[Survey Report on Supplemental Bonding Issues on the Outer Continental Shelf, Gulf of Mexico Regional Office, Minerals Management Service]
[From the U.S. Government Printing Office, www.gpo.gov]

Report No. 99-i-141

Title: Survey Report on Supplemental Bonding Issues on the Outer
       Continental Shelf, Gulf of Mexico Regional Office, Minerals
       Management Service

Date:  December 22, 1998


                  **********DISCLAIMER**********

This file contains an ASCII representation of an OIG report.
No attempt has been made to display graphic images
or illustrations.
Some tables may be included, but may not resemble those
in the printed version.
A printed copy of this report may be obtained by referring
to the PDF
file or by calling the Office of Inspector General, Division of
Acquisition and Management Operations at (202) 208-4599.

                  ******************************





U.S. Department of the Interior
Office of Inspector General



SURVEY REPORT


SUPPLEMENTAL BONDING ISSUES ON THE OUTER CONTINENTAL SHELF,
GULF OF MEXICO REGIONAL OFFICE, MINERALS MANAGEMENT SERVICE

REPORT NO. 99-I-141
DECEMBER 1998






MEMORANDUM


             TO:  The Secretary

           FROM:  Eljay B. Bowron
                  Inspector General

SUBJECT SUMMARY:  Final Survey Report  - "Supplemental Bonding
                  Issues on the Outer Continental Shelf,
                  Gulf of Mexico Regional Office,
                  Minerals Management Service" (No. 99-i-141)

Attached for your information is a copy of the subject final
surveyreport.  The objective of the survey was to determine
whether theMinerals Management Service's Gulf of Mexico Regional
Office requiredoperators to obtain supplemental bonding in
accordance with applicableregulations and guidelines.

The Office had not obtained sufficient supplemental bonds to
cover theestimated facility abandonment costs for offshore
platforms, wells,and other facilities.  The Service developed
objective standards formaking these financial assessments in the
draft document "Supplemental Bond Procedures" but did not
formally approve or publish that document.  In addition, the Gulf
of Mexico Region had not reviewed 59 nonexempt companies to
determine whether supplemental bonds were required because,
according to Regional personnel, Regional policy provided for a
supplemental bonding review only when lease activity caused a
review to be conducted.  The  bond coverage for these 59
nonexempt companies was $107 million less than the estimated
liability for removal of all facilities for  their leases.  As a
result, the Government could be responsible for facility
abandonment costs of $107 million for those leases that had
insufficient bond coverage.

In its response, the Service concurred with the report's
recommendation.  Based on the response and subsequent
information, we considered the recommendation resolved but not
implemented.

If you have any questions concerning this matter, please contact
me at (202) 208-5745 or Mr. Robert J. Williams, Assistant
Inspector General for Audits, at (202) 208-4252.


Attachment




                                             C-IN-MMS-001-98-R


SURVEY REPORT


Memorandum

     To:  Director, Minerals Management Service

   From:  Robert J. Williams
          Assistant Inspector General for Audits

Subject:  Survey Report on Supplemental Bonding Issues on the
          Outer Continental Shelf, Gulf of Mexico Regional
          Office, Minerals Management Service (No. 99-i-141)

INTRODUCTION

This report presents the results of our survey of selected
aspects of the Minerals Management Service's supplemental bonding
program on the Outer Continental Shelf in the Gulf of Mexico.
The objective of the survey was to determine whether the
Service's Gulf of Mexico Regional Office, in New Orleans,
Louisiana, required operators to obtain supplemental bonding in
accordance with applicable regulations
and guidelines.  This review was requested by Service officials,
who asked that we focus on the implementation of existing
guidelines related to requirements for revisions to or
cancellation of supplemental bonds. Specifically, the Service
wanted us to determine whether its controls were adequate to
ensure that (1) companies were providing supplemental
bonds, when required, that were sufficient to cover estimated
abandonment costs; (2) supplemental bonds were held no longer
than needed; and (3) supplemental bonds were released only when
appropriate.

BACKGROUND

A primary responsibility of the Minerals Management Service is to
manage and regulate the exploration, development, and production
of oil and gas located on the Outer Continental Shelf in a safe
and environmentally sound manner.  The Service's Outer
Continental Shelf program generated an estimated $4 billion of
the total $5.1 billion of Federal receipts for oil and gas during
fiscal year 1997.

