TIS speaks out on seabed mining
Plan to rid Suwarrow of rats
Mitiaro a key biodiversity area
TAU compliance ‘a work in progress’
Aitutaki power station a ‘model’ installation
Service stations mostly improper
Red flags raised
TIS speaks out on seabed mining
In its most recent newsletter Te Ipukarea Society posed a range of questions around seabed mining. The statement is as follows:
“With the passing of the Seabed Minerals Act 2009, the pressure to move ahead with the mining of our deep sea manganese nodules is beginning to mount.
With millions of dollars on offer, and a national budget deficit, the temptation to open the door to foreign investment in the mining industry is significant.
Even now, the Canadian company Endeavour has a $15 million proposal on the table for government to consider in the sale of exploration licenses.
All this before it is clear what impact seabed mining might have on our environment and society.
While the nodules lie on the surface of the seabed and “mining” is likely to be only to a depth of 30cm, there are still several concerns TIS has regarding this industry.
- What will SOPAC be doing to assist the Cook Islands with ensuring ecologically
- Will there be any serious research to determine the impacts of mining
on the ocean ecosystem?
- How long is sediment that is disturbed on the seabed likely to be in
suspension (carried in the water)?
- How will the nodules be brought to the ocean surface?
- What will be done with unwanted sediment once it reaches the surface?
- Where will the nodules be processed and what impact will this have there?
These questions are based around concerns over the impact on our fisheries and environment because of the sediment and the chemical components in the waste of nodule processing.
We also have concerns about management:
- Will companies be able to onsell their licenses to another company and
benefit from future trading?
- What will be done with revenue to ensure long term benefits from this
- Are there plans to add citizens and environmental concerns groups such
as ours in the Seabed Minerals Committee for improved community and stakeholder
We are pleased to know that the draft Model Contract Agreement will be a useful tool for negotiating agreements with mining companies.
We already have wealth around us (coral reefs, fisheries, tourist attractions), and we need to be very careful (precautionary principle) that whatever we do does not impact this wealth.”
Plan to rid Suwarrow of rats
Environment groups want to rid Suwarrow’s motu of rats, to preserve species of black noddies (like the one pictured).
Te Ipukarea Society is planning a project with the National Environment Service to eradicate rats from Suwarrow National Park to protect Suwarrow’s seabird populations.
The threat to Suwarrow’s seabirds was revealed when a rat infestation was discovered on Motu Tou during a seabird survey in 2008.
The survey found that no Black Noddys were nesting on Motu Tou though this species was observed nesting there during a survey in 2000. Motu Tou also has few nesting birds of other species.
Invasive species are a main cause of biodiversity loss in the Pacific.
Rats, cats and other introduced mammals are believed to be responsible for 90 percent of extinctions since 1800, and remain the key cause of decline for 90 percent of the region’s 200+ threatened birds.
If left unchecked the risk of these rats invading the other islets remains and as such the potential for severely degrading our National Park.
Suwarrow is internationally known for its globally significant populations of seabirds including 13 percent of the world’s Lesser Frigatebirds, a reputation that could be threatened if there is no control over rats and other introduced mammals.
Rat eradication involves the laying of rat bait on infected motu following a carefully planned programme. All measures are taken to ensure there are no negative effects on the environment and that impacts on other species are minimised.
The eradication is planned for August-September this year and will be followed by implementation of a biosecurity plan to prevent rats being brought in again.
Suwarrow was identified as an Important Bird Area and Key Biodiversity Area during the Conservation in the Cooks: Setting Priorities, Building Capacities project funded by CEPF via Birdlife International.
Mitiaro a key biodiversity area
Mitiaro vainetini following a workshop in Mitiaro.
Te Ipukarea Society visited Mitiaro last month to raise awareness about the unique biodiversity on the island and the identification of Mitiaro as a Key Biodiversity Area and Important Bird Area.
This follows visits to Mangaia, Mauke, Atiu and Aitutaki where similar work was done.
Mitiaro qualifies as an Important Bird Area because of the presence of the endangered Rimatara Lorikeet (Vini kuhlii) and the Cook Islands Warbler (Acrocephalus kerearako) which is found only on Mitiaro and Mangaia and nowhere else in the world.
Mitiaro is also a Key Biodiversity Area because of two species of plant found only in Mitiaro and nowhere else in the world and five species
of plant only found in the Cook Islands.
KBAs and IBAs mark the places on earth that have global importance for conservation. They must meet one or more internationally accepted criteria. In simple terms for the Cook Islands, a place can qualify as a KBA/IBA if it contains globally threatened plants or animals, unique species or globally significant populations of a species.
