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DEC taking new tack on risk assessment Five months after a critical NAS review of a larger project, Alaska now looking to find the causes of North Slope oil spills Eric Lidji For Petroleum News
When the State of Alaska began examining the risks facing oil and gas infrastructure back in 2007, it pictured the project as the most comprehensive of its kind, covering the thousands of individual pipelines, wells, terminals and facilities across Alaska. Now, the state is narrowing the focus considerably, looking only at the causes of North Slope oil spills.
Following a harsh critique from the National Academy of Sciences last October, the Alaska Department of Environmental Conservation made “a significant mid-course correction,” according to Ira Rosen, the state project manager for the risk assessment. The project began as a look at all oil and gas infrastructure on the North Slope, in the Cook Inlet, along the trans-Alaska oil pipeline and at its terminus, the Valdez Marine Terminal. Now, the effort is focused on oil spills from North Slope pipeline infrastructure. The state made the shift because the original plan didn’t work. “A critical factor was the acknowledgement that the planned methodology could not be implemented as designed,” Rosen said.
Using the SPILLS database, a 20-year record of spills across the state, for a variety of liquids and even for small amounts, the DEC will look for trends among the causes of North Slope oil spills, especially the role of aging infrastructure, and then recommend prevention measures. Emerald/ABS, the joint venture contracted to conduct the initial risk analysis, is no longer on the project, but Nuka Research and Planning Group is still organizing the program and a new contractor, Cycla Corp., is looking at how other oil countries regulate the industry. The DEC also set up a five member “expert panel” to review the analysis along the way and make recommendations to prevent future spills.
The state announced the new effort in March and the goal is to finish it by July. Rosen said there is enough money from the original appropriation to fund this new effort.
Significantly narrowed scope In some sense, it’s fitting to focus on North Slope oil spills. The project came about following a pair of high profile oil spills at BP-operated facilities on the North Slope in 2006. After being elected governor, Sarah Palin sought to address regulatory gaps in oversight by creating the Petroleum Systems Integrity Office, repealing an agency created by her predecessor, and launched the risk assessment. Palin did not intend for the program to be narrow in any way, though. In May 2007, she requested $5 million for “a comprehensive assessment of the condition of Alaska’s oil and gas infrastructure” and focused on the interconnected nature of oil and gas facilities and equipment, saying, “No such system-wide risk assessment has ever been conducted of this complex system.”
That complexity ended up being a problem, though.
From the beginning, the state struggled to get industry on board. Conflicts abounded.
The state owns the land and the resource, while industry owns the infrastructure. The state wanted to include industry risk management systems in its study. The state struggled to find a contractor that was both well versed in the minutia of the Alaska oil industry, but not professionally bound to the companies and systems it would be scrutinizing.
On top of all that, the state kicked off the project as it was also suing BP over those 2006 spills.
“One of the biggest factors in our consideration was determining what we could actually accomplish with information we either had in hand or were 100 percent sure of obtaining,” Rosen wrote to Petroleum News in a May 18 e-mail. Whereas the previous effort depended on companies handing over lots of information, SPILLS is run by the state (and searchable online).
“We took extracts from the SPILLS database, augmented with data from other sources and sent it to the companies for validation,” Rosen said. “We also asked for company information about their pipelines and spill histories. We have gotten a good response and this part of the project has been completed.”
He said DEC worked with BP and ConocoPhillips “fairly extensively over the past few weeks.”
“System of systems” missing This more modest approach is, by definition, not comprehensive. While recent spills have been on the North Slope, the state of infrastructure in other parts of the state is of no less concern.
The 800-mile trans-Alaska oil pipeline has a fairly solid record despite gunshots, explosions and earthquakes, but is pushing 35 and facing integrity challenges associated with low throughput, which the owners are addressing.
The Cook Inlet basin is even older, and recently showing signs of wear. The eruption of Mount Redoubt highlighted vulnerabilities at the nearby Drift River Oil Terminal. Chevron just shut-in its Anna Platform because of a corroded pipeline riser.
Rosen said the state would not decide whether to analyze the infrastructure in other parts of the state until after it finishes this current phase studying spills on the North Slope.
Perhaps a larger omission, though, is the decision not to explicitly study the “system of systems.” The National Academy of Sciences report said vulnerabilities tend to occur where various systems connect, each part owned by a different company or overseen by a different agency. The original risk assessment included that high level review, tying in with an ongoing review by the PSIO of potential “gaps” in state oversight.
Relying on SPILLS, though, limits what the state can learn about these problems.
“To the extent that this information has been captured in the spill reports, it will be evaluated,” Rosen said. “This was part of the dilemma of working with limited information. A lot of the information we want is not available. One of the outcomes of this study will be recommendations for improving the information in the SPILLS database.” A broader analysis, though, means solving the original problems that made the original risk assessment not useful for the state: a realistic scope and cooperation from industry.
Editor’s note: A quarter cup of seawater is considered a reportable spill on Alaska’s North Slope.
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