OPS Programs
Compliance and State Programs
OPS believes that an effective compliance
program is one that encourages industry to maintain and enhance pipeline
integrity. OPS is working with its state partners and the pipeline industry
to improve a good transportation safety record that statistically has shown
no significant change over the past ten years. We are exploring non-regulatory
approaches to improve pipeline integrity and give operators options to
correct problems that will achieve the best long term safety results. We
are also updating our regulations to reflect best industry practices by
making them more performance-based and less prescriptive. Under this partnership
approach, we focus on the best safety solutions developed by mutual agreement
and de-emphasize collecting penalties for insignificant safety violations.
We believe that this cooperative relationship increases the potential for
improvements that address pipeline integrity.
To understand more about the operation
of specific pipeline facilities, OPS is planning routine inspections more
effectively, downplaying paperwork review, and emphasizing physical inspections.
Instead of assessing penalties for minor safety infractions, OPS inspectors
are noting deficiencies and actively encouraging good operating practices
by sharing best practices and working with operators to achieve improvements.
Even prior to the FY 1995 budget increase,
performance measures indicating how OPS allocated inspection resources
for CY 1992-1994 reflected a 50% increase in time spent inspecting pipelines
even though staffing levels had only increased 19%. We planned our inspections
more carefully and were able to work with operators to shift our focus
from records review to more on site physical inspections. Additionally,
during that time frame, OPS increased new construction inspection by 62%
and accident investigation by 156%.
The other major activity to improve
pipeline integrity is our risk management initiative. OPS is developing
working partnerships with State agencies and industry to explore how risk
management programs can be successful as an alternative to the existing
regulatory system. The goal is having operators design and implement plans
that, with regulatory approval, best use their companies' resources to
address risks inherent in their individual systems.
OPS plans to use the interactive approval
process we designed for the Oil Pollution Act of 1990 (OPA) program of
spill response plan review and approvals as a model for risk management
program review and approvals. OPS has learned valuable lessons from two
years experience working with hazardous liquid operators on their oil spill
response plans mandated by OPA. Working cooperatively with industry, we
achieved complete compliance by the statutory deadline. In addition, the
working relationships developed in the approval process provided a foundation
of trust and cooperation that has paid valuable dividends in successfully
planning OPA emergency response exercises. OPS sees a strong parallel between
the success of the OPA experience and the opportunity to create a safer
pipeline system through risk management approaches with pipeline operators.
Work is underway through a joint government/industry
team on design of a new performance measurement system to establish a baseline
for the safety level operators have achieved under existing minimum Federal
safety standards. We are identifying new types and multiple levels of measures
are resulting, from operator-specific to global, societal outcomes. Examples
include measures of operator performance, such as percent of lines internally
inspected and repaired; OPS performance, such as percent of pipelines covered
by acceptable risk management programs; and overall safety performance,
such as number of pipeline incidents in high population areas or environmentally
sensitive areas, and so on. These initiatives demonstrate OPS' enhanced
commitment to working with industry, States, and other pipeline stakeholders
to wisely use resources to better protect people and the environment.
Number of Pipeline Safety Inspections Conducted on a Yearly Basis since Fiscal Year 1990
[The information follows:]
OPS SAFETY INSPECTIONS* |
Region |
EA |
SO |
CE |
SW |
WE |
TOT |
No. of Inspectors in 1996
** |
7 |
8 |
8 |
9 |
8 |
40 |
1990 |
13 |
47 |
53 |
74 |
102 |
289 |
1991 |
53 |
73 |
59 |
51 |
108 |
344 |
1992 |
78 |
100 |
226 |
114 |
116 |
634 |
1993 |
62 |
88 |
243 |
184 |
149 |
726 |
1994 |
58 |
68 |
238 |
197 |
114 |
676 |
1995 |
117 |
102 |
273 |
181 |
172 |
845 |
1996 |
181 |
140 |
236 |
242 |
217 |
1016 |
EA=Eastern Region; SO=Southern Region; CE=Central Region;
SW=Southwest Region; WE=Western Region; TOT=Total
*Includes the following types of inspections: standard, drug/alcohol, follow-up, construction, public complaint and accident.
** These numbers do not include headquarter inspector positions that supply technical support but do include state liaisons.
