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A last resort for responding offshore Experts explain the ins and outs of the new federal and state oil dispersant use plan for oil spill responses in Alaska seas ALAN BAILEY Petroleum News
The approval on Jan. 27 of a new federal and state plan for the use of dispersants in response to an oil spill offshore Alaska brings to the fore the potential use of the technique in the seas surrounding the state.
On Feb. 8 at the Alaska Forum on the Environment some members of the team that developed the new plan explained some of thinking that went into the plan’s features. The plan was developed under the auspices of the Alaska Regional Response Team, the advisory board that coordinates government policies for responding to oil spills in Alaska.
Dispersants applied to oil polluted water break the oil into tiny droplets, distributing the droplets through the water column and accelerating the breakdown of the oil by bacterial action. Applied in a timely fashion, dispersants will quickly dispose of a surface oil slick, potentially preventing the slick from fouling a shoreline. But critics of the technique argue that the dispersed oil and dispersant chemicals can poison and pollute organisms that would not otherwise be impacted by an oil slick floating on the water surface.
Mark Everett, Coast Guard co-chair for the ARRT, told the Forum for the Environment that dispersants are very rarely used in oil spill responses and tend to be reserved for very large spills, in situations where the mechanical removal of spilled oil proves impractical. But in those rare circumstances where dispersant use is appropriate, dispersants form a powerful weapon in the responder’s toolkit, he said. Hence the need for a plan for dispersant use.
“We have to be ready to be able to use it,” Everett said. “You cannot pull that together at the last minute.”
Pre-authorization zone The new Alaska dispersant use plan, which replaces an outdated plan dating from 1989, includes what is referred to as a “dispersant pre-authorization zone” in a region north and south of the Alaska Peninsula, and extending around southern Alaska to the Prince William Sound region. The zone starts 24 nautical miles out from the coast. It extends 100 nautical miles out, on the north side of the Alaska Peninsula, and 200 miles out on the south side. All areas of the state’s coastline and offshore seas that are not in the pre-authorization zone are classified as undesignated areas, Everett explained.
Decisions on dispersant use in the undesignated areas must be made on a case-by-case basis, using an evaluation of the relative merits of this particular response technique in the circumstances of a spill.
The U.S. Coast Guard regulations that kick in for an oil spill incident inside the pre-authorization zone do not actually authorize the use of dispersants, Everett said. Instead, they authorize the federal on-scene commander for the incident to order the mobilization of dispersant supplies, equipment and trained personnel. The commander must still go through a prescribed protocol for making a dispersion use decision, based on an evaluation of whether dispersant application is appropriate for the environment, Everett said.
Moreover, the pre-authorization zone and its attendant regulations only apply to a tanker vessel carrying crude oil and having a U.S. approved vessel response plan - an incident involving any other type of vessel would be viewed as if it occurred in an undesignated area. And the requirements for dispersant use approval in an undesignated area are more stringent than in the pre-authorization zone, Everett said.
Access to resources required The operator of a regulated vessel traversing the pre-authorization zone must have access to appropriately staged resources that enable the mobilization of the means of applying dispersants for up to five hours, starting within seven hours of an order by the federal on-scene commander for that mobilization, Everett said. And, recognizing that operators need time to establish the means of meeting these regulatory mandates, the pre-authorization zone will not go into effect until 24 months after the new Alaska dispersant use plan was approved.
During that 24-month hiatus in pre-authorization zone implementation there will be an opportunity to designate avoidance areas within the zone, areas of particular environmental sensitivity where the rules for the undesignated area would apply. Dispersant application would not be prohibited in the avoidance areas, but these areas would be subject to a more protective standard, Everett explained.
Cmdr. Matthew Mitchell, U.S. Coast Guard chief of planning and force readiness for western Alaska, said that, given the need for scientific expertise in designating avoidance areas, specialists from the Department of the Interior would lead the working groups tasked with the designations. There are five spill response planning subareas within the entire area of the pre-authorization zone - each subarea plan will require changes to accommodate the avoidance area designations.
Everret commented that there had been discussion around the possibility of developing a pre-authorization zone for the Arctic offshore but that, given a lack of agreement between of all of the agencies on that possibility, that particular concept had been dropped. The designation of a pre-authorization zone offshore the Aleutians and southern Alaska recognizes in particular the high risk associated with the carriage of crude oil by tanker in that region, he said.
Tribal and public comments With the new dispersant use plan being jointly developed by the federal government and the state of Alaska, federal laws required consultation with Alaska tribal entities and state laws required an opportunity for public comments on the plan proposals. Consequently, a draft version of the plan underwent a two-year tribal consultation and public comment process. The planning team received more than 500 public comments, and 154 comments from 18 of the 76 tribes invited to consultations.
Everret said that tribal comments particularly emphasized the need to maintain a healthy, clean environment that would sustain communities’ culture and way of life. Tribes are also concerned to be involved in dispersant policy development and decision making, he said.
Rick Bernhardt, Alaska Department of Environmental Conservation unit manager, said that many public comments expressed concern about the impact of dispersant use on long-lived mammals such as whales. However, there appears to be a misconception that dispersants magnify the toxicity of oil, when in fact the use of dispersants redistributes the toxicity through the water column. The tradeoff involved in dispersant use is a reduction in the persistence of the spilled oil in the environment and an ability to prevent the oil from hitting the coastline, Bernhardt said.
Consultation before decision And, in a spill response, the unified command for the response would consult with the U.S. Fish and Wildlife Service and with the National Marine Fisheries Service, the federal wildlife trustee agencies, to determine whether dispersants would be an appropriate tool, Bernhardt said.
One outcome from the public comments that were submitted has been a decision to jointly fund with the Oil Spill Recovery Institute a study into the potential use of an emerging technology involving use of enzyme-base materials that can simulate the effect of bacteria to break down spilled oil, Bernhardt said.
Everret commented that, overall, the new Alaska dispersant use plan introduces a higher level of stakeholder involvement and a higher standard of environmental protection than the old plan that it supersedes. The new plan requires an especially high level of environmental monitoring for dispersant use. And, before dispersants can be used, the response team must conduct and evaluate a small-scale test of dispersant application, to verify technique effectiveness. The test must be repeated in each 24-hour operational period when dispersants may be applied.
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