Pipeline Safety: Status of Improving Oversight of the Pipeline	 
Industry (19-MAR-02, GAO-02-517T).				 
								 
The Office of Pipeline Safety (OPS) oversees the safety of 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 implementation rate of any transportation agency for	 
recommendations from the National Transportation Safety Board. 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. OPS has also	 
made progress on other initiatives to improve the agency's	 
oversight of the pipeline industry including (1) 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, (2) allowing more	 
states to oversee a broader range of interstate pipeline safety  
activities, and (3) increasing the use of fines, thereby	 
reversing OPS' former trend of relying more heavily on less	 
severe corrective actions. OPS has made progress in responding to
recommendations from the Safety Board and statutory requirements,
but some recommendations and requirements 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. 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.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-517T					        
    ACCNO:   A02912						        
  TITLE:     Pipeline Safety: Status of Improving Oversight of the    
Pipeline Industry						 
     DATE:   03/19/2002 
  SUBJECT:   Pipeline operations				 
	     Transportation safety				 
	     Safety regulation					 
	     Safety standards					 
	     Hazardous substances				 
	     OPS Risk Management Demonstration			 
	     Program						 
								 

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GAO-02-517T
     
Testimony Before the Subcommittee on Energy and Air Quality Committee on
Energy and Commerce House of Representatives

United States General Accounting Office

GAO 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

Page 1 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. 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

1 U. S. General Accounting Office, Pipeline Safety: The Office of Pipeline
Safety Is Changing How It Oversees the Pipeline Industry, GAO/ RCED- 00- 128
(Washington, D. C: May 15, 2000) and Pipeline Safety: Progress Made, but
Significant Requirements and Recommendations Not Yet Complete, GAO- 01- 1075
(Washington, D. C.: September 28, 2001).

Page 2 GAO- 02- 517T

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

Page 3 GAO- 02- 517T

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.

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
Background

Page 4 GAO- 02- 517T

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 fig. 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

Source: GAO?s analysis of OPS data.

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

0.0 0.5 1.0 1.5 2.0 2.5 3.0 1989 1990 1991 1992 1993 1994 1995 1996 1997
1998 1999 2000 Total incidents Major incidents Annual average (total
incidents) Annual average (major incidents)

Page 5 GAO- 02- 517T

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.

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. 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. 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

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. OPS Has Made

Progress in Implementing Integrity Management Programs and Other Initiatives

Page 6 GAO- 02- 517T

large hazardous liquid pipelines. 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.

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

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. OPS Is Taking Action to

Improve Data

Page 7 GAO- 02- 517T

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.

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
States Are Taking a

Greater Role in Overseeing Interstate Pipeline Safety Activities

Page 8 GAO- 02- 517T

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. 5

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.

5 Arizona, California, Connecticut, Iowa, Michigan, Minnesota, New York,
Ohio, Virginia, West Virginia, and Washington. OPS Is Increasing its Use

of Fines

Page 9 GAO- 02- 517T

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 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 OPS Has Not

Implemented Significant Safety Board Recommendations and Statutory
Requirements

Page 10 GAO- 02- 517T

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.

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 OPS Faces Major

Challenges in Implementing its Initiatives

Page 11 GAO- 02- 517T

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. 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

6 Pipeline operators must also maintain compliance with uniform regulations
establishing minimum safety requirements.

Page 12 GAO- 02- 517T

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.

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.

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 http:// www. gao. gov. Individuals making key contributions to
this testimony were Helen Desaulniers, Susan Fleming, Judy GuilliamsTapia,
Michael Horton, Wyatt Hundrup, and Sara Vermillion. Observations

Contacts and Acknowledgments

(545012)
*** End of document. ***