What’s in an oil spill contingency plan? Prevention and response and the essence of preparedness

From the executive director:

Mark Swanson
Mark Swanson

It’s fall now in Alaska. You can feel it in the air. You can see it in the new snow deposited on the mountain peaks after the rain clouds clear away. Commercial and recreational salmon fisheries are over for the year and in Valdez, the RV parks, hotels, and restaurants are emptying out. Suddenly, there is ample parking at the harbor. With the visible end of summer and the beginning of fall, there is a certain seriousness and palpable urgency to preparations for winter. In Valdez, we receive an average of 27 feet of snow per year, and wind speeds can run into the triple digits during storms. Only the foolhardy go into the winter season unprepared.

This fall, comments for the revised Valdez Marine Terminal Oil Discharge Prevention and Contingency Plan, known as the “terminal c-plan,” have come due and the council has now submitted our recommendations. Reviewing the plans and providing advice aimed at improving plans for the oil terminal and associated tankers is one of the fundamental tasks assigned and opportunities afforded to the council under the Oil Pollution Act of 1990 and state statutes.

The oil discharge prevention and contingency plans have five parts: the Response Action Plan; a Prevention Plan; Supplemental Information; a Best Available Technology review; and the Response Planning Standard. With all of those elements the c-plan is complex and detailed.

As anyone who has witnessed winter storm related problems can attest, nature will discover the weakness in your preparations. Having a roof collapse, a structure crushed, or a boat sink is dangerous, could negatively impact the environment, and is expensive and embarrassing. Similarly, a big disastrous oil spill will reveal weaknesses in prevention or response plans. We don’t want to wait for a disaster to be reminded of the cost-effectiveness of sound preparations and the value of learning from previous mistakes. We have already experienced a big oil spill disaster here.

Since the Exxon Valdez oil spill that brought about current c-plan requirements, various iterations of these plans have been approved on a 5 year cycle. We have had a good plan but should never accept that what has worked in the past will work in the future, especially if there have not been any spills and plans have not been tested through exercises and drills. As we become aware of new risks, planning shortfalls, and opportunities to better prevent and respond to spills, such discoveries need to be appropriately addressed. We ignore them at our own peril.

Learning from the school of hard knocks can be effective on an individual basis but may not translate beyond the original party unless others see they are facing similar risks. Part of the reason that these c-plans are released for public review is to give a chance for the risk-averse public to provide observations on important details the plan may have missed. We hope the state, Alyeska, and other oversight agencies will embrace many of the suggested improvements from the council and others.

It’s always better to prevent an accident than to respond to one. The state contingency plans include key sections focused on prevention and consequence mitigation measures. In particular, the state requires that each five year review cycle include a review of the best technology available to examine, among other things, the maintenance practices for buried metal piping containing oil.

Over the past few years the council has become increasingly concerned that terminal piping maintenance practices have omitted any direct inspection of miles of buried piping at the terminal. A failure and sudden loss of oil containment due to corrosion in these buried pipes could result in an incident similar to the event at a pipeline pump station that shut down the entire pipeline in 2010. New technology is available to inspect such piping sections. Inspecting buried piping is not simple or inexpensive, but it is feasible and it would reduce oil spill risks. To Alyeska’s credit, following the pump station corrosion failure, their engineers have been diligently working on measures to inspect some of the terminal’s buried piping. Unfortunately, this work does not yet encompass all of the terminal’s oil piping and none of these new corrosion inspection plans or technology examinations seem to be included the final submitted version of the c-plan. The council thinks these efforts and considerations should be included. Even if leaking oil never makes it to the water, we’ve seen the winter time operational consequences of just such a corrosion related oil leak. We know the risk is real and the prevention solutions are available and achievable.

As winter approaches, we are personally reminded of the urgency of preparing for anticipated risks. The state has a good framework for ensuring an acceptable oil discharge prevention and contingency plan. A good contingency plan, further improved by incorporating or addressing public comments, will be a better plan.

• Mark Swanson is the executive director of the Prince William Sound Regional Citizens’ Advisory Council.

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