The Observer, September 2006
Alyeska Viewpoint: Management of spill response training is revamped
By Tom Stokes, manager Valdez Marine Terminal
Tom Stokes
The Valdez Marine Terminal (VMT) Oil Spill Response Training Management Program addresses an important area of emergency preparedness within Alyeska’s operations and maintenance. While emergency preparedness is a best practice, it is also regulated by both federal and state governments. Compliance with state and federal oil spill response regulations, such as 18 AAC 75, 40 CFR 112, and OPA 90, require Alyeska to have trained oil spill response personnel. The regulations also require that training be documented and adequate numbers of trained responders are available for response. Alyeska’s grant and lease requires trained and qualified personnel to be available for the effective operation and maintenance of the Trans Alaska Pipeline System (TAPS).
By meeting these requirements, Alyeska maintains its license to operate TAPS.
Besides assisting tankers in distress, Alyeska’s escort tugs can also start the response to an oil spill. Photo courtesy of Alyeska Pipeline.
Last year, as a result of internal and external reviews, the VMT launched a project to analyze and address detailed oil spill response needs for the terminal that resulted in recommendations for some major revisions in the oil spill response training management program. After a year of effort, the VMT response training has been substantially updated and systematic processes for sustaining the program were included.
To initiate the project, the first objective was set to re-define and document a program to assure personnel involved in oil spill response and incident management team functions described in the VMT Oil Spill Contingency Plan were appropriately trained and qualified to fulfill their roles and that documentation was readily available. In updating the spill response training program, considerations included the assurance that regulatory compliance would be maintained and the design would be flexible to allow for future personnel changes. This flexibility was critical in viewing the company moving into the future with the recognition of personnel turn-over and system changes. In terms of designing a program, this meant the first step was to be very clear about response job roles as well as who is assigned to each role. This first objective was substantially completed and this cleared the way for the second objective: making certain that response personnel identified in response roles are qualified.
The second objective was fulfilled by identifying the minimum training requirements for each role defined in the response. Once roles were compared against the identified training requirements, the project team was able to identify any training course or learning gaps in the system. The next objective was to identify all responders with their potential response roles and compare their training histories against the identified standards.
And the final objective was to create a review/assurance process whereby each role qualification was evaluated. To sustain the training program over the future, job roles were assigned to positions and qualification tracking becomes a function of the system defining the annual training requirements for Alyeska.
The scenarios in the oil spill contingency plans that Alyeska is required to staff represent the response planning standard or worst case discharge scenarios for each contingency plan. With the new oil spill training management program, Alyeska can continuously show that the numbers of responders are available and appropriately trained. Additional benefits include consistent training documentation and identification of requirements for an oil spill response.