The identification of KBAs and IBAs was assisted significantly by the Cook Islands Natural Heritage Database. This database, a 21 year project developed by the Cook Islands Natural Heritage Trust, records the species, biogeography, local names and uses of all plants and animals in the Cook Islands. Work to identify KBAs and IBAs in the Cook Islands is supported by the Critical Ecosystems Partnership Fund (CEPF) through Birdlife International.
CEPF is a joint initiative of l’Agence Francaise de Developpement, Conservation International, the Global Environment Facility, the Government of Japan, the MacArthur Foundation and the World Bank.
A fundamental goal is to ensure civil society is engaged in biodiversity conservation. The focus of CEPF is the conservation of threatened species and other globally important species.
TAU compliance ‘a work in progress’
Run for cover? Clad in hazard vests, New Zealand foreign minister Murray McCully, Minister for TAU Mark Brown, TAU chief executive officer Apii Timoti and former Chamber of Commerce president Steve Anderson near the “unacceptable” TAU Avatiu valley power station in May 2011.
Te Aponga Uira (TAU) has acted “constructively and responsibly” to safety upgrades recommended to its Avatiu valley power station, but the complexity of some problems remain as a major hurdle to upgrades, according to chief executive officer Apii Timoti.
Timoti said that TAU had taken steps to address the specific problems highlighted by New Zealand Department of Labour inspector Kim Comben in a 2010 report that slammed the power station as being “disconcerting” and as having the possibility of causing “dire consequences” for Rarotonga.
But Timoti, who would only speak to Cook Islands News via email and through communications advisor Trevor Pitt, said it was a work in progress to meet all of Comben’s recommendations, with some changes more easily fixed than others.
“The specific steps taken to address the issues have ranged from design/planning requirements to procedural matters,” he said late yesterday afternoon.
“Spillage/leaks, for example, are factors related to both procedure and design. While certain occurrences require diligence in housekeeping, others require more complicated, and capital investment-intensive, reconfiguring of the power plant.
“We have ‘ticked the box’ on some items but more complex solutions require business modelling.
“...The timeframe for change – to improve and upgrade – has been driven by numerous factors, which are influenced by scale and extent of work, available capital for investment, expertise, and available technology.
“We’ve done what we can to isolate, grade, and programme the work in terms of critical urgency.
“This is a general condition that even larger countries like New Zealand take into account when it comes to compliance.
“There is recognition of debilitating circumstances and factors that can contribute to, and determine, the speed of implementation processes.
“The power station is a 40-year-old plant that has aged considerably. It was constructed to all the regulatory standards at the time and has since been subject to ongoing programmes of capital-intensive retrofit to make improvements.”
In response to the report’s concerns over the lack of emergency procedures at the power station, Timoti said that TAU had been “strengthening” its capabilities to respond to emergencies, safe plant shut-down, management of crises, and recovery from disasters to continue generation.
“This covers our plans for fire response and evacuation, and cyclone (and tsunami) procedures. The responsibilities included under these plans have involved consulting and working closely with the Airport Fire Service and the Volunteer Brigade.”
When asked what role TAU had played in delaying the public release of the audit report, Timoti said that TAU received only the section related to the power station in early 2011 and that TAU had no authority to release the DG Audit Report.
“The 2011 court case has prevented public release of the report,” he said.
Also see: Power station posed ‘dire’ threat
Aitutaki power station a ‘model’ installation
Dangerous goods inspector Kim Comben also did site inspections in Aitutaki, where he found some of the same problems plaguing Rarotonga facilities – among them, lack of emergency preparedness and inappropriate site positioning.
Aquila Storage Tanks Amuri
At the time of Comben’s inspection, Aquila Storage Tanks’ facility had no security and its tanks had no bunding. The audit concluded that the actual location of the facility was also of concern, but noted that the problem lay with a lack of town planning in the Cook Islands.
“It was noted at the time of my visit the end cap was off the valve outlet and the valves were not secured from unauthorised access. The lack of town planning law allows installations such as this to be established in close proximity to residential properties. Whilst technically this site could be brought up to standard with some substantive costs, the issue remains as to whether it should be located where it is in the first instance. This matter of town planning is not restricted to this site, it applies as cross the Cook Islands as a whole. This matter will need consideration by government in respect of developing planning rules.”
Beyond that, Aquila had “no fire protection system” and relied on Airport Crash Fire for fire fighting, a precarious arrangement given Crash Fire was otherwise engaged during take-off and landing of aircraft.
TMN Ltd Arutanga
Like its counterpart in Rarotonga, TMN Ltd in Aitutaki was in “poor condition” in 2010.
“It was evident that this site had not had much maintenance carried out and it was in a very poor condition in so far as the tank storage area was concerned. Regrettably this site will require major attention and work to bring it back up to a compliant regulatory standard.”
