB OWA Winter Simulation Spill (10,000 m3)
3.5 Adjustment of Recovery Capacity Estimates based on Transit Times

One of the factors that could significantly impact the estimated response capacity is the lag time required for
vessels and equipment to transit from staging areas to the spill site. The 8 and 12-hour assumptions are not
realistic for all potential spill sites. As shown above, in Figure 3.1 and Table 3.2, some potential spills sites would
require 30 hours or more transit time for an OWTF traveling at typical speeds.
To gain some insight into the impact of delayed arrival times, additional simulations were run through the ROC,
with task forces arriving at staggered times and often realizing only part of established work periods. To
quantify this temporal adjustment, it was assumed that response forces will arrive with an equal average
distribution throughout the 24-hour day. Based on day and night lengths, the probabilities of a day or night
arrival are determined. Each of these probabilities is multiplied by the averaged day/night arrival time which
equals half the length of the day or night. Finally, the outcomes are added to transit time (in the case of a night
time arrival), or subtracted from the first work shift (in the case of day arrival).
The net effect of the temporal adjustment is to reduce and redistribute the time available for recovery
operations. While any given task force will arrive at a discrete time, with a discrete adjustment, the average of
these is amortized over the entire force creating an approximation of the total time lost. A set of ROC runs
was conducted, incorporating these temporal adjustments. The outputs showed that in the 72-hour timeframe
for a CCAA spill, the quantity of oil recovered was reduced by roughly 25%. For an OWA spill, the 72-hour
quantity of oil recovered was reduced by roughly 40%.
The temporal adjustments emphasize the importance of quickly mobilizing response resources to the scene in
order to maximize recovery during the critical early stages of a spill. One way to address these efficiency losses
would be to increase the total number of task forces. Based on the same method used to calculate task force
needs, we estimated that an increase of 20% to task force sizes would be required to make up for the temporal
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adjustment for a CCAA spill, and 70% more task forces would be needed to address the 72-hour shortfall in the
OWA.31
Once the Northern Gateway on-water response system is described more completely, it will be possible to
estimate response capacity using known equipment storage locations, transit times, and recovery rates.
Eventually, functional exercises where equipment is deployed and tested under real-world conditions will
further refine the estimated capacity for on-water spill response along the Northern Gateway tanker routes.

31
Instead of 8-20 OWTFs, 10-34 OWTFs would be required to meet the recovery goal.
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Part 4. Conclusion
This study set out to analyze the capabilities and limitations of on-water mechanical oil spill response
(containment, recovery and removal of oil) in two areas along the potential vessel routes associated with the
Northern Gateway project. The methodology layered two related analyses in an attempt to provide additional
insight into how effective existing on-water spill recovery systems might be in cleaning up an oil spill from a
Northern Gateway tanker.
In order for any oil spill response to be conducted, the vessels, equipment and people involved in the response
must be able to safely and effectively deploy spill recovery systems. Existing oil spill cleanup equipment is
subject to operating limits which are tied to various environmental and on-scene conditions. This study looked
at four operating limits wind, sea state, temperature, and daylight and estimated the percentage of time that
one or more of these factors (or some combination of factors) would exceed established operating limits and
thus preclude on-water oil recovery. The results of this analysis estimate the response gap for a representative
OWA site Dixon Entrance found that the response gap (period of time during which no response would be
possible based on environmental factors) was 45% overall. The response gap for Dixon Entrance in the
fall/winter was significantly higher (68%) than for the spring/summer (25%). The response gap for a
representative CCAA site Nanakwa Shoals was estimated to be 7% overall, with fall/winter significantly
higher (14%) than spring summer (less than 1%).
A response gap analysis is only an estimate, but it helps to create realistic expectations about the opportunity to
conduct on-water oil spill recovery operations. The response gap analysis confirms that oil spill recovery is more
likely to be precluded during winter months, and that conditions which would preclude recovery occur more
frequently in the open water area. The 68% response gap for Dixon Entrance in the winter does not reflect all
environmental conditions, only those for which datasets were available. This figure is important because it
begins to set the stage for a true worst case scenario. If a Northern Gateway tanker spilled oil in Dixon
Entrance, during the winter months, no response would be possible for more than 2/3 of the time.
While the response gap analysis considers the opportunity or possibility for oil spill response, the second
analysis the response capacity analysis estimates the potential effectiveness of oil spill recovery systems in
the two operating areas during times when a response is possible, and estimates the amount of resources that
would be needed to recover a 10,000 m3 spill within 72 hours of the release.
During the 32% of time that response would be feasible for a winter spill at Dixon Entrance, the estimated
number of open water task forces required to contain and recover 100% of the oil in 72 hours, under favorable
conditions, is as much as 20 for a 10,000 m3 diluted bitumen spill and 14 for a 10,000 m3 synthetic crude oil spill.
Each open water task force consists of a large purpose-built oil spill recovery vessel with integrated skimming
capacity of 400 m3/hr and storage for 635 m3 of recovered oil, as well as 1-2 workboats, 200m of ocean boom,
and up to 38 crewmembers. Multiplying such a task force by 14 or 20 requires a spill response capacity that
does not presently exist in Western Canada.
Real-world limitations to spill recovery effectiveness would likely reduce the estimated efficiencies derived from
the ROC simulations. Factors that could reduce efficiency include slick spreading and thickness, delays in arrival
time for response resources, environmental limits to effectiveness, potential for submerged oil, and logistical
support constraints. Throughout this report, secondary containment was frequently discussed as a limiting
factor to spill response, because adequate empty tankage is rarely available immediately to support on-water
recovery. Without adequate storage for recovered oil and water, response operations can quickly grind to a halt
and the window of opportunity for oil recovery can be lost.
Page 53 of 62
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Once the operating parameters for Northern Gateway tankers are established and a marine oil spill response
system established to support tanker operations, it will be possible to more precisely estimate the response gap
and determine the on-water recovery capacity for spills from Northern Gateway tankers.

