At the time of its original design, the useful life of the Valdez Marine Terminal (VMT) was thought to be 30 years and many of the subsystems and components were designed accordingly. The lifetimes of most VMT components are limited due to wear by mechanical action and corrosion, which is due to electrolytic currents and the handling of inherently corrosive fluids.
The identification of specific corrosion instances is difficult because many are hidden in buried pipe and on the inside of pipe and other components that must be disassembled. Inspection of such components is difficult and expensive.
2012 Corrosion Survey
The council’s 2005 survey of Alyeska’s corrosion abatement activities (see below) indicated that such were in compliance with applicable regulations. At that time Alyeska was in the process of implementing the Reliability Centered Maintenance (RCM) paradigm for major assets at the VMT. The council’s recent maintenance advisory audit of the VMT has indicated that the RCM paradigm appears to have fallen into partly into disuse. Although proper maintenance is one avenue by which corrosion issues are addressed, many of Alyeska’s corrosion issues are identified, corrected, and otherwise addressed have always been outside of the RCM paradigm.
Because many corrosion problems are hidden and require expensive inspection techniques, the council is concerned that some corrosion issues will remain hidden until there is a failure of an oil-handling component.
Objectives of the 2012 project:
- to assess extent to which the Alyeska’s recent cathodic protection projects have addressed corrosion issues at the VMT;
- to survey Alyeska’s efforts to address corrosion issues at the VMT;
- to verify that Alyeska has procedures in place to identify and to address corrosion issues;
- to verify that inspection schedules are sufficiently frequent to address recurring corrosion;
- to verify that appropriate standards regarding corrosion are in use at VMT and that these standards drive appropriate correction, maintenance, and inspection schedules;
- to verify that permitted extants of corrosion are acceptable and that inspection schedules are sufficiently frequent and thorough such ongoing and corrosion will be identified and will not exceed beyond permitted levels.
2005 Corrosion Abatement
In 2005, the council conducted a project to:
- Identify the extent to which corrosion issues exist at VMT
- Monitor Alyeska’s efforts to address corrosion issues at the VMT
- Verify that Alyeska has procedures in place to identify and to address corrosion issues
- Verify that maintenance schedules are sufficiently frequent to address recurring corrosion
- Verify that appropriate standards regarding corrosion are in use at VMT and that these standards drive appropriate maintenance and inspection schedules
- Verify that permitted extents of corrosion are acceptable and that inspection schedules are sufficiently frequent and thorough
An independent contractor’s review of VMT corrosion issues indicates that only one regulatory issue — not having the required plan drawings of the cathodic protection (CP) system at the Valdez Marine Terminal — was identified. The drawings are required by 49 CFR 195.589. The existing drawings are not to scale and do not show in detail all the cathodic protection assets with their associated cabling. Consequently, the existing drawings are not adequate for accurate project planning. Additionally, the final report references the on-going dispute between Alyeska and the U.S. Department of Transportation regarding those pipes and other structures at the VMT that are subject to the stricter DOT regulations regarding corrosion.