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Contingency plan for terminal under review

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The oil spill contingency plan for the Valdez Marine Terminal is undergoing its five year renewal. During a public comment period in December, the Council voiced concern over a “prevention credit” that reduces the amount of oil that the industry must be ready to clean up if a spill were to occur.

One of the Council’s primary duties is reviewing spill contingency plans for the oil industry in Prince William Sound. The Council has been reviewing these plans since 1990.

“Over 30 volunteers, staff, and contractors spent hours reviewing documents and coordinating these comments,” noted Linda Swiss, the Council’s project manager for contingency planning. The three volumes that make up the oil spill contingency plan for the Valdez Marine Terminal contain over 1,000 pages in total.

What’s in a contingency plan?

Oil spill contingency plans contain details about the steps to be taken before, during, and after an oil spill.

  • Before: what’s being done to prevent an oil spill
  • During: how the industry will respond to an oil spill, including where the equipment and personnel would come from
  • After: plans are updated to reflect lessons learned from previous spills

“These plans are a good way for stakeholders to understand how their resources and livelihoods are protected,” Swiss says.

Oil spill contingency plans are prepared by the operators of Alyeska’s marine terminal and oil tankers and are subject to state approval.
There are separate plans for spills from the Valdez Marine Terminal and from the tankers that load crude oil at the terminal. Plans undergo an update, review, and approval process approximately every five years.

Liners under crude oil storage tanks still of concern

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 crude oil storage tanks at the Valdez Marine Terminal are surrounded by massive asphalt-lined cells that are designed to contain oil in case of a spill from a tank. The cell walls can be seen in this photo. Photo by Linda Robinson.

One of the central issues the Council is concerned about is an asphalt liner surrounding the large oil storage tanks.

Each tank holds approximately 23 million gallons of oil. If a tank were to leak oil, the liners act as a backup system that is supposed to contain the oil until it can be cleaned up and before it can contaminate ground water or Port Valdez. The backup or “secondary containment” system consists of a huge bowl-shaped area around the tank. The area is lined with asphalt, which is buried under several feet of gravel.

Why does the Council care about this liner?

The Exxon Valdez oil spill taught the lesson that a certain amount of equipment and trained personnel must be on hand to respond quickly.

The amount of response equipment and personnel varies according to the storage capacity. At the terminal, this is based on the maximum amount one of the oil storage tanks can hold, which is approximately 23 million gallons.

Alyeska receives a 60% “prevention credit” for various prevention measures. Most of that 60% is for having the asphalt liner around the tanks. This means they plan for a spill of 40% of the total volume of one tank, which is 8.5 million gallons. If more than 8.5 million gallons is spilled, they would still be responsible for cleaning it up, however, more equipment would be needed than is currently listed in the plan.

Is the liner still intact?

This liner was installed when the terminal was built and is approaching 50 years old. From time to time, sections of the gravel layer over the liner have been removed when work is done for other projects. When this is done, cracks and holes are often found in the liner.

“There are crude oil storage tanks holding half a million barrels of oil sitting on a steep slope above Port Valdez within a secondary containment system with known integrity issues,” the Council noted in their comments.

Testing the liner

Because the liner is buried under gravel, it is expensive and time-consuming to dig it up for a visual examination. Excavation could also damage the liner. In 2022, the Council conducted a study of methods to evaluate the liner without removing the gravel. Alyeska is planning to conduct a pilot test this summer using an approach similar to the method recommended in that report.

What is a prevention credit? Spilled oil can never be completely recovered, so regulations are designed to encourage companies to prevent spills from happening in the first place. One way to do this is to give “credit” for prioritizing spill prevention.
In Alaska, the amount of equipment and personnel that an oil company must keep on hand to respond to a spill depends on the potential size of a spill. If a company takes actions to prevent or reduce the risks of a spill, they can qualify for such a credit. This allows the company to keep less equipment and personnel on hand to respond, because a spill is less likely.

Additional issues

The Council noted several issues aside from the liner, including:

  • The length of time between internal inspections of the storage tanks.
  • A lack of detail about the training to prevent oil spills.
  • Documents containing plan information that were not made available as part of the public review.

More information

The Council’s comments: PWSRCAC comments on 2024 VMT Contingency Plan Renewal

35 years after Exxon Valdez

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How has oil transportation changed in Prince William Sound?

