[Survey Report on Oversight Activities of the Trans-Alaska
Pipeline System, Bureau of Land Management ]
[From the U.S. Government Printing Office, www.gpo.gov]
Report No. 01-I-206
Title: Survey Report on Oversight Activities of the Trans-Alaska
Pipeline System, Bureau of Land Management
Date: February 7, 2001
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U.S. Department of the Interior Office of Inspector General
EXECUTIVE SUMMARY
Oversight Activities of the Trans-Alaska Pipeline System,
Bureau of Land Management
Report No. 01-I-206
February 2001
The 800-mile Trans-Alaska Pipeline System (TAPS), which is operated by the Alyeska
Pipeline Service Company, transports almost 20 percent of the Nation s domestically
produced oil. Federal and State of Alaska agencies are required to ensure that TAPS
operates safely, that oil spills are responded to timely, and that the environment is
protected. One of these agencies, the Bureau of Land Management (BLM), enforces a
Federal right-of-way Agreement on Federal lands, and another agency, the Alaska
Department of Natural Resources, enforces the State s lease on State-owned and private
land. In 1990, BLM and the Alaska Department of Natural Resources created the Joint
Pipeline Office (JPO) to better coordinate Federal and State pipeline regulatory efforts.
The objective of the survey was to determine whether BLM adequately resolved
deficiencies previously identified in TAPS.
We found that JPO took action to close all but 4 of 4,920 previously identified
deficiencies, and after completion of our audit fieldwork, JPO reported that 1of the
remaining 4 items was closed. We also noted that JPO was developing a centralized data
base to document its oversight activities, such as inspections conducted and deficiencies
cited; JPO needs to take steps to ensure that information presented in its reports is
accurate and supported; and JPO access to information from an Alyeska data base that
identified TAPS maintenance records would aid in scheduling its monitoring of activities.
Also, in July 1999, a private interest group made 44 allegations against JPO and Alyeska
regarding the mismanagement of TAPS, which included electrical violations, materials
that could not be traced to authorized suppliers, and improper inspector certifications.
Based on our analyses of a matrix of these allegations prepared by JPO and a report
prepared by Alyeska s consultant, we determined that the allegations were not supported,
were already known, or were being addressed by JPO or Alyeska.
We recommended that JPO (1) complete implementation of the centralized data base, (2)
implement an internal quality control review process, and (3) obtain better access to
maintenance data in Alyeska s data base.
AUDITEE COMMENTS AND OFFICE OF INSPECTOR GENERAL
EVALUATION
BLM concurred with the report s three recommendations and agreed to take the
recommended corrective actions. Based on the response, the recommendations were
considered resolved but not implemented.
C-IN-BLM-002-99-R
SURVEY REPORT
February 7, 2001
Memorandum
To: Director, Bureau of Land Management
From: Roger La Rouche
Acting Assistant Inspector General for Audits
Subject: Survey Report on Oversight Activities of the Trans-Alaska Pipeline System,
Bureau of Land Management (No. 01-I-206)
INTRODUCTION
This report presents the results of our survey of the Bureau of Land Management's (BLM)
oversight activities of the Trans-Alaska Pipeline System (TAPS). The objective of the
survey was to determine whether BLM adequately resolved deficiencies previously
identified in TAPS.
BACKGROUND
TAPS, which is operated by the Alyeska Pipeline Service Company, transports almost
20 percent of the Nation's domestically produced oil. The 800-mile pipeline extends from
Prudhoe Bay, north of the Arctic Circle, over Federal, State of Alaska, and private lands, to
the Port of Valdez on Prince William Sound. It crosses permafrost, 3 mountain ranges,
about 800 rivers and streams, and 3 seismic fault zones. Alyeska operates the pipeline for
seven owner companies.
