2010-2011 Annual Report
Environmental Protection and Monitoring
Environmental Protection & Science
The Oil Pollution Act directs our council to review, monitor, and comment on Alyeska's environmental protection capabilities, as well as the actual and potential environmental impacts of terminal and tanker operations. The Act also calls on us to develop recommendations on environmental policies and permits. The council carries out this work through two major programs: Terminal Operations, and Environmental Monitoring. Under the leadership of the Scientific Advisory Committee and the Terminal Operations and Environmental Monitoring Committee, the council commissions scientific studies to determine actual or potential risks, to document levels of pollution and biological effects, and to better understand new technologies and the environmental costs or benefits that might be associated with their use.
Operations at the Valdez Tanker Terminal
Besides posing the risk of a major oil spill caused by earthquake or accident, Alyeska's Valdez tanker terminal produces ongoing air and water pollution from routine operations, as allowed by its permits from regulatory agencies. The council monitors terminal operations with the goals of minimizing the risk of spills and ensuring that permitted pollution is within or below regulatory limits and that those limits are set at the lowest feasible levels.
Oil Flow in Barrels and Dollars
The council has monitored oil loading at the Valdez Marine Terminal since January 2003. At that time, an average of 968,000 barrels of North Slope crude moved onto tankers every day, down from a peak of about 2 million barrels per day in the early 1990s. Oil flow has continued to decrease, reaching a rate of only about 541,000 barrels per day during the first five months of 2011.
Economically, the decline in production has been more than offset by
increasing oil prices. In 2002, the oil moving through Valdez was valued at about $700 million per month. In May 2011, the oil loaded at the Valdez terminal was worth about $2 billion, almost three times as much.
The council continues to monitor storage of incoming crude at the Valdez Marine Terminal. The storage tanks where the oil is held until it can be loaded onto tankers have a total working capacity of 6.9 million barrels. Inventories during the second half of 2010 generally ranged from 30 percent to 80 percent of capacity. Maintaining adequate storage capacity is important as a shock absorber to give the terminal sufficient flexibility to cope with fluctuations in pipeline or tanker operations.
In January 2011, leaks in the piping at Pump Station 1
at Prudhoe Bay prompted the shutdown of the pipeline for two extended periods while temporary fixes were implemented. During these shutdowns, some tanker loading continued at the terminal, with the result that storage tank inventories were drawn down to the point—about 7 percent of capacity—below which Alyeska prefers not to go for fire safety and other reasons. However, inventories increased again as normal operations resumed, and, by the end of the first half of 2011, were approaching the 90 percent level of approximately 6.2 million barrels.
Inventories are not permitted to exceed 95 percent, and inventory levels above 80 percent are deemed problematic by Alyeska, regulators and the council. When needed, the company directs North Slope oil producers to cut back on production to prevent over-filling the Valdez storage tanks.
During 2010 and 2011, storage inventories ranged from 80 percent to 85 percent on 14 occasions and were between 85 percent and 90 percent on two occasions. High inventories are typically due to restricted loading attributable to either adverse weather conditions or berth maintenance. On occasion, the lack of availability of a tanker may cause a spike in inventory.
Air and Water Quality
For many years, the council has been concerned about emission of hazardous air pollutants from the Ballast Water Treatment Facility at the Valdez terminal. This facility services tankers arriving in Valdez with oily ballast water in their cargo tanks, and, as recently as 2003, processed 10 million gallons of it per day. Though the use of oily ballast has declined with the advent of double-hulled tankers—which carry ballast water in dedicated tanks between their hulls rather than in their oil tanks—the facility still treats an average of 2 million gallons per day of oily ballast as well as fresh water that collects in the man-made containment ponds—known as secondary containment cells—around the crude oil storage tanks.
Emissions from the ballast water facility were greatly reduced when vapor controls were installed on the first stage of water treatment in 2008. Additional reductions occurred in 2010 and 2011 when vapor control was expanded to encompass the entire treatment process. The council estimates air pollution from the ballast water facility has been reduced by 98 percent from 2003 levels.
System Integrity Issues at the Terminal
The council monitors operations at the Valdez terminal with several goals in mind.