In this photo, three fishing vessels practice pulling bright orange oil spill boom in proper formation, with a skimmer in the middle of the boom. This configuration creates a channel for collecting and skimming oil.
The Exxon Valdez oil spill taught many lessons about preparedness, including local mariners’ knowledge about the waters in our region is vital to spill response. Today, over 300 vessels and their crews are trained and on contract to Alyeska’s Ship Escort Response Vessel System, or SERVS, to respond in the event of a spill. The fishing vessel program is a major improvement to the oil spill response system, which was not in place during the Exxon Valdez oil spill. In this photo, the crews of several Homer fishing vessels practice using oil spill boom and skimmers during annual contracted vessel training. Photo by Cathy Hart.

In 1989, the few measures in place were inadequate to prevent the Exxon Valdez oil spill and the available response resources were insufficient to contain and clean it up. Congress found that complacency among the oil industry, and the regulatory agencies responsible for monitoring the operation of the Valdez Marine Terminal and vessel traffic in Prince William Sound, was also a contributing factor in the disaster.

In the years following the spill, regulatory agencies, industry, and citizens worked together to make sure the painful memories and hard lessons of the Exxon Valdez were not forgotten. Changes were enacted to reduce the chances of another spill and to prepare for an effective cleanup if another should occur.

Much has improved in the intervening decades, but there are lingering concerns.

See also: Then & Now: 35 Years After the Exxon Valdez Oil Spill

Laws and regulations

One of the most important results of the oil spill was the enactment of the federal Oil Pollution Act of 1990, or OPA 90, which addressed many deficiencies, including liability, compensation, and oversight. It also established permanent, industry-funded citizen oversight groups for Prince William Sound and Cook Inlet.

Both federal and state laws now require more comprehensive prevention measures and planning for larger spills and require more spill response equipment to be immediately available.

An unlikely alliance of regulators, politicians, oil industry executives, and international spill response experts came together after the spill to reimagine oil spill preparedness and response in Prince William Sound. More: How Alaskans redefined oil spill prevention and response

Prevention: The most effective protection

Photo of weather buoy near Valdez Marine Terminal.
Modern technology means weather buoys can stream real-time weather conditions to help make better operational decisions. Photo by Rob Campbell.

No oil spill can ever be completely cleaned up. Preventing an oil spill is the most effective way to protect human health, local communities and economies, and the environment. Since 1989, improvements have drastically reduced the risk of oil spills.

Double hulls

All tankers transporting oil through Prince William Sound are now double hulled. Double hulls, basically two steel skins separated by several feet of space, can reduce or eliminate spills that result from groundings or collisions.

Alyeska’s Ship Escort Response Vessel System

The Ship Escort Response Vessel System, known as SERVS (SERVS’ website), was developed after the Exxon Valdez spill. SERVS’ mission is to prevent oil spills by helping tankers navigate safely through Prince William Sound and to begin an immediate response if there is a spill.

Improved tanker escorts

A major component of SERVS are the powerful tugs that escort tankers safely through our waters. Two tugs accompany each laden tanker out of Prince William Sound. These tugs can assist should the tanker experience a malfunction and begin immediate spill response if needed. SERVS also keeps trained response crews on duty around the clock and has spill response equipment ready.

Cleaning up a spill: Must be quick and effective

Photo of Prince William Sound escort tug.
In 2018, Alyeska began work with their new spill prevention and response contractor, Edison Chouest Offshore. These services include operation of escort tugs, oil recovery storage barges, and associated personnel. These resources are key oil spill prevention and response assets for Prince William Sound.
To fulfill their contract, Edison Chouest built new purpose-built tugs, such as the Elrington above; and spill response barges, such as the new OSRB-5. These vessels represented a significant improvement for the oil spill prevention and response system. In some cases, new general-purpose tugs replaced conventional tugs that were over 40 years old. Photo by Jeremy Robida.

While prevention measures are the best way to avoid damage from oil spills, even the best system cannot remove all risks. Alyeska’s SERVS has implemented many improvements since 1989, creating the world-class oil spill prevention and response system in place today.

Contingency plans

Contingency plans, extensive documents which contain details on preventing and cleaning up oil spills, are required by state and federal law.

Some changes in the contingency plans since 1989 include:

Spill drills

Before 1989, few oil spill drills were conducted in Prince William Sound. Today, three major exercises take place per year, along with several smaller drills. The drills provide opportunities for response personnel to work with equipment and practice procedures.

1989 vs 2024: Spill response equipment

In 1989, there were only 13 oil-skimming systems in Alyeska’s response inventory; today, 90 are available. Only 5 miles of oil spill boom were available in 1989; today, around 40 miles are on hand. Alyeska had only one 500,000-gallon barge at that time to store recovered oil and the water that comes with; today, storage capacity is now 37 million gallons.