Tanks were too close together and some showed “signs of corrosion” requiring attention.
Also present at the facility were “signs of environmental ground contamination”.
Comben’s report concluded that the Aitutaki port area was susceptible to fuel spillage.
“There is no secondary containment for the area and any leakage will naturally flow into the sea. The area where the containers stand is not secured, there is a possibility that they may be tampered with. This area is busy on the weekends, people park vehicles in the vicinity of the tanks which is not desirable given their volatile contents. The area needs to be secured, bunded, labelled with Hazard warnings and be issued with a Dangerous Goods Storage licence.”
The power station was applauded as a “model installation”.
Having been recently upgraded at the time of Comben’s visit in 2010, it was “clean with no evidence of spillage”. The station was progressing work to decommission service and day tanks, as old tanks were corroding and seeping diesel.
Service stations mostly improper
The former BP and Juhi tank farm at Panama, now owned by Pacific Energy Ltd, had the cleanest bill of health under the Dangerous Goods Act.
Most service stations that the New Zealand Department of Labour’s Kim Comben inspected in 2010 were being improperly maintained and operated.
The most shocking issue was environmental contamination, which seemed to be prevalent at filling points.
“It appears that the suppliers are nozzle filling the underground tanks and not using liquid tight and vapour tight connections. This is a hazard and will have to be followed up by the Ministry of Internal Affairs to establish the suppliers filling methods and where necessary take remedial action,” Comben’s report said.
Comben’s report again revisits the issue: “The matter of environmental management needs to be considered in addition to underground tanks having to be secondary contained. The vehicle standing area should be of an impervious service and drainage from the forecourt should be through via separator. This requirement should be implemented when a new service station is built or upgraded.”
Also of concern for Comben was the “relatively high ratio of fuel retailers on Rarotonga given the population”.
“It is questionable whether it is really necessary to have a high ratio of retail outlets. Consideration should be given on how to control the number of service stations. A new outlet had been opened in 2010 and another one was about to. Where an outlet closes and the premises cease to be licensed, the underground tank is to be removed. If the tank remains at a premises that has closed down it should continue to be licensed.”
The audit noted the preference of service station operators to bypass suppliers and pursue the cheaper route – importing petrol and diesel direct from New Zealand in tanktainers.
“The interest is not without its complications. As the first issue that arises is that the tanks at service stations are small, they would be incapable of containing the total volume from an ISO Tanktainer in single drop. Thus there would be a necessity to store the Tanktainer on site until it could be emptied. Most of the service stations are in residential areas and in one instance adjacent to a school.”
The arrangement was complicated by the fact that “bulk storage in residential areas presents a high hazard to the community”.
Comben did not provide a detailed analysis of each service station in the Cook Islands but made general observations. In particular, though, he noted that Aquila Service Station in Aitutaki was “being operated in a dangerous manner. It was clear that there was little or no understanding about the risks associated with the operation of a storage and dispensing facility for the retailing of fuels by the management. There were a number of matters that were a significant cause for concern.”
No sand covered the petrol tank, as is necessary for thermal protection in the event of a fire.
Tubing was “inadequate and dangerous”. The audit concluded that “the potential for a serious accident to occur at this site is very high”.
Red flags raised
A 2010 audit raises some major red flags in relation to the state of dangerous goods facilities on Rarotonga and Aitutaki.
Released on Tuesday, the audit report is revealing in its assessment of fuel and power suppliers and retailers in the Cook Islands.
It addresses issues around the proximity of fuel storage facilities to the foreshore and of service stations to private homes, the disproportionately high number of service stations on Rarotonga, and a widespread lack of emergency and fire plans.
In late 2009 the Ministry of Internal Affairs commissioned the New Zealand Department of Labour’s technical leader hazardous substances Kim Comben to inspect sites on Rarotonga and Aitutaki and to subsequently prepare a report. His visit followed on from an audit in 2008, and its objective was to determine whether his previous recommendations had been followed.
Comben conducted site inspections between May 18 and June 1 of 2010.
Since his visit, dangerous goods facilities have addressed his areas of concern, says the Ministry of Internal Affairs. In the absence of a comprehensive list of improvements and upgrades, Cook Islands News is publishing excerpts of the report which represents a snapshot of the circumstances as they were in 2010.
The Air BP Rarotonga facility rated high in terms of compliance with dangerous goods legislation.
At the time of Comben’s inspection, the Nikao facility belonged to BP, but has since been acquired by Tahiti-based company Pacific Energy Limited.
In 2010 the site was “well operated and maintained”, its purpose to deliver jet fuel from the wharf to the airport.
Comben did raise concerns around the location of the facility.
