The Observer, March 2005
More work needed on review of oil terminal overhaul – Council
State and federal regulators at the Joint Pipeline Office are revising their assessment of Alyeska Pipeline’s proposed overhaul of the tanker terminal in Valdez in response to detailed comments by the citizens’ council.
The agency issued its assessment in November and found the project would have no significant environmental impact. The council hired a contractor to go over the document, and concluded the no-impact finding was premature.
Alyeska has proposed a major upgrade--called Strategic Reconfiguration--of the Valdez terminal where oil tankers load North Slope crude. Photo by Stan Jones.
“We strongly recommend the Environmental Assessment be revised to examine all the impacts, alternatives, and consider additional mitigation to reduce the environmental impacts of this proposed project,” Executive Director John Devens wrote the pipeline office in a Dec. 30 letter accompanying the council’s comments.
The comments, including Devens’ letter, can be downloaded from the council web site, www.pwsrcac.org.
The council comments came one day after the federal Environmental Protection Agency weighed in to the pipeline office with similar concerns. “It does not appear that the EA (Environmental Assessment) has adequately identified and addressed the potentially significant air quality impacts on public health for the proposed reconfiguration,” wrote Christine Reichgott, an official in EPA’s Seattle regional office.
Alyeska refers to its massive undertaking as Strategic Reconfiguration. It would see major alterations to most major components at the terminal, including the fire-fighting system, power generation, vapor control, and the huge tanks used to store crude oil until it is loaded onto tankers. However, the Alyeska proposal omits one project the council hoped would be included in Strategic Reconfiguration: overhauling the facility that cleans oil remnants out of the ballast water of arriving tankers.
The Ballast Water Treatment Facility is a major source of dangerous air pollution at the terminal, and the council has been encouraging Alyeska to fix it for years. The council repeated the call for an upgrade in its December comments on Strategic Reconfiguration. The EPA letter also noted Alyeska’s failure to propose a plan for upgrading the ballast water facility.
Alyeska has indicated that the declining need for oily ballast treatment as a result of replacement of older tankers by new double-hulls – which carry very little oily ballast – will require overhaul of the facility, but the company has yet to identify a schedule or provide a plan for review.
The company, according to the EPA letter, had indicated it would reduce emissions from the Ballast Water Treatment Facility as part of Strategic Reconfiguration, but then didn’t address it in the proposal submitted to the Joint Pipeline Office. Additional information is needed, Reichgott wrote, to evaluate the project’s impacts.
Among the council’s concerns with Alyeska’s proposal:
• Failure to upgrade Ballast Water Treatment Facility as part of Strategic Reconfiguration.
• Proposed freshwater firefighting system might not provide enough water to fight a worst-case fire in the oil storage tanks. The existing system relies on seawater pumped from Port Valdez.
• Reducing the number of crude oil storage tanks, as proposed, could mean the tanks would fill up during protracted periods of bad weather. That could result in pressure to sail tankers in risky conditions, or to delay needed inspections, repairs, or scheduled maintenance.
• Reduced staffing could increase the chance of a catastrophic accident, or impair Alyeska’s ability to respond to one.
• Alyeska’s plan to put internal floating roofs on the crude oil tanks is not explained in enough detail to determine how it would affect the risks of fire, explosion or spills.
• Insufficient analysis of the social and economic impacts of reconfiguration.
• Analysis of Alyeska’s plans for new power generation vapor combustion systems failed to identify an environmentally preferable alternative, or adequately address fire and explosion risks.
The council’s comments grew out of a workgroup process. Participants included community members, as well as staff from the Joint Pipeline Office and Alyeska’s Strategic Reconfiguration team. Alyeska and the pipeline office participated on an advisory basis and were not co-signers of the comments.
Alyeska on Jan. 13 strongly defended its Strategic Reconfiguration plans in letters to the Joint Pipeline Office. The letters suggested EPA and the council misunderstood the project, the regulatory requirements, and the regulatory approval process.
“In sum,” wrote Robert Shoaf, Alyeska’s liaison to the Joint Pipeline Office, “the proposed system meets appropriate design criteria and will function as intended.”
The matter is now in the hands of the regulators. In late January, officials of the Joint Pipeline Office said the council’s concerns were being addressed and that changes would be made in the final version of the assessment. The pipeline office also said the council would be involved in future changes to the project.