The Gulf of Mexico Regional Office conducts all oil and gas
leasing and resource management functions on the Outer
Continental Shelf within the Gulf of Mexico and Atlantic areas.
Various lease terms and conditions cover lessee rights and
obligations relating to developing oil and gas resources, paying
royalties, posting bonds, removing facilities, and protecting the
environment.  Federal regulations and the Service's requirements
contained in Notices to Lessees and Operators and Letters to
Lessees and Operators[1] further define lessee
obligations.  Lessees may assign[2] their lease rights and
obligations to other companies.  If all of the rights and
obligations are assigned, the assignor is considered a prior
lessee, and the assignee is considered the current lessee.  If a
percentage of the lease rights and obligations is assigned, the
assignor and the assignees are considered to be co-lessees.  All
prior and current lessees have joint and several liability[3] for
fulfilling the lease obligations.

According to the Service's data, as of November 1997, the Gulf Of
Mexico had 7,104 leases, which contained more than 3,800
platforms and about 15,000 oil and gas wells.  The platforms vary
in size and complexity.  Simple platforms may have only a single
well, whereas major platforms may have multiple wells, living
quarters, production equipment, and pipeline facilities.  From
1942, when oil and gas development began in the Gulf of Mexico,
through November 1997, 5,423 platforms were installed and 1,605
platforms were subsequently removed from the Gulf.  Of the 3,800
remaining platforms, about 780 were considered to be major
platforms.

The financial liability for abandoned facilities is the Region's
estimates[4] of the costs to remove platforms, plug wells, and
clear sites in the Gulf of Mexico if those facilities are no
longer needed. Further, according to the Service's Technical
Information Management System,[5] as of our review, the
abandonment liability for removal of all facilities in the Gulf
of Mexico was about $5.6 billion.

The Code of Federal Regulations (30 CFR 256.52) requires every
lease to be covered by a general bond to ensure lessee compliance
with all terms and conditions of the lease.  For leases issued
since August 1993, the amount of the general bond increases as
development of the leased acreage progresses from exploration
through production. According to the Code of Federal Regulations
(30 CFR 256.52 and 256.53), the amounts for each stage of
development are as follows:  (1) the minimum bond is $50,000 per
lease or $300,000 per area when there is no development on the
lease, (2) the bond is $200,000 per lease or
$1 million per area when there is a proposed Exploration Plan[6]
or an approved Exploration Plan and the lease is being assigned,
and (3)  the bond is $500,000 per lease or $3 million per area
when there is a proposed Development and Production Plan[7] or an
approved Development and Production Plan and the lease is being
assigned.  According to the Technical Information Management
System, the Region had general bonds totaling $388 million as of
November 1997 covering all 7,104 leases in
the Gulf of Mexico.

The Code of Federal Regulations (30 CFR 256.53(d)) permits the
Service's Regional Director to require a supplemental bond when
it is determined that additional security over the general bond
amount is necessary.  Notice to Lessees and Operators 89-07,
dated December 15, 1989, describes certain lease-specific events
that would cause the Service to analyze the need for supplemental
bonding.  These events include an assignment of the lease, the
submission of certain operational plans, or an indication that
the lease operator has had financial difficulties.  Notice to
Lessees and Operators 89-07 also permits the Service to exempt
certain companies from supplemental bonding if the companies have
been determined to be financially capable of fulfilling their
lease abandonment obligations.  The Service's Letter to Lessees
and Operators dated November 5, 1993, states that a company may
be exempted from supplemental bonding when 25 percent of the
company's net worth equals or exceeds its estimated lease
abandonment costs and the company meets or exceeds one of the
following standards:  (1) has 500 employees, (2) has a net worth
of $35 million, (3) has annual oil and gas sales of $45 million,
or (4) was restricted from joint bidding on Outer Continental
Shelf leases. As of November 1997, 81 companies with interests in
the Gulf of Mexico met these requirements (referred to as exempt
companies), while 101 companies did not meet these requirements
(referred to as nonexempt companies).  Of the 101 companies, 42
companies had provided supplemental bonds covering $245 million
of liability for facilities abandonment, and 59 companies had not
provided any supplemental bonding.

