Trans-Alaska Pipeline:

Regulators Have Not Ensured That Government Requirements Are Being Met

RCED-91-89: Published: Jul 19, 1991. Publicly Released: Aug 5, 1991.

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Pursuant to a congressional request, GAO examined the adequacy of regulatory oversight of the Trans-Alaska Pipeline System (TAPS), focusing on TAPS: (1) operational safety; (2) oil spill response capabilities; and (3) ability to protect the environment.

GAO found that: (1) several federal and state agencies had TAPS monitoring, oversight, and enforcement responsibilities; (2) regulators essentially accepted the pipeline operation contractor's reports regarding TAPS conditions and did not independently evaluate corrosion prevention and detection systems; (3) although aware of deficiencies in the corrosion prevention and detection systems, regulators did not direct the contractor to take action until after the contractor detected significant pipeline corrosion in 1989; (4) regulators conducted little oversight of terminal operations; (5) regulatory review of the oil-spill response plan was cursory until after the Exxon Valdez oil spill, after which federal and state regulators reevaluated oil-spill risks and response capabilities; (6) regulators do not plan to require the contractor to conduct a drill to fully test its response capabilities; (7) there was no long-term monitoring program to assess TAPS overall environmental impact, making it difficult to assess oil-spill impacts or to identify the most appropriate containment, cleanup, and disposal technologies; (8) regulators did not have adequate systems to carry out their oversight responsibilities, did not dedicate sufficient staff for monitoring pipeline activities, and did not coordinate oversight activities to ensure comprehensive monitoring of all pipeline activities; and (9) several regulators assigned staff to a joint oversight office composed of federal and state agencies with statutory authority over TAPS.

Matter for Congressional Consideration

  1. Status: Closed - Not Implemented

    Comments: Congress has taken no action on this recommendation. However, Alyeska provides up to $2 million a year and more if special projects are undertaken.

    Matter: To help ensure that sufficient funds are available to support improved oversight, Congress may wish to consider requiring Alyeska to fully reimburse the joint offices for all reasonable oversight costs as it is now required to do for the Bureau of Land Management.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: The joint office has completed an assessment of Alyeska's corrosion and cathodic protection programs.

    Recommendation: To ensure that TAPS is standing up to the special engineering design and operating requirements intended to lessen the potential for oil spills, the Secretaries of the Interior and Transportation should, in cooperation with the state of Alaska, reassess the adequacy of Alyeska's corrosion prevention and detection efforts, including: (1) the cathodic protection system intended to protect the pipeline from corrosion; and (2) plans to better detect and correct internal and external corrosion along the pipeline and at the Valdez terminal.

    Agency Affected: Department of the Interior

  2. Status: Closed - Implemented

    Comments: The joint office has completed an assessment of Alyeska's corrosion and cathodic protection programs.

    Recommendation: To ensure that TAPS is standing up to the special engineering design and operating requirements intended to lessen the potential for oil spills, the Secretaries of the Interior and Transportation should, in cooperation with the state of Alaska, reassess the adequacy of Alyeska's corrosion prevention and detection efforts, including: (1) the cathodic protection system intended to protect the pipeline from corrosion; and (2) plans to better detect and correct internal and external corrosion along the pipeline and at the Valdez terminal.

    Agency Affected: Department of Transportation

  3. Status: Closed - Implemented

    Comments: The leak detection system has been tested several times since September 1991. Regulators witnessed the testing. Alyeska is in the process of updating its leak detection system.

    Recommendation: To ensure that TAPS is standing up to the special engineering design and operating requirements intended to lessen the potential for oil spills, the Secretaries of the Interior and Transportation should, in cooperation with the state of Alaska, require Alyeska to test its leak detection system at various levels of pipeline operations to determine what levels of leakage will trigger an alarm and decide if those leak detection threshold levels meet approved design levels.

    Agency Affected: Department of the Interior

  4. Status: Closed - Implemented

    Comments: The leak detection system has been tested several times since September 1991. Regulators witnessed the testing. Alyeska is in the process of updating its leak detection system.

    Recommendation: To ensure that TAPS is standing up to the special engineering design and operating requirements intended to lessen the potential for oil spills, the Secretaries of the Interior and Transportation should, in cooperation with the state of Alaska, require Alyeska to test its leak detection system at various levels of pipeline operations to determine what levels of leakage will trigger an alarm and decide if those leak detection threshold levels meet approved design levels.

    Agency Affected: Department of Transportation

  5. Status: Closed - Implemented

    Comments: The joint office has completed a review of (1) the permafrost, (2) rock slope stability, and (3) river erosion. They are taking appropriate remedial actions as a result of this review.

    Recommendation: The Secretary of the Interior, in cooperation with the state of Alaska, should improve monitoring and evaluation of Alyeska's efforts to assess and mitigate geologic hazards along the pipeline and at the terminal, including those intended to: (1) stabilize the rock slopes at the terminal and along mountainous sections of the pipeline; (2) safeguard permafrost; and (3) guard against potential damage to the pipeline as the result of river erosion.

    Agency Affected: Department of the Interior

  6. Status: Closed - Implemented

    Comments: EPA issued final regulations (40 CFR part 112) on Oil Pollution Prevention and Response; non-Transportation-related Onshore and Offshore Facilities on July 17, 2002. Section 112.7, Subpart B of these regulations implemented GAO's recommendation that EPA's existing regulations be revised to ensure oversight of the integrity of crude oil storage tanks.

