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Letter to President Obama Regarding Gulf of Mexico Spills Reported by MMS and a Request to Withdraw New York's Marcellus Shale Horizontal Hydrofracking draft SGEIS

July 30, 2010

President Barack Obama
The White House
1600 Pennsylvania Avenue
Washington, DC 20500

Dear Mr. President:

I wrote you on June 6th to provide detailed information compiled from the National Response Center (NRC) database documenting dozens of major offshore oil spills in the Gulf of Mexico involving BP and a host of other corporations.

I write today to profile an additional 324 spills compiled from a separate federal Minerals Management Service (MMS) database. See Appendix A:

MMS Data

These data further document that critical aspects of the Deepwater Horizon catastrophe were earlier reported at other spill sites, including drill rig fires, sunken rigs, detached risers, valve failures, blow-out preventer problems, wellbore cementing mishaps, lack of contingency plans, massive uncontrolled releases and oil slicks as large as ten miles long and five miles wide. Note that the Deepwater Horizon was involved in four major spill incidents prior to the recent disaster.

That is why the largest oil catastrophe in American history was obviously foreseeable and should have been prevented. Frankly, it strains credulity that you and environmental authorities were persuaded that offshore drilling risks were negligible given that MMS reported more than 550,000 barrels (23,100,000 gallons) of oil and other materials had spilled from 1964 to 2009. It is equally shocking that authorities were so ill-prepared to respond to the current crisis once it occurred.

A total of 23 BP spills were reported to MMS. In addition, a total of 301 other spills were reported to MMS involving Amoco Production Company, Atlantic Richfield Company/Shell, Chevron Oil Company, Conoco, Inc., Exxon Corporation, Gulf Oil Corporation, Mobil Oil Exploration & Producing Southeast I, Penzoil Company/Texaco, Shell Deepwater Development Inc., Shell Offshore Inc., Texaco, Inc. and other firms.

I have summarized some of the most disturbing incidents for your review. Please note that at least 86 incidents reportedly involved no Remedial Action or “Materials Dissipating,” “Sheen Dissipated,” “Dissipating Naturally,” “Materials Not Recoverable,” “ No Actions Can Be Performed,” or “No Remediation Possible.” Other spills continued to leak for multiple years. See Appendix B.

Please note that MMS spills are often cross-referenced in the NRC database, but the two databases are inconsistent with one another. Some spills are reported in one database, but not the other, even when similar reporting requirements apply. As a result, it is impossible to determine how many offshore spills have occurred in the Gulf of Mexico using a single federal government regulatory information source. I urge you to rectify that problem without delay.

Strict Liability/Financial Surety

Given all the profoundly hazardous oil spills that have been reported to federal authorities, I reiterate my earlier request that you require strict liability and financial surety for all offshore drilling responsible parties as a key safeguard in the event of disaster. Had this been done earlier, our nation would not be struggling to cope with the financial consequences of the recent Deepwater Horizon disaster.

Request for Immediate Marcellus Shale Action

The pressure to exploit America’s offshore oil and gas resources is matched by the zeal to mine the largest natural gas reserve in the nation: the Marcellus Shale that underlies portions of ten states from New York to Tennessee and contains an estimated 500 trillion cubic feet of gas.

Given my detailed documentation of the federal government’s long-standing inability to cope with oil and gas drilling hazards, I request that you make certain the immense contamination hazards in the Gulf are not replicated in the groundwaters of New York and other states.

I request that you immediately instruct the U. S. Environmental Protection Agency (EPA) to require New York’s Marcellus Shale horizontal hydrofracturing draft Supplemental Generic Environmental Impact Statement (draft SGEIS) to be withdrawn and revised to address the “grave reservations” expressed by EPA Region 2. See Attachment C:

Unless this is achieved, the drinking water relied upon by more than 10 million New Yorkers would remain imperiled.

On 12/30/09, EPA Region 2 wrote to DEC to express concerns about numerous fundamental shortcomings in DEC’s draft SGEIS:

“…greater emphasis needs to be placed on the potential health impacts that may be associated with gas drilling and hydrofracturing. EPA suggests that New York State Department of Health (DOH) join NYSDEC as a co-lead on the SEQRA [State Environmental Quality Review Act] document.

“While protecting the New York City watershed is important because of the millions of New Yorkers who rely on this drinking water supply, we also have concerns about water quality impacts throughout the state. Just because fewer people rely on upstate water sources does not imply that these supplies are not also worthy of protection.