Page 54 of 62
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Part 5. References
Alaska Department of Environmental Conservation (ADEC). 2006. Spill Tactics for Alaska Responders (STAR)
Manual. http://dec.alaska.gov/spar/perp/star/docs.htm
American Society for Testing and Materials (ASTM). 2003. Standard Practice for Classifying Water Bodies for Spill
Control Systems. F625-94.
Department of Fisheries and Oceans. 2012. Wave Height Data Search. http://www.meds-sdmm.dfo-
mpo.gc.ca/isdm-gdsi/waves-vagues/search-recherche/index-eng.asp. Accessed May June 2012.
Det Norske Veritas (DNV). 2010. Marine Shipping Quantitative Risk Analysis: Enbridge Northern Gateway
Project. Technical Data Report to Joint Review Panel.
FrankMohn AS Environmental Products (FRAMO). 2011. FRAMO TransRec 150 Oil Recovery and Transfer System
Technical
Description.

Revision
B,
dated
10/6/2011.
http://www.opecsystems.com.au/files/Technical_Spec_TransRec_150.pdf
Genwest Systems, Inc. 2012. Response Options Calculator (ROC). Online tool and Technical Manuals.
http://www.genwest.com/roc Accessed May-June 2012.
Gramann, U. 2012. Description of Available Meteorological Data for Evaluation of Enbridge Northern Gateway
Pipeline Proposal. Mountain Weather Services.
Hay and Company Consultants (Hayco). 2011. Hydrocarbon Mass Balance Estimates: Inputs for Spill Response
Planning. Technical Data Report to Joint Review Panel.
International Maritime Organization (IMO). 2005. Regulation 21: Construction Requirements for Oil Tankers.
Moffatt and Nichol. 2007. Methanex Corporation Kitimat Marine Terminal Modifications, TERMPOL No. 3.15,
Environmental Risk Analysis.
National Oceanic and Atmospheric Administration. 2012. Automated Data Inquiry for Oil Spills (ADIOS) Tool.
http://response.restoration.noaa.gov/oil-and-chemical-spills/oil-spills/response-tools/adios.html Accessed May
2012.
National Research Council Canada. 2012. Sunrise/Sunset/Sun Angle Calculator. http://www.nrc-
cnrc.gc.ca/eng/services/hia/sunrise-sunset/angle-calculator.html. Accessed May June 2012.
NAV CANADA. 2001. The Weather of British Columbia. Ottawa, ON.
Nuka Research and Planning Group, LLC. 2006. Response Gap Methods. Report to Prince William Sound
Regional Citizens Advisory Council.
Nuka Research and Planning Group, LLC. 2007. Response Gap Estimate for Two Operating Areas in Prince
William Sound, Alaska. Report to Prince William Sound Regional Citizens Advisory Council.

Potter, S. (ed). 2004. World Catalog of Oil Spill Response Products. Ottawa, Ontario, Canada. SL Ross
Environmental Research Ltd. Eighth edition, 2004-2005.
Ship Escort/Response Vessel System (SERVS). 2011. Tactics Manual. Public review draft.
Page 55 of 62
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SL Ross Environmental Research, Ltd. 2010a. Properties and Fate of Hydrocarbons Associated with Hypothetical
Spills at the Marine Terminal and in the Confined Channel Assessment Area. Technical Data Report.
SL Ross Environmental Research, Ltd. 2010b. Properties and Fate of Hydrocarbons Associated with Hypothetical
Spills at the Marine Terminal and in the Open Water Area. Technical Data Report.
S.L. Ross Environmental Research Ltd. 2011. Spill Response Gap Study for the Canadian Beaufort Sea and the
Canadian Davis Strait. Report to the National Energy Board.
Terhune, K. 2011. Preliminary Mechanical Response Gap Analysis for the Enbridge Northern Gateway Project.
Living Oceans Society.

