Oil discharge prevention and contingency plans (ODPCPs) have been required under Alaska statutes and regulations for oil exploration, production, storage, and transportation facilities since 1992. BP Exploration (Alaska) Inc. (BPXA) has prepared and submitted their North Slope ODPCPs (Milne Point, Endicott, Greater Prudhoe Bay, and Northstar) as a single volume for each facility under these requirements. However, in 2011, when the four plans were renewed, BPXA elected to present their ODPCPs in two volumes for each facility. The purpose of this organizational change from one to two volumes was to focus information in each volume; the first volume is a stand-alone Emergency Action Plan for spill responders, dedicated to spill response planning and preparedness, and the second volume is dedicated to spill prevention requirements and procedures.
The 2-volume edition allows BPXA's plan writers, operators, and regulators to concentrate on specific response or prevention topics and regulatory compliance. The 2-volume plan is easier to use and revise through the amendment process.
This approach is allowed under Alaska regulations and was embraced by the Alaska Department of Environmental Conservation. Federal regulators (Bureau of Safety and Environmental Enforcement, US Environmental Protection Agency, US Coast Guard, and US Department of Transportation) have reviewed and approved the 2-volume response plans as well.
According to regulators, with such large ODPCPs, the effort to maintain publication efficiency during public review creates a potential risk of confusion or lack of sufficient detail, which may lead to comments that focus on form or style, rather than content. Working with two volumes circumvented this potential problem.
Due to the size and lengthy history of the facilities, an comprehensive Alaska regulations governing the contents of ODPCPs, two volumes allowed BPXA to include all of the necessary information for the plans without creating a storage or ergonomic problem for the reviewers. Regular users of the ODPCPs at the BPXA facilities have found that working with a smaller, more focused volume is more efficient.
