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Federally Unregulated Gathering Pipelines Could Help Enhance Safety' 
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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

March 2012: 

Pipeline Safety: 

Collecting Data and Sharing Information on Federally Unregulated 
Gathering Pipelines Could Help Enhance Safety: 

GAO-12-388: 

GAO Highlights: 

Highlights of GAO-12-388, a report to congressional requesters. 

Why GAO Did This Study: 

Pipelines are a relatively safe mode of transportation for hazardous 
liquid and natural gas and are regulated by the Department of 
Transportation’s (DOT) Pipeline and Hazardous Materials Safety 
Administration (PHMSA) and state entities. Included in the nation’s 
pipeline network are an estimated 200,000 or more miles of onshore “
gathering” pipelines, which transport products to processing 
facilities and larger pipelines. (See figure.) Many of these pipelines 
have not been subject to federal regulation based on their generally 
rural location and low operating pressures. While incidents involving 
gathering pipelines regulated by PHMSA have resulted in millions of 
dollars in property damage in recent years, comparable statistics for 
federally unregulated gathering pipelines are unknown. This report 
identifies (1) the safety risks that exist, if any, with onshore 
hazardous liquid and natural gas gathering pipelines that are not 
currently under PHMSA regulation and (2) the practices states use to 
help ensure the safety of these pipelines. GAO surveyed state pipeline 
safety agencies in all 50 states and the District of Columbia; 
interviewed officials at PHMSA, state pipeline safety agencies, 
pipeline companies, and industry associations; and analyzed data and 
regulations. 

What GAO Found: 

While the safety risks of onshore gathering pipelines that are not 
regulated by PHMSA are generally considered to be lower than for other 
types of pipelines, PHMSA does not collect comprehensive data to 
identify the safety risks of unregulated gathering pipelines. In 
response to a GAO survey, state pipeline safety agencies cited 
construction quality, maintenance practices, unknown or uncertain 
locations, and limited or no information on pipeline integrity as 
among the highest risks for federally unregulated pipelines. Without 
data on these risk factors, pipeline safety officials are unable to 
assess and manage safety risks associated with these pipelines. 
Furthermore, changes in pipeline operational environments cited in 
response to GAO’s survey and by industry officials could also increase 
safety risks for federally unregulated gathering pipelines. 
Specifically, land-use changes are resulting in development 
encroaching on existing pipelines and the increased extraction of oil 
and natural gas from shale deposits is resulting in the development of 
new gathering pipelines, some of which are larger in diameter and 
operate at higher pressure than older pipelines. PHMSA is considering 
collecting data on federally unregulated gathering pipelines, but the 
agency’s plans are preliminary, and the extent to which PHMSA will 
collect data sufficient to evaluate the potential safety risks 
associated with these pipelines is uncertain. 

A small number of state pipeline safety agencies GAO surveyed reported 
using at least one of five practices that were most frequently cited 
to help ensure the safety of federally unregulated pipelines. These 
practices include (1) damage prevention programs, (2) considering 
areas of highest risk to target resources, (3) safety inspections, (4) 
public outreach and communication, and (5) increased regulatory 
attention on operators with prior spills or leaks. However, the 
sharing of information among states on the safety practices used 
appears to be limited. Some state and PHMSA officials GAO interviewed 
had limited awareness of safety practices used by other states. 
Increased communication and information sharing about pipeline safety 
practices could boost the use of such practices for unregulated 
pipelines. However, information targeted at gathering pipelines on 
PHMSA’s website, including relevant safety practices and state 
activities, is limited. 

Figure: Pipeline System: 

[Refer to PDF for image: illustration] 

Depicted on the illustration: 

Wellheads; 
Gathering pipeline; 
Processing facility; 
Transmission pipeline; 
Distribution pipelines; 
Meters. 

Source: PHMSA. 

[End of figure] 

What GAO Recommends: 

DOT should (1) collect data on federally unregulated hazardous liquid 
and gas gathering pipelines and (2) establish an online clearinghouse 
or other resource for sharing information on pipeline safety 
practices. DOT provided technical corrections on a draft of this 
report. 

View [hyperlink, http://www.gao.gov/products/GAO-12-388]. For more 
information, contact Susan A. Fleming at (202) 512-2834 or 
flemings@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Limited Information on Safety Risks and Changing Operational 
Environments Are Leading PHMSA to Consider Collecting Data: 

States Could Benefit from Sharing Safety Practices: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Summary Results, GAO Pipeline Safety Regulations Survey: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: PHMSA Class Designations for Gas Pipelines: 

Figures: 

Figure 1: Pipeline System: 

Figure 2: Interstate and Intrastate Agents for PHMSA: 

Figure 3: Excavation Damage: 

Figure 4: Changing Land Use around Pipelines: 

Figure 5: Current and Prospective Shale Gas Regions: 

Figure 6: Number of Incidents for All Federally Regulated Pipeline 
Systems, 2004 through 2010: 

Figure 7: Total Property Damage for All Regulated Pipeline Systems, 
2004 through 2010: 

Figure 8: Most Frequently Used Safety Practices by States for 
Gathering Pipelines: 