United States Environmental Protection Agency. 2011. EPA Response to Enbridge Pipeline Spill in Michigan.
Accessed November-December 2011, http://epa.gov/enbridgespill/documents.html

Washington State Oil Spill Advisory Council (OSAC). 2009. Assessment of Capacity in Washington State to
Respond to Large-Scale Marine Oil Spills. www.psp.wa.gov/downloads/OSAC/.../2009report_combined.pdf

Page 56 of 62
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Part 6. Appendices
Appendix A: ROC Output Summaries (Mass Balance) for 16 Simulations

Table A.1: Recovery capacity of a single NSTF for CCAA Summer Conditions
Oil
24 hours
48 hours
72 hours
Recovered Evaporated Remaining Recovered Evaporated Remaining Recovered Evaporated Remaining

(% water)
32

MKH
487 m
940 m
8573 m
713 m
1107 m
8180 m
832 m
(76%)
1312 m
7960 m
CLB
472 m3
1972 m3
7557 m3
695 m3
2035 m3
7270 m3
811 m3
(71%)
2078 m3
7112 m3
ASMB
273 m3
2997 m3
6731 m3
404 m3
3006 m3
6590 m3
461 m3
(70%)
3014 m3
6526 m3
SYN
474 m3
2546 m3
6775 m3
707 m3
2758 m3
5836 m3
802 m3
(0%)
2950 m3
4874 m3

Table A.2: Recovery capacity of a single NSTF for CCAA Winter Conditions
Oil
24 hours
48 hours
72 hours

(% water)
33

MKH
298 m3
675 m3
7766 m3
534 m3
887 m3
7443 m3
731 m3
(62%)
1015 m3
7208 m3
CLB
268 m3
1735 m3
7998 m3
429 m3
1944 m3
7627 m3
523 m3
(59%)
2002 m3
7475 m3
ASMB
295 m3
2861 m3
6844 m3
343 m3
2972 m3
6685 m3
387 m3
(67%)
2982 m3
6632 m3
SYN
353 m3
2547 m3
6896 m3
478 m3
2762 m3
6054 m3
537 m3
(0%)
2961 m3
5100 m3

32
33
Percentage of water in emulsion at hour 72.

Page 57 of 62
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Table A.3: Recovery capacity of a single OWTF for OWA Summer Conditions
Oil
24 hours
48 hours
72 hours

(% water)
34

MKH
311 m3
907 m3
8781 m3
538 m3
1074 m3
8387 m3
714 m3
(74%)
1165 m3
8118 m3
CLB
298 m3
1936 m3
7766 m3
534 m3
2023 m3
7443 m3
731 m3
(70%)
2061 m3
7208 m3
ASMB
356 m
2982 m
6633 m
552 m
3000 m
6414 m
676 m
(81%)
3004 m
6285 m
SYN
353 m3
2552 m3
6889 m3
573 m3
2766 m3
5955 m3
695 m3
(0%)
2961 m3
4956 m3
Table A.4: Recovery capacity of a single OWTF for OWA Winter Conditions
Oil
24 hours
48 hours
72 hours

(% water)
35

MKH
206 m3
726 m3
9067 m3
333 m3
947 m3
8720 m3
457 m3
(64%)
1069 m3
8474 m3
CLB
188 m3
1771 m3
8042 m3
326 m3
1977 m3
7697 m3
461 m3
(61%)
2020 m3
7519 m3
ASMB
292 m3
2899 m3
6790 m3
414 m3
2981 m3
6586 m3
492 m3
(80%)
2989 m3
6500 m3
SYN
286 m3
2552 m3
6956 m3
353 m3
2769 m3
6166 m3
403 m3
(0%)
2971 m3
5205 m3

34
35

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Appendix B. Acronyms and Abbreviations

ADEC
Alaska Department of Environmental Conservation
ADIOS
Automated Data Inquiry for Oil Spills
API
American Petroleum Institute
ASMB
Alberta Sweet Mixed Blend (synthetic crude oil)
ASTM
American Society for Testing and Materials
bbl
Barrel
BC
British Columbia
Celsius
CCAA
Confined Channel Assessment Area
CLB
Cold Lake Bitumen
cm
Centimeters
cP
Centipoise (viscosity unit of measure)
cST
Centistoke (viscosity unit of measure)
DFO
Department of Fisheries and Oceans
DNV
Det Norske Veritas
FRAMO
FrankMohn AS Environmental Products
FRV
Fast Response Vessel
ft
Feet
F/V
Fishing Vessel
GIS
Geographic Information System
GOSRP
General Oil Spill Response Plan
GRP
Geographic Response Plan
ha
hectare
HiVisc
High Viscosity
HQ
Headquarters
hr
Hour
HRO
Highly Reliable Organization
ICS
Incident Command System
IMO
International Maritime Organization
JRP
Joint Review Panel
kg
Kilograms
km
Kilometers
kph
Kilometers per hour
kts
Knots
LTF
Lightering Task Force