Pursuant to the provisions of the Trans-Alaska Pipeline Authorization Act of 1973 (43
U.S.C. 1651), the United States, acting through the Secretary of the Interior, executed the
Agreement and Grant of Right-of-Way for Federal land on January 23, 1974 with the seven
oil companies. The Agreement expires on January 22, 2004. In addition, the State executed
a lease with the original seven oil companies for a right-of-way on State lands. The
rights-of-way were granted for the purpose of constructing, operating, and maintaining an
oil transportation pipeline consisting of one line of 48-inch-diameter pipe and related
facilities. In addition, the Agreement for TAPS identifies the responsibilities, authorities,
and requirements of all of the parties. According to the Agreement, the oil companies are
required to ensure full compliance with all Federal laws and regulations and all provisions
of the Agreement, including 47 stipulations that address areas such as fire prevention and
suppression, health and safety, and contingency plans. Federal and State agencies are
required to monitor and enforce the laws, requirements, and regulations intended to ensure
that TAPS operates safely, that oil spills are responded to timely, and that the environment
is protected. These agencies include BLM, which is responsible for enforcing the Federal
right-of-way Agreement on Federal lands, and Alaska's Department of Natural Resources,
which enforces the State's lease on State-owned and private land. The Department of
Transportation's Office of Pipeline Safety is responsible for overseeing the operational safety
of the entire pipeline under the Hazardous Liquid Pipeline Safety Act (49 U.S.C. 60108).
In addition, the Environmental Protection Agency and the Alaska Department of
Environmental Conservation are responsible for enforcing environmental regulations such
as the Clean Water Act (33 U.S.C. 1251) along the pipeline and at the Valdez Marine
Terminal in Valdez, Alaska. In 1990, BLM and the Alaska Department of Natural Resources
created the JPO to better coordinate Federal and State pipeline regulatory efforts. JPO is
funded primarily by BLM and the Alaska Department of Natural Resources. Alyeska is
required, however, to reimburse BLM for all reasonable costs related to overseeing the
pipeline, and by agreement, Alyeska began in 1990 to reimburse Alaska for part of its costs.
Staff are provided by BLM, other Federal agencies, and several State agencies. JPO's costs
were $2.7 million in 1997 and $3.3 million in 1998 (Federal and State agencies that have
responsibilities regarding TAPS are in Appendix 1).
Previously Identified Pipeline Deficiencies
The July 1991 General Accounting Office report titled "Trans-Alaska Pipeline Regulators
Have Not Ensured That Government Requirements Are Being Met" ( No. GAO/RCED-91-
89) stated that the grounding of the Exxon Valdez in March 1989 and its resultant oil spill
and discovery of corrosion along the pipeline focused more attention and concern on the
risks associated with transporting oil. The report also stated:
To successfully fulfill their oversight responsibilities, the five regulatory
agencies can no longer be content with relying on Alyeska to police itself.
The complacency that has existed in the past must be replaced with a
systematic, disciplined, coordinated approach that will ensure TAPS'
operational safety, oil spill response, and environmental protection. The
formation of the joint office as well as recent increases in staffing levels by
BLM and other agencies are encouraging signs that more oversight attention
will be paid to TAPS' activities in the future.
In 1993, Alyeska and JPO each hired consultants to provide audits of the operations of the
pipeline. These audit reports and subsequent technical reports (see Appendix 2) presented
4,920 audit action items that identified deficiencies in pipeline operations. In 1994, one
consultant categorized the audit deficiencies based on priority levels and entered the
information into the audit compliance tracking system, which was used by both Alyeska and
JPO to track the audit findings. JPO uses definitions for the priority levels as follows:
Priority 1 (P-1) - Those structures, systems, and components which prevent
or mitigate the consequences of an accident or natural event which could
cause significant harm to the health and safety of the public, significant harm
to the environment, or significant loss of pipeline integrity.
Priority 2 (P-2) - Those structures, systems, and components that do not meet
the definition of P-1, but which are important for compliance with regulations
regarding safety and the environment, and for the reliable transport of oil.
This level requires selected application of quality program elements.
Priority 3 (P-3) - Those structures, systems, and components that by
themselves would have minimal impact on safety and the environment, and
for the reliable transport of oil, but to which Alyeska elects to apply selected
quality program elements.
