Pipeline Safety
Status of Improving Oversight of the Pipeline Industry Gao ID: GAO-02-517T March 19, 2002The Office of Pipeline Safety (OPS) oversees 2.2 million miles of pipelines that transport potentially dangerous materials, such as oil and natural gas. OPS has been slow to improve its oversight of the pipeline industry and implement critical pipeline safety improvements. As a result, OPS has the lowest rate of any transportation agency for implementing the recommendations of the National Transportation Safety Board. In recent years, OPS has taken several steps to improve its oversight of the pipeline industry, including requiring "integrity management" programs for individual operators to assess their pipelines for risks, take action to mitigate the risks, and develop program performance measures. OPS has also (1) revised forms and procedures to collect more complete and accurate data, which will enable OPS to better assess the causes of incidents and focus on the greatest risks to pipelines; (2) allowed more states to oversee a broader range of interstate pipeline safety activities; and (3) increased the use of fines. OPS has made progress in responding to recommendations from the Safety Board and statutory requirements, but some key open recommendations and requirements, such as requiring pipeline operators to periodically inspect their pipelines, are now more than a decade old. OPS faces challenges that include (1) developing performance measures for the integrity management approach, (2) ensuring sufficient resources and expertise to oversee operators' integrity management programs, (3) providing consistent and effective enforcement of integrity management program requirements, and (4) issuing requirements for integrity management programs for operators of gas transmission pipelines.
GAO-02-517T, Pipeline Safety: Status of Improving Oversight of the Pipeline Industry
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United States General Accounting Office:
GAO:
Testimony:
Before the Subcommittee on Energy and Air Quality, Committee on Energy
and Commerce, House of Representatives.
For Release on Delivery:
Expected at 2:00 p.m. EST:
Tuesday, March 19, 2002:
Pipeline Safety:
Status of Improving Oversight of the Pipeline Industry:
Statement of Peter F. Guerrero:
Director, Physical Infrastructure Issues:
GAO-02-517T:
Mr. Chairman and Members of the Subcommittee:
We appreciate this opportunity to testify on the Office of Pipeline
Safety‘s (OPS) oversight of the safety of our nation‘s pipeline
infrastructure. Our statement is based on reports we issued in May 2000
and September 2001, as well as ongoing work for Mr. Dingell of this
Subcommittee.[Footnote 1]
OPS oversees the safety of 2.2 million miles of pipelines that transport
potentially dangerous materials, such as oil and natural gas.
Historically, OPS has been slow to take action to improve its oversight
of the pipeline industry and implement critical pipeline safety
improvements. As a result, OPS has the lowest implementation rate of
any transportation agency for recommendations from the National
Transportation Safety Board (the Safety Board). This lack of
responsiveness has prompted Congress to repeatedly mandate basic
elements of a pipeline safety program, such as requirements to
periodically inspect pipelines. In recent years, OPS has initiated
several actions to improve its oversight of the pipeline industry,
including requiring ’integrity management“ programs for individual
operators to assess their pipelines for risks, take action to mitigate
the risks, and develop program performance measures. We are here today
to discuss (1) OPS‘ progress in implementing integrity management and
other initiatives, (2) OPS‘ progress in responding to recommendations
from the Safety Board and statutory requirements, and (3) issues that
are critical to the future success of OPS‘ initiatives to improve the
safety and oversight of the pipeline industry.
In summary:
OPS has moved forward with its new risk-based regulatory approach”
integrity management”that requires operators to develop programs that
focus on the greatest risks to their pipelines. This approach differs
significantly from its traditional approach of inspecting pipelines for
compliance with uniform regulations establishing minimum standards.
OPS plans to review and monitor these programs, which will be unique for
each of more than 400 hazardous liquid and natural gas transmission
operators. OPS has issued final rules requiring the phased
implementation of these programs for operators of hazardous liquid
pipelines. The agency also plans to issue a final rule for operators of
natural gas transmission pipelines by the end of 2002.
OPS has also made progress on other initiatives that are intended to
improve the agency‘s oversight of the pipeline industry. These
initiatives include:
* Revising forms and procedures to collect more complete and accurate
data, which will enable OPS to better assess the causes of incidents and
focus on the greatest risks to pipelines. According to the Safety Board
and industry associations, these actions address the underlying
problems with OPS‘ data, such as limited data on the causes of
incidents. OPS hopes to implement most of its initiatives to improve
data in 2002. However, according to industry associations, it may be
several years before OPS has sufficient data to thoroughly evaluate
industry trends, especially for hazardous liquid pipelines.