Workload Measures
CIVIL PENALTIES (in millions) |
Measures: |
1998* |
1997* |
1996 |
1995 |
1994 |
Proposed |
$0.500 |
$0.500 |
$0.532 |
$0.750 |
$1.145 |
Collected |
|
|
|
$0.239 |
$0.600 |
*Estimated
TRAINING |
Measures: |
1998* |
1997* |
1996 |
1995 |
1994 |
Classes |
17 |
16 |
16 |
16 |
20 |
Seminars |
23 |
23 |
30 |
41 |
30 |
Students |
2,850 |
3,254 |
3,586 |
4,447 |
3,589 |
*Estimated
OUTREACH/NARUC & NAPSR CONFERENCES |
Measures: |
1998* |
1997* |
1996 |
1995 |
1994 |
Conferences |
9 |
9 |
9 |
8 |
8 |
Participants |
240 |
235 |
230 |
200 |
180 |
*Estimated
STATE COMPLIANCE ACTIVITIES--NATURAL GAS PROGRAM |
Measures: |
1995 |
1994 |
1993 |
1992 |
No. of Operators |
13,554 |
10,750 |
11,574 |
10,461 |
No. of Operators Inspected |
6,620 |
5,503 |
5,430 |
6,183 |
No. of Inspection Units |
16,074 |
13,314 |
13,179 |
13,312 |
No. of Inspection Units
Inspected |
8,435 |
7,008 |
7,390 |
8,252 |
No. of Inspectors |
289 |
271 |
264 |
251 |
Person Days Spent on Inspections |
26,617 |
27,192 |
26,355 |
26,077 |
No. of Noncompliances Found |
12,864 |
16,687 |
17,937 |
19,614 |
Enforcement Actions Initiated |
3,523 |
2,831 |
3,346 |
3,220 |
STATE COMPLIANCE ACTIVITIES--HAZARDOUS LIQUID PROGRAM |
Measures: |
1995 |
1994 |
1993 |
1992 |
No. of Operators |
370 |
318 |
288 |
250 |
No. of Operators
Inspected |
237 |
243 |
214 |
183 |
No. of Inspection
Units |
548 |
488 |
438 |
400 |
No. of Inspection
Units Inspected |
327 |
308 |
310 |
281 |
No. of Inspectors* |
84 |
69 |
70 |
73 |
Person Days
Spent on Inspections |
1,720 |
1,691 |
1,510 |
1,754 |
No. of Noncompliances
Found |
465 |
631 |
845 |
975 |
Enforcement Actions Initiated |
84 |
140 |
155 |
160 |
*Some inspectors may be counted under both gas/liquid programs.
REGULATORY DEVELOPMENT |
Measures: |
1998* |
1997* |
1996 |
1995 |
1994 |
ANPRM |
1 |
0 |
0 |
0 |
1 |
NPRM |
2 |
3 |
2 |
2 |
4 |
FR |
3 |
5 |
7 |
4 |
10 |
STATE WAIVERS |
10 |
10 |
28 |
11** |
2 |
FEDERAL WAIVERS |
1 |
1 |
1 |
5 |
1 |
TECHNICAL STUDIES |
2 |
4 |
6 |
2 |
2 |
INTERPRETATIONS |
20 |
30 |
40 |
84*** |
15 |
ALERT NOTICES /ADVISORY
BULLETINS |
1 |
1 |
1 |
2 |
9 |
NTSB RECOMMEN-DATIONS CLOSED |
3 |
4 |
1 |
5 |
6 |
*Estimated
**This number of waivers is atypical.
***Beginning in 1995, this number includes drug and alcohol rule interpretations.
Number of Comprehensive Onshore Pipeline Facility Inspections by Fiscal Year
[The information follows:]
ONSHORE INSPECTIONS |
Year |
No. of Inspections |
1991 |
225 |
1992 |
307 |
1993 |
304 |
1994 |
292 |
1995 |
427 |
1996 |
502 |
1997* |
580 |
1998* |
600 |
*Estimated
Estimated Inspection Intervals by Federal Region for Onshore Units
[The information follows:]
ESTIMATE INSPECTION INTERVALS* |
Region |
Years |
Eastern |
0.95 |
Southern |
1.20 |
Central |
1.75 |
Southwest |
2.60 |
Western |
1.50 |
*These estimates are based on available FTE performing 18 standard inspections per year.
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