Priority 4 (P-4) - Those structures, systems, and components not designated
P-1, P-2 or P-3 and for which application of normal industry practices results
in acceptable quality.
The General Accounting Office issued the report in August 1995 titled "Trans-Alaska
Pipeline Actions to Improve Safety Are Under Way" (No. GAO/RCED-95-162) (see Prior
Audit Coverage section of this report). The report stated that Alyeska had made progress in
resolving the audit action items but that it was taking longer than originally planned. By the
end of April 1995, Alyeska had corrected about 3,030 (62 percent) of the 4,920 audit action
items identified.
As of March 2000, JPO had cleared all but 4, 1 of which consolidated 14 prior audit
deficiencies, of the 4,920 audit deficiencies. The remaining four audit deficiencies consisted
of two Priority 1 and two Priority 2 deficiencies.
Comprehensive Monitoring Program
Since 1995, JPO has been providing oversight of TAPS as part of the Comprehensive
Monitoring Program developed by Booz-Allen & Hamilton, Inc., a consultant to improve the
effectiveness of JPO's operation. The consultant determined that to address risk effectively,
JPO needed to focus more on Alyeska's management of pipeline operations and maintenance
activities. The Program has a three-tier approach to oversight. Surveillance, the first tier,
is where the most basic monitoring occurs through observations in the field by verifying
compliance with (1) grant and lease stipulations, (2) plans to correct pipeline deficiencies
identified by audit, and (3) Alyeska's established procedures for specific TAPS activities.
Tier two involves assessments that capture trends and identify findings from related
surveillances and engineering reports. Assessments are the primary method JPO uses to
issue findings to Alyeska that require corrective action. These assessments are more
technical in nature and are designed primarily to communicate findings to Alyeska. Tier
three is reporting. That is, assessment findings, as well as Alyeska's responses to findings,
trends, and conditions, are included in Comprehensive Monitoring Program reports, which
normally cover an 18-month period.
The results of the Comprehensive Monitoring reports issued during the year are rolled up
into JPO's annual report. The annual report presents JPO's work plan objectives and its
accomplishments for the previous year, as well as the upcoming year's work program goals.
SCOPE OF SURVEY
The survey was performed during September 1999 through May 2000 at JPO's and
Alyeska's offices in Anchorage and Fairbanks, Alaska, and at the Valdez Marine Terminal.
To accomplish our stated objective, we interviewed JPO agency personnel, Alyeska
personnel, members of the Regional Citizens' Advisory Council,and personnel associated
with recent allegations of TAPS mismanagement. We also observed JPO's surveillances of
slope stability on Treasure Creek north of Fairbanks and observed operations at the Valdez
Marine Terminal Operations Control Center during scheduled pipeline repairs. As part of
our review, we followed up on allegations concerning TAPS mismanagement (see section
"Allegations" in this report) made in July 1999 related to the falsification of records, the
harassment of employees, deficiencies in electrical systems, and deficiencies in Alyeska's
quality assurance program and in the Valdez Marine Terminal Vapor Control System. The
Acting Assistant Secretary for Land and Minerals Management responded to these
allegations in an August 12, 1999 letter.
We also reviewed JPO's files on prior pipeline deficiencies that were classified as closed.
We selected 28 audit action items (13 Priority 1 and 15 Priority 2) that were cleared by JPO
from 1994 through 1998 to determine whether the closures were adequately supported. We
selected closed audit action items that pertained to the allegations regarding TAPS,
including those related to the Valdez Marine Terminal.
Our survey was conducted in accordance with the "Government Auditing Standards," issued
by the Comptroller General of the United States. Accordingly, we included such tests of
records and other auditing procedures that were considered necessary under the
circumstances. As part of our review, we assessed JPO's systems of internal controls
applicable to inspecting and tracking prior pipeline deficiencies and monitoring compliance
with Federal and State regulations and found weaknesses relating to tracking and reporting
compliance issues. These weaknesses are discussed in the Results of Survey section of this
report. Our recommendations, if implemented, should improve the internal controls in these
areas.