* Allowing more states to oversee a broader range of interstate pipeline
safety activities. State pipeline safety inspectors are an invaluable
resource for OPS because they are familiar with pipeline safety issues
unique to their states. OPS responded to our May 2000 recommendations
that the agency better utilize this resource by allowing states to
participate in a wider range of oversight activities, such as reviewing
integrity management programs for pipelines in their individual states.
* Increasing the use of fines, thereby reversing OPS‘ former trend of
relying more heavily on less severe corrective actions. From 1990
through 1998, OPS decreased the number and amount of fines while
increasing the use of less severe corrective actions, such as letters
of concern. We questioned this change in OPS‘ enforcement policy and
recommended in May 2000 that the agency determine the impact of the
reduced use of fines on safety. According to OPS officials, the agency
is not able to determine this impact as we recommended because it does
not have sufficient data to link its compliance actions with
improvements in safety. Nevertheless, OPS determined that its
enforcement policy was perceived negatively and did not adequately
address safety concerns. OPS subsequently changed its enforcement
policy to make better use of its full range of enforcement tools,
including increasing the number and severity of fines. According to OPS
officials, the agency plans to collect data that will allow it to link
its compliance actions with improvements in safety. We are evaluating
OPS‘ response to our recommendation.
OPS has made progress in responding to recommendations from the
Safety Board and statutory requirements, but still has not implemented
some significant recommendations and requirements. In May 2000, we
reported that OPS had the lowest rate of any transportation agency in
responding to recommendations from the Safety Board and had not
completed 22 out of 49 statutory requirements imposed since 1988. OPS
has since improved its responsiveness to the Safety Board‘s
recommendations and taken action on eight statutory requirements.
However, some recommendations and requirements dealing with issues
that are critical for pipeline safety”such as requiring pipeline
operators to periodically inspect their pipelines”are more than a
decade old and OPS still has not implemented them. According to OPS
officials, the agency‘s ongoing initiatives should fulfill the majority
of the open recommendations and requirements before the end of 2002.
OPS faces major challenges in implementing its initiatives and in
fulfilling the Safety Board‘s recommendations and statutory
requirements. These challenges include (1) developing performance
measures for the integrity management approach, (2) ensuring sufficient
resources and expertise to oversee operators‘ integrity management
programs, (3) providing consistent and effective enforcement of
integrity management program requirements, and (4) issuing requirements
for integrity management programs for operators of gas transmission
pipelines. We are reviewing these issues as part of our ongoing work,
and will address them in our final report.
Background:
OPS regulates the safety of almost 2.2 million miles of pipelines,
which is enough to circle the earth 88 times. There are three primary
types of pipelines under OPS‘ jurisdiction. Natural gas transmission
pipelines”about 322,000 miles”transport natural gas over long distances
from sources to communities. An additional 1.7 million miles of natural
gas distribution pipelines continue transporting the gas throughout the
communities to consumers. Finally, about 155,000 miles of hazardous
liquid pipelines generally transport crude oil to refineries and
continue to transport the refined oil product, such as gasoline, to
product terminals and airports.
These pipelines transport the bulk of natural gas and petroleum products
in the United States and are the safest mode for transporting these
potentially dangerous commodities. Although pipeline incidents resulted
in an average of about 24 fatalities per year from 1989 to 2000, the
number of pipeline incidents is relatively low when compared with those
involving other forms of freight transportation. On average, about 66
people die each year in barge accidents, about 590 in railroad
accidents, and about 5,100 in truck accidents. Despite the relative
safety of pipelines, pipeline incidents can have tragic consequences,
as evidenced by the incidents at Bellingham, WA, and Carlsbad, NM.
These incidents, which caused 15 fatalities, highlighted the importance
of pipeline safety and the need for more effective oversight by OPS.
From 1989 through 2000, the total number of incidents per 10,000 miles
of pipeline decreased by 2.9 percent annually, while the number of major
pipeline incidents (those resulting in a fatality, an injury, or
property damage of $50,000 or more) per 10,000 miles of pipeline
increased by 2.2 percent annually. (See figure 1.) Over the same time
period, pipeline mileage increased 1.6 percent annually from 1.9 to 2.2
million miles of pipelines.