“…we have concerns regarding potential impacts to human health and the environment that we believe warrant further scientific and regulatory analysis. Of particular concern to EPA are issues involving water supply, water quality, wastewater treatment operations, local and regional air quality, management of naturally occurring radioactive materials disturbed during drilling, cumulative environmental impacts, and the New York City watershed. EPA recommends that these concerns be addressed and essential environmental protection measures established prior to the completion of the SEQRA process [emphasis added].”

Since I believe these concerns warrant your immediate utmost action, I request that you withhold federal environmental funding to New York until Governor David Paterson and his Department of Environmental Conservation fulfill EPA’s request for revising the draft SGEIS.

As you have now learned through bitter experience in the Gulf of Mexico, it is essential to prevent pollution problems instead of responding to irreparable contaminations hazards after they have occurred. I respectfully urge you not to make the same mistake twice.

Please do not hesitate to contact me if you have any questions I might be able to answer. I look forward to receiving your prompt written reply.

Yours very truly,

Walter Hang

Cc: Honorable Lisa P. Jackson
Honorable Judith Enck
Honorable David Paterson
Honorable Alexander Grannis
Honorable Michael Bloomberg
Honorable Charles Schumer
Honorable Kirsten Gillibrand
Honorable Henry Waxman
Honorable Edward Markey

Appendix A

Appendix B

BP Deepwater Horizon, 6/30/2003: “An emergency riser disconnect occurred when drilling vessel failed to maintain station keeping against 44 knot winds, 3.8-4.0 knot loop current, and 12-14' sea conditions. The vessel used all eight thrusters at 100% power but still moved 108 ft. off center and was unable to maintain position. When the rig had drifted about 35 meters (108 ft) off center, it was forced to perform an emergency disconnect of its riser. This caused a maximum of 1,817 barrels of 14.9 pounds per gallon 52% Novaplus synthetic-based drilling mud (SBM) to be released into offshore waters.”

BP Seg 10” #5625 (DOT), 9/29/1998: “The pipeline system, which originates in SP 49, consists of a 10" pipeline 156,000' in length of which 125,000' are in OCS waters. The system has an operating capacity of 59,000 bbl per day. Four primary production platform are connected. The platforms were shut in for the hurricane on September 28, and began to restore operations September 29. The gas & oil pipeline was parted 3' by mud slide caused by Hurricane Georges. Pipeline cracked along a weld. Deviations from established other-than-normal (i.e., after a hurricane) startup operating procedures contributed to the failure to identify the leak promptly.” A total of 7,500 barrels of crude oil reportedly spilled.”

Equillon Pipeline, 1/21/2000: “The Transocean 96 drilling rig, a semi-submersible mobile drilling unit (MODU), was being towed by 3 tugs from a well site at SS 361 to another location when a motor failed and dropped an anchor cable. It was later determined that the anchor was dragged 20 miles from the rig's originating location to the point where it hooked the pipeline approximately 1.05 miles from Platform A. The 24" Poseidon pipeline (operated by Equilon) was dragged laterally along seafloor approximately 650' from the original location. In addition to this damage, a 50% tear and a 92% tear occurred on the girth welds on the riser. The riser was also torn from the riser clamps. It is estimated that 2,240 barrels of crude oil was lost from the pipeline.”

Rowan Companies, 9/24/2005: “The Rowan Ft. Worth jack-up rig's legs collapsed and the hull floated off location during Hurricane Rita. Prior to the storm, the Rowan Ft. Worth was located at the South Marsh Island 146B 3-pile fixed platform. The hull was never located even though
more than 1,200 square miles were searched as of July 2006. At the time of the hurricane, there were approximately 1,494 bbl of diesel oil on board in secured vessels.”

