Pipeline Safety Initiatives:
Program Overview
OPS safety jurisdiction over pipelines covers more than 3,000 gathering, transmission, and distribution operators as well as some 52,000 master meter and liquefied natural gas (LNG) operators who own and/or operate approximately 1.6 million miles of gas pipelines, in addition to over 200 operators and an estimated 155,000 miles of hazardous liquid pipelines. OPS currently has approximately 70 employees: half work at Headquarters in Washington, DC, and the other half work in the five OPS regional offices located in Washington, DC; Atlanta, GA; Kansas City, MO; Houston, TX; and Lakewood, CO. These employees work within the following programs to carry out the mandated regulatory and enforcement responsibilities of the Office of Pipeline Safety:
Integrity Management Rule-making
PHMSA's Office of Pipeline Safety (OPS) intends to incorporate a process into its regulations to validate pipe integrity in high-density population areas, waters where a substantial likelihood of commercial navigation exists, and areas unusually sensitive to environmental damage.
On November 18th and 19th 1999, OPS held a public meeting to determine the extent to which operators now have integrity management programs, to explore effective ways to promote their development and implementation by all operators, and to discuss mechanisms by which OPS could confirm the existence and adequacy of such operator-developed programs.
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Risk Management Initiative
A variety of activities related to the concept of risk management have been initiated within the Office of Pipeline Safety and the pipeline industry over the last couple of years. These activities have been motivated by a desire, a recognition, a concern, and a concept on the part of both the government and the industry.
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National Pipeline Mapping System (NPMS)
The U.S. DOT Office of Pipeline Safety (OPS) administers the national regulatory program to assure the
safe and environmentally sound transportation of natural gas, liquefied
natural gas and hazardous liquids by pipeline. The Accountable Pipeline
Safety and Partnership Act of 1996 requires that OPS adopt rules requiring
interstate gas pipeline operators to provide maps of their facilities to
the governing body of each municipality in which the pipeline is located.
OPS is also required to adopt rules requiring pipeline operators to identify
facilities located in unusually sensitive areas and high density population
areas, to maintain maps and records detailing that information, and to
provide maps to federal and state officials upon request. A joint government-industry
pipeline mapping quality team (MQAT I) developed a set of strategies concerning
how the OPS could develop reasonable pipeline location information without
creating an undue burden on the pipeline industry. The findings of MQAT
I are described in, "Strategies for Creating a National Pipeline Mapping System". The second joint Government/Industry Pipeline Mapping Quality Action Team (MQATII) developed standards for the states and the national repository as well as Pipeline and Liquefied Natural Gas Operator Submission standards. MQATII drafted these standards and incorporated appropriate recommendations outside those developed by the action team.
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Oil Pollution Act (OPA)
The liquid pipeline network in the United States
consists of about 155,000 miles of hazardous liquid pipelines that more than 220
operators run. The Office of Pipeline Safety (OPS) has regulations for pipeline
design, construction, operation, maintenance, and emergency response to ensure
safe hazardous liquid transportation. The Agency's mission is to protect people
and the environment through a comprehensive program featuring effective risk
management, regulatory compliance, and a strong, balanced Federal-State
partnership.
OPS implements the Oil Pollution Act of 1990 (OPA
'90) provisions for onshore oil pipelines. OPS seeks to make pipeline oil spills
less likely, to diminish the spills' threats to people and the environment, and
strengthen the response to spills.
Just as oil tanker operators are required to
submit oil spill response plans to the Coast Guard and refinery operators are
required to submit the plans to the Environmental Protection Agency, oil
pipeline operators are required to submit their facility response plans (FRP's)
to OPS for review and approval. More than 1,500 facility response plans have
been submitted to OPS. They represent 250 oil pipeline operators and lines that
range from three inch gathering systems to thirty-six inch product lines and the
forty-eight inch Trans-Alaska Pipeline System. OPS thoroughly reviews the plans,
emphasizing the adequacy of the pipeline operator's response resources, incident
command system, and ability to protect environmentally sensitive areas. OPS
makes sure that pipeline operators' plans are consistent with the National
Contingency Plan and the local Area Contingency Plan, which the Coast Guard and
EPA write.
