Review of proposed contingency plan shows some areas improved, others need more detail

Council project manager

The council has been analyzing proposed changes to the Valdez Marine Terminal Oil Discharge Prevention and Contingency Plan during a recent public review.

This plan, created and managed by Alyeska Pipeline Service Company, describes how the company would contain and clean up oil spilled from the terminal in Valdez.

The current plan is being reformatted into four separate volumes. One of the new volumes describes tactics specific to oil spilled on land. The council applauded creation of this user-friendly manual.

The council also supports the addition of a technical manual which focuses on marine spill response operations. This manual is part of the tanker oil spill contingency plan, which underwent a similar review process in 2012.

The council has expressed concerns that the proposed new plan may not contain enough detail to demonstrate Alyeska’s ability to fully respond to a spill as required by state and federal regulations.

The review was extensive, requiring a page-by-page comparison between the proposed plan and the previous plan. The changes were significant enough to require a separate document explaining why some information was deleted and where that information, if still required, now appears in the plan.

During the first phase of the public review, the council submitted requests for additional information to the Alaska Department of Environmental Conservation, the agency in charge of the review process. The council was looking for more information on prevention and response training, facility descriptions, and additional details on preventing a spill.
The council identified several areas of concern, including:

  • Integrity of the secondary containment liners for the terminal’s crude oil storage tanks. The liners serve as a barrier in the event a tank ruptures, and must remain “sufficiently impermeable” according to state regulations. If the liner is considered still in good condition, Alyeska is able to plan for a smaller spill, thus requiring less personnel and equipment for a response.
  • Whether adequate equipment and personnel with the necessary level of training are available to respond to a spill.
  • Lack of details on prevention and response training.
  • Specifics on handling, transporting and disposing of waste generated from a spill, available in the current plan, are not included in the proposed plan.
  • Making sure that enough detail exists on required prevention measures such as leak detection, tank overfill alarms, and inspection schedules.
  • Information that was previously available in the plan such as facility diagrams and maps have been removed.

The plan is reviewed and updated every five years. The last time the plan was renewed was 2008.

The first version of the proposed new plan was submitted by Alyeska to the agency for a “sufficiency review” in October 2012. That review was to determine whether the plan contained sufficient information for the next step of the process, the public review. The agency found that the draft plan needed additional information before being reviewed by the public. Alyeska revised the plan and the agency deemed it satisfactory for review on February 14, 2013.

The council submitted requests for information in March. Once the Alaska Department of Environmental Conservation reviews all input from the public, they will determine areas where more detail is needed, and issue requests for more information to Alyeska.

The next step will be for Alyeska to respond to the department.

The current plan expires on May 9, 2013.

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