"All members of the Integrity Management Team provide key support to these Specialists in the execution of their duties," the relocation analysis says. "The loss of key contributors in the move to Anchorage would result in a loss of critical knowledge and skills that are required to perform the functions necessary to insure continued regulatory compliance. This loss will leave Alyeska at risk of receiving" violations from the PHMSA, "as well as potential enforcement actions from" Alaska's Joint Pipeline Office.
Alyeska is now having difficulty filling those vacancies, which Hostler had said would happen by the end of June.
"The immediate risk to TAPS that is present because of the business decision is that several members of Alyeska's integrity management team have resigned," the BP Alaska official said. "This presents a significant risk to the integrity monitoring of TAPS, emergency response capability, as will as a regulatory compliance risk. It is also clear that Alyeska has no plan to quickly place qualified and competent replacements in their vacated positions. The regulatory compliance risk is more than just paperwork, it represents a set of operating and maintenance standards that must be maintained and as the report highlights will be increased likelihood for violations. This is akin to [Minerals Management Service] not closely monitoring the compliance to its regulations on the Deepwater Horizon rig."
"When you combine the removal of personnel from some of the TAPS pump stations as part of the strategic reconfiguration project with this action, you are left with considerably less capability to respond to integrity issues or emergency responses," the BP official added. "The spill at pump station 9 is a case in point that it would have been spotted quicker and would have spilled less if any at all if that pump station had been manned."
Emails sent to BP's ombudsman's office and the relocation analysis point out that the any loss of integrity management staff will "set Alyeska back on progress that [the company] made" since 2007, when it beefed up its integrity management team after Hostler testified to Congress about corrosion prevention efforts on TAPS.
A careful review of violation and penalty assessment records posted on the PHMSA web site lists more than 100 probable violation incidents between 2001 and 2007, many of which are related to integrity management issues such as corrosion monitoring deficiencies. But since 2007, there has been a reduction in violation assessments ,which, employees argue, is directly related to the company's investment in integrity management.
The analysis further states that a relocation to Anchorage would result in the loss of half of the integrity management team staff. That prediction was borne out, according Alyeska employees, as eight of the 18 people who were asked to relocate to Anchorage quit and two more are likely to depart the company. Alyeska is now having difficulty filling those vacancies, which Hostler was quoted as saying would happen by the end of June.
Replacing these personnel will be a challenge, according to a pipeline industry report published in July 2009.
The Interstate Natural Gas Association of America warned managers in the pipeline industry that areas of greatest personnel risk are "positions that require significant industry experience and would be at risk from a shrinking industry workforce pool due to attrition, such as pipeline integrity engineers, project engineers/managers, and construction managers."
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