OPS seeks to better protect people and the
environment by conducting table top and area exercises. OPS has conducted more
than 80 table top and about six area exercises to test how well operators
prevent and respond to oil spills. The scenarios present worst case scenarios. A
team of Federal, State, and local environmental and emergency response agencies
and company representatives design the area drills, which include equipment
deployment. The working relationships built during drills helped government and
industry workers better prevent and respond to oil spills from pipelines. OPS
helps conduct and evaluate drills that the Coast Guard, EPA, and industry
sponsor.
OPS works with the National Response Team and the
eleven Region Response Teams that the EPA and Coast Guard lead. For example, OPS
played a key role in drafting and implementing an Integrated Contingency
Planning tool that won a Hammer Award for streamlining Federal contingency
planning requirements. Rather than filing several contingency plans, operators
could meet all Federal requirements with a single plan. OPS works closely with
natural resource trustee agencies, including the Department of the Interior and
the National Oceanographic and Atmospheric Administration, to identify sensitive
resources that need extra protection from oil spills. OPS responds to
catastrophic pipeline spills by sending inspectors to investigate the accident
and sending a liaison officer to represent OPS in the unified command structure.
This practice provides a source of pipeline expertise for the EPA or Coast Guard
on-scene coordinator. For more information on the OPA '90 program, contact the
Office of Pipeline Safety at (202)366-4595.
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Unusually Sensitive Areas (USA)
The pipeline safety statute directed the Office
of Pipeline Safety (OPS) to describe areas that are unusually sensitive to
environmental damage in the event of a hazardous liquid pipeline release, and to
establish a method for identifying hazardous liquid pipelines located in those
areas. The goal is to provide added protection to these particularly sensitive
areas.
Once USAs are identified and located, pipeline
operators will conduct risk assessments to determine if a release from a
particular pipeline segment can impact an USA. The risk assessments will include
consultations, when necessary, with Federal and state agencies responsible for
protecting threatened and endangered species, depleted marine mammals, or
critical drinking water resources. Segments of pipeline where a release could
impact an USA will be subject to additional prevention, mitigation, and response
measures. OPS recently published a proposed rule on Enhanced
Protection in High Consequence Areas that identifies how pipeline
operators are to address and best protect USAs, as well as other high
consequence areas.
On December 30, 1999, OPS published a Notice
of Proposed Rulemaking for USA's (PDF, 66K) in the Federal Register. This proposed
rule defines drinking water and ecological areas that are unusually sensitive to
environmental damage if there is a hazardous liquid pipeline release. The
comment period for the proposed rule closes June 27, 2000.
Five public workshops and numerous technical
meetings were held to create the proposed definition and model for USAs. The
first workshop was held on June 15-16, 1995, and focused on criteria being
considered to determine USAs. A second workshop held on October 17, 1995,
focused on developing a process that could be used to determine if an area is a
USA. The third workshop on January 18, 1996, focused on guiding principles for
determining USAs. A fourth workshop held April 10-11, 1996, discussed the
criteria, components, and parameters of the terms that have been used when
describing USAs. The fifth workshop held June 18-19, 1996, discussed drinking
water resources. Additional information on these workshops can be obtained
through the Dockets Unit, Room 8421, PHMSA, U.S. DOT, 400 Seventh Street, SW,
Washington, DC 20590-0001 (reference Docket PS-140) or by contacting Christina
Sames at (202) 366-4561.
OPS and the American Petroleum Institute (API)
have pilot tested the proposed definition and model for USAs in the states of
Texas, California, and Louisiana. These states represent about forty-six percent
of liquid pipelines in the United States. The pilot was conducted to determine
whether there are good data sources available to support the model, whether the
model provides a functional definition that can be used to define and identify
USAs, and if the resultant maps identify the majority of the drinking water and
ecological USAs in the three states. OPS published a Notice
of Intent to Pilot Test in the Federal Register to describe the pilot
test.
On April 27 and 28, 2000, OPS held a public
workshop to discuss the USA drinking water definition and model, the USA
ecological definition and model, and the pilot results. Workshop
attendees included federal and state agencies, academia, environmental
groups and members of the public. The workshop also served to kick off a
technical review of the pilot results. The review will help identify other data
sets that might be used, other resources that might be considered, and will help
improve the definition's capability to identify the majority of USAs. This
technical/peer review is the final step in the pilot study.
OPS will use the comments of this technical /
peer review of the models and the pilot study, public comments on the final
report of the pilot study, and comments on the proposed rule itself to move
toward a final USA definition by the end of this year. API plans to publish a
guidance document describing the model and its application, to assist operators
in understanding this issue.
