Council report assesses risks and safety culture at Alyeska’s Valdez Marine Terminal

View full report (PDF 4.1MB): “Assessment of Risks and Safety Culture at Alyeska’s Valdez Marine Terminal”*

New report: “Assessment of Risks and Safety Culture at Alyeska’s Valdez Marine Terminal”

Prepared by Ms. Billie Pirner Garde, contractor to the Prince William Sound Regional Citizens’ Advisory Council.

This report was initiated in June 2022, in response to safety concerns at the Valdez Marine Terminal (VMT) brought to PWSRCAC by current and former Alyeska employees.

Key finding from the report

The purpose of the assessment documented in the report was to reach a determination, based on the information provided to PWSRCAC, on whether there is a current level of unacceptable safety risk to the VMT, its workforce, the community of Valdez, and the environment. After reviewing all information available through the assessment, it is Ms. Garde’s conclusion that there currently is an unacceptable safety risk to the VMT, and consequently no reasonable assurance that the VMT is operating safely and in compliance with its regulatory requirements.

Inadequate resources (e.g., staffing, equipment, adequate safety and reporting systems) and budget pressures are a common theme in all the issues addressed throughout the report. There is no substantive information in this report regarding safety or process safety issues that is not already available to Alyeska. The failure of the company to act on the information it has is one of the primary weaknesses identified by the assessment.

The Exxon Valdez oil spill in 1989, and Alyeska’s failure to perform effective response capability, changed the industry and Alaska forever. It should have permanently changed Alyeska’s respect for the dangers inherent in its operations as well. Unfortunately, the current situation reveals that due to changes in the organization, availability of resources, quality and audit functions, maintenance and system upgrades, and operational integrity and compliance have suffered significantly under recent corporate management. At the same time, regulatory oversight at the VMT has also diminished.

Report recommendations

Over the past several years, PWSRCAC has become increasingly concerned with budget cuts and reductions in staffing levels at agencies with key oversight responsibilities at the VMT, including the Bureau of Land Management (BLM) and the Alaska Department of Environmental Conservation. The consequences of reduced oversight have, generally, never been favorable for the Alaska public and its environment.

The PWSRCAC Board of Directors endorses all recommendations contained in Ms. Garde’s report. This includes PWSRCAC recommending that Congress initiate a Government Accountability Office (GAO) audit to determine the adequacy of the present regulatory oversight of Alyeska’s VMT operations by federal and state agencies with responsibility over the VMT, including compliance with the Federal Grant of Right-of-Way and Stipulations, and the State Lease.

In line with the recommendation for Congress, the Council is requesting that the State of Alaska initiate an assessment, or audit, of the present regulatory oversight of Alyeska’s VMT operations by state agencies with responsibilities over the VMT.

Per the report recommendations, PWSRCAC is also requesting that the federal Occupational Safety and Health Administration (OSHA) conduct or commission a full independent audit of applicable VMT systems for compliance with Process Safety Management.

The importance of the operational integrity of the VMT cannot be overstated because an incident or accident could interrupt the flow of oil from the Alaska North Slope, thus endangering U.S. energy supplies and energy security. With new oil development on the horizon, every effort must be made to ensure the integrity of systems and infrastructure within the Trans Alaska Pipeline System (TAPS).

The main recommendations include specific requests for Alyeska and the TAPS Owners to:

  • Commission an independent full assessment of the Alyeska safety management systems and determine a specific timeline for actual completion of the necessary changes to ensure safe operations;
  • Commission an immediate independent audit to be conducted of all deferred maintenance at the VMT; and
  • Provide mandatory training for all supervisory and management personnel on their responsibilities to manage in a manner that promotes a strong safety culture, upholds a compliance culture, and does not tolerate harassment, intimidation, retaliation, or discrimination.

These recommendations and requests include more details, which can be found in the Recommendations section of the report. The Council acknowledges that there are recommendations directed internally to PWSRCAC and we will be considering appropriate actions in an effort to address these.

Next steps

The issues and recommendations covered by this assessment and report will take some time to address, possibly years. The Board and staff will now be following up with Alyeska, the Delegation, Governor, Legislature, and regulatory agencies to collect any input and thoughts on the path forward. Discussions need to take place with all parties, once they have had an opportunity to review the information contained in the report, to hopefully outline a process to ensure these matters are addressed in a timely manner.