Figure 1: Major and Total Incidents per 10,000 Miles of Pipeline:
[See PDF for image]
This figure is a multiple line graph with lines depicting incidents in
the following four categories for the years 1989 through 2000:
Total incidents;
Annual average (total incidents);
Major incidents;
Annual average (major incidents).
Source: GAO‘s analysis of OPS data.
[End of figure]
Traditionally, OPS carried out its oversight responsibility by
requiring all pipeline operators to comply with uniform, minimum
standards. Recognizing that pipeline operators face different risks
depending on such factors as location and the product they carry, OPS
began exploring the concept of a risk-based approach to pipeline safety
in the mid-1990s. In 1996, the Accountable Pipeline Safety and
Partnership Act directed OPS to establish a demonstration program to
test a risk-based approach. The Risk Management Demonstration Program
went beyond OPS‘ traditional regulatory approach by allowing individual
companies to identify and focus on risks to their pipelines. Since the
program‘s initiation in 1997, OPS has approved six demonstration
projects.
OPS Has Made Progress in Implementing Integrity Management Programs and
Other Initiatives:
Partly on the basis of OPS‘ experience with the Risk Management
Demonstration Program, the agency has moved forward with a new
regulatory approach that requires pipeline operators to comprehensively
identify and address risks to the segments of their pipelines that are
located in ’high consequence areas“ where a leak or rupture would have
the greatest impact.[Footnote 2] This approach requires individual
pipeline operators to develop and follow an integrity management
program. Each program must contain specific elements, including a
baseline assessment of all pipelines that could affect high consequence
areas, periodic reassessment of these pipeline segments, prompt action
to address any problems identified in the assessments, and measures of
the program‘s effectiveness.
Although OPS has issued final rules requiring integrity management
programs for operators of hazardous liquid pipelines, the agency has not
issued a proposed rule for operators of gas transmission pipelines. In
December 2000, OPS issued a final rule for operators of ’large“
hazardous liquid pipelines, defined as pipeline systems of at least 500
miles. Under this rule, individual operators were required by December
31, 2001 to identify pipeline segments that can affect high consequence
areas, and then develop a framework for their integrity management
program and a plan for conducting baseline assessments by March 31,
2002. OPS issued a similar rule for operators of ’small“ hazardous
liquid pipelines that are less than 500 miles long on January 16, 2002,
with later deadlines. For natural gas transmission pipelines, OPS
anticipates issuing a final rule in fall 2002.[Footnote 3]
OPS plans to review and monitor operators‘ programs for compliance with
the integrity management requirements, but will not formally approve
operator programs. OPS is currently in the first of a four-phase plan
for reviewing and monitoring integrity management programs for
operators of large hazardous liquid pipelines.[Footnote 4] In phase
1”scheduled to be completed by the end of April 2002”OPS is reviewing
operators‘ identification of pipeline segments that impact high
consequence areas. During phase 2”from July 2002 to July 2004”OPS will
inspect the more fully developed framework and assessment plans. After
July 2004, OPS plans to monitor operators‘ implementation of their
individual programs through periodic inspections in phase 3, and review
and respond to notifications from operators of changes in their
programs in phase 4.
OPS is hiring and training additional inspectors to review and monitor
operators‘ programs. OPS had 56 inspectors in fiscal year 2001 and plans
to hire an additional 30 inspectors”a 54-percent increase”by the end of
fiscal year 2003. OPS plans to augment its inspection force with
contractor and state support as it develops the necessary expertise to
review and monitor operators‘ programs. OPS has also developed a list
of training courses that will be required for federal and state
inspectors, and it is currently scheduling this training. OPS officials
anticipate that it will take about 2 years to provide this training to
all federal and state inspectors.
In addition to the integrity management programs, OPS is making progress
on other initiatives for improving data, involving states, and
increasing the use of fines. These initiatives are intended to improve
pipeline safety and the agency‘s oversight.
OPS Is Taking Action to Improve Data:
DOT‘s Inspector General, the National Transportation Safety Board, and
others have reported that OPS‘ data on pipeline incidents and
infrastructure are limited and sometimes inaccurate. For example, in the
past, OPS‘ incident report forms have used only five categories of
causes for incidents on natural gas distribution pipelines, four
categories for those on natural gas transmission pipelines, and seven
categories for those on hazardous liquid pipelines. As a result, about
one-fourth of all pipeline incidents were attributed to ’other causes,“
which limited OPS‘ ability to identify and focus on the causes of
incidents. In addition, data on the amount of pipeline mileage in
various infrastructure categories (such as age or size) are necessary
for a meaningful comparison of the safety performance of individual
pipeline companies. OPS did not require hazardous liquid pipeline
operators to submit this type of data and did not collect complete data
from natural gas pipelines. Finally, the information on incident
reports filed by operators sometimes changes as the incident
investigation proceeds. OPS did not have a procedure for ensuring that
operators submitted revised reports when needed.
