and in a buildup of hydrocarbons in the food-chain; the latter may eventually affect the consumer. If we are not to permit unchecked deterioration of a presently clean and productive environment, we must establish the degree of environmental degradation and the pollution levels which we are willing to accept. This task can be aided by making use of existing experience. Many inshore and offshore areas of our coastal zone, in different climatic regions, are exposed to oil pollution. A correlation of the existing pollution levels in these areas with the environmental state and with the pollution levels in sea food is a feasible and necessary part of this task. It will require also the establishment of maximum permissible levels of fossil fuel contamination in food. This is a more extensive but not more difficult task than the establishment of pollution baselines. The effort expended is relevant to, and the standards developed are needed and applicable in, other marine areas which may be subjected to increasing oil pollution in the near future, e.g. the continental shelf along the eastern seaboard. 3. CONTROL OF POLLUTION LEVELS To provide a measure of true environmental protection, the results of the baseline study and of the continued operational survey must be assessed in terms of the established maximum permissible pollution levels. If the fossil fuel level in the environmental or the environmental deterioration exceed the maximum permissible levels, the oil influx to the environment must be reduced, e.g. through better control of routine or of accidental discharges, through appropriate recovery techniques or through the reduction of oil throughput. A precedent exists in U.S. oil shale development policy. There, the U.S. Department of the Interior requires ecological surveys before and during shale plant operations, and production quotas will be tied directly to the environmental status.3 I believe that granting the permit at this time would provide no mechanism to detect rapidly the unanticipated environmental deterioration and to arrest the rise of the pollution level in the environment and in fisheries products. Denial of the permit would eliminate entirely the pollution, environmental degradation and destruction of fisheries resources, inshore and offshore in Alaska, on the high seas and in the waters of the contiguous United States, that would otherwise result from the transport of the Alaskan oil. Deferral of the permit, in anticipation of later granting, could provide the time to carry out the necessary baseline studies in Alaska, to assess the environmental effects of oil in terms of our experience in presently polluted areas, and to establish maximum permissible oil pollution levels in the environment and in food. To a large extent, this effort is possible with existing chemical and biological methods. The results are applicable to other areas where production is anticipated; the availability of such data and standards should hasten substantially decisions which will have to be made elsewhere. Sincerely yours, MAX BLUMER, 2 We envisage coordinated chemical and biological studies, similar to our Buzzards Bay survey; these should be carried out in different climatic regimes and in areas which are affected by oil production, by refining, and by oil transport. Sampling should extend from the most heavily affected regions outward to clean control areas. 3 I refer to policy information presented in a lecture by Dr. R. T. Stone, U.S. Department of the Interior, at the International Symposium on Science and Technology of Oil Shale, Curitiba, Brazil, December 12-17, 1971. Further, the Draft, Environmental Impact Statement for the Prototype Oil Shale Leasing Program, U.S. Department of the Interior states (p. IV-9): "An important objective of this prototype program is to compare the actual environmental impact with the projected impact. To this end, the air and water quality would be measured and assessments made of the environmental consequences by both the operator and Government representatives. If it is found that the operations do not meet the standards specified in the lease, an immediate adjustment of the operations would be made. Failure to comply in a reasonable time could result in cancellation of the lease. Where operations cause unforeseen environmental effects, operating plan requirements to control such effects would be changed to the maximum extent possible, consistent with the terms of the lease." I have been advised that you have indicated a substantial and An exact comparative analysis of the permafrost problems to Permafrost is not a material. It is a condition in which the After reading newspaper accounts of the information presented to both the House and Senate Interior subcommittees, particularly that by Dr. Robert R. Curry, I can understand how confusion could result. In fact, Dr. Curry's testimony to the Senate subcommittee reminded me of my first attempts at studying permafrost 25 years ago when, after my first year, I too thought I knew all about permafrost only to find out since how little I then knew about it. Unfortunately, I am afraid I must regard most of the rest of his technical remarks in the same light as for example his comments concerning heat flow, which are erroneous, his statement that "10 to 45 foot offsets that are entirely probable along the Alaskan route," and his statement, "This means that landslides, particularly landslides into the sea with associated giant sea waves up to hundreds of feet high as observed in southern Alaska, are virtually certain in the pipeline vicinity within its lifetime (underlining added). The art of earthquake prediction is still in its infancy and such definite remarks are not justified. No pipeline, either trans-Alaskan or trans-Canadian, can be hidden from view. The Alaskan route would cross about 730 miles of permafrost terrain; the Canadian route would cross about 1,400 miles of permafrost terrain. Where either route crosses rock or well drained coarse gravel areas no particular. engineering problems will be encountered as a result of permafrost conditions. Where either route crosses fine grained soil materials, these materials will contain ice wedges allowing for differential