The Alaska Department of Environmental Conservation approved the new Prince William Sound Tanker Oil Discharge Prevention and Contingency Plan and associated response plans for individual vessels effective November 2, 2012.
These plans—usually known as contingency plans—are prepared by oil tanker operators subject to state approval. The operators specify what they will do to prevent and clean up oil spills from their vessels.
During the review period, the council called for several updates and improvements to the plans.
In 18 pages of formal comments submitted to the Alaska Department of Environmental Conservation on Oct. 12, the council made a number of recommendations for improving the contingency plans before they were given final approval.
One recommendation dealt with downstream response, meaning oil-spill clean-up in communities outside Prince William Sound.
While much of the news coverage of the 1989 Exxon Valdez spill focused on effects inside the Sound, the spilled oil was carried out of the Sound by tidal and coastal currents within a week of the grounding on Bligh Reef. Ultimately it spread to Cook Inlet, Kodiak, and even the village of Chignik, some 460 miles southwest of the spill site. While state regulations require clean-up of oil that escapes the Sound, those requirements are much less specific than for oil still within the Sound.
In its comments, the council encouraged the state and the tanker operators “to set a timetable for the implementation of drills and exercises to ensure that all parties are prepared to mount an effective response in downstream communities.”
Another focus of council comments was the plan for using commercial fishing vessels in the clean-up of oil spills in the Sound, including spills that spread outside it. Under state requirements, tanker operators must be prepared to clean up 300,000 barrels of oil within three days. The plan drafted by the operators claims that having 275 fishing vessels under contract will meet that standard.
The council disagreed.
Historically, the operators and the state have agreed that, on any given day, only about 75 percent of vessels on contract can be counted upon to be available and ready to respond in the required time frame. By the council’s estimate, 371 vessels would have to be under contract to make sure enough were ready to respond when actually needed. The council recommended such a requirement be incorporated in the new contingency plan.
The council’s other recommendations dealt with such issues as:
• protection of sensitive areas before spilled oil arrives
• on-water recovery of spilled oil
• incorporation of Best Available Technology
• the incident command system for managing oil-spill cleanups
• availability of tankers and barges of opportunity that can be pressed into service for hauling away oil recovered during a cleanup
• operating in darkness
• Realistic Maximum Response Operating Limitations, meaning the most severe weather and sea conditions in which it is realistically possible to conduct cleanup operations.
The department attempted to address some of the council’s concerns in their final approval document. Their statement noted that some areas of the plan will need to be verified by oil spill drills and exercises, such as:
• nearshore and open water response
• sensitive area protection
• availability, access and training of certain fishing vessels
• tankers and barges of opportunity
• operating in darkness
• availability of specialty vessels
The council is hopeful future exercises will verify the effectiveness of the plan.