OPS is taking action to collect data that will allow it to more
accurately determine the causes of incidents, analyze industry trends,
and compare the safety performance of operators. For example, OPS
revised its incident report forms in 2001 for hazardous liquid and
natural gas transmission incidents to include 25 categories of causes
and plans to revise the form for natural gas distribution incidents by
the end of 2002. Furthermore, OPS is assigning an inspector in each
region to review incident report forms for completeness and accuracy,
and has instituted new electronic notification procedures to ensure
that operators submit revised incident reports, if necessary. OPS also
plans to institute annual reports for hazardous liquid pipeline
operators, and is in the process of revising annual report forms for
all natural gas pipeline operators. Finally, OPS is conducting studies
of incident information to improve its understanding of the causes of
incidents. According to OPS officials, most of these improvements will
be implemented for 2002 data.
According to the Safety Board and industry groups, OPS‘ initiatives
address the underlying data problems and will enable OPS to better
understand the causes of incidents so the agency can focus its efforts
to improve safety. However, officials from industry groups told us that
it will be several years before OPS has sufficient data to analyze
trends in incidents. Officials from the Safety Board also noted that
these initiatives are merely a first step, and they emphasized that OPS
should periodically reassess its forms and procedures and take steps to
revise them as necessary. We are evaluating OPS‘ data improvement
initiatives as part of our ongoing work.
States Are Taking a Greater Role in Overseeing Interstate Pipeline
Safety Activities:
OPS is allowing more states to help oversee a broader range of
interstate pipeline safety activities. Although OPS relies heavily on
state inspectors to oversee intrastate pipelines, it reduced its
reliance on states to inspect interstate pipelines in the mid-1990s
when it moved to a more risk-based, system-wide approach to inspecting
pipelines. At that time, OPS believed it would be too difficult to
coordinate participation by individual states in the new inspection
process. However, in our May 2000 report, we found that allowing states
to participate in interstate pipeline safety inspections could improve
pipeline safety by increasing the frequency and thoroughness of
inspections to detect safety problems. Additionally, state pipeline
safety inspectors are likely to be familiar with pipelines in their
jurisdictions and the potential risks faced by these pipelines. We
recommended that OPS work with state pipeline safety officials to
determine which activities would benefit from state participation and,
for states that are willing to participate, integrate their activities
into the safety program. We also recommended that OPS allow state
inspectors to assist in reviewing the integrity management programs
developed by the companies that operate in their states to help ensure
that these companies have identified and adequately addressed safety
risks to their systems.
OPS responded to our recommendations in 2001 by encouraging more
states to oversee the safety of interstate pipelines in their states.
These states may perform a broad range of oversight activities, such as
inspections of new construction, oversight of rehabilitation projects
and integrity management programs, incident investigation, standard
inspections, and participation in nonregulatory program initiatives.
Other states that want to participate on a smaller scale may apply for
specific, short-term projects, such as inspecting new pipeline
construction projects. As of January 2002, 11 states”up from 8 in
2000”have been approved to participate in all oversight activities, and
an additional 4 states have been approved to participate on short-term
projects.[Footnote 5]
OPS Is Increasing its Use of Fines:
OPS is increasing its use of fines for safety violations, thereby
reversing a trend of relying more heavily on less severe corrective
actions. From 1990 to 1998, OPS decreased the proportion of enforcement
actions in which it proposed fines from about 49 percent to about 4
percent. During this time, the agency increased the proportion of
warning letters and letters of concern from about 33 percent to about
68 percent. OPS made this change in order to place more emphasis on
’partnering“ to improve pipeline safety rather than on punishing
noncompliance. As of May 2000, OPS could not determine whether this
approach was effective in maintaining compliance with safety
regulations. Consequently, we recommended that DOT determine whether
OPS‘ reduced use of fines had maintained, improved, or decreased
compliance with pipeline safety regulations.