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m
3
Meter
Cubic meters
m/hr
Cubic meters per hour
MHB
MacKay Heavy Bitumen
mph
Miles per hour
m/s
Meters per second
MSRC
Marine Spill Response Corporation
nm
Nautical Mile
NG
Northern Gateway
NOAA
National Oceanic and Atmospheric Administration (United States)
NSTF
Nearshore Task Force
OSAC
Washington State Oil Spill Advisory Council
OSRV
Oil Spill Response Vessel
OWA
Open Water Area
OWTF
Open Water Task Force
PWS
Prince William Sound
RCA
Response Capacity Analysis
RGA
Response Gap Analysis
RGI
Response Gap Index
ROC
Response Option Calculator
SCAT
Shoreline Cleanup Assessment Team
SERVS
Ship Escort/Response Vessel System
SG
Specific gravity
SYN
Syncrude
Syncrude
Synthetic crude oil
TDR
Technical Data Report
TF
Task force
TOO
Tanker of Opportunity
US
United States
USCG
United States Coast Guard
USEPA
United States Environmental Protection Agency
VLCC
Very large crude carrier
WA
Washington
Page 60 of 62
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Appendix C: Meteorological Data Summary

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Mountain Weather Services

PO 4341 3967 Broadway Ave Smithers BC V0J 2N0
T: 250.877.0001
Description of Available Meteorological

Data for Evaluation of Enbridge Northern
Gateway Pipeline Proposal
Uwe Gramann, P.Met.

Smithers, BC
July 2012
(A43220)