    Recommendation: The Administrator, Environmental Protection Agency (EPA), should revise its regulations to ensure oversight of the integrity of crude oil storage tanks.

    Agency Affected: Environmental Protection Agency

  7. Status: Closed - Implemented

    Comments: The contingency plan is constantly being updated, and the joint office is involved in that process in conjunction with witnessing drills. Quality assurance procedures have been developed.

    Recommendation: To ensure that resources and equipment are adequate to respond to a large-scale leak and can be promptly mobilized and deployed, the Secretary of the Interior should, in cooperation with the state of Alaska, continue to periodically review and update all components of Alyeska's oil-spill contingency plan as was done for the April 1991 plan.

    Agency Affected: Department of the Interior

  8. Status: Closed - Implemented

    Comments: In March 1992, the joint office actively participated in a full-scale drill.

    Recommendation: To ensure that resources and equipment are adequate to respond to a large-scale leak and can be promptly mobilized and deployed, the Secretary of the Interior should, in cooperation with the state of Alaska, actively participate and observe Alyeska's oil-spill drills and training exercises and require that Alyeska address deficiencies identified during those drills.

    Agency Affected: Department of the Interior

  9. Status: Closed - Implemented

    Comments: The joint office witnessed and actively participated in a March 1992 full-scale drill that tested the leadership, coordination, communication, equipment, and personnel mobilization required to respond.

    Recommendation: To ensure that resources and equipment are adequate to respond to a large-scale leak and can be promptly mobilized and deployed, the Secretary of the Interior should, in cooperation with the state of Alaska, require Alyeska to conduct a company-wide, full-scale drill that tests the leadership, coordination, communication, and equipment and personnel mobilization required to locate, contain, and clean up a large-scale oil spill.

    Agency Affected: Department of the Interior

  10. Status: Closed - Implemented

    Comments: Alyeska published a bibliography of all northern spill research data. The joint office has reviewed it and finds no known gaps.

    Recommendation: To ensure that the environmental impacts of TAPS are known and that contamination from future oil spills is minimized, the Secretary of the Interior should, in cooperation with the state of Alaska and Alyeska, review existing studies and rank research needs so that the available resources will be used to address the highest-priority environmental research needs and so that a long-term systematic monitoring strategy can be developed that assesses the pipeline's environmental impacts over time and the environmental consequences of oil spills.

    Agency Affected: Department of the Interior

  11. Status: Closed - Not Implemented

    Comments: The joint offices indicated that each site requiring cleanup will be evaluated on a case-by-case basis.

    Recommendation: To ensure that the environmental impacts of TAPS are known and that contamination from future oil spills is minimized, the Secretary of the Interior should, in cooperation with the state of Alaska and Alyeska, establish realistic cleanup standards on the basis of acceptable levels of contamination.

    Agency Affected: Department of the Interior

  12. Status: Closed - Not Implemented

    Comments: The joint offices, in conjunction with Alyeska, has assessed and evaluated various technologies. The state has established a Technology Review Council to identify, evaluate, and recommend new technologies that might have application in Alaska.

    Recommendation: To ensure that the environmental impacts of TAPS are known and that contamination from future oil spills is minimized, the Secretary of the Interior should, in cooperation with the state of Alaska and Alyeska, determine the advantages of various technologies to effectively contain, clean up, and dispose of oil spilled on water and on land, especially in arctic and subarctic conditions.

    Agency Affected: Department of the Interior

  13. Status: Closed - Implemented

    Comments: The joint office has obtained firm commitments from all five primary regulators. BLM and Alaska's DNR serve as the federal and state point agencies. Several other agencies coordinate with the joint office on an as needed basis.

    Recommendation: The Secretaries of the Interior and Transportation and the Administrator, EPA, should, in coordination with the state of Alaska, ensure that the new joint office provides systematic, disciplined, and coordinated oversight of TAPS. At a minimum, this requires: (1) central leadership; (2) adequate funding; (3) firm commitments to participate from the primary regulators of TAPS; and (4) clear and enforceable requirements, adequate numbers of well-trained staff, and coordination among the responsible federal and state agencies.

    Agency Affected: Department of the Interior

  14. Status: Closed - Implemented

    Comments: The joint office has obtained firm commitments from all five primary regulators. BLM and Alaska's DNR serve as the federal and state point agencies. Several other agencies coordinate with the joint office on an as needed basis.

    Recommendation: The Secretaries of the Interior and Transportation and the Administrator, EPA, should, in coordination with the state of Alaska, ensure that the new joint office provides systematic, disciplined, and coordinated oversight of TAPS. At a minimum, this requires: (1) central leadership; (2) adequate funding; (3) firm commitments to participate from the primary regulators of TAPS; and (4) clear and enforceable requirements, adequate numbers of well-trained staff, and coordination among the responsible federal and state agencies.

    Agency Affected: Department of Transportation

  15. Status: Closed - Implemented

    Comments: The joint office has obtained firm commitments from all five primary regulators. BLM and Alaska's DNR serve as the federal and state point agencies. Several other agencies coordinate with the joint office on an as needed basis.

    Recommendation: The Secretaries of the Interior and Transportation and the Administrator, EPA, should, in coordination with the state of Alaska, ensure that the new joint office provides systematic, disciplined, and coordinated oversight of TAPS. At a minimum, this requires: (1) central leadership; (2) adequate funding; (3) firm commitments to participate from the primary regulators of TAPS; and (4) clear and enforceable requirements, adequate numbers of well-trained staff, and coordination among the responsible federal and state agencies.

    Agency Affected: Environmental Protection Agency

 

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