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Federal/State Partnership
The statutes under which OPS
operates provide for state assumption of all or part of the intrastate
regulatory and enforcement responsibility through annual certifications
and agreements. Most states have supported the concept of common stewardship
in pipeline safety. This cooperative, collaborative relationship between
the federal and state government--the Federal/State Partnership--forms
the cornerstone of the pipeline safety program.
Federal grant funds are used
as an incentive to improve state program performance and to encourage states
to take on more responsibility for pipeline. OPS is authorized to reimburse
a state agency up to 50 percent of the actual cost for carrying out the
state's pipeline safety program, including the cost of personnel and equipment.
Federal funding is determined through an allocation formula based on factors
such as the extent to which the state asserts safety jurisdiction, whether
the state has adopted all federal requirements, and the number and qualifications
of the inspectors.
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Regulatory Development
The federal pipeline safety regulations:
(1) assure safety in design, construction, inspection, testing, operation,
and maintenance of natural gas and hazardous liquid pipeline facilities
and in the siting, construction, operation, and maintenance of LNG facilities;
(2) set out parameters for administering the pipeline safety program; (3)
require pipeline operators to implement and maintain anti-drug and alcohol
misuse prevention programs for employees who perform safety-sensitive functions;
and (4) delineate requirements for onshore oil pipeline response plans.
The regulations are written as
minimum performance standards, setting the level of safety to be attained
and allowing the pipeline operators discretion in achieving that level.
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Compliance and Safety
A major aspect of pipeline safety
is a sound, comprehensive compliance program, conducted by Regional Offices.
To allocate its compliance resources in a manner to maximize the impact
on safety, OPS uses a computer-based tool, known as the pipeline
inspection priority program (PIPP), which ranks pipeline units on system
characteristics, filed reports, and accident data. PIPP increases productivity
by targeting inspections based on risk.
OPS investigates major pipeline
accidents to determine whether violations of regulations occurred, whether
revisions or additions to the regulations are needed and to ascertaining
the cause of an accident. The objectives of an OPS investigation are to
ensure future integrity of the pipeline and develop a sound basis for any
enforcement actions taken.
In addition to their responsibility
for overseeing the compliance of interstate operators, the OPS regional
offices are responsible for monitoring the performance of the state agencies
participating in the federal/state pipeline safety program as well as performing
inspections of interstate pipeline systems and those intrastate facilities
not under state jurisdiction.
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Training and Qualifications
The PHMSA Office of Pipeline Safety Training and Qualifications provides a number of training activities designed to familiarize government and industry personnel with the requirements of pipeline safety regulations and to educate federal and state inspectors in compliance requirements, inspection techniques, and enforcement procedures. These activities include various State-hosted seminars and in-depth classroom training in Alabama and at the Department's Transportation Safety Institute in Oklahoma.
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Pipeline Safety Data Analysis
OPS collects, compiles, and analyzes
pipeline safety data to aid in decision making associated with regulation
revisions, compliance, and training. OPS maintains a reporting system for
compiling accident/safety-related condition reports submitted by gas and
hazardous liquid pipeline operators as well as annual reports submitted
by gas pipeline operators which include information on miles and types
of pipelines. Pipeline Operator filed incident reports, annual reports for
natural gas companies, and safety-related conditions reports are found under the
ONLINE library section of this website at http://ops.dot.gov/library/libindex.htm.
Summary statistics are published on this website at http://ops.dot.gov/stats/stats.htm
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Drug and Alcohol Program
The drug and alcohol testing regulations require operators of gas, hazardous liquid and carbon dioxide pipelines, other than operators of master meter systems and liquefied natural gas (LNG) facilities to have anti-drug and alcohol misuse prevention programs applicable to persons who perform operating, maintenance, or emergency-response functions covered by the DOT pipeline safety regulations in 49 CFR Parts 192, 193 or 195, and to conduct drug and alcohol testing in accordance with the regulations. Drug testing under Part 199, Subpart A is to be conducted prior to employment, after an accident, randomly, upon reasonable cause, and upon the return to duty
of an employee who fails or refuses a drug test conducted under Part 199. Alcohol testing under Part 199, Subpart B is to be conducted upon reasonable suspicion, upon the return to duty of an employee who fails or refuses an alcohol test conducted under Part 199.
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