According to OPS officials, the agency is not able to determine the
impact of its compliance actions on safety as we recommended because it
does not have sufficient data. Nevertheless, OPS concluded that its
decreased reliance on fines was perceived negatively by the public and
Congress, and that the letters of concern did not allow OPS to
adequately address safety concerns. OPS subsequently changed its
enforcement policy to make better use of its full range of enforcement
tools, including increasing the number and severity of fines. According
to OPS officials, the agency plans to collect data that will allow it
to link its compliance actions with improvements in safety. We will
follow up on OPS‘ progress in this area during our current review.
OPS Has Not Implemented Significant Safety Board Recommendations and
Statutory Requirements:
OPS is taking action on open recommendations from the Safety Board and
statutory requirements, but has still not implemented important
recommendations and requirements. In May 2000, we reported that OPS
historically had the worst response rate”about 69 percent”of any
transportation agency to Safety Board recommendations. These
recommendations dealt with a variety of issues that are critical for
pipeline safety, such as requiring operators to periodically inspect
pipelines and install valves to shut down the pipeline in an emergency.
Some of these recommendations were more than a decade old. OPS has
been working to improve its responsiveness over the last several years
by initiating activities in response to the recommendations and
improving communications with the Safety Board. The Safety Board has
been encouraged by OPS‘ efforts to improve its responsiveness,
particularly in the areas of excavation damage, corrosion control, and
data quality. However, the Safety Board remains concerned about the
amount of time OPS has been taking to implement recommendations. As of
February 2002, OPS had not implemented 42 recommendations, several of
which date from the late 1980s and deal with issues considered critical
to pipeline safety, such as requiring operators to inspect their
pipelines.
OPS maintains that its progress is better than the Safety Board
indicates. According to OPS officials, the majority of the
recommendations deal with integrity management and excavation damage
prevention, which the agency‘s ongoing initiatives should fulfill
before the end of 2002.
We also reported in May 2000 that OPS had not implemented 22 out of 49
statutory requirements that were designed to improve pipeline safety.
Similar to the open Safety Board recommendations, several of these
unfulfilled requirements dated from the late 1980s and early 1990s and
were related to important pipeline safety issues, such as internal
inspections and identification of pipelines in populated or
environmentally sensitive areas. Since May 2000, OPS has been working
to complete these requirements. As of February 2002, 8 of the 22
requirements were closed as a result of OPS‘ actions, 9 requirements
were still open, and the remaining 5 were reclassified as ’closed“
because OPS considered them to be superseded by amendments or other
requirements or because the agency did not believe it was required to
take further action. OPS plans to fulfill the majority of the open
requirements before the end of 2002.
OPS Faces Major Challenges in Implementing its Initiatives:
In our ongoing work, we are examining several issues that could affect
OPS‘ ability to implement its integrity management and data improvement
initiatives and, ultimately, fulfill the Safety Board‘s recommendations
and statutory requirements. These issues include (1) performance
measures for the integrity management approach, (2) sufficient
resources and expertise to oversee operators‘ integrity management
programs, (3) consistent and effective enforcement of integrity
management program requirements, and (4) requirements for integrity
management programs for operators of gas transmission pipelines.
Performance measures: In May 2000, we reported that OPS had not
developed programwide performance measures for the Risk Management
Demonstration Program, even though the act required such measures to
demonstrate the safety benefits of the program. OPS still has not
developed such measures. Despite the lack of quantifiable performance
measures for the demonstration program, OPS moved forward with
integrity management programs and faces the challenge of developing
performance measures for this new approach to regulating pipeline
safety. Such measures are essential to determine whether the new
approach is successful and what improvements may be needed. However,
OPS does not have a complete and viable database of information on
pipeline incidents and an inventory of pipeline infrastructure on which
to establish certain performance measures. OPS has taken steps to
improve its data, but it may be several years before the agency can
accumulate sufficient data to evaluate trends in the pipeline industry.
Resources and expertise: Pipeline operators are in the best position to
develop integrity management programs that are tailored to their
pipelines; however, it is critical for OPS to have adequate resources
and expertise to oversee the programs. After OPS issues a final rule on
integrity management programs for natural gas transmission pipelines,
the agency estimates that there will be more than 400 hazardous liquid
and natural gas pipeline operators with individual programs in various
stages of development. OPS must ensure that it has a sufficient number
of inspectors to oversee these programs while maintaining its other
oversight responsibilities. Moreover, while OPS has resolved to include
states in reviewing and monitoring operators‘ programs, the agency
faces a challenge to determine how best to leverage federal and state
resources and provide training to state inspectors.