Elf Total Fina, 8/9/2000: “Oil from a 200-barrel maximum capacity bad oil tank overflowed through the pressure vacuum relief valve and spilled through the first deck grating onto the generator building located on the second deck. Oil penetrated various small openings in the generator building roof and gravitated down an “I” beam onto an exposed hot surface of the generator
exhaust where it ignited. The fire flashed back through the building roof and ignited oil that had accumulated in the adjacent heater treater skid. The fire flashed through the first deck grating and melted the plastic sight glasses on both the bad oil and good oil tanks. This released additional oil that fueled the fire through the sight glass valves. After attempts to extinguish the fire failed, all personnel were evacuated to the M/V Ocean Runner 1 and transported to Unocal’s EI 276 B platform. The platform fire loop located on the generator melted and performed a total platform shut-in. Workboats from adjacent fields sprayed seawater onto the EI 275 A platform. A Fast Response Unit equipped with 500 feet of expanded boom was dispatched to the platform. A total of nine M/V’s responded to the distress call and assisted throughout the night to contain and control the fire that continued on the top deck of the platform. A pollution surveillance flight of the area determined that pollution originating from the platform was teardropped shaped and extended 10 miles in length from the platform and about 5 miles wide at the widest point. The platform operators had bypassed the Level Safety High (LSH) on the bad oil tank to make use of the full capacity of the storage space during platform start up operations and then failed to monitor the by-passed LSH sufficiently to prevent tank overflow. The containment plan was not sufficient to contain an overflow. The fire caused an estimated $1.7 million in damages to the platform.”

Marathon Offshore Pipeline Company/Pioneer Natural Resources, 9/24/2005: “The East Cameron 322A 8-pile fixed platform was destroyed by Hurricane Rita…The platform has since been a source of chronic or intermittent leaks through Spring 2007. Pioneer is monitoring the platform and filing daily reports with MMS. The operator reported approximately 53.4 bbl lost in chronic and intermittent leaks from October through December 2005…The 725 bbl lost at the time of the hurricane, plus 53.4 bbl of chronic pollution in the fourth quarter of 2005 total to 778.4 bbl in 2005…Throughout 2006, there was an additional loss of approximately 142.8 bbl of crude oil in intermittent releases. Pioneer had begun the process of clearing debris and plugging abandoning the wells…An additional 52.9 bbl was reported in 2007.”

LLOG Exploration and Production Co.: “On March 11, 2005, at 1300 hours the wellhead connector on the BOP Stack on the Diamond Offshore Ocean Saratoga semisubmersible rig (working for LLOG Exploration in Green Canyon 157) inadvertently unlatched due to improperly connected Blowout Preventer control lines. The well had production casing set, a subsea tree installed and the last in-hole operation prior to the incident occurring was to perforate the production interval. This is an oil producing reservoir and the rig was in 2,614 feet of water. Upon the Wellhead Connector unlatching, the differential pressure between the weighted completion fluid in the riser and the normal seawater pressure caused the stack to separate from the wellhead profile on the top of the subsea tree.”

Fleet Operators, 5/9/2003: “While offloading potable water to the EI-277A facility, the M/V "April" bumped the facility and sustained a hole just above the water line. The vessel began taking on water and sank. There were no injuries. A sheen originated from the vessel. The vessel had 10,993 gallons (261.7 barrels) of diesel oil and 78 gallons (1.9 bbl) of lube oil on board. There was no attempt to recover the vessel or the petroleum products.”

Shell Offshore Inc., 2/28/2005: “When circulating bottom up, a larger amount of cement returned to the surface than expected. The pressure increase was misinterpreted when the second isolation ball entered the smaller pipe. The interface was diverted to the Gulf to keep the cement out of the pits. When the contaminated fluid got to surface, the fluid engineer and the foreman on tour planned on dumping the interface which is usually less than 20 barrels. This procedure was
understood by the operator to be an acceptable practice. The operator's acceptable practice for dumping the interface (usually less than 20 bbls of SBM) may be in question. The operator did not have a contingency plan to prevent synthetic base mud from entering offshore waters during cementing operations. In this particular case they dumped 280 barrels before diverting the fluid back to the pits. This resulted in approximately 204 barrels of of 54% synthetic-based mud (SBM) and 76 barrels of cement entering into the offshore waters. It is estimated that the lost SBM contained approximately 110 barrels of synthetic base oil.”

Taylor Energy, 9/3/2008: “The Mississippi Canyon 20 A 8-pile fixed platform installed in Federal waters in 1984, was completely destroyed as a result of a mud flow incident during Hurricane Ivan in September 2004. After Hurricane Ivan, the platform was found to be lying on its side, submerged nearly 75% below the mudline, approximately 800 feet from its original location. Estimates for cleanup operations have ranged up to $500 million (Taylor 2007). As of June 2009, decommissioning and abandonment operations at MC 20 A are the last activity for Taylor Energy which sold and transferred all its other GOM properties to Ankor Energy in 2009.
Approximately 72.0 bbl seeped from the structure between July 1 to September 30, 2008. Three pollution domes were installed over three distinct plumes in May 2009.”

Appendix C