Public Comment Regarding the Draft NPDES Permit for BWTF at Alyeska Marine Terminal

In overview, the operators of the BWTF are tasked by regulation to stay within proscribed limits of pollutant effluent concentrations and to do no significant harm to the environment of Port Valdez. According to results from 28 years of Alyeska?s Environmental Monitoring Program (AEMP), the operators appear to have essentially succeeded in their task. Discharged oil concentrations are reported at very low levels and with the exception of the localized changes to infauna and elevated stress in fish near the diffuser, no significant harm to the environment has been documented. However, the PWSRCAC review finds that the data are, in places, inconclusive in supporting this assessment. Since 1977, various environmental parameters, including physical, chemical, and biological concerns, have been the focus of the AEMP. Many sites or parameters were examined for a few years and then dropped when they seemed to imply an ineffective technique, no harm to the environment, or no exceedance of limits. In hindsight, some of those decisions may have been made with inadequate information and optimistic confidence.