SCOPE OF SURVEY

In performing our survey, we reviewed data on existing facilities
and bond coverage from the Service's Technical Information
Management System, examined selected lease and bond documents,
and interviewed or contacted Service officials about bonding
requirements.  To respond to the Service's request, we performed
a limited review of the Service's release of bonds.  Our audit
work was performed at the Gulf of Mexico
Regional Office; the New Orleans District Office in New Orleans,
Louisiana; and the Service's Royalty Management Program offices
in Lakewood, Colorado.

Our audit was made, as applicable, 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
audit, we evaluated the system of internal controls to the extent
we considered necessary.  We found internal control weaknesses in
the Service's supplemental bonding program.  Our recommendation,
if implemented, should improve the internal controls in this
program.  We also reviewed the Department's
Report on Accountability for fiscal year 1997, which includes
information required by the Federal Managers' Financial Integrity
Act of 1982, and the Service's annual assurance statement for
fiscal year 1997 to determine whether any reported weaknesses
were within the objective and scope of our review.  Neither the
Accountability Report nor the Service's assurance statement
addressed the Service's supplemental bonding program.

PRIOR AUDIT COVERAGE

The Office of Inspector General has not issued any audit reports
on the Service's supplemental bonding program.  However, in May
1994, the General Accounting Office issued the report "Interior
Can Improve Its Management of Lease Abandonment" (No.
GAO/RCED-94-82), which recommended that the Service "complete a
rulemaking to place time limits on the phase-in of both the
increased general bond amounts and supplemental bonding under the
new criteria."  The new criteria that the General Accounting
Office was referring to were the increased general bond amounts
specified in the Code of Federal Regulations (30 CFR 256) and the
Service's procedures for requiring supplemental bonds
specified in its Letter to Lessees and Operators dated November
5, 1993.  In May 1997, the  Service published rules that
established December 8, 1997, as the date by which companies were
required to comply with the increased general bond amounts.
However, as discussed in the Results of Survey section, we found
that the Service had not esta blished a time limit for obtaining
supplemental bonds.

RESULTS OF SURVEY

The Gulf of Mexico Regional Office had not obtained sufficient
supplemental bonds to cover the estimated facility abandonment
costs for offshore platforms, wells, and other facilities. A
November 5, 1993, Letter to Lessees and Operators stated that
effective November 26, 1993, the Service

  . . . may require additional security in the form of a
  supplemental bond or bonds on a case-by-case basis to ensure
  present and future compliance with all lease obligations.
  Factors to be examined by the authorized MMS [Minerals
  Management Service] officer in determining the need for
  supplemental security include, but are not limited to, a
  lessee's financial ability, record of meeting obligations, and
  projected financial strength.

The Service developed objective standards for making these
financial assessments in the draft document "Supplemental Bond
Procedures" but did not formally approve or publish that
document.  In addition, the Region had not reviewed 59 nonexempt
companies to determine whether supplemental bonds were required
because, according to Regional personnel, Regional policy
provided for a supplemental bonding review only when lease
activity caused a review to be conducted.  The  bond coverage for
these 59 nonexempt companies was $107 million less than the
estimated liability for removal of all facilities for  their
leases.  As a result, the Government could be responsible for
facility abandonment costs of $107 million for those leases that
had insufficient bond coverage.

Bond Adequacy

At the time of our survey, the Gulf of Mexico Region had not
periodically reviewed the adequacy of lessees' or operators'
supplemental bond coverage.  Notice to Lessees and Operators
89-07
states:

  Supplemental bonds may be deemed necessary, under the
  provisions   of 30 CFR 256.61 [redesignated 30 CFR 256.53]
  after operations or   production have begun, prior to approval
  of:  assignments of   interests in leases, designations of
  operator, exploration plans, development and production plans
  or development operations coordination documents, or at any
  other time, where the Minerals Management Service infers that
  the obligee may not have the financial wherewithal or expertise
  to carry out the obligations of the lease.
  Such inference may be drawn when the obligee has demonstrated a
  failure to comply with royalty or rental payments, failed to
  comply with OCS [Outer Continental Shelf] operating
  regulations, or otherwise indicated a potential inability to
  carry out the obligations of the lease.