This image is a bar chart graphic that shows the difference in equipment between 1989 and 2024. It compares 13 oil skimmers compared to 90, 5 miles of boom compared to 40, and 500,000 gallons of capacity compared to 37,000,000 today.

Concerns remain

Although there have been many improvements, there are still many areas of concern, meriting the continued attention and sustained efforts from the Council. A few of these include:

Council report on changes:

More about improvements and remaining concerns in the publication “Then & Now: 35 Years After the Exxon Valdez Oil Spill”

Tim Robertson: Real-life experiences improve oil spill response

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Volunteer Spotlight

Photo of Tim Robertson on a small motorized boat on the ocean with a rocky coast in the background.
Tim Robertson is a member of the Council’s Oil Spill Prevention & Response Committee. The committee works to minimize the risk and impacts associated with oil transportation through research, advice, and recommendations for strong and effective spill prevention and response measures, contingency planning, and regulations.

Growing up in western North Carolina, over 3,000 miles away from Alaska, Tim Robertson and his brothers Roy and Andy knew all about the 49th state. His dad was obsessed.

“If there was a TV show or a movie or anything about Alaska, he drug the whole family to see it,” Robertson says. All three brothers ended up moving here.

These days Tim splits his time between Alaska and Hawaii. At first glance, it might seem like the two states are very different, but Tim’s values are present in both.

“I’m a small-boat guy on big water,” he says. “There’s the same connection with the ocean. A lot of mornings I watch the sun rise from the water. It’s a big part of what I am.”

Robertson spent his first few years in Alaska working in an oil-related field, first as a research biologist for Alaska Department of Fish and Game, then for an oil field service company.

He dreamt of a different career though. Robertson acquired land in Seldovia in 1985, and partnered with another family to build Harmony Point Wilderness Lodge, an ecotourism business. They had only been in business a few short years when the Exxon Valdez ran aground.

“The first time I ever heard of ICS [Incident Command System] was when we had a community meeting after the spill,” says Robertson.

Read more

Under-studied component of hydrocarbons documented in discharge from terminal

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A new report examined hydrocarbons that enter Prince William Sound from the Valdez Marine Terminal that until recently have received little attention.

Researchers Maxwell Harsha and David Podgorski from the University of New Orleans investigated the current process of removing crude oil residue from tanker ballast water. They were specifically looking for a type of compound called oxygenated hydrocarbons, as well as heavy metals.

What are oxygenated hydrocarbons?

Hydrocarbons are made of hydrogen and carbon molecules. There are a variety of types, depending on how these molecules are arranged. Crude oil is a mixture of types of hydrocarbons.

Hydrocarbons can become “oxygenated” when atoms of oxygen become attached to hydrocarbon molecules. This family of compounds is currently not monitored or regulated because they cannot be detected with the same process as other components of crude oil. Concerns about these compounds are emerging due to potential risks to human health and the environment.

Residue left in ballast water

Three treatment processes are employed to remove hydrocarbons from oily ballast water: gravity separation, pressurized air treatment called dissolved air flotation, and biological treatment.

Harsha and Podgorski compared samples of water taken at different points during the process of cleaning ballast water at the terminal.

The study’s results demonstrate that the treatment process effectively removes most hydrocarbon compounds, such as benzene, toluene, ethylbenzene, and xylene (BTEX). These are considered the most harmful to humans and other organisms, known to cause cancer and neurological impacts. The concentration of hydrocarbons in the water after treatment is at historically low levels. The researchers also found that one of the steps in the treatment, which uses dissolved air to remove small particles of hydrocarbons from the water, may lead to the formation of oxygenated hydrocarbons that are then released into Port Valdez.

Traditional monitoring techniques used at the Valdez Marine Terminal identify other hydrocarbons, but don’t catch oxygenated hydrocarbons.

Image describes cycle of removing oil from ballast water as described in the photo's caption.
How are hydrocarbons cleaned from ballast water? Oily ballast water is pumped into the treatment facility where it is processed to remove contaminants. It is first allowed to settle, which separates most of the oil by gravity. That oil is skimmed off, and then the water is treated with an air bubble process that removes additional compounds. The final stage is a biological treatment where oil-eating bacteria digest more of the hydrocarbon residue. In this image, the red asterisks note the points where researchers took samples.

What is ballast water?

Tankers sometimes pump seawater into empty crude oil storage tanks to help balance the vessel during rough seas. When a vessel carrying oily ballast water arrives at the Valdez Marine Terminal, the water is treated to remove hydrocarbons before discharged into the sea at Port Valdez.

Read the report: Examining the Effectiveness of Ballast Water Treatment Processes: Insights into Hydrocarbon Oxidation Product Formation and Environmental Implications

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