We also reviewed the Departmental Report on Accountability for fiscal year 1998, which
includes information required by the Federal Managers' Financial Integrity Act of 1982, and
BLM's annual assurance statements on management controls for fiscal years 1998 and 1999
to determine whether any reported weaknesses were within the objective and scope of our
review. No reported weaknesses identified were within the scope of our review.
We also reviewed BLM's Annual Performance Plans for fiscal years1999 and 2000, which
include information required by the Government Performance and Results Act of 1993, to
determine whether any goals or objectives related to JPO were within the scope of our
review. We found that no goals or objectives related to JPO were identified in the Annual
Performance Plans.
PRIOR AUDIT COVERAGE
The Office of Inspector General has not issued any audit reports related to JPO. During the
past 5 years, however, the General Accounting Office has issued one audit report on TAPS.
The report, "Trans-Alaska Pipeline Actions to Improve Safety Are Under Way,"
(GAO/RCED-95-162) dated August 1995, focused on determining whether the planned
corrective actions would address deficiencies in the pipeline's electrical systems, quality, and
preventive maintenance and whether regulators had taken actions to improve oversight of
the pipeline. The report also discussed the root causes of pipeline deficiencies. The report
stated that Alyeska had corrected about 3,030 (62 percent) of the almost 4,920 deficiencies
identified and that the root causes of the pipeline's deficiencies included Alyeska's
philosophy of reacting to problems rather than conducting programs aimed at prevention and
early detection and regulators' inadequate oversight of contractor operations. The report did
not contain any recommendations.
RESULTS OF SURVEY
The results of our review are summarized as follows:
JPO's actions to close all but 4 of the 4,920 previously identified audit action
items were adequately supported.
JPO was developing a centralized data base to document its oversight activities,
such as inspections conducted and deficiencies cited. Because the data base was
not yet compiled, we did not attempt to determine whether JPO effectively
accomplished its inspection and oversight duties.
JPO needs to establish an internal quality control review process to ensure that
information presented in its Comprehensive Monitoring Program reports and
annual reports is accurate and supported.
JPO could more effectively schedule its monitoring activities if it had better
access to information from an Alyeska data base that identified TAPS
maintenance records.
Allegations of July 1999 concerning TAPS mismanagement were not supported,
were already known, or were being addressed by JPO or Alyeska.
Previously Identified Pipeline Deficiencies
We found that except for the four remaining open items, JPO's actions to close the 4,920
pipeline deficiencies identified previously were adequately supported. We based our
conclusion on a review of 28 Priority 1 and Priority 2 case files taken from JPO's Audit
Compliance Tracking System data base. The case files contained sufficient documentation
to address the deficiencies cited. For example, one audit action item identified 16 of 464
locations where the pipeline was initially in contact with the vertical support member.
Alyeska had subsequently moved the pipeline away from the supports. Alyeska, however,
had not performed a technical review of the situation and did not have written procedures on
how to involve engineering in analyzing the stresses put on the pipeline. Alyeska revised
its maintenance and repair manual to include engineering involvement in any future contact
evaluation/repair. Both the revised repair manual and the engineering analysis of the stresses
involved were submitted to JPO for review. JPO accepted the corrective action based upon
the development of procedures and manuals. In addition, JPO had conducted surveillances
on 7 of the 28 cases.
A JPO official said that JPO's approach to closing the audit action items was to confirm that
a corrective action plan by Alyeska addressed the apparent cause of the finding. Specifically,
the official stated that JPO reviewed 100 percent of the corrective action plans and analyzed
100 percent of the supporting documentation for the Priority 1 audit action items, reviewed
100 percent of the corrective action plans and analyzed 20 percent of the supporting
documentation for the Priority 2 audit action items, and reviewed 100 percent of the
corrective action plans for the Priority 3 audit action items. The official also said that any
review of the corrective action plans for Priority 4 audit action items was left for Alyeska's
internal audit function. The JPO official also said that a verification of the effectiveness of
these corrective actions would take place only as part of the surveillance process under the
Comprehensive Monitoring Program. The surveillances are scheduled as part of JPO's
annual work plan and can be either active or passive. An active surveillance consists of a site
visit to confirm that a corrective action has been taken to monitor Alyeska's activities, or to
follow up on a nonconformance report or corrective action request issued by Alyeska. A
passive surveillance is a review of engineering reports or other data submitted by Alyeska.
