Many changes stemming from transition of marine services contractor to Edison Chouest
By Linda Swiss
Council Project Manager
Updates to two oil spill prevention and response contingency plans are currently underway. The Alaska Department of Environmental Conservation, or ADEC, solicited public comments regarding the changes to the spill prevention and response plans this past summer.
The plans are prepared by the operators of Alyeska’s marine terminal and oil tankers and are subject to state approval. These plans specify what operators will do to prevent and clean up oil spills. There are separate plans for spills from the Valdez Marine Terminal and from the tankers that carry oil. Both plans undergo an approval process approximately every five years. With the marine services transition in Prince William Sound, Edison Chouest Offshore’s new equipment means the details in the plans will change, triggering a public review.
In 43 pages of formal comments submitted to ADEC in August and September, the Council made a number of recommendations to either maintain the same level of preparedness or improve the proposed plans.
Tanker plan amendments
Major changes are proposed to the tanker plan due to the ongoing marine services transition.
In its comments, the Council stated that “changing such a significant portion of the prevention and response system in Prince William Sound at one time defies a clear regulatory precedent.”
To help manage this, the Council suggested a well-documented process which shows that each new asset meets requirements prior to the release of its counterpart from the current system. This process would include demonstrations of new equipment and capabilities of the crews operating the equipment.
One of the positive changes is an additional task force dedicated to protecting areas that are particularly sensitive to crude oil.
Among the Council’s other concerns:
- More computer modelling is needed to verify that all vessels are capable for their assigned tasks.
- The number of personnel is reduced, and the Council is concerned there may not be enough personnel on skimming barges.
- Training requirements are reduced for escort crews.
- The plan contains fewer details about training, including removal of job roles, which describe tasks and training needed to perform those tasks.
The terminal plan
The first of two amendments to the terminal plan focus on changes to one of the oil spill “scenarios” in the contingency plans. These seven scenarios illustrate hypothetical responses to spills, including to land and water, that could occur. The industry must show how prepared they are to respond to all seven of these scenarios before the plans are approved and oil can be shipped.
Changes are being made to a scenario that depicts a catastrophic failure of the crude oil piping system that carries oil from the storage tanks to the loading berths. In the current plan, industry has committed to protect two environmentally-sensitive areas that are particularly susceptible to crude oil with boom to divert oil away within the first critical hours after a crude oil spill. The proposed version could delay this protection by several hours.
The second of the two amendments focused on the changes due to the marine services transition. Among other concerns, the Council noted:
- Descriptions and goals for training responders were deleted.
- Job roles were removed as in the tanker plan.
- The Council recommended that the current level of detail be retained.
As the Observer went to press, the Council had just received news that one of the three amendments had been approved.