Schantz: Collaboration leads to better solutions for prevention and response

Image with a quote from the Oil Pollutions Act of 1990: "Only when local citizens are involved in the process will the trust develop that is necessary to change the present system from confrontation to consensus.”
Photo of Donna Schantz
Donna Schantz

By Donna Schantz
Executive Director

The Oil Pollution Act of 1990 notes congressional findings from the Exxon Valdez oil spill. Included in those findings was the need to foster the long-term partnership of industry, government, and local communities. This is a key piece of the foundation on which the Council was formed.

The Council may not always agree with industry and regulators, but we strive to maintain positive working relationships and build trust. While we do not hesitate to raise concerns when we perceive potential rollbacks in oil spill prevention and response safeguards, it is just as important to recognize when we are in agreement.

I am pleased to report the Council will be supporting Alyeska in a recent appeal they filed with the Environmental Protection Agency (EPA) (page 2). Our independent review verifies that systems Alyeska currently has in place at the Valdez Marine Terminal capture over 99% of the emissions addressed by the rule – a higher reduction goal than is currently being required. The Alaska Department of Environmental Conservation (ADEC) has also voiced support of Alyeska’s appeal to the EPA.

This collaborative approach goes both ways. For example, after months of coordination, Alyeska has also agreed to support a project proposed by the Council to look at the chemical composition and concentration of oxygenated hydrocarbons released from the terminal. Oxygenated hydrocarbons are less studied than other hydrocarbon products and they are potentially toxic in the aquatic environment. Revisions to the scope of work were necessary to satisfy Alyeska’s concerns, mostly related to COVID impacts and their desire to focus resources on their priority operational goals. This is another example of how good communication, strong relationships, and a willingness to work together can lead to solutions that support everyone’s goal of moving oil safely.

There are concerns with the integrity of the secondary containment liner at the Valdez Marine Terminal that we hope can be addressed in a similar fashion. In January, the Council requested an adjudicatory hearing with ADEC in support of the department’s decision to require additional evaluation and testing of the liner. Alyeska also requested a hearing seeking to remove any requirement for further liner testing.

Secondary containment systems are required by Alaska regulation to hold oil in the event of a spill from a tank or pipe until the spill can be detected and cleaned up. The protection of groundwater and Port Valdez, in the event of a breach of one of the terminal’s large crude oil storage tanks, is dependent largely on the integrity of the liner, so it is of critical importance that the liner be inspected to ensure there are no cracks or holes.

For two decades the Council has voiced concern over the ability of the secondary containment liners within the system to meet regulatory standards. The liners were installed during original construction of the terminal, 45 years ago, and the type of liner installed then would not be allowed by regulations today. Additionally, when relatively small sections of the liner have been inspected over the years during other maintenance work, damage to the liner has been discovered. The Council’s persistent calls for more rigorous evaluation and testing, or even replacement of the liner, have not been adequately addressed.

Image with a quote from the Oil Pollutions Act of 1990: "Only when local citizens are involved  in the process will the trust develop that is necessary to change the present system from confrontation to consensus.”

The Council is hoping to find a more collaborative approach to addressing our concerns with the secondary containment liner, in lieu of a hearing. Regardless of how this process proceeds, the ultimate goal is to work together with industry and regulators to give citizens a voice in decisions that impact the safe operation of the terminal and tankers in Prince William Sound.

We often share the following quote from the Oil Pollution Act of 1990 congressional findings, “Only when local citizens are involved in the process will the trust develop that is necessary to change the present system from confrontation to consensus.” We will continue to try and work together with industry and regulators to find solutions that improve oil spill prevention and response.

Council supports Alyeska’s appeal to EPA

In late 2020, Alyeska Pipeline Service Company appealed a July 2020 Environmental Protection Agency air quality rule that would regulate emissions from the crude oil storage tanks at the Valdez Marine Terminal.

Alyeska asserted that the new rule would not result in emissions reductions at the terminal, that local residents would not see air quality benefits, and that Alyeska was already controlling air pollution from the storage tanks using optimal methods.

Alyeska noted that the existing control system at the terminal captures 99.94% of all tank vapors, while the reduction goal for the updated rule is 95%.

The Council hired experts at John Beath Environmental to conduct an independent review of Alyeska’s appeal and their assertions, to determine if the Council should support Alyeska’s appeal or not.

