The Council’s annual report, Year in Review 2022/2023, is now available. This report covers the many programs and projects we’ve been working on over the past year, such as oil spill prevention and response, environmental monitoring, oil spill contingency plans, operations at the Valdez Marine Terminal, invasive species monitoring, our outreach efforts, and much more. Highlights from this year include:
An assessment of risks and safety culture at the Valdez Marine Terminal
Ensuring the adequacy of secondary containment liners for the terminal’s crude oil storage tanks
Supporting solutions for sustainable funding for state spill
prevention and response
Improvements to how the Council monitors weather and sea currents in our region
Monitoring oil spill drills and exercises
Reexamining the Council’s position on use of dispersants in our region
In April 2023, the Council released an assessment of risks and safety culture at the Valdez Marine Terminal. This report was initiated in June 2022, in response to safety concerns brought to Council staff by current and former Alyeska employees.
The Council worked with Billie Pirner Garde, a national expert on safety culture for work environments in energy industries. Garde previously worked as a consultant for both Alyeska and BP on numerous issues such as open work environments, safety cultures, and employee concerns programs.
Garde interviewed the concerned individuals, allowing them to remain anonymous. They reported inadequate staffing, equipment, and safety and reporting systems. Pressure to reduce budgets was a common theme.
One person quoted in the report noted, “we are as safe as the budget allows.”
According to the interviews, the availability of resources, quality and audit functions, maintenance and system upgrades, and operational integrity and compliance have all suffered significantly under recent corporate management.
“Virtually every serious accident investigation confirms that the tension between cost on the one hand, and compliance and safety on the other hand, contributed to the event.”
– Billie Pirner Garde
Alyeska employees
Garde notes in the report that the interviewees all cared deeply about the safe operation of the terminal, and the safety of their colleagues, the community, and Prince William Sound. She credits the integrity, knowledge, and skill of the Alyeska workforce for holding together an aging infrastructure.
Regulatory oversight diminished
Government budget pressures have also contributed to the problems. Over the past several years, the Council has voiced concerns about cuts and reductions in staffing at oversight agencies, including the Bureau of Land Management and the Alaska Department of Environmental Conservation.
“The consequences of reduced oversight have, generally, never been favorable for the Alaska public and its environment,” Garde notes in the report.
Report recommendations
At a special meeting of the Council’s Board of Directors in April, the Council endorsed all recommendations in the report, including that Congress initiate a Government Accountability Office audit to determine the adequacy of the present regulatory oversight of terminal operations by federal and state agencies.
Other recommendations include:
The State of Alaska initiate an assessment, or audit, of the present regulatory oversight of terminal operations by state agencies;
The federal Occupational Safety and Health Administration conduct or commission a full independent audit of applicable terminal systems for compliance with Process Safety Management;
Alyeska and the Trans Alaska Pipeline System owners commission an independent full assessment of the company’s safety management systems and determine a specific timeline for actual completion of the necessary changes to ensure safe operations; that they commission an immediate independent audit to be conducted of all deferred maintenance at the terminal; and provide mandatory training for all supervisory and management personnel on their duty to promote a strong safety culture, uphold a compliance culture, and not tolerate harassment, intimidation, retaliation, or discrimination.
Response from Alyeska
The Council has been encouraged by Alyeska’s response.
John Kurz, the new president of Alyeska, joined the Council’s Board of Directors at the May meeting. He told the Board that he and Alyeska’s executive team are taking the report seriously. He noted that they have formed a team to look into issues identified to determine what is going well, what areas they may be falling short, and what actions they are going to take to address them.
“There is nothing more important than life and family,” Kurz said, when explaining his views on safety in the workplace. “Because I care about everyone that works for us, I also want everyone to experience everything life has to offer, and therefore we will be injury free.”
Schantz says she knows that the staff at Alyeska and the regulatory agencies are dedicated to operating as safely as possible with the resources they are given. “The Council agrees with the sentiment expressed by Alyeska executives that this report provides an opportunity for improvement,” she said. “We stand ready to support Alyeska, and state and federal regulatory agencies, in our role as an advisor.”
“The greatest successes result from citizens, industry, and regulators working together to maintain and improve safeguards to prevent and prepare for future oil spills,” Schantz added.
The full report, including more detail on the resulting recommendations, is available on the Council’s website:
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.
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.
Conclusions
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.
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.
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.
The Council’s annual report, Year in Review 2022/2023, is now available. This report covers the many programs and projects we’ve been working on over the past year, such as oil spill prevention and response, environmental monitoring, oil spill contingency plans, operations at the Valdez Marine Terminal, invasive species monitoring, our outreach efforts, and much more. Highlights from this year include:
In April 2023, the Council released an assessment of risks and safety culture at the Valdez Marine Terminal. This report was initiated in June 2022, in response to safety concerns brought to Council staff by current and former Alyeska employees.
