Pipeline Cplan
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11-05-01 Letter to DEC regarding supplemental comments from the Alaska Forum on the
Trans-Alaska Pipeline 2001 Draft Oil Spill Contingency Plan*click icon to download pdf file*
Overview:
In light of the Oct. 4 bullet hole spill at Trans-Alaska Pipeline System (TAPS) MP 400, the Alaska Forum for Environmental Responsibility, on behalf of the Sierra Club, Arctic Connections, Northern Alaska Environmental Center, Alaska Center for the Environment, Greenpeace, and Cook Inlet Keeper, offer the following supplemental comments on the TAPS Oil Spill Contingency and Prevention Plan (C-plan). In comments on the draft C-plan submitted Oct. 8, the Alaska Forum questioned the value of the filing by Alyeska of essentially the same 12 spill scenarios in 2001 that were written for the 1998 plan. We also reiterated concerns – expressed clearly at and after the stakeholder C-plan meetings at Glennallen December 8, 1999 and November 16, 2000 – that ADEC should require field testing by Alyeska of its ability to execute the responses outlined in the scenarios. The undersigned groups believe that the unacceptably long delay in closing the bullet hole at MP 400 demonstrates the consequences of the failure to require Alyeska to write and field-test C-plan scenarios in a meaningful manner.....
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10-08-01 Letter to D.E.C. regarding The Alaska Forum's comments on the Trans-Alaska Pipeline 2001 Draft Oil Spill
Contingency Plan.*click icon to download pdf file*
Overview:
Following the Exxon Valdez oil spill in 1989, there was an increase in public attention on spill prevention and response in Alaska; this includes not only the marine transportation system, but also TAPS. The Alaska Forum acknowledges that many advances to C-plans have been made in that time. But the Alaska Forum also believes that the ability of the Alyeska Pipeline Service Company (APSC) to prevent and respond to an incident has been steadily eroded over the past several years due to pump station closures and budget reductions, while operating modifications related to decreased oil throughput and aging infrastructure appear to have increased operating risks.
The many unanswered questions about past and current C-plans, coupled with clear indications of inadequate training and ineffective exercise performance, demonstrates that APSC and the Joint Pipeline Office have allowed a general degradation of the TAPS C-plan. Worse still, the Alaska Forum’s view that ADEC and JPO have permitted the obfuscation of the most basic points that any C-plan should address: Does the TAPS C-plan contain provisions necessary to prevent or reduce the likelihood of spills, and, if a spill does occur, can APSC provide prompt and effective actions to minimize oil loss and clean up spilled oil?.....
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