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Alaska proposes changes to spill contingency planning regulations
The Alaska Department of Environmental Conservation is considering changes to oil exploration and production facility oil spill contingency planning regulations. Its goals are to reduce ambiguity and conflicting interpretations and to improve the clarity and certainty of the regulations, which would result in consistent application of the requirements.
‘Umbrella’ plan proposed One of the many changes under consideration would be to “accept a single plan to address multiple facilities based on geographic area, similarities in operations, logistical considerations or other factors.”
Designed to clarify regulations, this proposed change, DEC says, would allow more than one oil exploration well within a single region to be covered under an “umbrella” plan submitted by an operator along with site-specific data for each well. The change would also allow contingency plans to cover multiple facilities within a geographic area to facilitate regionally based response planning.
Currently, an exploration or production facility C-plan must include “a plan and time frame for drilling a relief well or otherwise controlling an exploration or production well blowout.”
DEC proposes to instead mandate that a C-plan must include “the planned method to control a well blowout within 15 days; the holder of an approved contingency plan must have a well blowout contingency plan; the well blowout contingency plan shall be made available to the department for review and verification upon request.” Other DEC proposed changes Other proposed changes deal with adopting current practices, such as the ongoing development of stand-alone response references — the North Slope Tactics Manual, for example; clarification of definitions, such as “typical environmental conditions” for designing summer and winter response scenarios; the supplemental information required in a C-plan, allowing nonmechanical response methods to be among the measures proposed for certain conditions; changes to make the specific compensatory measures to reduce the environmental consequences of a discharge subject to best-available technology requirements; clarification of regs dealing with state registration of a spill contractor; reduce ambiguity and clarify issues related to the calculation of the response planning standard for an exploration or production facility, which, among other things, would allow flexibility in determining the response planning standard for operations such as the proposed Point Thompson development, where a large proportion of volatile gas is associated with the oil and significant reductions in the amount of oil discharged to the lands or waters of the state could be realized by voluntary ignition of a well blowout; address confidentiality concerns by providing for the protection of certain proprietary data required by DEC to determine compliance; and specification of a 15-day total timeframe for calculating the response planning standard.
Under DEC’s proposed changes, the well blowout contingency plan would not be part of the oil discharge prevention and contingency plan application, but would be available to the department “for review and verification on request, and any shortcomings discovered through such inspection could be cause for modification of the operator’s plan approval”
DEC has developed a discussion draft of proposed changes to the contingency plan requirements that includes the department’s rationale for each proposed change.
Comments are due to DEC no later than June 25.
See website http://www.state.ak.us/dec/dspar/cpr/cprhome.htm
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