Regional officials said that these guidelines did not provide for
periodic reviews of the adequacy of supplemental bonding on
either a company or a lease basis and that unless activity on a
lease caused a supplemental bond review to be conducted, they
would not periodically perform supplemental bond reviews.  We
also noted that the Region's existing guidelines did not provide
objective standards upon which to base such a review.  The
Region's draft document "Supplemental Bond Procedures," which a
Regional  official said would be issued in August 1998, stated,
"A review of each lessee's cumulative potential liabilities will
be initiated immediately following implementation of these new
procedures.  A review of each lessee's cumulative potential
obligations will be conducted annually."  Regional officials told
us that after the new guidelines are issued, they intend to
perform annual reviews of the adequacy of bond coverage for all
leases and request additional supplemental bonding when
necessary.

Without adequate bond coverage, the Government may have to pay to
remove abandoned facilities.  The Service had not reviewed the
supplemental bonding of 59 nonexempt companies as of November
1997. The Service's Technical Information Management System
produced a report that showed that the 59 nonexempt companies had
a facility abandonment liability of $107 million that was not
covered by bonding as of November 1997.  The largest unbonded
liability was $9.6 million, and the smallest was $50,000.  During
our survey, the Region was also revoking the supplemental bond
exemptions of companies that no longer met the exemption
standard. These companies also needed supplemental bond coverage
reviews.  Based on information contained in the Bond Allocation
Detail Reports[8] for 3 of the 59 nonexempt companies, we found
the following:

  - The first nonexempt company was responsible for 17 leases
  that contained 17 sites, 26 platforms, and 123 wells.  The
  estimated cost to remove these facilities was about $29
  million.  However, there was an exempt co-lessee for four
  leases that had an estimated abandonment cost of $4.1 million.
  Therefore, the facility abandonment liability for the company
  was about $24.9 million.  Total bond coverage of the nonexempt
  company's abandonment liability was $23.2 million, which
  consisted of a general bond of $3 million and 10 supplemental
  bonds of $20.2 million. The unbonded liability was therefore
  about $1.7 million.

  - The second nonexempt company was responsible for 9 leases
  that contained 9 sites, 6 platforms, and 12 wells. The
  estimated cost to remove these facilities was $8 million.
  However, there was an exempt co-lessee for one of  the leases
  that had an estimated facility abandonment liability of
  $800,000.  Therefore, the remaining abandonment liability for
  the nonexempt company was $7.2 million.  The company's
  abandonment liability was covered by a $3 million general
  bond.  The unbonded liability was therefore $4.2 million.

  - The third nonexempt company was responsible for 12 leases
  that contained 4 sites, 7 platforms, and 16 wells.  The
  estimated cost to remove these facilities was $8.4 million.
  However, there was an exempt co-lessee for one of the leases
  that had an estimated abandonment liability of $300,000.
  Therefore, the facility abandonment liability for the nonexempt
  company was $8.1 million.  This liability was covered by a $3
  million general bond, a $200,000 supplemental bond, and two
  additional $500,000 supplemental bonds.  This resulted in an
  unbonded liability of $3.9 million.

Although the Service had not financed the removal of any
facility, other governmental agencies that have missions similar
to those of the Service have paid for the removal of abandoned
facilities under their respective jurisdictions.  For example, as
of September 1997, the State of Louisiana had plugged 216 wells
for State leases at a cost of $9.6 million but had a backlog of
more than 3,100 wells that needed to be
plugged.  Since 1991, the Bureau of Land Management has spent
$1.6 million to plug 131 onshore wells but has a backlog of more
than 300 wells that need to be plugged at an estimated cost of
more than $3 million.

According to the Service's fiscal year 1997 budget justification,
many of the older facilities are operated by small independent
oilcompanies that do not have the financial resources of the
largercompanies that traditionally worked on the Outer
Continental Shelf during the past 40 years.  As such, we believe
that the Service needs to ensure that the Government is
adequately protected from having to cover the costs of removing
abandoned facilities.

Bond Release

In response to the Service's request, we found that the Region's
procedures for bond release were adequate and that, based on our
limited testing, the bonds were promptly released or
appropriately retained as the situation warranted.  The Region
initiated procedures to release a bond when it received a request
from the company that submitted the bond, which typically
occurred upon lease assignment or termination.  If attributable
to an assignment of the lease, the Region released the bond on
the original operator when it received a bond from
the new operator.  If attributable to lease termination, the
Region released the bond when all facilities were removed and all
royalties were paid.  At the time of our review, 24 bond release
actions were pending because of  disputes or appeals regarding
the removal of facilities or payment of royalties.

