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PWSRCAC's Voice in Contingency Plan Review
PWSRCAC's Oil Spill Prevention and Response Committee (OSPR) is actively involved in the contingency plan and drill review process on a continual basis. As mandated by the Oil Pollution Act of 1990, one of the council's responsibilities is to review these plans in light of new technological developments and changing circumstances.

This role is an important way to combat potential industry and agency complacency because it involves local citizens in the process of preparing, revising, and adopting oil spill contingency plans.

 


Chemical Dispersants: Are They Safe and Effective?

Chemical dispersants are substances applied to spilled oil that disperse oil into the water column, rather than leaving it floating on the surface in a slick.

Among the council's concerns is the scarcity of reliable scientific data about the efficiency, toxicity, and persistence of dispersants and dispersed oil in Prince William Sound/Gulf of Alaska conditions.


Oil Spill Response Progress


An oil skimmer is lowered over the side of a boat-PWSRCAC photoOne of the council’s responsibilities is to monitor the adequacy of oil spill response, so we participate in drills and actual responses in several ways. Our representatives convey local concerns, advice, and observations to the officials managing the response. They also help communicate developments in the response effort to local communities.

Prevention measures can reduce the size and frequency of oil spills. But prevention efforts will never become fail-safe, so the industry, regulatory agencies, and the public must be prepared to respond to spills that do occur. It is incumbent upon those who handle and carry crude oil, as well as regulatory agencies and the public, to make sure that spilled oil is contained and recovered to the greatest extent humanly possible.

The speed and effectiveness of the response to an oil spill depend on the availability of equipment, resources, and trained personnel; on planning and preparation; and ultimately, on favorable weather.

 

Contingency Plans


Anyone who handles or transports crude oil or refined oil products as cargo must have a government-approved contingency plan for preventing and responding to spills. State and federal laws and regulations determine what must be in the plan and what must be provided in the way of drills, training, acquisition of equipment, etc. The requirements depend on the type of vessel or facility, the location, and the amount and type of cargo involved.

Alyeska Pipeline was required to have a contingency plan before the Exxon Valdez spill, but it was not well implemented. Spill response duties were assigned to personnel with other day-to-day operational tasks and equipment was not adequately maintained. The initial response in March 1989 was slow, ineffective, and poorly coordinated.

The size of spill assumed in a response plan makes a tremendous difference in the resources and equipment that must be available. Alyeska's 1987 contingency plan, approved by the state, said a spill of 8.4 million gallons (three-quarters the size of the Exxon Valdez spill) was highly unlikely and reasoned that "Catastrophic events of this nature are further reduced because the majority of tankers calling on Port Valdez are of American registry and all of these are piloted by licensed masters or pilots."

Since then, state and federal agencies have expanded plan requirements and changed some of the assumptions. The federal Oil Pollution Act of 1990 (OPA 90) and Alaska state laws passed after the Exxon Valdez spill led to the first regulations requiring contingency plans for individual tankers.

• Both state and federal law now require planning for larger potential spills than in the past, and require more spill response equipment to be immediately available.
• Plan holders must have enough equipment immediately available to deal with a spill of 12.6 million gallons of oil (slightly larger than the Exxon Valdez spill) within 72 hours.
• They must also plan for spills of almost 40 million gallons, but may rely more on equipment to be brought in from outside the Prince William Sound area for these larger spills.
• Those required to have contingency plans in order to operate must provide greater assurances that personnel are being trained, that equipment and resources are available to be mobilized quickly, and that all players have practiced their roles in preparation for an actual spill.

As the consortium that operates the trans-Alaska pipeline and terminal for its seven owner companies, Alyeska Pipeline holds the contingency plans for spills on the pipeline and at the Valdez tanker terminal. In Prince William Sound, the tanker owners and operators must have their own approved contingency plans, although they contract with Alyeska Pipeline to provide the initial response described in the plans.

Under these contracts, Alyeska Pipeline manages the spill response for up to the first 72 hours after a spill. After that, it may transfer management of the response to the spiller, as long as the U.S. Coast Guard and the Alaska Department of Environmental Conservation (ADEC) agree that the spiller or its representative is ready to take over.


Equipment Ready


Conex units at Tatitlek store oil spill response equipment--PWSRCAC photoThe first three days after the Exxon Valdez oil spill afforded nearly ideal weather for oil recovery. Seas and winds were calm. But the equipment wasn't ready. Seventeen hours after the grounding, neither the leading edge of the spill nor the grounded tanker had been boomed. The few skimmers on-scene were operating ineffectively. Skimming soon halted because there was no more room to store the recovered oil-water mixture. Throughout the first few days, debate raged about use of dispersants. Exxon argued for widespread dispersant use, but didn't have enough dispersant or the equipment to do the job and never received regulatory approval.

The situation now is quite different. Prince William Sound is home to Alyeska Pipeline's Ship Escort Response Vessel System (SERVS), one of the top oil spill response forces in the world.

SERVS has several functions. It helps tankers navigate safely through Prince William Sound and responds to a tanker problem or a spill. SERVS also responds to spills on the southern portion of the trans-Alaska pipeline and at the Valdez tanker terminal.