T: 250.877.0001
P URPOSE
Publicly available meteorological and oceanographic observations were collected from land based stations
and buoys along the B.C. north and central coast. The collected data was used to establish a frequency
analysis of wind and visibility occurrences along the proposed tanker routes as well as Terrace and Prince
Rupert Airports. The data further aided in establishing a response gap analysis conducted by Nuka
Research Planning Group.
D ISCUSSION
The data obtained by EC and DFO vary immensely from station to station with respect to start of
observation period, end of observation period, observation interval and missing data. The reliability of the
data is difficult to assess without a detailed analysis of each station set.
The most apparent issue with the dataset are irregularly missing periods of data. In general, land
observations have more complete datasets compared to buoy observations. One of the more problematic
stations in this regard is the Nanakwa shoals buoy, where as much as 15% of hourly data is missing
(possibly more). A very cursory first look could not detect any bias in this missing data. It is however
suspected that a large number of missing observations are due to equipment failure that is triggered by
inclement weather. It is therefore conceivable that the dataset is underreporting such conditions.
Nanakwa shoals, however, observes the only reliable and representative wind speed along the inland
route (CCAA), since it is located in the middle of Douglas Channel, and is as such well exposed to along
channel winds (e.g. arctic outflows). It is also not located on an Island or land that would slow winds
through divergence and friction. However, since its location is not coinciding with the narrowest section
of Douglas Channel it is conceivable that higher wind speeds along the CCAA will remain undetected.
Another problem is the lack of visibility data along the proposed routes. The only stations reporting
visibility are lighthouses and airports, none of which are located along the confined channel assessment
area (CCAA). As a result there is no record of visibility observations along the inland route. It is noted, that
the proponent commissioned a maneuvering study that did not test maneuvers at visibilities below 3
nautical miles. Visibilities of less than 3 nautical miles are quite common at Terrace airport, which is
expected to have generally better visibility than Douglas Channel along the CCAA, due to its location
further inland. Visibilities observed at marine lighthouses have two distinct problems: Lighthouses report
at irregular hours (most commonly in 3 hour intervals) and most of them do not report between 10PM
and 4AM; in many cases not even between 4PM and 4AM. Additionally, lighthouses are located on land
experiencing better daytime visibilities than open water due to the adjacent warmer land mass and
slightly drier conditions. Considering that the timing of most lighthouse observations are biased towards
daytime conditions, they should be considered a best case scenario when evaluating restrictions along
the proposed tanker routes caused by visibilities.
The most reliable data within the set are (manual) airport observations from Terrace and Prince Rupert
Airports. Their strength is the long period (over 50 years), a very consistent data set (only few missing
Mountain Weather Services; PO 4341; 3967 Broadway; Smithers; BC; V0J 2N0; weather@uniserve.com; T: +250.877.0001
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T: 250.877.0001
observations) as well as 24-7 observations. Unfortunately, these airports are located at somewhat
protected locations (especially Terrace) and wind and visibility conditions can be considered too benign
compared to conditions along the proposed routes.
Wind observation stations that represent conditions at the proposed LNG terminal in Bish Cove are
unrepresentative for winds along the proposed route as well as for the proposed Enbridge tanker
terminal. The Bish Cove LNG Terminal is naturally protected from winds blowing along Douglas Channel by
its location in a cove hidden behind a land barrier. The proposed Enbridge tanker route as well as the
proposed Enbridge Terminal are exposed to dominant winds blowing along Douglas Channel. As a result,
Bish Cove wind data is not recommended to be used for the planning process or operations of the
Enbridge project.
Wind observations installed by the proponent are not part of this data set and the locations of the
associated observations stations subject to boundary layer effects from nearby objects and/or divergent
flows underestimating wind speeds compared to what tankers would encounter along the route. It is
understood that these stations are only used to verify the proponents wind models. It is not
recommended to use them for tanker operations and decision making that depend on wind observations
fully representative along the proposed route. Wind speeds measured at Terrace Airport are also not
recommended to be used for operational decisions due to its location within a multi-valley confluence
zone that is unrepresentative for conditions along the CCAA.
Triple Island lighthouse observations have a special significance in that this location is one of the pilot
boarding stations. The length and good consistency of the dataset (Jan-1953 until Dec-2001) adds to its
importance. Wind speed and visibility is considered representative for the region since it is well exposed
in all directions.
Particular importance should be given to the units of visibility if this data is to be compared to third party
datasets. Data provided here presents visibility in kilometer as provided by Environment Canada. Visibility
in marine environments, however, including Environment Canadas marine forecasts, most commonly
refer to nautical miles (1nm=1.852km). Furthermore, aviation visibility observations and restrictions, such
as visual flight rules most commonly refer to visibility in statute miles (1sm=1.609km).
Uwe Gramann, P.Met., Senior Meteorologist
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A PPENDIX
D ATA H ANDLING AND C ONVERSIONS
All available buoy and land data was retrieved from web servers of Environment Canada (EC) and the
federal Department of Fisheries and Oceans (DFO) by a Linux shell script routine and then imported into
MS Access for further handling. The dataset was assembled under the general assumption that DFO
source data is accurate unless flagged. Since EC data does not contain flags all land based data was
assumed to be accurate unless a cursory review found errors in any parameter, in which case the entire
observation was deleted. No detailed error or bias analysis was conducted. The strengths and limitations
listed here were discovered while conducting routine and basic data checks and analyzing the data (for
some of the results see also Station and Data Notes).
The resulting database was subjected to the following steps:
All DFO buoy data flagged with the numbers 3 (doubtful), 4 (erroneous) or 7 (off position) were
deleted. (see also http://www.meds-sdmm.dfo-mpo.gc.ca/isdm-gdsi/waves-vagues/formats/csveng.htm )
Data from the following stations were deleted due to redundancy and the fact that nearby data
existed with longer records: Prince Rupert, Prince Rupert 2, Prince Rupert Auto, Sandspit,
Sandspit AWOS, Terrace Skeena Bridge.
All duplicate records within each stations data set were deleted.
If necessary, data was converted to common units according to the following formulae:
1 m/s
1m
1 km/h
1 km
1 km/h
1 m/s
= 1.942615 knots
= 3.281 feet
= 0.539956 knots
= 0.539956 nautical mile
= 0.2778 m/s
= 3.6 km/h
The column labeled date was renamed to Datum (German for date) to avoid naming conflict
with date functions intrinsic to MS Access. This parameter was considered to be the start of
observation validity.
All observations were limited to a maximum validity duration of 1 hour. Validity of less than 1
hour was determined chronologically by the start time of the next available observation of the
same station. (End of validity of observation is listed in column ValidUntil).
Daylight hours were used from Terrace in the year 1975. It was confirmed that daylight data from the
years 2012 and 1950 do not vary by more than 1 minute. Daylight timing was adjusted to match DFO buoy
data in Greenwich Mean Time.
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T: 250.877.0001
D ATA SOURCES
DFO B UO Y D AT A :
DFO Buoy data was downloaded from
http://www.meds-sdmm.dfo-mpo.gc.ca/isdm-gdsi/waves-vagues/search-recherche/index-eng.asp
DFB Buoy Column and Flag descriptions can be found at
http://www.meds-sdmm.dfo-mpo.gc.ca/isdm-gdsi/waves-vagues/formats/csv-eng.htm
EC C LI MAT E /L A N D D A T A :
EC online climate data was downloaded from
http://climate.weatheroffice.gc.ca/climateData/canada_e.html
EC online climate data descriptions can be found at
http://climate.weatheroffice.gc.ca/prods_servs/documentation_index_e.html#tableOfFlags
D A Y LI G HT
DA T A :
http://www.nrc-cnrc.gc.ca/eng/services/hia/sunrise-sunset/angle-calculator.html
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T: 250.877.0001
D ATA C OLUMNS
DFO B UO Y D AT A :
Location
StationID
Datum
ValidUntil
Q_Flag
Latitude
Longitude
WaterDepth
VCAR m
WvPkPd s
VWH m
VCMX m
VTP s
WDIR deg
WSPD mpers
WSS mpers
Gust mpers
WDIR 2 deg
WSPD 2 mpers
Gust 2 mpers
Pressure hPa
Pressure 2 hPa
Temp deg C
SeaSurfcTemp deg C
Location Name
Location DFO Identifier
Date and time observed (UTC)
Time of next obs or 1 hour after "Datum", whichever comes first
Quality control flag
Latitude of Buoy Locatoin
Longitude of Buoy Locatoin
The depth values are presented in metres
Characteristic significant wave height (m)
Wave spectrum peak period (s)
Characteristic significant wave height (reported by the buoy) (m)
Maximum zero crossing wave height (reported by the buoy) (m)
Wave spectrum peak period (reported by the buoy) (s)
Direction from which the wind is blowing ()
Horizontal wind speed (m/s)
Horizontal scalar wind speed (m/s)
Gust wind speed (m/s)
Direction from which the wind is blowing ()
Horizontal wind speed (m/s)
Gust wind speed (m/s)
Sea level atmospheric pressure (mb)
Sea level atmospheric pressure (mb)
Dry bulb air temperature (C)
Sea surface temperature (C)
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T: 250.877.0001
EC C LI MAT E /L A N D D A T A
Location
Datum
ValidUntil
Data Quality
Temperature degC
Temperature Flag
Dew Point degC
Dew Point Flag
RH percent
RH Flag
Wind Dir 10deg
Location Name
Date and time observed (PST)
Time of next obs or 1 hour after "Datum", whichever
comes first
The temperature of the air in degrees Celsius (C).
The dew point temperature in degrees C
Relative humidity in percent
The direction (true or geographic, not magnetic) from
which the wind blows. Expressed in ten's of degrees,
wind Dir Flag

