Request for Proposals: Review of EPA Air Quality Rule

The Council is inviting proposals to evaluate the Environmental Protection Agency’s (EPA) final rule that amended the 2004 National Emissions Standards for Hazardous Air Pollutants for Organic Liquids Distribution.

Alyeska Pipeline Service Company has objected to the rule, arguing provisions of the rules would adversely affect the operation and maintenance of their facility and would not significantly improve local air quality.

This work includes:

  • A review of the 2020 rule and survey of research related to the topic
  • Evaluate the strengths of APSC’s concerns and summarize findings
  • Prepare a written final report
  • Identify gaps in the research on this topic and provide recommendations for future research

The final work product of this effort is a written report and virtual presentation to the Council’s Board of Directors on the results.

Submittal Deadline: May 14, 2021
Award Announcement: May 21, 2021

For more information about this RFP, including background information, a detailed scope of work and timeline, and instructions on how to submit your proposal, please download the full RFP: 

RFP: Review Of EPA Air Quality Rule (0.3 MB)

Questions

Inquiries regarding this request for proposals should be directed via email to Alan Sorum.

The Council received several questions about this RFP. Clarifications are below: 

Question: Will the following documents or information be available for the contractor to review during the project?

  1. Document: Valdez Marine Terminal’s (VMT) latest Title V permit and its associated permit applicationAnswer: The VMT’s latest Title V permit and associated application will be available for this project. The latest Title V permit was issued in 2012, while the latest Title V permit application was submitted in 2016, as part of the renewal of the 2012 permit. Both documents will be added to this webpage for review. That webpage is referenced on page 6 of the request for proposals.
  2. Document: Operating data the VMT may have provided as inputs for the latest (if any) air dispersion modeling (whether done by VMT or others) – Answer: The Council is not in possession or aware of operating data Alyeska may have provided for recent air dispersion modeling.
  3. Document: Speciation of the North Slope crude oil typically received (e.g., C1 to C10 straight-chain alkanes and HAPs as defined by MACT standards)Answer: The Council has a detailed report regarding the physical and chemical properties of a 2015 Alaska North Slope crude oil sample obtained from the VMT. That report includes the straight-chain alkanes as well as polycyclic aromatic hydrocarbons contained in that 2015 oil sample – among other physical (e.g. density, API gravity, viscosity) and chemical information (e.g. biomarkers, sulfur content) contained in the report. A more recent report pertaining to a 2019 Alaska North Slope crude oil sample may be available, but that will need to be obtained from oil industry partners and should be obtainable in a timely manner.
  4. Document: Latest TRI reporting of point and area air emissions for HAPS (since the state emissions inventory does not speciate VOC) – ideally in the form of the facilities calculation workbook – Answer: The Council is not in possession or aware of this information. It would likely need to be requested from Alyeska Pipeline Service Company.
  5. Document: Methodology by which the emissions from the conservation vents to the atmosphere have been estimated by VMT (or its contractors) – Answer: The conservation vent emissions methodology may be contained in the Valdez Marine Terminal’s latest Title V permit application or in past air quality exceedance reports that Alyeska Pipeline Service Company provided to the Alaska Division of Environmental Conservation. The Council has the latest Title V application and at least some of the past air quality exceedance reports. If the Council is not in possession of this information, it should be attainable from Alyeska Pipeline Service Company or the Alaska Division of Environmental Conservation.

Question: Will it be possible for our team to contact VMT staff directly to gather information (or do so through your organization), during the project, or must our work be done using only currently disclosed information? – Answer: Yes, it will be possible to contact VMT staff, through the Council, during the project. However, depending on the request, obtaining information from Alyeska Pipeline Service Company can be a slow process. Therefore, to the greatest extent reasonable, to meet the goals of this project in a timely manner, we would like it to proceed with the currently available information.

New buoys now streaming weather conditions from Port Valdez

Photo of new buoy deployed in 2019.

Two new buoys are now in place and broadcasting weather conditions in the vicinity of the Valdez Marine Terminal.

Photo of new buoy deployed in 2019.

The buoys collect weather data such as temperature, wind speed, wind direction, and barometric pressure, as well as oceanographic information like surface current direction and speed, wave heights, and water temperature. This data will help improve understanding of the meteorological and physical oceanographic environment in Port Valdez.