Recommendation

We recommend that the Director, Minerals Management Service,
expedite formalizing procedures for annual lease or company
reviews to ensure that the supplemental bonding is  adequate.
The Service should also establish a date for which all companies
will be reviewed to determine whether supplemental bonds are
necessary.

Minerals Management Service Response and Office of
Inspector General Reply In the October 28, 1998, response
(Appendix 1) from the Director, Minerals Management Service, the
Service concurred with the recommendation.  Based on the
Service's response and information the Service subsequently
provided, we consider the recommendation resolved but not
implemented.  The Service subsequently provided a target date
of December 31, 1998, for issuance of a Notice to Lessees to
implement the recommendation.  Accordingly, the recommendation
will be referred to the Assistant Secretary for Policy,
Management and Budget for tracking of implementation (see
Appendix 2).

Other Matters

Companies that have supplemental bond exemptions are referred to
as exempt operators.  As of November 1997, 81 companies that had
oil and gas interests in the Gulf of Mexico were determined to be
financially capable and therefore exempt from supplemental
bonding.  During our review, we found that the Region had not
compared the estimated facility abandonment costs of  shared
leases with the net worth of either company when one or more of
the co-lessees had been exempted from supplemental bonding
requirements. Regional officials said that the shared lease
liability was omitted from the review of co-lessees because the
Regional Director had stated that leases having one or more
exempt co-lessees were exempt from supplemental bond coverage.
However, this is contrary to the Service's Letter to Lessees and
Operators dated November 5, 1993, which states:

     A waiver of this supplemental bond requirement on a
     specific lease will be granted by the authorized MMS
     [Minerals Management Service] officer if at least one lessee
     meets the following criteria:

      1.  The MMS-estimated cumulative potential lease
     abandonment liability for the lessee is less than or equal
     to 25 percent of the most recently available and
     independently audited calculation of that lessee's net
     worth.  Assumed herein is that each colessee is separately
     liable for 100 percent of abandonment
     costs.  [Emphasis added.]

We found that each co-lessee was not always held separately
liable for 100 percent of abandonment costs in determining
supplemental bond exemptions.  For example, during 1997, there
were 21 platforms and 19 wells on Lease G-04909.  The Region
estimated the costs to remove the facilities at $9.4 million.
Company A and Company B were co-lessees for Lease G-04909, and
both companies were exempt from supplemental bonding.  The Region
did not add the $9.4 million to either Company A's
or Company B's liability for facility abandonment when comparing
the liability with the net worth of either company.

We are not making any formal recommendations on this issue
because our review did not disclose any instances in which adding
the total estimated facility abandonment liability for shared
leases would have resulted in exceeding the 25 percent net worth
of the exempted companies.  However, we believe that this issue
may become significant in the future as leases are assigned to
companies which have net worth lower than that of existing major
companies.  Accordingly, we encourage the Service to develop
procedures which ensure that the total estimated
facility abandonment liability for leases that have co-lessees is
less than 25 percent of the net worth of at least one co-lessee
before it grants supplemental bond exemptions.

Minerals Management Service Response and Office of
Inspector General Reply

In its response (Appendix 1), the Service disagreed with our
suggestion relating to developing procedures for the total
estimated facility abandonment liability on shared leases.
Specifically, the Service stated that (1) its decision "to not
include shared liability when two or more co-lessees are exempt
was based in part on the very small likelihood that two companies
financially strong enough to meet the supplemental bonding
criteria for self bonding would both go into insolvency at the
same time";  (2) the Letter to Lessees and Operators
dated November 5, 1993, "is not current" and that it "will be
correcting" the document; (3) it "disagrees" that it should
"develop procedures to ensure total liability is added into a
company's liability when two or more exempt companies are
co-lessees . . . before knowing whether a problem will develop
and before knowing the exact nature of a possible future
problem"; and (4) it will "continue to review and evaluate" its
supplemental bonding program and "revise the program as needed"
considering the option suggested in our report.