The four remaining open audit action items are as follows:
- Audit action item 1955 consolidated 14 action items (2 Priority 1, 10 Priority 2, 1
Priority 3, and 1 Priority 4) that captured improvements to the change management process
and the engineering drawing program. The findings associated with this item discussed the
as-built condition of TAPS, stating that TAPS drawings and data were not current and not
representative of the installed facilities.
- Audit action item 2076 (Priority 1) said that the remote gate valve control system
needed to be upgraded to improve security against unauthorized intrusion and to prove
remote diagnostic ability to detect and correct system impairments.
- Audit action item 2113 (Priority 2) said that the measurement of performance and
the training of technicians and controllers needed to be upgraded.
- Audit action item 50528 (Priority 2) said that workpad bridges had to have adequate
clearance to accommodate the 50-year flood clearance requirements, adequate load capacity,
seismic integrity, and use of non-low-temperature steel.
We concluded that resolution of these four audit action items had not been accomplished
because of the long-term nature of the improvements needed and the complexity of the
improvements. For example, audit action item 50528 for improvements to workpad bridges
resulted in Alyeska's removing one bridge in 1998 and replacing four bridges in 1997 and
1998. In addition, Alyeska said that it planned to replace one bridge and upgrade nine more
bridges in 2000. Alyeska estimated that the four open audit action items would be closed
during 2000.
Inspection and Oversight
JPO has been conducting surveillances since 1995 as part of the Comprehensive Monitoring
Program. JPO develops annual work plans to schedule planned work loads for the
subsequent year by program area and to allocate personnel to perform its inspection and
oversight activities of TAPS. The work loads are based on a list of planned projects
submitted by Alyeska, problems identified by JPO during prior surveillances, open audit
deficiencies, and nonconformance reports submitted by Alyeska that identify pipeline-related
problems. In addition, JPO released seven Comprehensive Monitoring Program reports from
1997 through 1999. The issuance of these reports was recommended by a consultant, who
said that JPO should focus its monitoring on 12 program areas. In 1999, JPO consolidated
the 12 areas into 4 areas: maintenance, operations, construction, and culture. Comprehensive
Monitoring Program reports are designed to provide information to concerned citizens and
regulatory agencies on particular focus areas and discuss Alyeska's compliance with grant
and lease stipulations. The reports are the bases for JPO's annual reports. JPO did not,
however, develop a comprehensive compliance tracking system to centrally record its
inspection and oversight activities and Alyeska's compliance with Agreement stipulations
and Federal and State regulations along the pipeline and its related facilities until November
1999.
JPO began development of a new Comprehensive Monitoring Program data base in 1999 that
would identify all the Agreement stipulations and Federal and State regulations by pipeline
facility and by regulatory agency. As of November 1999, JPO had entered all of the 1999
surveillances into the data base and was in the process of entering all prior years' data. JPO
estimated that 1997, 1998, and 2000 surveillances would be in the data base by September
30, 2000. When fully operational, according to JPO officials, the new data base should be
able to document all oversight work performed, including assessment and engineering
reports, from 1997 to 2000 by JPO and its related agencies and to provide JPO with
sufficient information to effectively schedule future surveillances to determine whether all
facilities are complying with the applicable stipulations and regulations.