Furthermore, OPS‘ integrity management initiative represents a
fundamental shift in how it oversees the pipeline industry. Federal and
state inspectors that are accustomed to using a checklist approach for
inspecting pipelines for compliance with uniform regulations will have
to be trained to evaluate programs that are unique to individual
operators. For example, under the new requirements, operators may use a
variety of inspection techniques to assess the safety of their
pipelines. Inspectors must be familiar with all of these inspection
techniques, know when it is appropriate to use them, and know how to
interpret the results.
Enforcement: The variability of individual operator programs will make
it difficult for OPS to enforce the requirements of the integrity
management program. OPS‘ integrity management requirements for
hazardous liquid pipelines allow pipeline operators flexibility to
design and implement integrity management programs based on pipeline-
specific conditions and risks.[Footnote 6] However, this flexibility
will result in unique programs for each operator and require more
judgment on the part of inspectors. To ensure that the program
requirements are consistently and effectively enforced, OPS is
developing a comprehensive set of inspection protocols that are
intended to provide clear criteria to inspector staff for evaluating the
adequacy of operator actions and making enforcement decisions. As noted
previously, OPS believes its staff will need increased training and
expertise to make these types of judgments.
Final rule for natural gas transmission pipelines: OPS has issued the
final rules requiring integrity management programs for operators of
hazardous liquid pipelines; however, significant differences between
natural gas transmission pipelines and hazardous liquid pipelines
present challenges for OPS in developing a similar rule for operators
of natural gas transmission pipelines. For example, to facilitate the
movement of natural gas under pressure, transmission pipelines tend to
vary more in diameter than hazardous liquid pipelines. These variations
make it more difficult for natural gas transmission pipelines to
accommodate internal inspection devices. The Interstate Natural Gas
Association of America estimates that about 45 percent, or about
145,000 miles, of natural gas transmission pipelines would require
alternative inspection methods because modifying the pipelines to
accommodate internal inspection devices would not be feasible. OPS
plans to identify alternative inspection methods that would be
effective in assessing the integrity of these pipelines. OPS has 8
months to resolve this issue if it is to meet the goal of issuing a
final rule by the end of 2002.
Observations:
We are encouraged by OPS‘ recent efforts to improve its oversight of
pipeline safety and believe they are steps in the right direction.
However, a number of challenges remain. These challenges include
developing performance measures for the integrity management approach,
ensuring sufficient resources and expertise to oversee operators‘
integrity management programs, providing consistent and effective
enforcement of integrity management program requirements, and issuing
requirements for integrity management programs for operators of gas
transmission pipelines. It is imperative for OPS to meet these
challenges to ensure the safety of the nation‘s pipelines.
Mr. Chairman, this concludes my testimony. I would be pleased to answer
any questions you or Members of the Subcommittee may have.
Contacts and Acknowledgments:
For information about this testimony, please contact Peter F. Guerrero
at (202) 512-4907 or guerrerop@gao.gov. This statement is available on
GAO‘s home page at [hyperlink, http://www.gao.gov]. Individuals making
key contributions to this testimony were Helen Desaulniers, Susan
Fleming, Judy Guilliams-Tapia, Michael Horton, Wyatt Hundrup, and Sara
Vermillion.
[End of section]
Footnotes:
[1] U.S. General Accounting Office, Pipeline Safety: The Office of
Pipeline Safety Is Changing How It Oversees the Pipeline Industry,
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/RCED-00-128]
(Washington, D.C: May 15, 2000) and Pipeline Safety: Progress Made, but
Significant Requirements and Recommendations Not Yet Complete,
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-01-1075] (Washington,
D.C.: September 28, 2001).
[2] For hazardous liquid pipelines, a high consequence area is defined
as a populated area, an environmentally sensitive area, or a
commercially navigable waterway. For natural gas transmission
pipelines, OPS is developing a definition that focuses on populated
areas.
[3] OPS issued a proposed rule to define high consequence areas for
natural gas transmission pipelines on January 9, 2002.
[4] OPS anticipates following a similar process to review and monitor
integrity management programs developed by operators of small hazardous
liquid and natural gas transmission pipelines.
[5] Arizona, California, Connecticut, Iowa, Michigan, Minnesota, New
York, Ohio, Virginia, West Virginia, and Washington.
[6] Pipeline operators must also maintain compliance with uniform
regulations establishing minimum safety requirements.
[End of section]
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