“There exists an ongoing matter with the continuous erosion of the foreshore. This will given time and major weather events have an effect on the operation of this terminal. It was confirmed at the time of the follow up audit that there had been no action in respect of the ongoing foreshore erosion issues. It is recommended that the new owners of the terminal monitor any foreshore loss over the longer term. Whilst this is not considered to be an issue in the short term, steps need to be taken so the loss rate of the foreshore can be established.”
Comben noted that since his 2008 audit, Air BP had followed recommendations, upgrading bunding “to BP standards” and fixing a corroded tank “with urgency”.
At the time of its 2010 inspection Air BP Rarotonga lacked a Rarotonga-specific emergency procedures plan and fire systems for its tanks.
The audit called Toa “non-compliant” with dangerous goods legislation.
Comben’s 2010 report noted that bunds were “ineffective in the containment of products should a major leakage occur”, and said that Toa’s “deficient” compounding “presents a serious risk to the site, the environment and the community”.
At the time Toa claimed it had not updated bunding and compounding because it was involved in litigation and because it could not predict the future of its nearly-expired lease.
Today, Toa says it is committed to becoming a fully-compliant facility.
“The area of non-compliance for Toa was that the bunded area surrounding the depot’s above-ground tanks was not impervious,” director Brett Porter wrote yesterday in an email sent from Auckland.
“This bunded area is required in case of a major fuel spill in order that fuel products do not leach and contaminate the surrounding land. Toa had committed to undertaking this work some four years ago when the requirement became mandatory under the Dangerous Goods Act.
“We could not however do the work until we had certainty of our lease on the Panama site. The move to Nikao for Toa enables us to provide the requirements for a completely compliant facility.”
The audit report also noted that a container had seeped waste oil through its bund wall and into the ground. However, Comben notes that “prompt action was taken to remedy this and a full repair was effected by the next day”.
Triad Pacific Petroleum
Triad Pacific Petroleum was also deemed non-compliant with regulations.
Comben raised initial concerns over Triad’s reluctance to allow him to inspect its premises.
“Initially when Mr J Tommy and myself visited the site for the follow up inspection I was informed by Mr Graeme Wiggs, manager of the site, who stated that Mr Chris Vaile the owner was not happy that I attend an inspection unless I was an employee of the Ministry of Internal Affairs. As a result we left the site without conducting an inspection, approximately one hour later the Ministry of Internal Affairs was advised by Triad that they had reconsidered their view and were willing to allow an inspection to commence. We then revisited the terminal.”
Upon entering the facility, however, Comben noted it was “evident” that Triad had undertaken “significant upgrading of the terminal”.
He then congratulated Triad for being equipped with “necessary safety data information” and an updated emergency plan.
Comben noted that Triad had put a “considerable effort” into replacing and strengthening bund walls which were found in 2008 to be “extremely deficient with evidence of ground contamination”.
He also observed that Triad had replaced pressure vacuum vents for unleaded petrol tanks, but said it was “perturbing... that it had taken two years”.
The audit raised concerns about Triad undertaking work without first obtaining consent.
Comben described “the practice of doing major changes (such as those described) without licensing authority consent” as “unacceptable”. He said the practice “perpetuates ongoing non-compliance issues and invalidates the Dangerous Goods licence that is issued for the site”.
Many of its tanks were not built according to specification.
The audit took issue with Triad’s location, acknowledging that the fault lies with a lack of “town planning”.
“The site where the terminal is located is susceptible to cyclones. Attention had been given to the seaward side of the terminal in respect of the installation of new cyclone resistant bund walls, these walls formed part of the upgrade to the bunding on the site. The issue of ongoing erosion is a matter that will need to be monitored over the longer term of the operation of the site. This terminal faces similar issues to the erosion of the foreshore as with the nearby Air BP Terminal.”
Comben’s audit notes that Origin’s standards of compliance “had slipped since the last audit in 2008 with little action having been taken on the 2008 audit”.
“The reasons for this are not entirely clear; however it was disappointing to see, especially from a company such as Origin Energy.”
The report raised concerns that Origin’s site was “dependent on sea water for fire-fighting purposes” and reliant on Airport Crash Fire, which is not available when aircraft are taking off and landing. The report was also concerned that Origin’s emergency plan was not complete.
Comben’s report observed that TMN Ltd, trading as Super Gas, was using tanktainers to store fuel rather than transport it.
“There appeared to be a belief that this was a satisfactory arrangement as long as the tanktainer was emptied within three days. This is not the case. Tanktainers are designed for the transport of product and not necessarily for longer term storage.”
It had not commissioned an environmental impact assessment report for increased storage, nor had it applied for a dangerous goods licence for same. There was also no fire protection in place.