Wind Speed kmh
The speed of motion of air in km/hr, usually observed

at 10 m above the ground
Wind Speed Flag

Visibility km
Visibility Flag
Station Pressure kPa
Station Pressure Flag
Hmdx
Hmdx Flag
Wind Chill
Wind Chill Flag
Weather
Visibility in kilometers (km) is the distance at which

objects of suitable size can be seen and identified.
Atmospheric pressure in kiloPascal (kPa)
humidex
Wind chill
Weather
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S TATION M AP N ORTH
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T: 250.877.0001
S TATION M AP S OUTH
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T: 250.877.0001
S TATION AND D ATA N OTES

Location
Type
Latitude
Longitude
First
Record
Last
Record
Obs
Interval
01-Feb-94
13-Dec-01
3 hourly
01-Feb-94
13-Dec-01
3, 6 hourly
01-Mar-94
29-Feb-12
Obs Hours
Wind
Vis
Wave
Comments
4, 7, 10, 13 ,16
TRUE
TRUE
FALSE
No Night Obs, Occasional day obs msg
7,10,16
TRUE
TRUE
FALSE
hourly
24-7, btn April 20 2004 and June 2010: twice

hourly
TRUE
FALSE
FALSE
No obs July 2010 until March 2011
Boat Bluff
Lighthouse
52.65
-128.517
Bonilla
Lighthouse
53.5
-130.633
Bonilla_Auto
Marine Auto
53.5
-130.633
Cape Scott
Lighthouse
50.7833
-128.417
01-Jun-66
13-Dec-01
3 hourly
4,7,10,13,16,19,22
TRUE
TRUE
FALSE
Cape_St_James
Lighthouse and Marine Auto
51.9333
-131.017
01-Jan-53
6 hourly
4,10,16,22 until end of 1956 then hourly
TRUE
TRUE
FALSE
Cape_St_James_CS
Marine Auto
51.9333
-131.017
hourly
24-7
TRUE
FALSE
FALSE
Cumshewa_Island
Marine Auto
53.0333
-131.6
hourly
24-7
TRUE
FALSE
FALSE
DixonEntranceCentral_46145
Buoy
54.3833
-132.433
hourly
24-7
TRUE
FALSE
TRUE
Some Missing Obs
DixonEntrance_46205
Buoy
54.1667
-134.333
31-Aug-92
06-Mar12
01-Mar12
01-Mar12
01-Mar12
24-7
TRUE
FALSE
TRUE
Intermittent data chunks missing
Dryad_Point
Lighthouse
52.1833
-128.1
Irregular
4,7,8,9,10,11,13,16
TRUE
TRUE
FALSE
EastDellwood_46207
Buoy
50.9
-129.9
13-Dec-01
05-Mar12
hourly
24-7
TRUE
FALSE
TRUE
Occasional Missing Months
Ethelda_Bay
Lighthouse
53.05
-129.683
Irregular
5,6,7,8,10,12,14,16 until Jul 1962 then