OPA 90 mandates for the Council include developing long-term partnerships with government and industry, while also directing it to take steps to eliminate the previous complacency of those groups that led up to the 1989 Exxon Valdez oil spill. This is a challenging mission to achieve. It can be difficult to maintain productive relationships with those to whom you must also provide critical feedback, especially during times of serious reductions in staffing and budgets for those entities. While PWSRCAC recognizes this report could generate tension with Alyeska and some of the state and federal regulatory agencies with oversight responsibilities at the VMT, we hope to work with all parties to address these issues in a manner that will lead to a constructive and productive path forward.

Alyeska, state and federal regulators, and the Council all do their best to work with all parties in a highly professional manner, seeking results that will help prevent further oil spills or accidents. This mature, collegial, and cooperative approach has helped protect Alaska from another Exxon Valdez-type of oil spill or other devastating accident over the past three plus decades. But, as the report findings indicate, it takes constant vigilance, training, and monitoring to help ensure that Alaska will be spared another major oil spill.

We know that Alyeska and the associated regulatory agencies have dedicated staff working daily on the Trans Alaska Pipeline System, doing their best to ensure it is operated as safely as possible with the resources they are given. We also recognize that Alyeska and the associated regulatory agencies all have full plates in fulfilling their missions which benefit our nation in terms of safe transport and storage of Alaska North Slope crude oil. And, considering the events taking place in global affairs, the importance of those missions continues to grow.

PWSRCAC recognizes that while zero defects in such missions is the clear intended goal, we also acknowledge there will be times when issues, problems, and deficiencies arise that must be dealt with and resolved once identified. The view of the PWSRCAC, as authorized by Congress, is that the work of this Council should be carried out in a collegial, cooperative, and constructive manner to be of substantial assistance to the mission of Alyeska, and the associated state and federal regulatory agencies, in transport and storage of oil safely through the VMT and associated tankers.

PWSRCAC sincerely appreciates the spirit of cooperation present at its March meeting with Alyeska and hopes to continue to support their work to address the issues raised in the report in the long term. The Council’s Board of Directors and staff agree with the sentiment expressed by Alyeska executives after their receipt of the draft report, that this report provides an opportunity to make Alyeska better by looking into these issues, addressing problems, and making sure employees are heard. It is the Council’s hope that Alaska Congressional Delegation, Governor, Legislature, and regulatory agencies with oversight of the VMT also view the findings and recommendations in the report as an opportunity for improvements to the system.

The Council stands ready to support Alyeska, and state and federal regulatory agencies, in our role as an advisor. We believe firmly that the greatest successes result from citizens, industry, and regulators working together to maintain and improve safeguards designed to prevent and prepare for future oil spills.

Full report: 

Assessment of Risks and Safety Culture at Alyeska's Valdez Marine Terminal (4.1 MB)

Transmittal letters: 

Transmittal letter to the Alaska Congressional Delegation (0.4 MB)

Transmittal letter to Alaska Senate President and Speaker Of The House (0.3 MB)

Transmittal letter to Alyeska Pipeline Service Company (0.3 MB)

Transmittal letter to Governor Dunleavy (0.3 MB)

Transmittal letter to Joint Pipeline Office (0.3 MB)

Transmittal letter to OSHA (0.3 MB)

* Correction: Please note the file name was corrected 4/24/2023 at 1:50 p.m. New direct link:

Electric current can find damage in underground liners

A new Council report shows how electricity can be used to “see” damage in the asphalt liners that are intended to contain oil in case of a spill at the Valdez Marine Terminal.

The terminal’s vast crude oil storage tanks are surrounded by a secondary containment system. This system consists of huge containment cells (two tanks per cell) that would act like a bathtub, holding the oil until it can be cleaned up.

To keep oil from leaking into the surrounding environment, these cells are lined with a special type of asphalt. About 5 feet of gravel fill sits on top of this liner.

These asphalt liners can become brittle with age and are susceptible to physical and chemical damage. Over the years, the gravel fill has been removed in a few places to visually inspect the liner. About 20% of the time, holes or cracks were found.

Removing all the fill to visually inspect and repair the liner would be an expensive and time-consuming project, and the excavation equipment could cause further damage to the liner. Alyeska is looking for ways to evaluate the liner without having to excavate.

