Council’s archives hold valuable lessons

Donna Schantz

Since its inception, the Council has placed a high value on keeping a historical record of documents related to the transportation of oil through Prince William Sound. This includes information that documents the background and rational for implementing many of the safeguards put in place based on lessons learned from the Exxon Valdez oil spill. Our archive today is home to over 36,000 files containing a wealth of information.

Many of these documents are scientific studies and technical reports sponsored by the Council, dating back to the early days of our existence. A great example are two studies conducted by Dr. Richard Fineberg in the early 2000s, one on the profits from the oil industry and another on how the industry plans to clean up its facilities after oil no longer flows through the pipeline.

Dr. Fineberg, who died in 2024, conducted studies for other organizations, and our internal document archives contain a record of many of them. A look through some of these is enlightening, such as his 1996 report titled “Pipeline in Peril – A Status Report on the Trans-Alaska Pipeline.” This report was sponsored by the Alaska Forum for Environmental Responsibility, which is no longer in business, to look into reports from “concerned employees” that Alyeska had been cutting corners, putting employees and the environment at risk.

These sentiments echo statements made by concerned employees starting in 2022, as documented in our 2023 report by Billie Pirner Garde titled “Assessment of Risks and Safety Culture at Alyeska’s Valdez Marine Terminal.”

Who is paying attention to these details?

After the Exxon Valdez oil spill, the U.S. Congress found that complacency on the part of industry and government was a contributing factor to the incident. The writers of the Oil Pollution Act of 1990 included a call for the creation of citizen councils to give citizens a voice in the decisions that can put their livelihoods, resources, and communities at risk.

Our organization is one of those councils. Our 2023 Garde report is a reminder that our mission and purpose are not only still relevant, but needed just as much if not more today. Fortunately, upon receiving the Garde report, Alyeska initiated a hard look at their safety culture, technical capacity, process and policy, as well as the safety concerns brought forward, and has taken actions to address many of the concerns.

Why is oversight important?

Walt Parker, former member of our Board, had a long history of involvement with the oil industry in Alaska. Among the many roles he served during his career, Parker was appointed chairman of the Alaska Oil Spill Commission that was created to investigate the causes of the Exxon Valdez spill. The Commission issued 52 recommendations to improve national, state, and oil industry policies, including one recommendation that called for the creation of our Council. In the forward to their final report, “Spill: The Wreck of the Exxon Valdez – Implications for Safe Transportation of Oil,” Parker described their efforts in the 1970s to design a system that would prevent spills from the soon-to-be oil transportation facility.

Parker wrote that the 1989 spill “could have been prevented if the vigilance that accompanied construction of the pipeline in the 1970s had been continued in the 1980s.”

Instead, as the commission discovered, by 1989, complacency and cost-cutting had returned, leading to disaster.

Fighting complacency

The Council was created, in part, in anticipation of a time when memories of the Exxon Valdez oil spill begin to fade. When there is no one left who can recall the smell of the oil, the sight of suffering wildlife, the feel of anger and despair because livelihoods may have been destroyed, it is more likely that protections may begin to appear stale, burdensome, and unnecessary.

The fact that there has not been another major oil spill in our region since 1989 is a testament to the safeguards put in place following that disaster. These safeguards are built on many lessons learned over time; historical knowledge that is key to maintaining our present system of prevention and preparedness. It is critical that industry, government, and citizen leaders remain cognizant of that history. The Council will always advocate for maintaining and improving our current systems, as well as staying vigilant against measures that could allow complacency to weaken existing protections.

Approval for oil spill contingency plan for terminal comes with conditions

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.

Secondary containment liners must be evaluated

This image shows the giant crude oil storage tanks at the Valdez Marine Terminal. The walls of the massive asphalt-lined cells can be seen surrounding the tanks in this photo.
The Council has been concerned about these nearly 50-year-old liners for years. In 2023, the Council funded a project to evaluate methods that could be used to inspect the underground liners without excavating them.

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:

The image is a graphic showing the cycle for renewal of oil spill contingency plans. The cycle begins with industry drafting updated plans, which is submitted to the Alaska Department of Environmental Conservation or ADEC. Sometimes ADEC requests clarifications or more information. Once they are satisfied, ADEC opens a public comment period. The Council and other members of the public submit comments, and ADEC reviews the input. Sometimes complicated issues require an extra public review period. Once ADEC is satisfied, they issue a final approval. Over the next five years, the plans are tested during drills and exercises. Then the cycle begins again when the industry takes the lessons from drills and drafts a new proposed plan.
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.

Law could adversely affect fishing vessel response program

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.

A small vessel pulls a bright yellow boom into formation during an exercise. The Valdez Marine Terminal is on shore in the background.
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.

Anchorage meeting and events, January 23-24

The Prince William Sound Regional Citizens’ Advisory Council will held a Board meeting in Anchorage Thursday and Friday, January 23-24, 2025.

The Council conducted regular business during the meeting, including updates from Council ex officio members, staff and committees. Other topics included on the agenda were:

  • An activity report by Alyeska Pipeline Service Company on the Valdez Marine Terminal and Ship Escort Response Vessel System operations, including a presentation on their Risk and Safety Culture Assessment Management Action Plan Closeout Report.
  • An update from Council staff on the renewal of the Valdez Marine Terminal contingency plan and subsequent request for informal review relating to concerns about analysis of the East Tank Farm secondary containment system liners.
  • A presentation on volatile organic compound and hazardous air pollutant emissions from the 2022 crude oil storage tank vent incident at the terminal.
  • A report on additional information requested by Alyeska related to the Council’s 2023 “Crude Oil Storage Tank Vent Damage” report, which outlines concerns related to worker safety in the aftermath of the 2022 tank vent damage incident.
  • Reports on the results from the Council’s Long-Term Environmental Monitoring Program 2024 sampling for hydrocarbons and a pilot study to analyze 23 metals in sediments collected adjacent to the Valdez Marine Terminal and Gold Creek reference site.

Council Board meetings are routinely recorded and may be disseminated to the public by the Council or by the news media.

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