TESTIMONY ON TRANS-ALASKA PIPELINE
RIGHT OF WAY RENEWAL ENVIRONMENTAL
Walter B. Parker
Alaska Forum for Environmental Responsibility
26 July 2002
This testimony is largely based on my personal history with the Environmental Impact Assessment process, design review and stipulation development that preceded the congressional authorization of TAPS in 1973. From September 1968 to March 1970, I was the Federal Aviation Administration Planning Officer providing oversight of the air lift to Prudhoe Bay and associated airfields. From March 1970 to July 1971, I was the Transportation Planning Officer for the Federal Field Committee for Development Planning in Alaska, where I evaluated for the United States the pipeline and other transportation proposals under consideration at that time. In May 1974, Governor Egan requested that I serve as his Environmental Consultant on TAPS and I also became Director of the Technical Staff at the State Pipeline Coordinators Office. After becoming Commissioner of Highways in December 1974, I maintained contact with the TAPS project thru my responsibilities for the Dalton Highway and as Chair of the Alaska Oil Tanker Task Force for the state. In 1989 I became Chair of the Alaska Oil Spill Commission that investigated the wreck of the Exxon Valdez and in 1991 Chair of the Alaska Hazardous Substance Spill Technology Review Council.
Compared to the process we undertook prior to the construction of TAPS, the present review appears minimal both in its scope and in the time devoted to it. A renewal is being requested for an additional 30 years for a pipeline that has been in operation for 25. Without doubt the Reliability Centered Maintenance (RCM) analyses, 23 on the Valdez Terminal and 25 on the pipeline, have an enormous amount of information contained in them. However, in the time period involved it is very difficult for the interested public to obtain even a smidgeon of that information without highlighting the problem areas section by section. For myself, I am primarily concerned with corrosion, vertical support members (VSM)s and valves. The status of these at river crossings is obviously of particular concern.
My memories are of similar large piles of paper and endless file cabinets which those of us with oversight responsibilities faced at the beginning of construction. Our initial activities were concentrated on the Haul Road (later the Dalton Highway) where massive discrepancies in permafrost location that were not recognized in the computer designed highway (the first in Alaska) occupied us throughout the summer. I am on a Permafrost Task Force for the U.S. Arctic Research Commission and also Chair the Circumpolar Infrastructure Task Force for the Arctic Council. I am briefed on the continued development of the Arctic Climate Impact Assessment several times a year and believe me, it is true that things have been changing very rapidly in the areas affected by permafrost for the past two decades. As can best be determined now, the process is accelerating with some rapidity. I know that the owner companies of TAPS are conducting examinations of this but this information is not available as yet for review by U.S. or international permafrost experts. The JPO has identified a good many of the problems with the above ground sections but I believe the scope of the problem is under estimated at present.
At the beginning of the TAPS construction a great deal of emphasis was placed on the Quality Assurance/Quality Control (QA/QC) program specified in Section 9 of the Federal Grant and Section 16 of the State Lease. Now RCM is brought out as the means by which we can be assured that the pipeline will be maintained safely for 30 years. QA/QC came from NASA, RCM from the Navy. Both were and are focused primarily on vehicle integrity. QA/QC did not provide the assurance needed on the pipeline and certainly did not foresee the first major problems, such as the faulty welding procedures which were discovered by the State Office in the spring of 1975 to be faulty after checking those segments that were being welded in the pipe storage yards. The procedure has been adjusted so that the newest members of the Tulsa union that controlled pipeline welding in the country could do the down welds. QA/QC came in to defend them but could not withstand the questioning of Arnold Lebeau, the State’s consultant. The procedures were changed.
RCM is just another phrase until the quality of the oversight and of the Aleyska maintenance forces is examined and the budgets which will support those efforts are known. We have already heard from the head of BP about the future of maintenance budgets. Nothing was said by government policy makers or regulators in response.
The development of the stipulations involving seismic risk at times had 40 people, the best in the world, in the room as they were finalized. Due to the massive USGS efforts of the past 20 years the science of seismology has advanced dramatically. There is nothing to be found in JPO or Alyeska documents that indicates that a complete new look has been taken on the seismic problems of the pipeline. It would be nice to at least have a few of those involved at the peak of seismology involved in review of the existing situation, or if they have been, to let the rest of us in on it.
Getting back to river crossings, where one expects the absolute top of the state of best practices and best technology to be employed, I will provide you with a little history. In my role at the State Office I had to sign off on the bridges. Later as Highway Commissioner I continued to have the Yukon River bridge as a responsibility. During bridge construction I was advised that a massive fracture had been found in the bedrock under one of the piers. I climbed down in the caisson to look at it and, after intensive consultation, reluctantly gave the go ahead to inject epoxy in the fracture. The same system has been approved at the terminal to hold together the rocks under the tank farm. I have faith in epoxy when relatively new. Where is the research that supports continued reliance upon it 27 years after it was injected at the terminal and the Yukon River Bridge.
We made a reasonably good try at using the top of the state of the art in engineering and science when we constructed TAPS. Unless I hear a good deal more than is contained in present documents about upgrading the stipulations to recognize the advances over the past 30 years in the critical areas I have addressed, I will continue to have grave apprehensions about the ability of RCM or any maintenance regime to mitigate risks unless very firmly regulated and very well financed. As Chairman of the Alaska Oil Spill Commission, I submitted a 1300 page report to the State of Alaska and the United States on the collapse of Alyeska management oversight and the collapse of the state and federal regulatory regimes. The Congress adopted 50 of our 52 recommendations in OPA90. The present situation is certainly not as bad as it was in the 1980s but it still needs a lot of improvement which is addressed in Richard Fineberg’s report, The Emperor’s New Hose, and in his previous reports. I am seriously afraid that if the renewal is allowed to slip through without the kind of review requested in our reports, that it will be taken as a signal by both industry and regulators that this is indeed the best of all possible worlds and “What can go wrong?”. This is the kind of thinking that led to Exxon Valdez, Challenger and Three Mile Island, all of which we examined at the Oil Spill Commission.
RCM is too thin a reed upon which to place one’s faith for the next 30 years without a firm and uncompromising, section by section, analysis of the present problems. I will not repeat the recommendations of the Alaska Forum for Environmental Responsibility here, but since I had a hand in developing them, I strongly support each and every one, most importantly the request for an independent review similar to what was done on Exxon Valdez and the need for a citizen’s oversight council.
(Condensed oral remarks and BLM responses included in BLM Final Environmental Impact Statement, Vol. 6, Part 2, No. 117.)