To help identify the best liner testing methods, the Council has been working with Dr. Craig H. Benson, who has been teaching and practicing environmental and civil engineering for over 40 years, and has extensive experience in containment systems. A new report by Dr. Benson has several recommendations to help the Council provide advice to Alyeska regarding the secondary containment systems at the terminal in Valdez.

This image shows how electric current can flow through holes in a liner, allowing a technician with a sensor to locate damage in the liner.Dr. Benson evaluated several liner inspection techniques and determined that electrical leak location would likely be the best. This type of survey is done by applying electric currents to the ground outside the liner and measuring electric currents on the surface of the fill inside the liner. A solid liner would block the currents. Holes or cracks would allow the current to flow through. Currents that flow through the liner can be detected from the surface, allowing technicians to create a map of damaged areas.

Dr. Benson also analyzed how much of the liner would need to be tested to have confidence that the liner will reliably hold spilled oil. He determined that testing at least 20% of the liner would be enough to estimate how many holes may exist in the liner, with acceptable accuracy. However, 100% of the liner would need to be tested to find all the actual damage.

The importance of an undamaged liner

The Alaska Department of Environmental Conservation, or ADEC, gives Alyeska a 60% “prevention credit” because this secondary containment system is in place. This means that instead of having to provide response equipment to clean up a spill equal to the contents of the largest tank at the terminal (over 23 million gallons), Alyeska only has to provide response equipment and personnel to clean up a little over 8.5 million gallons.*

This is a substantial reduction in the amount of response personnel and equipment.

In May 2022, ADEC notified Alyeska that they needed to identify preliminary methods to evaluate the integrity of the liners by October 2023. Alyeska must identify final methods to evaluate these liners by March 2025.


*8.5 million gallons, or 204,180 barrels, is the volume of the largest tank, less a 5% prevention credit for drug/alcohol testing, 2% prevention credit for on-line leak detection, and 60% prevention credit for the secondary containment system.

Matt Cullin builds life of growth and success out of expertise in corrosion and failure analysis

Volunteer Spotlight

Cullin is a member of the Terminal Operations and Environmental Monitoring Committee. Volunteers like Cullin dedicate their time and expertise on committees who advise the Council’s Board of Directors on technical issues related to the safe transportation of oil through Prince William Sound.

At his job as the director of the University of Alaska Anchorage’s BP Asset Integrity and Corrosion Lab, Matt Cullin imagines himself as a detective.

“I do a lot of failure analysis work for the oil and gas industry,” he says. “Basically when stuff breaks, we do the CSI forensics to figure out why things broke and why they failed.”

They get big projects and a lot of smaller failures too. “Every couple of months somebody shows up with an old piece of pipe and asks us to tell them what happened.”

His goal isn’t just to solve the crime, though, he wants to learn how to prevent corrosion. For all of these projects, Cullin says his next question is always “how can you keep it from failing in the first place?”

Volunteering for the Council

Cullin also puts his background in mechanical engineering with a specialty in corrosion, materials, and failure analysis into use for the Council as a member of the Terminal Operations and Environmental Monitoring, or TOEM, Committee. He says working with the committee helps him better understand the pipeline and terminal. The students in his classes at UAA benefit too.

“Students have a lot of questions about the pipeline and the terminal,” Cullin says. “These are engineers who might go to work for the state or Alyeska and for them to have that information before they graduate is pretty neat. It’s not a given, when you get a university degree, that you’ll get to study this applied information that’s relevant to your local installation.”

“It’s a cool symbiotic relationship,” he adds.

Cullin recently partnered with a fellow TOEM member, Tom Kuckertz, and staff member Austin Love to create a model to help the committee estimate how much oil could potentially leak through a secondary containment liner at the terminal, if that liner was damaged.

“Typically, when you’re talking about modeling, you want to understand the physics,” he explains.

“I’m good at computer programming, so if you explain the model to me, and the equations that govern it, I can program almost anything. Once you have the equations, solving is the easy part.”

Cullin says you have to be willing to keep an open mind in this line of work. It requires a lot of “let’s figure this out” which he loves.

“Otherwise, it would be boring!”

Cullin says that taking things apart and figuring out how they work is the introductory spark for a lot of engineers. “You don’t have to have that to become an engineer, but it certainly helps to have that curiosity.”

“I really appreciate how it links everything together and you can describe the world in a mathematical form.”

‘Alaska gets its hooks in you’

Cullin’s dog Eva photobombs a scenic portrait. Photo courtesy of Matt Cullin.

ey figured out the physics that governed how the fluid would flow through the materials and then Cullin says it’s just a matter of programming.

