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Alyeska gets conditional C-plan OK for reconfig Plan submitted to owners in December, company hopes for decision near end of first quarter Kristen Nelson Petroleum News Editor-in-Chief
Alyeska Pipeline Service Co. has received conditional approval from the Alaska Department of Environmental Conservation and the U.S. Bureau of Land Management for amendments to its 2001 trans-Alaska pipeline oil discharge prevention and contingency plan to reflect the impact of changes the company is proposing as part of its strategic reconfiguration plan.
The regulatory approval cleared the way for Alyeska to submit the plan to pipeline owners.
Both Department of Environmental Conservation and BLM conditional approvals require Alyeska to do a number of things before it implements any strategic reconfiguration changes, including updating the 2001 screening risk analysis by Capstone Engineering Services to take into account changes proposed in the strategic reconfiguration, performing a crude oil fate and transport study and providing a management of change plan to address the transition from its current response organization
The company will also upgrade three of its four B-206L-3 helicopters to a B-407 or equivalent.
Alyeska has been studying reducing operating costs by modernizing the pump stations along the pipeline and automating their operation which affects its contingency plan because initial response after the strategic reconfiguration would not come from pump stations, but from other locations. That required a change in the company’s spill response plans, which are based on initial response from pump stations. (See stories on proposed changes in Petroleum News July 6 and July 13, 2003.)
Alyeska told regulators last year that it required approval of the C-plan changes before it could submit a proposal for strategic reconfiguration to the pipeline owners for approval. Switch from pump station to regional response Alyeska spokesman Mike Heatwole told Petroleum News Jan. 7 that Alyeska submitted the strategic reconfiguration plan to the pipeline owners for review and decision at the end of the year, and hopes for a decision near the end of the first quarter.
A strategic reconfiguration proposal for the Valdez Marine Terminal is about a year behind where Alyeska is with the pipeline, he said, and the company will be taking a look at ideas generated for changes at the terminal in the first two quarters of the year.
Changes in the company’s C-plan reflect a switch “from a pump station response to regional response,” Heatwole said. Under the strategic reconfiguration plan Alyeska “will be reducing the number of field personnel, but we will not be reducing the number of people dedicated to spill response.” There are 67 people now dedicated to spill response, he said, and there will be 67 under the new plan.
The times for initial response will change, he said. “In some areas response time increases, in some it would decrease.”
Alyeska has recommended changes in its response plan to mitigate changes in initial response time.
The company looked at some 200 identified containment sites along the pipeline, Heatwole said, looked at where it would be moving people around in the reconfiguration, and focused on areas where there would be an increase in time for initial response. In some places Alyeska is recommending upgrading its helicopter fleet to move more people faster, and the company is also recommending enhancing some of the containment sites and deploying some equipment at some sites, such as placing anchors for boom so that it could be deployed faster.
“It’s all a proposal at this point,” he said. Alyeska told the state it was a project proposal, and if the company gets approval, these are the things it wants to do, Heatwole said.
The state, in return, gave approval of C-plan amendments with conditions, including some things identified in the public comment period, particularly studies and risk assessments. The conditional approval, he said, gives Alyeska the ability to move forward with some level of regulatory certainty. Analysis update, additional plan amendments required The Department of Environmental Conservation is requiring that Alyeska update the Capstone Screening Risk Analysis, “a mile-by-mile study of risk conditions” along the pipeline conducted in the late 1990s, because the Capstone study assumed that pipeline maintenance and surveillance programs would remain the same. Those assumptions “should be re-examined,” the department said, so that changes in the way Alyeska will manage maintenance and surveillance in the future “are factored into the risk analysis update.”
The department also said that because it believes the strategic reconfiguration changes “will have line-wide impact,” it is requiring that the risk analysis update be done for the entire pipeline.
And, while Alyeska “has taken proactive steps to provide a preliminary outline of a crude oil spill fate and transport study,” the department said it wants the scope of the study “expanded to include seasonal variations and identification of potential mitigating measures.”
The department did find that because its response structure is regional, it is reasonable for Alyeska to complete the fate and transport study on a regional basis, “rather than requiring the study to be completed for the entire 800-mile pipeline route” before any portions of the strategic reconfiguration amendment can be implemented.
Once the study is completed, findings “should be evaluated against current response capabilities and the risk analysis update,” and against Alyeska’s “response timing assessments for individual containment sites.” Geographic response strategy not appropriate The Department of Environmental Conservation said the Prince William Sound Regional Citizens Advisory Council recommended geographic response strategy level response planning for the entire pipeline corridor, and that a multi-stakeholder workgroup for each of the five pipeline regions identify 20 such response areas each year, for a total of 100 a year.
The department said the council stated that the containment sites in the C-plan (more than 200) had the same goals as geographic response strategy areas.
The department disagreed, saying that while containment sites identified in the C-plan, including 64 with proposed enhancements are site specific, “they were not designed to protect specific individual high-value sites as much as to stop oil from entering a wide variety of environmentally sensitive areas along the pipeline corridor.” Geographic response strategy areas, the department said, “are site specific response strategies developed to protect specific environmentally sensitive areas and areas of public concern by identifying strategies, tactics, and resources needed to exclude or divert oil from the specific site.
“GRSs are designed to be defensive,” the department said, “while the containment sites are intended to identify sites, tactics and resources that may be utilized to contain oil as close to the pipeline as possible.” Alyeska’s approach offensive, not defensive The department did say the geographic response strategy is appropriate for marine areas for “specific high-value sites” and is required for marine vessel plan holders.
“However, there is no segment of the 800-mile pipeline route that could be identified as free from either environmental, scenic, recreation or other cultural value sites immediately adjacent or in the near downstream areas from the pipeline.”
Because the entire pipeline route is of value, the department said, containment sites are only one tool for protecting environmentally sensitive areas, and the C-plan “relies heavily on the training and knowledge of response and maintenance crews to rapidly identify alternative areas where control and containment tactics can be developed” in addition to the pre-identified containment sites.
The department said that the strategic reconfiguration amendments to Alyeska’s C-plan continue “to include an offensive rather than defensive approach” to protecting environmentally sensitive areas, “designed to control and contain oil as close to the pipeline as possible,” and that the department believes Alyeska’s plan is keeping with state regulations. More drills required The department is requiring more drills and exercises to validate new and revised scenarios in Alyeska’s amended C-plan, and said it will conduct unannounced exercises to determine Alyeska’s ability to respond within required time frames and provide adequate protection of environmentally sensitive areas. It also said the company’s oil spill exercise program through 2006 must focus on “response strategies, tactics and deployment logistics” modified in the amended C-plan.
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