One is to ensure that system issues having the potential to increase the risk of spilling oil to the environment or to increase air or water pollution during routine operations become known to the council in timely fashion. Areas of concern include:
• liner breaches in the secondary containment cells surrounding the oil storage tanks
• biological treatment of ballast water
• pipe and tank corrosion
• stability of rock slopes behind the power generation and ballast water facilities, and
• uncontrolled venting of oily vapors from the storage tanks.
Another goal is to ensure that proper procedures are developed and implemented to resolve new issues as they are identified.
One example of the council's work at the terminal is its continued monitoring of resolution of a set of ongoing secondary containment issues that are both old and new. They include repair of leaking manholes, repair of leaking industrial waste water sewer piping and the integrity of the secondary containment liners.
The integrity of the liners for the secondary containment cells around the oil storage tanks is important because these cells are intended to capture any oil spilled from the tanks themselves. The liners, made of special-purpose asphalt, appear to be fragile, with multiple instances of damage having been discovered in 2010 and 2011 during routine excavations. While it's unclear where Alyeska is in the process of developing and implementing measures to remedy the situation, regulators have indicated they expect permanent repairs to be complete by October 2012. The council continues to monitor the process to ensure the future integrity of the secondary containment system.
As a part of its efforts to assure compliance with new air quality regulations on emissions of particulates and carbon monoxide from its power boilers, Alyeska is exploring design changes to its electrical power generation system. At the company's invitation, the council participated in review of these design changes.
Maintenance Advisory Audit
The council became concerned about the condition of some of the equipment at the Valdez Marine Terminal after a number of issues apparently related to a lack of timely maintenance came to the council's attention. The issues included ongoing testing and repairs of the secondary containment cells around the oil storage tanks, the failure of a valve used to prevent the vapor pressure from becoming either too high or too low inside an oil storage tank, an actuator
failure on a flow valve in the firewater system that would have prevented it
from closing on demand, a washed-out protective berm on a slope above the building where oil being loaded to tankers is metered, and concerns about the condition of ground strapping for some of the terminal's high-voltage electrical distribution systems.
At its September 2010 meeting, the council board voted to review Alyeska's maintenance processes and activities at the terminal. The council contracted with a maintenance audit team consisting of experts intimately familiar with Alyeska's maintenance practices for the purpose of determining the extent to which Alyeska's maintenance activities are backlogged, and the extent to which such activities are in compliance with Alyeska's internal procedures and all applicable technical, legal, and regulatory requirements.
Alyeska's work to fix the leaks discovered in January 2011 at Pump Station 1
limited the company's ability to participate in the maintenance audit until March 2011. Once Alyeska was able to support the on-site activities of the maintenance audit team, three visits to company facilities were made from March through June to examine maintenance procedures and maintenance records, and to select specific systems and process equipment for detailed scrutiny. Numerous personnel, including managers responsible for maintenance, were interviewed for the purpose of developing an understanding of actual maintenance practices and comparing them with maintenance requirements and procedures for implementing the requirements as dictated by state federal regulations and good engineering practice.
In August 2011, as the contractors neared completion of their report, Alyeska Pipeline and regulatory agencies received briefings on the council's findings. It was anticipated the audit report would be completed in time for council board review and approval in September 2011.
Environmental Monitoring & Science
The council monitors the environment of Prince William Sound and adjoining waters for impacts from oil-industry operations. Scientific research into such impacts, as well as research into the effects of some oil-spill response tactics, makes up a large part of the work done under this program.
Chemical Dispersants
Chemical dispersants are substances designed to disperse spilled oil into the water column, rather than leaving it floating on top in a slick. The council promotes research and testing to increase knowledge about chemical dispersants and the environmental consequences of their use in Alaska waters.
The council has raised concerns about the efficacy and toxicity of dispersants for years, urging regulatory agencies to be conservative in their use. Because outstanding questions have not been answered and research has not demonstrated that dispersants would work at all in the waters of Prince William Sound, these concerns remain largely unaddressed and the council continues its advocacy for research into dispersant use in cold seawater. The council has taken the position that chemical dispersants should not be used in oil-spill response in our region until they are demonstrated to be effective and shown to minimize environmental harm.
