During the campaign to stop the dumping of the Brent Spar, it has been claimed in some media reports that Greenpeace based its activities on emotion and dogma to the exclusion of science. A scientific debate has ensued, which has included some attacks on our stance by scientists, including an Opinion piece in the journal Nature.
Greenpeace is contacting scientists directly in order to make available the information and arguments on which we based our decision. We feel that it is important that the scientific debate continues and that information is freely available to be discussed. We are confident that our scientific arguments are robust and invite you to contact us should you wish to discuss our position further or obtain any of the information or copies of documents that we hold. We took into account the available scientific knowledge, our commitment to valuing the environment, and our understanding of the political consequences of the dumping of the Brent Spar before starting our campaign.
Our actions were based on the following facts:
There is therefore insufficient scientific knowledge to support the assertion in Nature2 that the effect on deep-sea life would be `minimal or beneficial'. The article by Nisbet and Fowler in the same issue3 suggests that some deep sea organisms may benefit from heavy metals. This, however, tells us nothing about how the ecosystem as a whole will respond to a poorly known cocktail of radioactive scale, heavy metals, hydrocarbons and a residual amount of PCBs. Nisbet and Fowler hypothesise that a `carefully chosen location on the Mid-Atlantic Ridge' might be an appropriate disposal site. Yet Shell did not propose disposal at such a site, nor have any detailed studies been made of the effects of the Brent Spa's contents at any site.
The conclusions in Shell's documents rest on a number of unsubstantiated assumptions and take no account of the uncertainties in the inventory and the limited scientific understanding of the deep sea environment.
One assumption in the Impact Hypothesis5, for example, is that the most likely scenario is slow release of contaminants at the sea-bed over a period of a thousand years. This assumption has not been justified and contradicts a statement in the Auris report1, which states "It is likely that some or all of the tanks would be split, discharging their contents into the immediate environment or permitting their dispersion into the surrounding water" when the Brent Spar hit the sea bed.
It is further assumed5 that dispersed particulates will settle "with an even distribution within a 150m radius of the point source" and thus levels of heavy metals would be "negligible". The effects of finely dispersed hydrocarbons are described as "insignificant", based solely on a reference to unnamed fouling studies in the North Sea5,1. These studies supposedly indicate no adverse effects on organisms living in the vicinity - yet the studies are not identified in any way, nor is any data given. It is simply not adequate to extrapolate the results of toxicity studies carried out in shallow water environments to predict the likely impacts in deep water.
Greenpeace considers that both the lack of reliable data and inadequate knowledge of deep ocean systems must call into question Shell's conclusions of 'negligible harm' following dumping of the Spar. I enclose a copy of a memo6 from a Government scientist to his colleagues in which it is stated that the materials would be classified as hazardous waste. This led to the added hand written comment: "The bottom line is that the waste cannot be dumped at sea. The only option is to take ashore and treat". Although the Government have subsequently claimed that this advice relates to shallow water environments, such an interpretation is not obvious from the note itself. Furthermore, if the materials are too toxic to dump in shallow water, it is hard to see how dumping in deep water can then be justified, given that far less is known about the deep water environment.
During the latter half of last summer (1994) Greenpeace was made aware of an internal review being carried out by the Department of Trade and Industry (DTI) on options for decommissioning redundant offshore installations. It was clear that the Brent Spar was likely to be the first of the installations which would be proposed to be dumped at sea.
Under the International Maritime Organisation (IMO) guidelines, all of the structures in the shallower southern part of the North Sea must be brought ashore, but other options, including dumping (in situ toppling) were being considered for installations in the Central and Northern part of the North Sea. In the UK sector this would mean that between 50 and 60 installations could be dealt with in this way.
The harm caused by the Brent Spar, if it was dumped, would be added to if other oil installations were dumped later. But the BPEO only operates on a case-by-case basis so ignores the cumulative effects of dumping more than one installation.
If the dumping of the Brent Spar had been allowed not only would the dumping of a further 50 to 60 installations been made easier, but it may have been used as a precedent to allow the dumping of other obsolete installations from the North Sea fields, and possibly contaminated bulky items from other industries.
Greenpeace has always been concerned that the Brent Spar could have been used as a dangerous precedent in other ways. The Brent Spar contained materials which would be classified as low level radioactive and hazardous wastes under domestic and international legislation. The London Convention (formerly known as the London Dumping Convention) has not established de minimis levels (also known as exempt levels) for these substances. If the Brent Spar dumping operation had been allowed to go ahead it would have established a precedent for dumping a wide range of materials of similar contamination levels, in items such as construction materials contaminated with radioactivity, for example power station containment buildings and other civil and military engineering scrap. Such a precedent would have reversed the current trend towards responsible disposal methods, as opposed to dumping at sea.
