Oil Spill Contingency Plans

By LINDA SWISS
Council Project Manager

The current Valdez Marine Terminal Oil Discharge Prevention and Contingency Plan, set to expire this past May, has been extended to December 9, 2013.

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 plan is reviewed and updated every five years.

The proposed plan, submitted by Alyeska to the Alaska Department of Environmental Conservation in October, contained a large number of changes, including being reformatted into four separate volumes. This short-term extension will allow the plan renewal process to continue until the department has conducted a thorough review. The agency has asked Alyeska to provide additional information on several areas of the plan. The council will have an opportunity to provide input to the department during this information-exchange phase.

Once that information is provided, the official public review will proceed. The council expects to submit final comments during the public review.

By LINDA SWISS
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.

The Alaska Department of Environmental Conservation approved the new Prince William Sound Tanker Oil Discharge Prevention and Contingency Plan and associated response plans for individual vessels effective November 2, 2012.

These plans—usually known as contingency plans—are prepared by oil tanker operators subject to state approval. The operators specify what they will do to prevent and clean up oil spills from their vessels.

During the review period, the council called for several updates and improvements to the plans.

In 18 pages of formal comments submitted to the Alaska Department of Environmental Conservation on Oct. 12, the council made a number of recommendations for improving the contingency plans before they were given final approval.

One recommendation dealt with downstream response, meaning oil-spill clean-up in communities outside Prince William Sound.

While much of the news coverage of the 1989 Exxon Valdez spill focused on effects inside the Sound, the spilled oil was carried out of the Sound by tidal and coastal currents within a week of the grounding on Bligh Reef. Ultimately it spread to Cook Inlet, Kodiak, and even the village of Chignik, some 460 miles southwest of the spill site. While state regulations require clean-up of oil that escapes the Sound, those requirements are much less specific than for oil still within the Sound.

In its comments, the council encouraged the state and the tanker operators “to set a timetable for the implementation of drills and exercises to ensure that all parties are prepared to mount an effective response in downstream communities.”

Another focus of council comments was the plan for using commercial fishing vessels in the clean-up of oil spills in the Sound, including spills that spread outside it. Under state requirements, tanker operators must be prepared to clean up 300,000 barrels of oil within three days. The plan drafted by the operators claims that having 275 fishing vessels under contract will meet that standard.

The council disagreed.

Historically, the operators and the state have agreed that, on any given day, only about 75 percent of vessels on contract can be counted upon to be available and ready to respond in the required time frame. By the council’s estimate, 371 vessels would have to be under contract to make sure enough were ready to respond when actually needed. The council recommended such a requirement be incorporated in the new contingency plan.

The council’s other recommendations dealt with such issues as:
• protection of sensitive areas before spilled oil arrives
• on-water recovery of spilled oil
• incorporation of Best Available Technology
• the incident command system for managing oil-spill cleanups
• availability of tankers and barges of opportunity that can be pressed into service for hauling away oil recovered during a cleanup
• operating in darkness
• Realistic Maximum Response Operating Limitations, meaning the most severe weather and sea conditions in which it is realistically possible to conduct cleanup operations.
The department attempted to address some of the council’s concerns in their final approval document. Their statement noted that some areas of the plan will need to be verified by oil spill drills and exercises, such as:
• nearshore and open water response
• sensitive area protection
• availability, access and training of certain fishing vessels
• tankers and barges of opportunity
• operating in darkness
• availability of specialty vessels

The council is hopeful future exercises will verify the effectiveness of the plan.