Weather conditions throughout Prince William Sound

Terminal buoy result of cooperative partnership

The buoy closest to the terminal (pictured above) is the result of a partnership between the Council, the Prince William Sound Science Center, Alyeska Pipeline Service Company, the City of Valdez, and Valdez Fisheries Development Association.

“Partnerships like these result in collaborative science, which is the best base for providing answers to challenging questions related to planning an effective oil spill response,” said Donna Schantz, Executive Director for the Council. “The Council has long advocated for this kind of data collection at the terminal and believe the information generated will contribute to best practices for prevention and response.”

The partnership is a result of an agreement reached between the Council, the City of Valdez, Prince William Sound Aquaculture Corporation, Valdez Fisheries Development Association, Alyeska Pipeline Service Company, and the Alaska Department of Environmental Conservation regarding protections in the Valdez Marine Terminal contingency plan for two nearby areas that are particularly sensitive to spilled oil, the Solomon Gulch fish hatchery and a salt marsh known as the Valdez Duck Flats.

In 1994, the tanker Eastern Lion spilled 8,400 gallons of North Slope crude oil into Port Valdez. Oil reached the Duck Flats and hatchery before protective boom was in place.

After that spill, changes were made to the Valdez Marine Terminal contingency plan to ensure that protections were deployed quickly. A rapid-decision tool, called a “matrix,” was created to help responders assess when to deploy protective boom to the Solomon Gulch Hatchery and Valdez Duck Flats during the critical early hours of a response. In 2017, the matrix was modified, and the Council, the City of Valdez, Valdez Fisheries Development Association, and Prince William Sound Aquaculture Corporation appealed that decision.

Earlier this year, the parties agreed to stay the appeal in lieu of a collaborative workgroup process. The workgroup’s goal is to reach consensus on how to ensure the protection of the Solomon Gulch Hatchery and Valdez Duck Flats. The buoys will provide scientific data to help the workgroup better understand how spilled oil will move in Port Valdez. This knowledge will help determine the timing for deploying protective boom.

Second buoy monitors Valdez Duck Flats

A second buoy has been deployed near the Valdez Duck Flats to monitor conditions in that location. The second buoy has been made possible by partnerships with Prince William Sound Science Center, the City of Valdez, and Valdez Fisheries Development Association.

Map

The map shows the locations of the two sensitive areas of concern, as well as the location of the new buoys. The hatchery is a little over two miles from the terminal, and the flats are approximately four miles.

Piping inspections near completion

By Austin Love
Council Project Manager

For the first time since the facility’s construction was completed in 1977, a majority of the large diameter crude oil piping at Alyeska’s Valdez Marine Terminal is undergoing a comprehensive inspection, both externally and internally. The inspections of these 36 and 48 inch diameter pipes began in 2016, and will be completed by the end of 2018.

Alyeska can use the data from these inspections to evaluate the current, complete condition of the large diameter piping used to move Alaska North Slope Crude onto tanker ships at the terminal.

A tremendous amount of work by Alyeska and their contractors is making these inspections possible:

  • Concrete foundations had to be reinforced to accommodate loading stresses associated with the inspections;
  • Piping inspection tool access and retrieval points had to be created at multiple locations;
  • Sharp bends and large valves had to be removed from certain piping sections to allow for the passage of inspection equipment;
  • The piping has to be cleaned of accumulated wax and debris after 40 years of use; and
  • With the exception of a few necessary, planned pipeline shutdowns, most of this work was done while crude oil was still flowing through the pipeline and tank ships were still loading.

Read more

North Slope crude oil spills into Port Valdez

Oil collected inside boom during spill. Photo by Jeremy Robida.
Oil collected inside boom during spill. Photo by Jeremy Robida.

On September 21, approximately 100 gallons of North Slope Crude oil was spilled into Port Valdez. The spill occurred during a planned annual leak-test of the pipes that load oil onto tankers out at the end of loading Berth 5 at the Valdez Marine Terminal.

To conduct the annual test, Alyeska Pipeline Service Company uses the berth’s fire system to pump seawater into the crude piping to a pressure of 190 PSI, or pounds per square inch. That pressure is held for a prescribed amount of time to allow inspectors to visually check the pipes for leaks. However, that day Alyeska was unable to achieve the necessary 190 PSI test pressure and an apparent operational error led to a mixture of crude oil and seawater being spilled into Port Valdez. Alyeska is conducting a thorough investigation of the spill.

Read more

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