In early 2009, the council accepted two valuable literature surveys—"A Review of Literature Related to Oil Spill Dispersants 1997-2008" and "A Review of Literature Related to Oil Spill Solidifiers 1990-2008." (Oil spill solidifiers are products that combine with oil to produce a more solid, less sticky, rubbery compound that is easier to pick up and remove from the environment.)
These reviews were complemented by a searchable Excel database of all the recent research reports identified in the reviews. This database was updated in early 2010 to include research reports from 2009 and again in 2011 to include research reports from 2010.
Council representatives continue to participate in the Alaska Regional Response Team's Science and Technology Committee as it prepares to update the Alaska dispersant use guidelines. Information on the council's work on dispersants is available online at
www.tinyurl.com/pwsrcacdisp.
Hydrocarbon Toxicity
This project researches and addresses the gaps in knowledge about the long-term toxic effects of oil, dispersed oil, and residue from in-situ burning under study conditions closely approximating the marine waters in the council's region.
The biggest toxicity data gap is on the long-term effects. Thus, the project focuses on the components most involved in those effects, such as polycyclic aromatic hydrocarbons.
Two contracts under the project are under way, one with the Department of Fisheries and Oceans Canada and the other with the National Marine Fisheries Service.
Invasive species
Invasive species, long a major concern for the citizens' council, refers to the problem of non-indigenous plants, animals, or microorganisms reaching Alaska and establishing themselves here. Such invasions can harm native species, including commercially valuable ones such as salmon.
For the council, the primary concern is non-indigenous organisms arriving via oil tankers—either attached to hulls or riding in the ballast water that the tankers discharge into Prince William Sound before loading North Slope crude at the Alyeska terminal in Valdez.
The ballast water problem arises from the fact that most modern tankers employ segregated ballast tanks where "clean" seawater is used for stability. This "clean" ballast, taken in at ports of origin, teems with living organisms. While some are removed during the tanker's trip north, many remain to be discharged into Prince William Sound with the ballast water as the tankers approach the Alyeska terminal for loading.
Hull fouling occurs when organisms grow on oil tanker hulls in one port, and then are carried to different ports where they may fall off or reproduce and cause an invasion.
Because of the potential for invasions by harmful species, the council has made this issue a high priority since 1996.
For the third year in a row, the council supported an effort in the state legislature to create an Alaska Council on Invasive Species to serve as a statewide clearinghouse and coordinating body. Seats would be held by commissioners of state departments, and by representatives of soil and water conservation districts, conservation organizations, farmers, landscapers, commercial fishermen, commercial shippers, the University of Alaska agricultural program, Native corporations, and the public at large. No bill was introduced in the 2011 session so the council is searching for other options.
The council continued to provide leadership to citizen monitoring efforts, particularly for the European green crab. This crab, a known ballast-water-borne invader,
is an efficient and voracious predator that has invaded the west coast from San Francisco to Vancouver Island. It is feared that the green crab will find its way to
Alaska waters.
The monitoring program has evolved into a self-sustaining grassroots system since it was initiated by the council in 2000. Many communities now run their own operations. In Homer and Seward, they're handled by local science centers. The council continues to support some of the smaller communities to encourage participation for those areas. No green crabs have yet been captured in the council region by these trapping efforts.
Regional Environmental Monitoring
In 1993, the council established a Long-Term Environmental Monitoring Program, called LTEMP. The program assesses the status of hydrocarbon levels in the Sound, as well as long-term trends and any new developments that could have an effect on those levels.
Samples are collected at ten intertidal sites in Prince William Sound and the Gulf of Alaska. Mussel tissues and sediments from the sites are analyzed in a laboratory to determine whether hydrocarbons are accumulating, and, if so, their source. The result is the largest chronological data set ever compiled for hydrocarbons in Prince William Sound.
LTEMP sampling is conducted once per year at the two Port Valdez sites and at one site in eastern Prince William Sound. Every fifth year, all ten sites will be sampled. Before the current schedule was adopted in 2009, the sampling frequency was as high as three times annually at all ten sites.
The council's LTEMP reports, along with additional information on the program, are available online at www.tinyurl.com/ltemp.
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