This past November, the Alaska Department of Environmental Conservation, or ADEC, approved the renewal of the oil spill contingency plan for the Valdez Marine Terminal. The approval came with conditions.
The plan, created and managed by Alyeska Pipeline Service Company, describes how the company plans to prevent spills from the terminal in Valdez, and how they would contain and clean up oil in case prevention measures fail. The approval followed several rounds of public comment, which began in 2023, and is subject to several conditions. This means the plan is tentatively approved, but there are required steps that must be taken for the approval to be valid.
As one of the conditions, ADEC is requiring that Alyeska conduct further analysis of the secondary containment liners underneath the crude oil storage tanks at the terminal’s East Tank Farm. These liners, made up of catalytically-blown asphalt, are part of a system that is intended to contain oil in the event of a spill, preventing contamination of surface and groundwater.
The liners are hard to inspect because they are covered with five feet of ground material.
Credit for a solid liner
Alyeska receives a 60% “prevention credit” from ADEC based on the integrity of these liners. This credit allows Alyeska to plan for a smaller spill, thus reducing the amount of equipment and responders that are listed in the plan to begin a quick response.
The credit is contingent upon the asphalt liner meeting ADEC’s “sufficiently impermeable” standard. This standard is based on a formula that determines whether the liner is solid enough that it can contain spilled oil until it is detected and cleaned up. Cracks and damage have previously been discovered in some areas when the liner has been exposed.
Request for public review of test results
In a November letter to the department, the Council requested that ADEC allow a public review of any changes that result from Alyeska’s analysis of the liner. The Council also requested the addition of a deadline for the analysis and corrective actions if the analysis finds that the liner is not sufficiently impermeable to meet ADEC’s standard. ADEC issued a decision that imposed deadlines for completion of the liner evaluation by 2028. The department did not include a public review or corrective actions.
Future updates
These plans are required to be updated every five years by industry and submitted for public review. This update to the terminal plan expires in 2029.
How and why do contingency plans change over time? Read a 2021 Council-sponsored report on how the plan for a spill from tankers developed over the years:
Every five years, this oil spill contingency plan is renewed. The process starts with Alyeska, who updates the plan to include new technology or lessons learned during drills. A renewed plan is effective for five years, when the cycle will be repeated. This process ensures that the preparations for preventing and responding to oil spills will continue to improve.
Melton and his daughter show off their catch during a recent fishing trip. Photo courtesy of Matt Melton.
Matt Melton, like many others born and raised in Alaska, received an early education in oil spills. He was in fifth grade when he saw people on TV scooping up oil in buckets after the Exxon Valdez spill. His first instinct was to help. He asked his mom to take him to the cleanup but was told there were no hotel rooms in Valdez.
“Little did I know that this incident was going to have such an impact on my career,” he said.
Melton went on to study environmental science and technology at New England College during his undergraduate years, and later a master’s degree in organizational management at the same school. Then the 9/11 attacks happened.
“That was my first exposure to incident management,” Melton said.
New England College was close enough to New York that many students and the surrounding community were affected as many were during that time. As part of his studies, Melton assisted the campus operations team with crisis management planning. That experience set him on a career path in emergency response.
Today, Melton works in emergency response planning and training for PCCI, Inc., a Virginia-based company who maintains response equipment and conducts hazards training and exercises with global response teams.
Incident management, according to Melton, is a simple concept: assess, adapt, adjust, document, execute, and do it again. “It’s about preparing people to quickly and effectively solve complex problems during high-pressure emergencies,” he said.
Melton has responded to emergencies across different industries, ranging from oil spills to the COVID-19 pandemic. A key feature of a response is the Incident Command System, or ICS, a standardized emergency management structure first developed in the early 1970s to coordinate wildfire response. It has since been adopted for all types of emergency management.
Each response is different, and it’s impossible to plan for every detail in advance. He emphasizes that having the right people with the knowledge and experience to adapt is important.
“As soon as we’re done, we’re going to know how to do it,” Melton jokingly tells his trainees.
He pointed to the recent collapse of the Francis Scott Key Bridge in Baltimore as an example of large-scale emergency coordination. A ship lost power and collided with the bridge. The incident had the potential for major disruptions to regional and national transportation and economics.