Outside of work, Cullin has developed a passion for all things outdoors. He hikes, bikes, skis, packrafts, fishes, camps, and recently took up white water kayaking. He loves the variety of activities Alaska provides and just being outdoors.
“That’s what you’ve gotta do. I can’t just sit inside the house, especially during shoulder season. That doesn’t make me unique, though, just makes me like everybody else in Alaska.”

“When I was in Pennsylvania, I was not outdoorsy,” Cullin adds. “Alaska gets its hooks in you, you start doing this stuff, and then someone says ‘there’s a good job opportunity down in Arizona,’ and you’re like ‘yeah but they don’t have real mountains.’”

“The people that really embrace it, you’re not going to be able to leave.”

Schantz: Collaboration leads to better solutions for prevention and response

Image with a quote from the Oil Pollutions Act of 1990: "Only when local citizens are involved in the process will the trust develop that is necessary to change the present system from confrontation to consensus.”
Photo of Donna Schantz
Donna Schantz

By Donna Schantz
Executive Director

The Oil Pollution Act of 1990 notes congressional findings from the Exxon Valdez oil spill. Included in those findings was the need to foster the long-term partnership of industry, government, and local communities. This is a key piece of the foundation on which the Council was formed.

The Council may not always agree with industry and regulators, but we strive to maintain positive working relationships and build trust. While we do not hesitate to raise concerns when we perceive potential rollbacks in oil spill prevention and response safeguards, it is just as important to recognize when we are in agreement.

I am pleased to report the Council will be supporting Alyeska in a recent appeal they filed with the Environmental Protection Agency (EPA) (page 2). Our independent review verifies that systems Alyeska currently has in place at the Valdez Marine Terminal capture over 99% of the emissions addressed by the rule – a higher reduction goal than is currently being required. The Alaska Department of Environmental Conservation (ADEC) has also voiced support of Alyeska’s appeal to the EPA.

This collaborative approach goes both ways. For example, after months of coordination, Alyeska has also agreed to support a project proposed by the Council to look at the chemical composition and concentration of oxygenated hydrocarbons released from the terminal. Oxygenated hydrocarbons are less studied than other hydrocarbon products and they are potentially toxic in the aquatic environment. Revisions to the scope of work were necessary to satisfy Alyeska’s concerns, mostly related to COVID impacts and their desire to focus resources on their priority operational goals. This is another example of how good communication, strong relationships, and a willingness to work together can lead to solutions that support everyone’s goal of moving oil safely.

There are concerns with the integrity of the secondary containment liner at the Valdez Marine Terminal that we hope can be addressed in a similar fashion. In January, the Council requested an adjudicatory hearing with ADEC in support of the department’s decision to require additional evaluation and testing of the liner. Alyeska also requested a hearing seeking to remove any requirement for further liner testing.

Secondary containment systems are required by Alaska regulation to hold oil in the event of a spill from a tank or pipe until the spill can be detected and cleaned up. The protection of groundwater and Port Valdez, in the event of a breach of one of the terminal’s large crude oil storage tanks, is dependent largely on the integrity of the liner, so it is of critical importance that the liner be inspected to ensure there are no cracks or holes.

For two decades the Council has voiced concern over the ability of the secondary containment liners within the system to meet regulatory standards. The liners were installed during original construction of the terminal, 45 years ago, and the type of liner installed then would not be allowed by regulations today. Additionally, when relatively small sections of the liner have been inspected over the years during other maintenance work, damage to the liner has been discovered. The Council’s persistent calls for more rigorous evaluation and testing, or even replacement of the liner, have not been adequately addressed.

Image with a quote from the Oil Pollutions Act of 1990: "Only when local citizens are involved  in the process will the trust develop that is necessary to change the present system from confrontation to consensus.”

The Council is hoping to find a more collaborative approach to addressing our concerns with the secondary containment liner, in lieu of a hearing. Regardless of how this process proceeds, the ultimate goal is to work together with industry and regulators to give citizens a voice in decisions that impact the safe operation of the terminal and tankers in Prince William Sound.

We often share the following quote from the Oil Pollution Act of 1990 congressional findings, “Only when local citizens are involved in the process will the trust develop that is necessary to change the present system from confrontation to consensus.” We will continue to try and work together with industry and regulators to find solutions that improve oil spill prevention and response.

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