Terminal Operations

GAO report looks at Joint Pipeline Office

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Image is screenshot of GAO report.
The GAO’s report is available on their website: Trans-Alaska Pipeline: Clarifying the Roles of Joint Pipeline Office Agencies Would Enhance Safety Oversight.

A new report from the Government Accountability Office, or GAO, examines the current status of the Joint Pipeline Office, or JPO.

The JPO is a group of six federal and six state agencies that oversee various parts of the Trans Alaska Pipeline System. The office was formed after the Exxon Valdez oil spill by the Bureau of Land Management and the Alaska Department of Natural Resources to coordinate oversight between the 12 agencies. The last time the GAO reviewed the JPO was in 1995.

In 2023, Senators Lisa Murkowski and Dan Sullivan asked the GAO to conduct the assessment. They specifically asked the GAO to examine the current structure of the organization; how the organization has changed over time; whether the group effectively collaborates to ensure the safety of the pipeline and terminal; and whether the organization has sufficient personnel, resources, and authority to complete its mission.

The Senators’ request came about after a Council-sponsored report found that, among other issues, there had been a reduction in oversight of the terminal in recent years.

“We’ve just begun reviewing the GAO’s report and its recommendations,” says Donna Schantz, executive director for the Council. “We are extremely appreciative of the efforts of Senators Murkowski and Sullivan for requesting this report.”

The JPO: Then and now

“Since its formation in 1990 in response to the Exxon Valdez oil spill, JPO has played a critical role in overseeing the 800-mile pipeline and marine terminal that comprise the Trans-Alaska Pipeline System,” the GAO’s report says.

Until 2004, the JPO’s oversight activities “focused on producing Comprehensive Monitoring Program Reports, reviewing pipeline projects, preventing and responding to oil spills, preparing for the renewal of the TAPS right-of-way agreement, and responding to Alyeska employee concerns,” according to the GAO’s report. The group previously shared an office and published reports on its activities, which it no longer does.

The report says that, according to stakeholders, JPO “scaled back” its work due to a decrease in TAPS projects that required oversight. The report also notes that JPO’s oversight of TAPS was also impacted by shifts in agency roles.

JPO’s current role is unclear

The GAO report notes that the JPO currently functions “as a forum through which participating agencies share information and coordinate activities.”

The GAO recommends the JPO would benefit from outlining the intended outcomes of its current activities “including those aiming to inform the public of its oversight efforts.” This would “enable JPO agencies to work toward shared goals and ensure accountability.”

“Clarifying roles and responsibilities would enhance coordination among JPO agencies and help JPO identify any potential gaps in oversight,” according to the GAO.

The need to identify gaps in regulatory oversight was a significant finding in the Council’s 2023 report (see also “Two years later: Has safety at the terminal improved?”).

“We are encouraged to see the GAO recommend that the JPO needs to clarify its roles and responsibilities,” Schantz said. “The Council had also hoped that the GAO would identify potential gaps in regulatory oversight. Instead, while mentioning that potential gaps are a concern, they have recommended the JPO do this review for gaps themselves.”

In its 1995 review, the GAO noted that the JPO’s success depends on having adequate staffing and funds over the long term. Government agencies have been experiencing reductions in staffing, budgets, and resources for years, with losses increasing at some federal agencies in recent months. The Council is concerned about the JPO’s current capacity to monitor the complex systems at the terminal, along with their ability to follow through on the GAO’s recommendations.

“Everyone involved wants to make sure that oil is transported safely in Alaska,” Schantz said. “Comprehensive regulatory oversight is of critical importance to help ensure that adequate safety systems are in place to prevent devastating events from occurring. This also supports industry and their desire to increase energy development by providing consistency and timely guidance.

Study estimates emissions from 2022 incident

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A new Council report contains an estimate of crude oil vapors emitted during an incident at the Valdez Marine Terminal in 2022.