Today, Alyeska has at its disposal more than 60 skimming systems with a combined recovery capacity of over 12 million gallons of oil-water mixture in 72 hours. In 1989, only 13 systems were available; their combined capacity was about 1.2 million gallons in 72 hours.

A general concern of the council is that the oil industry may not be able to import spill-response equipment from outside the Prince William Sound region with the rapidity and in the quantities called for in the contingency plans. In a September 1998 drill, BP demonstrated it could import and deploy limited quantities of equipment from outside the region, but the council will continue to press government regulators to ensure the industry can perform on the scale required in this area.


Nearshore Response


Some of the changes since 1989 put more emphasis on shoreline protection, identification of sensitive areas such as hatcheries, and wildlife protection. A new term was coined—Nearshore Response—to describe the effort to protect shorelines threatened by spilled oil that has escaped initial containment.

Nearshore response is a major component of spill response in which local personnel, knowledge, and resources can be used to protect critical resources and shorelines. Industry groups, the citizens' council, and regulatory agencies have worked cooperatively to develop nearshore response plans.

Local fishing vessels are part of Alyeska's planned nearshore response. They are used, among other things, to transport response equipment, deploy and tend boom, and mobilize pre-staged equipment to protect fish hatcheries. Alyeska has provided response training to hundreds of fishing boats and their crews. The fishing vessels, based in communities in Prince William Sound, the Kenai Peninsula, and Kodiak Island, are under contract with Alyeska to respond to spills if willing and available at the time of an incident.

The oil industry has stockpiled spill containment and removal equipment at five fish hatcheries in Prince William Sound and at five community response centers that have been established in the sound. They are at Chenega, Cordova, Tatitlek, Whittier, and Valdez.

Two similarly equipped centers have been set up outside Prince William Sound. They are in Kodiak and Seldovia, and were established by the communities and the State of Alaska.

Each center provides manpower, equipment, and coordination of emergency responses. Response training for fishing vessel operators is provided by the industry, the State of Alaska, the Coast Guard, and the communities themselves.

Storage capacity for recovered oil was a problem in the 1989 recovery effort, when only a single barge with room for 500,000 gallons of oil was available. Boats would pick up the emulsified oil, only to find there was nowhere to put it. Alyeska now maintains storage capacity, much of it on barges, for over 34 million gallons of recovered oil and water mixture. However, the availability of adequate storage for recovered oil is still an outstanding question. The citizens' council has requested demonstrations to verify that lack of storage won't hinder nearshore oil recovery operations.

The oil industry is much better prepared today for nearshore response than it was a decade ago, but there is still room for improvement. The council believes the latest versions of the plans aren't specific enough about where boats and other equipment for nearshore response will come from. In particular, the council believes the full implementation of the nearshore plans as written would require the use of more commercial fishing vessels than are likely to be available at one time.

Spill Drills


Spill drills enable response personnel to become knowledgeable and proficient in the strengths and weaknesses of equipment and procedures. Before 1989, there were no major oil spill drills; today, major drills are conducted once a year, with frequent smaller drills. The major drills include state and federal agencies, fishing vessels, tanker owners and operators, and the citizens' council.

PWSRCAC is involved in monitoring the operational readiness of the Alyeska response system and equipment. The council has maintained the Preparedness Monitoring project since 1992.

An important aspect of spill response implemented since 1989 is use of the National Interagency Incident Management System, an incident command system first developed by fire fighters in California to coordinate management, resources, and roles during an emergency response.

In Alaska, this approach integrates the party responsible for the spill, the state, and the Coast Guard in a unified command structure that expands according to need. It also establishes a pre-determined decision-making process and a common language that significantly reduces confusion and misunderstandings among personnel from different organizations. This structure has been adapted by industry and government agencies to define and coordinate their roles and responsibilities in the event of a spill. The Incident Command System has been tested and practiced extensively in drills.

The Incident Command System's need for quick, wide-ranging communications is supported by a radio repeater system installed to cover Prince William Sound, Cook Inlet, and parts of the Gulf of Alaska.

State and Federal Funding


After the Exxon Valdez oil spill, an existing state spill response fund was expanded to ensure that reserves would be available for a major oil spill and to provide a long-term funding source for the State of Alaska's spill prevention and response programs. The money for this expanded role comes from a five-cent surcharge on every barrel of oil produced in Alaska. The surcharge drops to three cents when the reserve set aside for oil-spill response reaches $50 million; if the reserve is drawn down in an actual response, the surcharge rises to five cents again until the reserve is replenished.

To ensure that money will be available to pay for responding to and cleaning up major spills nationwide, the federal Oil Pollution Act of 1990 (OPA 90) required establishment of a $1 billion oil spill liability trust fund, funded by the oil industry.

OPA 90 strengthened federal authority to order spill cleanup action and requires the Coast Guard to direct spill response actions when any spill poses a risk to public health or safety. It also provides tougher criminal penalties and higher civil penalties for the spiller.