Concerns have been raised that the Spar, which was weakened when it was first moved into the horizontal position, will break up during inshore operations and release harmful materials into the near shore environment. Shell have tended to portray this problem as so serious that the safest thing to do is to dump the Spar at sea. Yet they assumed that the tanks would remain intact on hitting the sea bed when dumped, even though sinking the Spar would involve detonating explosives.
Clearly, a detailed structural survey is required, something Shell have not yet carried out. However, the offshore construction industry regard onshore dismantling as perfectly technically feasible. I enclose an article from the Sunday Times7 which makes it clear that firms are already claiming they can do the work. I also enclose sections of a report by Smit Engineering of Rotterdam8, commissioned by Shell in 1992, which clearly outlines the engineering tasks and includes details of how the Spar can be inspected and repaired if this proves necessary.
In fact the operations required to decontaminate the Brent Spar are in routine use by the offshore industry. Oily water and sludge reception facilities are present at most ports dealing with tankers and oil operations and radioactive scale is routinely removed from pipes onshore as part of the maintenance cycle. Once decontaminated, the reverse engineering operations involved in dismantling the Spar pose no more risk to the nearshore environment than a conventional surface vessel.
Furthermore, decommissioning is already carried out or planned for other installations. In the North Sea, nine platforms have already been removed and fifty are due to be decommissioned over the next ten years. Of the 219 oil and gas platforms in the North Sea, over 150 are due to be removed completely, for re-use or on-shore disposal, according to Government and industry plans9. In the Gulf of Mexico, Federal regulations require removal of installations down to 5 metres below the mudline. Over 900 installations have been removed there so far.
To contribute to the DTI review referred to above, Greenpeace commissioned its own report10. Our investigations found that exaggerated costs of onshore dismantling were being provided to the Government by the oil industry. Our consultants also discovered that it was technically and economically feasible to bring redundant installations onshore, and that this was the best environmental option. In addition it would create new jobs in the currently depressed offshore construction market.
It is feasible to deal with the Brent Spar on land although this will not be easy, just as it was not easy to first design, construct and operate offshore installations. It will cost Shell more, just as it cost Shell more to place platforms on sea than on land. The 'scientific' arguments for ocean dumping are being used as a way of disguising Shell's primary aim to cut costs at the expense of the environment.
Greenpeace believes in the fundamental principle that we should no longer needlessly dump wastes into the environment (which ever part) and that we must act responsibly to reduce waste and recycle, treat or contain harmful materials. Opinions on the Brent Spar depend not only on the scientific knowledge available but also on how deeply we value our environment and what damage and precedents we find unacceptable. Public concern about dumping may conflict with the values of some scientists, but it does not conflict with the available scientific knowledge.
We hope you have found this letter informative and that you feel able to join us in celebrating an important step forward in environmental protection - the decision not to dump the Brent Spar.
On Thursday 29th June, the Oslo Commission announced a ban on the dumping of oil installations at sea. Eleven Governments have sponsored this decision - only the UK and Norway have tabled reservations. We hope to persuade those Governments to change their minds.
Please feel free to contact me, or my colleagues, if you have any questions or require access to any more reports we have.
Dr Helen Wallace Science Unit
Enclosures:
Return to Brent Spar occupation home page
1. Aberdeen University Research and Industrial Services (1994), Removal and Disposal of the Brent Spar - a Safety and Environmental assessment of the options - "The Auris report"
2. Nature Opinion (1994), `Brent Spar, broken spur', Nature, Vol 375, p708, 29 June 1995.
3. Nisbet, EG and Fowler, CMR, `Is metal disposal toxic to deep oceans?', Nature, Vol 375, p715, 29 June 1995.
4. Shell (1994), Brent Spar Abandonment Best Practicable Environmental Option (BPEO)
5. Shell (1994), Brent Spar Abandonment Impact Hypothesis.
6. McMinn, W (1993), Memo to Dr J Campbell
7. Clough, P and Davison, J, (1995), `German industry bids to cash in on Brent Spar', Sunday Times, 2 July 1995.
8. Smit Engineering BV (1992), Feasibility Study - Phase I, II and III - Report for Scrapping of the Brent Spar. Contract to Shell UK Exploration and Production.
9. S.G. Warburg Research (1995), `North Sea Abandonment', 26 June 1995.
10. Reddy, S (1995), `No grounds for dumping', Greenpeace International, April 1995. ,