The Observer, May 2004

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Alyeska viewpoint: Alyeska ballast-water facility under study

by Rod Hanson

Late last month EPA’s Deputy Administrator announced plans to initiate rulemaking in response to petitions submitted by the citizens’ council and industry parties to EPA. These petitions requested that EPA reconsider its standards, issued in February, for hazardous air pollutants for facilities like the Valdez Marine Terminal that handle organic liquids. The citizens’ council describes its efforts elsewhere in this issue of the Observer. (See story, "EPA will reexamine air pollution question.")

What is Alyeska’s perspective?

Alyeska acknowledges that benzene and other volatile organics are released to the air from operations at the terminal’s ballast water treatment facility. We comply with our air quality permit requirements, though it’s true there are no specific air permit requirements governing waste water processes at our facility. As we’ve noted before, we disagree that a public health risk is presented by these emissions. A thorough air study in 1992 showed even without tanker vapor controls there was no unacceptable health risk associated with air emissions at the terminal. Today’s total terminal hazardous air pollutant emissions, including the ballast water treatment facility, are well under 10 percent of the emissions before tanker vapor controls were installed. Any health risk associated with terminal emissions has been correspondingly reduced more than 90 percent. Safety and health practices at the ballast water treatment facility to limit employee exposures, coupled with medical surveillance of potentially affected employees, show that we are taking appropriate steps to protect employee health. In over 20 years of medical surveillance, we have found no evidence of adverse health risk or adverse health effects to employees who participate in the surveillance program.

We recognize that many remain unsatisfied with these answers.

Alyeska values not only full compliance with regulatory requirements, including the strict terms of our federal water quality permit for the ballast water treatment facility. We are also committed to the health and safety of our workers and to the protection of the Alaska environment. We recently began a project to examine the performance of the Ballast Water Treatment Facility in light of continuing reduction in ballast volumes handled by the facility, a project that will also examine air emissions from the facility. Alyeska expects to learn from this study how well the facility is operating and how our operations may affect these emissions, and whether there may be operational steps that could minimize emissions. We are following a work plan that we have shared with the agencies, including EPA and the citizens’ council, and are taking their inputs on the plan and providing them the opportunity to observe our work. We will share the information we obtain from this effort with the agencies, the citizens’ council and the public.

Concurrently, we have initiated preliminary engineering studies that will evaluate the future operation of the ballast water treatment facility and the need to modify or otherwise replace portions of the facility. The engineering studies will include consideration of processes and equipment that may reduce emissions while maintaining or improving the efficiency of the facility. We have also provided access to the facility to the citizens’ council’s staff and consultants to allow the citizens’ council to conduct its own studies of its processes. We expect to share information as these efforts move forward. As we make decisions about potential changes at the Valdez Marine Terminal, we will look for ways to further reduce any health and safety risks and further reduce emissions from Ballast Water Treatment Facility as we are with other terminal facilities and operations.

Our vision for the Valdez Marine Terminal of the future is for a simpler, less complex operation that strives for flawless safety and system integrity and meets standards of environmental performance and regulatory commitments. The tanker fleet is already transitioning to modern double hull tankers that do not carry, or carry much less, ballast water that requires treatment. Throughput at the ballast water treatment facility is less than a third of design capability, and diminishing. As ballast throughput diminishes, emissions diminish as well. Declining ballast throughput and tanker fleet changes are realities that drive our engineering analysis for a cost-effective, environmentally sound operation.

There is no question that we will continue to have many discussions about the ballast water treatment facility. In the meantime, Alyeska is not standing still. We are taking initiatives today to assure that future treatment of much smaller volumes of oily ballast at the Valdez Marine Terminal will be part of a package of operations that will be more cost effective, occupy a smaller footprint, reduce the risk and consequence of spills, and reduce impacts to the environment we all share.

• Rod Hanson is manager of Alyeska’s Valdez Marine Terminal.