Quality Control Over Reporting
JPO needs to institute an internal quality control review process to verify that findings in its
annual and comprehensive monitoring reports on TAPS are adequately supported by accurate
and reliable source documentation. Without such a process, JPO does not have assurance
that information in its reports is accurate. For example, we found that JPO's April 1998
Comprehensive Monitoring Program report stated that Alyeska had complied with
Agreement stipulations on both fire prevention and suppression and on health and safety at
the Valdez Marine Terminal. JPO's compliance finding should have been qualified,
however, to clearly state that a review of the operability of the fire suppression system
review had not been conducted. In that regard, a 1999 JPO assessment found that sludge
accumulations brought into question the operability of the subsurface fire suppression system
and that, as a result, JPO ordered Alyeska to test the system.
Access to Alyeska Maintenance Records
We believe that direct access to Alyeska's passport system, a data base system that identifies
all Alyeska maintenance work orders by facility, would enable JPO to more effectively plan
its surveillances and evaluate Alyeska's compliance with the Agreement. In that regard, we
noted that the system had a backlog of 3,345 uncompleted work orders as of November
1999. According to a JPO official, JPO can request Alyeska to provide JPO with
maintenance data from Alyeska's passport system. We believe, however, that it would be
more effective for JPO to have "read only" access for use in planning its inspection and
oversight activities.
Allegations
Our review of the July 1999 allegations made against JPO and Alyeska consisted of our
analyses of a matrix prepared by JPO that addressed each of the 44 allegations and a report
prepared by Alyeska's consultant on the allegations. In addition, we had discussions with
a representative of the personnel who initiated the allegations. Our review of JPO's matrix
found that 2 allegations were not supported; 13 allegations had been previously identified
as a pipeline deficiency by JPO, Alyeska, or a consultant; or Alyeska had corrected the
problem for 10 allegations and had issued a plan for addressing the problem for 19
allegations. In addition, we reviewed documentation for JPO's matrix conclusions on a
sample of 10 of the 44 allegations and determined that JPO had adequately addressed the 10
allegations. The report by Alyeska's consultant and JPO also identified recurring issues
resulting from improper change management procedures, which is open audit action item
1955. In addition, the report identified recurring issues that are undergoing evaluation as
follows:
National Electrical Code violations for electrical components of the Valdez
Marine Terminal.
Use of project materials that, because of the lack of purchase order numbers,
could not be traced to authorized suppliers.
Supplies and materials not being inspected for quality by engineering personnel.
Improper inspector certifications.
Other recurring allegations against Alyeska management by Alyeska's employees were those
of "harassment," "intimidation," and "discrimination." A JPO comprehensive monitoring
report on Alyeska's Employee Concerns Program and JPO's monitoring of the Program
identified problems that resulted in 23 recommendations, which, according to a JPO official,
had been reported as implemented. Additionally, the official stated that JPO intends to
conduct another review of Alyeska's Employee Concerns Program in 2000 to confirm that
the recommendations have been implemented and to assess the effectiveness of the Program.
Recommendations
We recommend that the Director, BLM, require the JPO to:
1. Complete implementation of the comprehensive monitoring program data base
to ensure effective monitoring of TAPS before the Agreement and Grant of Right-of-Way
is renewed.
2. Implement an internal quality control review process to ensure that all external
JPO reports on TAPS are supported by accurate and reliable source documentation.
3. Obtain better access to maintenance data in Alyeska's passport system to assist
in effectively scheduling JPO surveillances. For example, JPO could obtain this information
by obtaining "read only" access at either Alyeska's computer terminals or by an on-line link
from JPO's computer system.
On August 11, 2000, we held an exit conference with BLM and JPO officials. Overall, the
officials agreed with the report's three recommendations. The officials, however, suggested
changes to the report, which we considered and incorporated as appropriate.
BLM Response and Office of Inspector General Reply.
In the November 3, 2000 response the (Appendix 3 ) to the draft report the Director, BLM,
stated that the "report is factually correct and well written" and they concurred with the three
recommendations. In subsequent communications, BLM officials informed us that the target
date for implementation of the three recommendations was March 31, 2001.
