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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.