The section of the standards being appealed establishes national emission limitations, operating limits, and work practices for major sources of hazardous air pollutants. Hazardous air pollutants can be harmful to human health and include carcinogenic compounds such as benzene, among nearly 200 other harmful compounds.

In addition to verifying Alyeska’s assertions, the review documented how the implementation of the new rule, as written by the EPA, would impact the amount of hazardous air pollutants coming from the terminal.

The Council’s independent review supports the key arguments in Alyeska’s appeal. The design of the existing vapor recovery system already controls vapors better than the alternatives required by the new rule. Imposing the entirety of the new rule at the terminal would not result in overall, local air quality benefits.

The Council will be supporting Alyeska in their appeal by sending a letter and the final report to the Environmental Protection Agency.

A Review of the Appeal to 2020 Updates to 40 CFR 63, Subpart EEEE by Alyeska Pipeline Service Company (11.3 MB)

Corrosion protection system for terminal’s crude oil pipes in good shape overall

Keith Boswell from National Pipeline Services observes cathodic protection system equipment at the Valdez Marine Terminal in 2019.

A recent study of operations and maintenance of Alyeska’s cathodic protection system found that the program was “very good;” however improvements are still needed.

National Pipeline Services, a consulting company that specializes in cathodic protections, conducted the study for the Council. They looked specifically at the systems that prevent corrosion in the metal piping that carries crude oil through the terminal to the large oil storage tanks.

The researchers based their report on a review of documents, procedures, testing, and results from previous inspections of those systems.

The final report summarized the systems currently in use at the terminal, as well as Alyeska’s methods for monitoring and testing the systems.

The researchers concluded that overall, it appears Alyeska has a “very good corrosion and cathodic protection program.” The procedures for operating and monitoring the system are adequate and within standard industry practices and Federal guided requirements.

The report also noted that certain improvements could further reduce the risk of a crude oil spill, such as ensuring data collection procedures are adequately implemented. Data used to ensure that the crude oil piping’s cathodic protection system is operating effectively does not appear to have been collected properly.

The researchers commended Alyeska on their use of remote monitoring systems, which continuously monitor and evaluate the systems. They added that Alyeska’s annual reporting for integrity management is exceptional and well documented.

Report:

Review of Cathodic Protection Systems at the Valdez Marine Terminal (1.9 MB)

Review of maintenance records finds improvements needed for oil storage tank

Oil spill unlikely as long as planned repairs are not delayed further

Photo of Tank 8, which is one of the large crude oil storage tanks at the terminal. This tank is 63 feet tall, 250 feet in diameter, and can hold up to 21,420,000 gallons of crude oil.
Tank 8, seen here being cleaned in preparation for an internal inspection, is one of the large crude oil storage tanks at the terminal. This tank is 63 feet tall, 250 feet in diameter, and can hold up to 21,420,000 gallons of crude oil. Photo by Austin Love.

Last year, COVID-19 delayed planned repairs to one of the large crude oil storage tanks at the Valdez Marine Terminal. Alyeska rescheduled those repairs for 2023. A recent Council study found that, as long as these repairs are not delayed any longer than 2023, a spill is unlikely.

Taku Engineering, an engineering firm with expertise in tank and piping inspections, assessing and controlling corrosion, and cathodic protection conducted the tank inspection review for the Council. Taku’s engineers analyzed Alyeska’s documentation of inspections and maintenance for Tank 8 located within the East Tank Farm at the Valdez Marine Terminal.

2019 inspection raised concerns

After some concerning findings during a 2019 inspection of the inside of Tank 8, Alyeska planned to replace the tank floor and cathodic protection system. The repairs were scheduled for 2020. However, the COVID-19 pandemic delayed those major repairs. The Alaska Department of Environmental Conservation extended the deadline for completion to 2023. The tank will then be removed from service and repairs made.

Council conducted study to minimize risk of oil spills

Taku’s report concluded that the immediate risk of a leak from Tank 8 between now and 2023 is low. The engineers made several recommendations that would help ensure that a spill remains unlikely. They found that an unmaintained seal around the perimeter of the tank allowed rain and snow melt to migrate and accumulate under the tank’s floor. Under certain circumstances, this could lead to damage. Taku recommended that Alyeska maintain the seal so water cannot cause these problems.

Taku also found that some of the cathodic protection system testing data was inadequate. That data is used to ensure that the system is operating effectively, safeguarding the tank’s floor from corrosion.

Report

Details are available in the final report: 

 

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