8,9,10,13,15 until Sept 1971 then
1,4,7,10,13,16,19
TRUE
TRUE
FALSE
3 hourly
4, 7, 10, 13 ,16
TRUE
TRUE
FALSE
hourly
24-7
TRUE
FALSE
FALSE
Some data missing June/July/August 2011

otherwise complete
hourly
24-7
TRUE
FALSE
FALSE
Has larger chunks of data missing esply before

April 2003
30-Sep-93
01-Feb-94
16-Apr-91
22-Nov-88
01-Feb-94
18-Oct-89
02-Dec-57
05-Apr-94
01-Jan-70
13-Dec-01
01-Feb-94
29-Feb-12
01-Feb-94
29-Feb-12
Intermittent data chunks missing
Green_Island
Lighthouse
54.5667
-130.7
Grey_Islet_Auto
Marine Auto
54.5833
-130.7
Holland_Rock
Marine Auto
54.1667
-130.35
Hoskins_Islet_Auto
Marine Auto
52.5333
-131.55
01-Feb-94
12-Jun-95
hourly
24-7
TRUE
FALSE
FALSE
Only one year of data
Ivory_Island
Lighthouse
52.2667
-128.417
1-Feb-94
13-Dec-01
3 hourly
4, 7, 10, 13 ,16
TRUE
TRUE
FALSE
No Night Obs, very consistent dataset
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Kindakun_Rocks
Marine Auto
Kitimat
T: 250.877.0001
53.3167
-132.767
MoE Air Quality
54.05
-128.683
Kitimat Whitesail
MoE Air Quality
54.0675
-128.64
Langara
Lighthouse
54.25
-133.05
Marine Auto
54.25
-133.05
Lucy_Island
Marine Auto
54.3
-130.6
Masset_Airport
Aviation Manned
54.0167
-132.117
Mc_Innes_Island
Lighthouse
52.2667
-128.717
NanakwaShoals_46181
Buoy
53.8167
-128.833
NorthHecate_46183
Buoy
53.5667
-131.133
Prince_Rupert_A
Aviation Auto
54.2833
-130.45
Rose_Spit
Marine Auto
54.1667
-131.667
Sandspit_A
Aviation Auto
53.25
-131.817
Sartine_Island
Marine Auto
50.8094
-128.897
SouthHecate_46185
Buoy
52.4
-129.8
SouthMoresby_46147
Buoy
51.8
-131.2
Terrace_A
Aviation Auto
54.4667
-128.583
Triple_Island
Lighthouse
54.3
-130.883
24-7
TRUE
FALSE
FALSE
Occasional Obs missing but generally very

consistent dataset
20-May94
Irregular
9,11,15 or 16
TRUE
TRUE
FALSE
No Night Obs, Very short and lots of obs missing
12-Mar10
hourly
24-7
TRUE
FALSE
FALSE
Wind direction is off by about 20 degrees

(adjusted to magnetic north, not geographic)
12 and 6
hourly
1,13,19 until Dec 1954 then 10,13,16,19 until

Sep 1971 then 1,4,7,10,13,16,19 until Aug
1985 then hourly
TRUE
TRUE
FALSE
No night nor early morning obs before Sep 1971
hourly
24-7
TRUE
FALSE
FALSE
hourly
24-7
TRUE
FALSE
FALSE
Chunks of data missing before until Nov 1998
hourly
6-17 or 7-18, 7 days a week
TRUE
TRUE
FALSE
No Night Obs
3 hourly
7,10,13,16,19,22 until Sep 1971 then

1,4,7,10,13,16,19,22 until June 1977 then
very inconsistent
TRUE
TRUE
FALSE
6-Mar-12
01-Feb-94
01-Apr-97
01-Jan-54
Langara_RCS
hourly
1-Feb-94
01-Feb-94
04-Feb-94
27-Oct-05
13-Dec-01
06-Mar12
29-Feb-12
01-Mar12
01-Jan-55
13-Dec-01
24-Nov-88
29-Feb-12
hourly
24-7
TRUE
FALSE
TRUE
Lots of irregularly missing obs
15-May-91
01-Mar12
hourly
24-7
TRUE
FALSE
TRUE
some/lots data missing; Winter of 98/99 almost

gone
16-Aug-61
21-Jan-05
hourly
24-7
TRUE
TRUE
FALSE
Very consistent dataset
01-May-94
01-Mar12
hourly
24-7; twice hourly from May 2004 until Feb