settlement when the ice melts beginning with the construction of the pipeline and continuing with the transportation of the hot (about 140° F) oil. Special engineering designs must be used in these areas to prevent both pipeline failure and environmental damage. Approximately half of the trans-Alaska route traverses finegrained, ice-rich soils and special engineering is required. The percentage ratio of fine grained soils on the trans-Canada route through the permafrost zone appears to be approximately the same although it has not been examined in near the same detail as has the trans-Alaska line. We do know that most of two of the proposed trans-Canadian routes through Alaska have bad permafrost soil conditions. We also know that the Canadian Government found the permafrost conditions at Aklavik (west bank of the west fork of the MacKenzie River) so bad in 1954 that they elected to move the entire town (700 people) to a new location and established the new town of Inuvik. know that the hot oil pipeline test section established outside of the new town of Inuvik had such poor permafrost soils that sections of this line settled 3.5 feet after the insulation We was removed from beneath the pipe. We know that the permafrost conditions associated with much of the Peel Plateau, which one of the proposed MacKenzie Valley Pipeline Research Limited routes would cross, are some of the worst in Canada. We also know that VIPs were not encouraged to visit the pipeline test site at Sans Sault Rapids because of the mudhole conditions that developed due to the thaw of permafrost soils. Dr. Curry stated that, "The MacKenzie River valley itself has less permafrost than might be expected by comparison to Alaska since it is the locus of a north flowing river carrying huge quantities of heat northward and thawing its near-shore areas. This statement is valid, as regards any pipeline, only if the pipe is buried bereath the bottom of the river. The nearsurface permafrost material, in which a pipeline would be buried, would be virtually unaffected by the heat of the MacKenzie River if the pipeline were located more than 100 feet from the year around flowing channel. (Dr. A. H. Lachenbruch's paper, Ceological Survey Bulletin 1052-B, which discusses permafrost beneath heated buildings, also is applicable to permafrost beneath rivers, roadways, and even the ocean edge.) Dr. Curry also discusses, inferentially, off-shore burial of a pipeline from Prudhoe Bay to the MacKenzie Delta, for which the engineering technology has not yet been developed in the arctic. The implication is that an off-shore pipeline in the Arctic Ocean would not be in permafrost. This is contrary to known information. Damage to the tundra surface during the period of construction can be as damaging or, in some cases, even more damaging to the environment and as dangerous to the integrity of a hot oil pipeline as the actual thawing of permafrost caused by the hot oil transmission. Thus roads usually are necessary to protect the environment during the construction period, for preventative maintenance of the pipeline after construction and for cleanup in case of pipeline leaks. Such roads are quite feasible in arctic Alaska, as well as arctic Canada, as the roads and airstrips that I designed for the western third of the DEWLINE in 1955 are still being successfully used. This same road design has now been adopted by the oil industry and the airstrips that I designed in 1968 and 1969 for PRUDHOE BAY and the DEADHORSE commercial airstrip are being used by C-130s and Boeing 737s. Roads in much of the Canadian area would be both difficult to build and expensive because the proposed trans-Canada routes cross rivers instead of paralleling them as the trans-Alaska route does in the main. Roads, for the operation of construction equipment and preventative maintenance of the hot oil pipeline after construction, are required to prevent damage to the tundra even should the engineers want to build an elevated pipeline or tramway. These type structures cannot just be "floated" into an area or even placed without using ground equipment. In addition, they, particularly tramways, require sophisticated foundation supports and hence would involve very ccnsiderable disruption of the surface with resulting modification to the underlying thermal regime of the permafrost. In summary, all pipeline construction in permafrost, be it Alaskan, Canadian, or Russian, causes engineering problems and is potentially damaging to the environment. This is particularly true unless the construction contractors are carefully and very firmly controlled and monitored by knowledgeable governmental agencies. The best construction possible in permafrost areas, with the least amount of environmental damage, is that which allows one to get out of the permafrost zone in as short a distance as possible. Thus, as regards permafrost conditions and the environmental damage potential associated with permafrost, the trans-Alaska route is at least twice as desirable as the Canadian route which has twice the distance through permafrost materials and has many major rivers to cross. I believe that the Department of Interior leaned too far over backwards in their attempts to be most objective and impartial in their environmental impact statement in discussing various possible hot oil pipeline transportation routes. This is certainly true as regards permafrost since the Department, U. S. Geological Survey, has the best group of recognized permafrost experts in the United States. The latter includes Dr. A. H. Lachenbruch who is internationally known as one of the world's foremost heat flow experts and who was recently visited by the director and assistant director of the premier Soviet permafrost research laboratory. A copy of Dr. Lachenbruch's classical treatise, "Thermal Effects of a Heated Pipeline in Permafrost," is enclosed. I am also enclosing a copy of an environmental analysis of the MacKenzie Valley Research Limited report, "Arctic Oil Pipeline Feasibility Study 1972" that I reviewed recently, along with copies of several other papers concerning permafrost prepared during the past 15 years. If I can be of further assistance, please do not hesitate to contact me. |