At the time of our review, the estimated facilities abandonment
liability on leases that had  one or more exempt co-lessees
amounted to $3.2 billion of the $5.6 billion total liability.
Because the issue of liability on shared leases has not resulted
in any problems, it was presented  in the Other Matters section
of this report without a formal recommendation.  However, we
believe that the Service, by adopting our suggestion, would be in
a better position to state that the total estimated facility
abandonment liability in the Gulf of Mexico is covered by a bond
or the amount is less than 25 percent of the net worth of the
responsible companies.  Without including the facility
abandonment liability of shared leases in making its bonding
exemption decisions, the Service has little support for its
statement that the companies are "financially strong."  We
believe that the Service should take a proactive approach rather
than wait for a liability problem to occur on leases that have
exempt co-lessees.

Since the report's recommendation is considered resolved, no
further response to the Office of Inspector General is required
(see Appendix 2).

The legislation, as amended, creating the Office of Inspector
General requires semiannual reporting to the Congress on all
audit reports issued, actions taken to implement
recommendations, and identification of each significant
recommendation on which corrective action has not
been taken.

We appreciate the assistance of Minerals Management Service
personnel in the conduct of our survey.

APPENDIX 2


STATUS OF SURVEY REPORT RECOMMENDATION


Finding/Recommendation
Reference

1


Status


Resolved; not implemented.


Action Required

No further response to the Office of Inspector General is
required.  The recommendation will be referred to the Assistant
Secretary for Policy, Management and Budget for tracking of
implementation.


[1] Notices and Letters to Lessees and Operators are formal
documents that provide clarification, description, or
interpretation of a regulation or Outer Continental
Shelf standard; provide guidelines on the implementation of a
special lease stipulation or regional requirement; provide a
better understanding of the scope and meaning of a regulation by
explaining the Service's interpretation of a requirement;
or transmit administrative information such as current telephone
listings and a change in the Service's personnel or office
addresses.

[2] An assignment is a transfer of all or a portion of the
lessee's recorded title
interest in a lease.

[3] "Joint and several liability refers to the sharing of rights
and liabilities among a group of people collectively and also
individually."  (Law Dictionary, Steven H. Gifis, Barron's Legal
Guides.)

[4] The Region's estimates of the costs to remove platforms, plug
wells, and clear sites were based primarily on actual costs
reported by companies for these activities.   The Region
determined that the companies' actual costs varied
significantly for removing platforms and clearing sites according
to the depth of the water at the site of the platform.
Accordingly, the Region's estimates of the costs to remove
platforms ranged from $350,000 to $1,500,000 and to clear sites
ranged from $150,000 to $500,000 depending on the water depth.
The cost to plug a well was estimated at $100,000.

[5] The Technical Information Management System is a  database
containing geologic, economic, leasing, and other information
related to the Service's Outer Continental Shelf program.

[6] The Code of Federal Regulations (30 CFR 250.33) states that
before beginning exploration activities, lessees are required to
submit an Exploration Plan for Service approval.  The Plan should
describe the proposed type and sequence of exploration
activities with a timetable for their performance.

[7] The Code of Federal Regulations (30 CFR 250.34) states that
before commencing production activities, lessees are required to
submit a Development and Production Plan for Service approval.
The Plan should provide a description of and time schedule
for development and production activities, including the dates
and sequences for drilling wells and installing facilities and
equipment. [8] Bond Allocation Detail Reports were produced from
the Technical Information Management System.   Each  report
pertains to one company.  The Gulf of Mexico Region
uses the reports to grant supplemental bond exemptions, review
bond coverage, and calculate facility abandonment liability.




ILLEGAL OR WASTEFUL ACTIVITIES SHOULD BE REPORTED

TO THE OFFICE OF INSPECTOR GENERAL BY:

Sending written documents to:



Within the Continental United States

U.S. Department of the Interior
Office of Inspector General
1849 C Street,N.W.
Mail Stop 5341
Washington, D.C. 20240

Calling:

Our 24 hour
Telephone HOTLINE
1-800-424-5081 or
(202) 208-5300

TDD for hearing impaired
(202) 208-2420 or
1-800-354-0996



Outside the Continental United States


Caribbean Region

U.S. Department of the Interior
Office of Inspector General
Eastern Division- Investigations
1550 Wilson Boulevard
Suite 410
Arlington, Virginia 22209

Calling:
(703) 235-9221


North Pacific Region

U.S. Department of the Interior
Office of Inspector General
North Pacific Region
238 Archbishop F.C. F'lores Street
Suite 807, PDN Building
Agana, Guam 96910


Calling:
(700) 550-7428 or
COMM 9-011-671-472-7279