2006
TRUE
FALSE
FALSE
Some Missing Obs
hourly
24-7
TRUE
TRUE
FALSE
Missing chunks after June 2003, but otherwise a

very consistend data set
hourly
24-7
TRUE
FALSE
FALSE
Some missing data
1-Jan-53
01-Feb-94
19-Jan-05
06-Mar12
12-Sep-91
01-Mar12
hourly
24-7
TRUE
FALSE
TRUE
Lots of irregularly missing obs; May 98 until

August 99 almost gone
17-Jun-93
01-Mar12
hourly
24-7
TRUE
FALSE
TRUE
Some Missing Obs; Jan through april of 2008

missing otherwise not too bad
12-Apr-55
2-Mar-12
hourly
24-7
TRUE
TRUE
FALSE
01-Jan-53
13-Dec-01
3 hourly
1, 13, 19 until Dec 1954 then

4,7,10,13,16,19,22
TRUE
TRUE
FALSE
P a g e | 11
(A43220)

T: 250.877.0001
WestMoresby_46208
Buoy
52.5
-132.7
WestSeaOtter_46204
Buoy
51.3
-128.7
12-Jul-90
07-Sep-89
Bish_Cove
Private
10-Nov-11
05-Mar12
hourly
24-7
TRUE
FALSE
TRUE
Some Missing Obs especially Winter 1992/93,

otherwise not too bad
05-Mar12
28-Mar12
hourly
24-7
TRUE
FALSE
TRUE
Very few complete months of data, aug 97

through 99 almost gone; good data after april
2003
hourly
P a g e | 12

Oil Spill Response Gap and Response Capacity Analysis

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Oil Spill Response Gap and Response Capacity Analysis

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(A43220)

Northern Gateway Pipelines Inc.

HAISLA NATION MOTION

In IR No. 2.29a), the Haisla Nation asked:

In IR No. 2.29g), the Haisla Nation asked:

In its IR No. 1.19g), Coastal First Nations asked (A2C2S9):

HAISLA NATION MOTION

In its IR No. 1.21a), Coastal First Nation asked:

HAISLA NATION MOTION

Transport Canada filed the TERMPOL Technical Review Committee Report on

HAISLA NATION MOTION

GROUNDS FOR MOTION

Hearing Order OH-4-2011, s. 4; and

principles of natural justice and procedural fairness.

how the proposed Project will impact the participant;

How the proposed project will impact the Haisla Nation

HAISLA NATION MOTION

The reason why the deadline was not met

HAISLA NATION MOTION

Whether the submission is likely to assist the Panel

HAISLA NATION MOTION

Whether similar submissions have been, or could be, made by others

How other parties could be disadvantaged as a result of the late submission

Other relevant considerations

HAISLA NATION MOTION

Scope of the Factors Northern Gateway Pipeline Project, August, 2009.

HAISLA NATION MOTION

Northern Gateways evidence is incomplete; as a result, the Haisla Nation seeks to

Northern Gateway is proposing mitigation measures that are based on an incomplete

Attachment 1 to August 1, 2012 Haisla Nation Motion

Lead Authors and Primary Editors

Contributing Authors and Analysts

Meteorological Data and Analysis

Response Gap Analysis

Response Capacity Analysis

1.2 Mechanical Recovery of Marine Oil Spills

Part 2: Oil Spill Response Gap Analysis

Vessels unable to keep on station,

Inability to track and encounter oil, and

Crew unable to work on deck due to ice or hypothermia,

Failure of skimming systems,

CONDITIONS THAT COULD PRECLUDE A RESPONSE

Winds > 15 to 20 m/s, but depending on other variables.

Part 3: Oil Spill Response Capacity Analysis

Open Water Area (Open water operating environment):

Confined Channel Assessment Area (Protected water operating environment):

American Petroleum Institute gravity (API gravity or API):

8 kph (2.22 m/s)

8 kph (2.22 m/s)

11 kph (3.05 m/s)

11 kph (3.05 m/s)

3.2.3 Operational Planning Parameters

1 hour for owned,15 dedicated16 resources in ready state17

Equipment owned by and personnel employed by operator.

2.5 hour for owned,20 non-dedicated21 resources in ready state22

Approximate Distance (km) from

Transit time (hrs) at 16.7 kph

Transit time (hrs) at 22.2 kph

Wright Sound Nexus

Far South Rocks

Equipment owned by and personnel employed by operator.

J-booming configuration (Source: ADEC, 2007)

3.2.5 Equipment and Recovery Specifications

1-63m OSRV; 1-10m support boat