Based on the responses, we consider the three recommendations resolved but not
implemented. Accordingly, the recommendations will be referred to the Assistant Secretary
for Policy, Management and Budget for tracking of implementation.
No further response to the Office of Inspector General is required (see Appendix 5).
Section 5(a) of the Inspector General Act (5 U.S.C. app. 3) requires the Office of Inspector
General to list this report in its semiannual report to the Congress. In addition, the Office of
Inspector General provides audit reports to the Congress.
APPENDIX 1
JOINT PIPELINE OFFICE
FEDERAL AND STATE AGENCIES LOCATED AT
THE JOINT PIPELINE OFFICE
Federal Agencies
Department of the Interior, Bureau of Land Management
Environmental Protection Agency
State of Alaska Agencies
Department of Natural Resources
Department of Environmental Conservation
Department of Fish and Game
Department of Labor
Office of Management and Budget, Division of Government Coordination
COOPERATING FEDERAL AGENCIES NOT LOCATED AT
THE JOINT PIPELINE OFFICE
Department of Transportation, Office of Pipeline Safety
U.S. Coast Guard
U.S. Army Corp of Engineers APPENDIX 2
REPORTS AND KEY EVENTS SINCE 1993
CONCERNING TRANS-ALASKA PIPELINE SYSTEM ACTIVITIES
July 1993 Hearing on Trans-Alaska Pipeline System (TAPS), House Committee on
Energy
and Commerce. (Hearings held to examine Alyeska Pipeline Service Company's
ability to manage and operate TAPS safely and the effectiveness of the Federal
Government's oversight of Alyeska.)
August 1993 BLM contracts with Quality Technology Company (QTC) to audit TAPS
operations.
September 1993 TAPS owners contract with Arthur D. Little, Inc., to perform an
independent
assessment of TAPS operations.
November 1993 BLM issues Phase I audit report by QTC, which reports
numerous problems with
TAPS electrical systems.
November 1993 House of Representatives Committee on Energy and Commerce,
Subcommittee
on Oversight and Investigations, holds hearing on TAPS as followup to July
hearings.
December 1993 Arthur D. Little, Inc., issues its Phase I interim report on the
assessment of TAPS
operations. (The report identified 1,132 action items of the 4,920 action items.)
January 1994 QTC completes Phase II report for the BLM audit. (The QTC audit
identified 22
overall deficiencies, and Alyeska translated the 22 deficiencies into 208 audit
action items.)
February 1994 Joint Pipeline Office (JPO) hires Stone & Webster Engineering
Corporation to
assist with providing oversight of the pipeline system.
February 1994 JPO hires Booz-Allen Hamilton to review JPO organization.
June 1994 Booz-Allen Hamilton issues the "Final Report - Comprehensive
Monitoring
Program for JPO" and the "Final Report - Organization and Staffing for JPO."
July 1994 Arthur D. Little, Inc., issues its final report on TAPS. (The report identified
an
additional 3,100 audit action items. With these items and with additional findings
from other audits, the audit action items totaled 4,920.)
August 1995 The General Accounting Office issues the report "Trans-Alaska Pipeline:
Actions
to Improve Safety Are Underway." (Report states that Alyeska corrected 3,030 of
4,920 identified audit action items.)
July 1999 Declaration letter dated July 9 to the Congress and the Secretary of the
Interior
transmits allegations concerning the integrity of TAPS.
August 1999 Alyeska hires Little Harbor Consultants to review the allegations in the
declaration letter to the Congress.
September 1999 Little Harbor Consultants issue a report on TAPS that addresses
the allegations
in the declaration letter to the Congress.
APPENDIX 3
RESPONSE TO DRAFT REPORT FROM BLM APPENDIX 4
STATUS OF AUDIT REPORT RECOMMENDATIONS
Finding/Recommendation
Reference
Status
Action Required
A.1, A.2, and A.3 Resolved; not
implemented. No further response to the Office
of Inspector General is required.
The recommendations will be
referred to the Assistant Secretary
for Policy, Management and
Budget for tracking of
implementation.