Damage from snow and ice during winter 2021-2022

Over the winter of 2021 to 2022, excessive snow and ice built up on top of the vast tanks that store crude oil at the terminal, damaging the pressure vacuum vents on many of the tanks. In some cases, the vents were completely sheared off. These vents control the internal tank pressures, preventing dangerous overpressure or vacuum conditions.

The image shows two photos. One is a distance shot of the storage tanks, which demonstrates how vast the tanks are. The second photo is a closeup of the vents, which are metal and stick up off of the top edge of the tanks.
Oil is stored in tanks until it can be loaded onto ships for transport. Each of the storage tanks can store over 21 million gallons of crude oil.
Pressure vacuum vents are located on the outside edge of the roof on each tank. (Larger image)

During normal tank operations, the internal tank pressure can vary. Oil levels inside the tanks increase or decrease, and other factors such as sunlight heating the tanks can affect the internal pressure.

When the tank vapor pressures get too high, the vents can open and release those vapors to the atmosphere. They also prevent too much oxygen from entering the tanks, which could lead to a fire or explosion.

Damage to the vents led to concerns about the release of crude oil vapors into the surrounding atmosphere and other dangers.

Evaluating the impact

In incidents like these, precise emission volumes are difficult to measure. However, estimates can be calculated using key data points. Last year, the Council hired Dr. Ron Sahu, a nationally respected expert in air quality and engineering, to do just that. By gaining a better understanding of the volume of emissions that was released, the Council hoped to better understand the potential effects on the environment of Port Valdez or nearby residents from this incident.

The Council provided Dr. Sahu with documents from Alyeska and data from the State of Alaska, acquired via public records requests. From these documents, he was able to determine key points such as:

  • The number of tank vents that were damaged.
  • The extent of damage to individual vents.
  • The time period between when the damages were discovered until vent repairs were made and when pressure management of the tanks stopped.
  • The amount of oil in each tank.

Dr Sahu also considered ambient conditions such as temperature, among other factors to complete his analysis.

Using special software developed by the U.S. Environmental Protection Agency that calculates air pollutant emissions from organic liquid storage tanks, Dr. Sahu conservatively estimated that between 79 to 193 tons of volatile organic compounds and hazardous air pollutants were released into the surrounding atmosphere from February through March 2022. Dr. Sahu emphasizes that his estimate is conservative, and that the total is likely higher. Among other factors, he only accounted for losses when the oil levels were not changing in the tanks.

He also provided input on Alyeska’s response to the incident, including areas to improve safety.

Alyeska disagrees with the estimate

Dr. Sahu used the best information that was available to the Council at the time of the report’s release. In preliminary feedback provided by Alyeska, they disagreed with the report’s calculations, noting that they believe the total emissions to be lower. The Council has requested additional information on what Alyeska believes to be inaccurate; however, Alyeska has so far declined to provide any more feedback, limiting the Council’s ability to address their concerns.

Read the report

The full report details Dr. Sahu’s calculations and how he arrived at his conclusions: Report on VOC Emissions from Snow Removal Incident at VMT in 2022

Pilot test evaluates testing methods for buried liners

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How do you detect damage underground? The Council, Alyeska, and the Alaska Department of Environmental Conservation, or ADEC, have been trying to answer that question. The results from a recent pilot test are providing direction to help ensure that oil will not leak through the secondary containment liners under the storage tanks at the Valdez Marine Terminal.

Finding flaws in an underground liner

Last summer, Alyeska conducted a pilot test for locating damage in the special asphalt liners that surround the crude oil storage tanks at the terminal.

The liners are part of a system surrounding the tanks that is designed to prevent oil from leaking into the environment. The liners are difficult to examine because they are buried under several feet of earthen fill. Digging them up for inspection is expensive, time-consuming, and historically has caused damage.

Since the liners were installed nearly 50 years ago, only a small percentage has ever been uncovered and evaluated for damage. When sections have been uncovered, holes or cracks have been found about 19% of the time.

Both Alyeska and the Council have been looking for a method that can determine whether there are cracks or faults in the liner, and if so, where they are located, without having to dig, per requirements set by ADEC.