“That was a massive collaboration of different entities. There were multiple entities represented in the Unified Command. You would think it would be crazy, but it went really smooth.”
Melton says training plays a critical role in effective response.
“People who don’t understand ICS get hung up on little things or let ego get in the way,” he said. “In Alaska, we train so much and focus on key operational aspects to achieve the objectives of the response.”
Melton sees a similar commitment to preparedness in the Council, where he serves as vice chair of the Oil Spill Prevention and Response Committee.
“We have a range of maritime and response experts who work who work hard to support the committee’s mission,” he said.
Melton volunteers for the Council because of what’s at stake.
“That pipeline and the ships that come in and out of Port Valdez represent a piece of the financial lifeblood of Alaska,” he said. “After any response, especially the Exxon Valdez, we learn a lot of hard lessons,” he said. “The RCACs, whether it’s Cook Inlet or Prince William Sound, don’t let folks forget where we ended and how we don’t want to go back there again.”
Melton adds that the industry and regulatory representatives who participate in the committee’s meetings are an important part of the process.
“They’re some of the biggest advocates for the environment and the people because they understand how critical it is to keep oil safely in the pipeline and on the ships,” he adds. “They don’t want spills any more than we do.”
In 2023, a Federal law was passed that could affect Alyeska’s contracted fleet of fishing vessels trained to help respond in case of an oil spill in Prince William Sound.
Fishing fleet available for a quick response
When the Exxon Valdez oil spill happened, the response was delayed. Much of the damage could have been lessened if clean-up efforts had started immediately. One of the most important lessons of that spill was that local fishing crews can help with a quick response.
The local fishing crews who joined the 1989 response realized that pulling oil spill boom was similar to pulling a net of fish. They also knew the region’s waters well, and were aware of dangers like shallow areas or changing tides that could leave a vessel stranded, among other hazards.
In the years since the spill, Alyeska formalized this relationship, developing a program to make sure they have a contracted fleet of vessels that are trained, on-call, and immediately available to support a response in case of another spill. Today, Alyeska holds contracts with more than 350 of these vessels. They invest in training for crew members every year to make sure they are always ready to respond.
Alyeska trains the crews to handle oil spill response equipment, tow oil spill boom in proper formation, and tow the small barges used to store the oil and water mix that is recovered during a spill response. They are skilled in deploying, operating, and maintaining this equipment.
Alyeska responders practice maneuvers in front of the Valdez Marine Terminal. Photo by Nelli Vanderburg.
Consequences for the contracted fishing vessel program
If a real event were to occur, Alaska’s fishing crews would be ready to respond.
However, a section of the National Defense Authorization Act of 2023 that was intended to exempt fishing vessels from the inspection requirements when working an oil spill was interpreted by Coast Guard to require the vessels to undergo inspections.
These vessels are uninspected and were designed and built specifically for fishing, not oil spill response. These vessels have not been subject to Coast Guard inspection before and many would not be able to meet inspection requirements, meaning they would be excluded from participating in a response.
“Trying to replace uninspected fishing vessels with vessels that meet Coast Guard inspection requirements would completely dismantle the program that has been part of the response system in Prince William Sound for decades,” said Donna Schantz, executive director for the Council. “This would greatly diminish oil spill response capabilities in our region, as well as the entire nation. The trained fleet, made up of contracted local fisherman who understand the waters, are the backbone of the response system and are essential to help mitigate impacts to people, communities, economies, and the environment.”
Workgroup partnership looking for a solution
The Council has been participating in a workgroup to help develop a solution that would allow the current fleet to remain in operation. Members include the Council, Cook Inlet Regional Citizens Advisory Council, Alyeska/SERVS, and other industry and oil spill removal organizations across the country.
In December, the Council welcomed a new staff member, Suparat Prasannet. Prasannet has a background in office management, previously overseeing operations at Alaska Immigration Law Center, where she streamlined systems and kept everything running smoothly. Alongside her administrative expertise, Prasannet is pursuing a degree in marketing.
Her duties as the IT/Admin Assistant for the Council include maintaining and managing hardware, software, online services, network infrastructure, and oversight of the Council’s historical digital archive, among other duties. She replaces Hans Odegard, who was promoted to Director of Administration last year.