Results from pilot test

Of the methods that were tested last July, electrical leak location was determined to be the most feasible. 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. The currents that flow through the liner can be detected from the surface, allowing technicians to create a map of damaged areas.

Further analysis to come

Alyeska conducted this pilot test in preparation for a larger-scale test. When approving the last update to Alyeska’s oil spill contingency plan, ADEC placed a condition on the plan’s approval, requiring that Alyeska conduct further analysis of the liner. The timeline for these additional tests is yet to be determined.

How much of the liner needs to be tested?

The Council hired Dr. Craig Benson, Distinguished Professor Emeritus of the University of Wisconsin-Madison, and Dr. Joe Scalia, Associate Professor of Civil and Environmental Engineering at Colorado State University, to weigh in on the pilot test results. They determined that when the large-scale testing is done, at least 20% of the liner needs to be examined to be able to confidently estimate the frequency and size range of defects in the liner.

Details in the report:

Find out more about the pilot test and the expert’s recommendations in the report:

Two years later: Has safety at Alyeska improved?

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Alyeska’s response yields many improvements although concerns remain

Screenshot of cover of report
View 2023 report (PDF 4.1MB): “Assessment of Risks and Safety Culture at Alyeska’s Valdez Marine Terminal”

A 2023 Council report identified some serious safety risks at Alyeska’s Valdez Marine Terminal. Since that time, the Council has been monitoring the actions taken by Alyeska to improve the work culture and more effectively promote an atmosphere of safety. Many areas have improved over the last two years. Some improvements are still in process and some areas of concern remain.

The 2023 report raised concerns about whether the terminal was operating safely and in compliance with regulations. The report was authored by Billie Pirner Garde, a national expert on safety culture for work environments in energy industries. In the report, Garde made a series of recommendations aimed at improving the situation.

Alyeska’s efforts to improve

When the report was first released, the Council was encouraged by its reception. Alyeska President John Kurz spoke to the Council and said that he and Alyeska’s executive team were taking the report seriously.

Alyeska formed an internal team to follow up and develop a plan to address the issues.

“Alyeska has engaged in a substantial amount of work to address the recommendations directed towards them,” says Donna Schantz, executive director for the Council.
Auditors reviewed worker safety and processes at the Valdez Marine Terminal

Alyeska conducted internal reviews and contracted with a third party to audit various factors that affect safety at the terminal.

Auditors compared the current safety system with federal requirements for “process safety management.” OSHA developed this set of standards to help industries safely manage the hazards of working with highly hazardous chemicals. This guidance helps recognize, evaluate, and control risks that could occur while working with hazardous materials.

The auditors identified some areas of improvement in Alyeska’s systems. Alyeska reported that corrective actions have been taken, and there are currently no outstanding audit findings. They also worked on better aligning their documentation regarding process safety management, including the creation of a compliance manual, and conducted additional training.

Alyeska also reviewed their deferred maintenance backlog. Among other issues, Alyeska improved how they evaluate risks associated with work orders. This ensures that higher-risk orders are identified appropriately. Alyeska has prioritized existing work orders and is monitoring any past due and upcoming commitments.

A few issues still remain. A review of human factors was conducted, and a program to help address and mitigate human-related accidents is still being developed. Alyeska also continues to review and assess recommended practices for establishing safety systems.

Alyeska working to encourage culture of safety

Garde’s report recommended mandatory training for supervisors to encourage a stronger safety culture. Alyeska has completed that training.

Alyeska also reported that they continue to develop and improve their employee concerns program. The success of that effort is yet to be determined.

Updated recommendations

Garde recently developed some additional recommendations. Among those, she recommended the Council develop a set of performance indicators that would serve as an objective measure for comparison when talking to Alyeska about concerns.

Remaining concerns

Though many of the safety issues have been addressed, the Council still has concerns: Alyeska has lost key staff with extensive institutional knowledge in recent months; gaps in regulatory oversight and monitoring remain unaddressed; and the Council and contractor Billie Garde continue to receive reports from employees concerned about safety issues.

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