Figure 9: Pipeline Marker: 

Figure 10: Examples of Rural and Residential Gathering Pipeline 
Operational Environments near Dallas-Fort Worth: 

Figure 11: Gathering Pipeline Construction Documentation in Texas: 

Abbreviations: 

ANPRM: Advanced Notice of Proposed Rulemaking: 

DOT: Department of Transportation: 

NAPSR: National Association of Pipeline Safety Representatives: 

PHMSA: Pipeline and Hazardous Materials Safety Administration: 

psi: pounds per square inch: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

March 22, 2012: 

The Honorable John D. Rockefeller IV:
Chairman:
Committee on Commerce, Science, and Transportation:
United States Senate: 

The Honorable Frank R. Lautenberg:
Chairman:
Subcommittee on Surface Transportation and Merchant Marine 
Infrastructure, Safety, and Security:
Committee on Commerce, Science, and Transportation:
United States Senate: 

Pipelines are a relatively safe mode of transportation for hazardous 
liquid and natural gas. The nation's network of more than 2.5 million 
miles of pipeline is largely regulated by the Department of 
Transportation's (DOT) Pipeline and Hazardous Materials Safety 
Administration (PHMSA) and state entities. Part of this network 
consists of more than 200,000 miles (estimated) of onshore "gathering" 
pipelines, which transport hazardous liquid and natural gas products 
from wells to processing facilities and to larger transmission 
pipelines. Many of these gathering pipelines, however, have not been 
subject to PHMSA regulation because they are generally located away 
from population centers and operate at low pressures.[Footnote 1] In 
recent years, incidents involving gathering pipelines regulated by 
PHMSA have resulted in millions of dollars in property damage. 
Comparable statistics for federally unregulated gathering pipelines 
are unknown because PHMSA does not collect such data. 

You requested that we review pipeline safety issues related to onshore 
gathering pipelines not regulated by PHMSA. To do so, we examined (1) 
the safety risks that exist, if any, with onshore hazardous liquid and 
natural gas gathering pipelines that are not currently under PHMSA 
regulation and (2) the practices states use to help ensure the safety 
of these federally unregulated onshore gathering pipelines. 

To identify safety risks that may be associated with gathering 
pipelines, we reviewed PHMSA safety regulations and analyzed data on 
pipelines regulated by PHMSA to understand the types of pipeline data 
currently collected, as well as to compare and analyze accident, 
injury, fatality, and other trends. We determined that these data were 
complete, reasonable, and sufficiently reliable for the purposes of 
this report. For both objectives, we developed and administered a 
survey to 52 pipeline safety agencies[Footnote 2] in all 50 states and 
the District of Columbia to collect information on, among other 
things, onshore gathering pipelines, the perceived pipeline safety 
risks associated with those pipelines, and the safety practices used 
for those pipelines. We received a 100 percent response rate for this 
survey. We also interviewed officials at PHMSA, selected state 
pipeline safety agencies, pipeline companies, and industry 
associations. We conducted site visits to Dallas-Fort Worth, Denver, 
and Pittsburgh; we selected these locations based on geography, 
existing pipeline infrastructure, and other factors. 

We conducted this performance audit from February 2011 to March 2012 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

Pipelines transport roughly two-thirds of domestic energy supplies 
through approximately 2.5 million miles of pipelines throughout the 
United States. These pipelines carry hazardous liquids and natural gas 
from producing wells to end users (residences and businesses). Within 
this nationwide system, there are three main types of pipelines. 

* Gathering pipelines. Gas gathering pipelines collect natural gas 
from production areas, while hazardous liquid gathering pipelines 
collect oil and other petroleum products. These pipelines then 
typically transport the products to processing facilities, which in 
turn refine and send the products to transmission pipelines. According 
to PHMSA officials, traditionally, gathering pipelines range in 
diameter from about 2 to 12 inches and operate at pressures that range 
from about 5 to 800 pounds per square inch (psi). These pipelines tend 
to be located in rural areas but can also be located in urban areas. 
PHMSA estimates there are 200,000 miles of gas gathering pipelines and 
30,000 to 40,000 miles of hazardous liquid gathering pipelines. 

* Transmission pipelines. Transmission pipelines carry hazardous 
liquid or natural gas, sometimes over hundreds of miles, to 
communities and large-volume users (e.g., factories).[Footnote 3] For 
natural gas transmission pipelines, compression stations located 
periodically along the pipeline maintain product pressure. Similarly, 
pumping stations along hazardous liquid transmission pipelines 
maintain product flow. Transmission pipelines tend to have the largest 
diameters and pressures of any type of pipeline, generally ranging 
from 12 inches to 42 inches in diameter and operating at pressures 
ranging from 400 to 1440 psi.[Footnote 4] PHMSA has estimated there 
are more than 400,000 miles of gas and hazardous liquid transmission 
pipelines. 

* Distribution pipelines. Gas distribution pipelines continue to 
transport natural gas to residential, commercial, and industrial 
customers, splitting off from transmission pipelines. These pipelines 
tend to be smaller, sometimes less than 1 inch in diameter, and 
operate at lower pressures--0.25 to 100 psi.[Footnote 5] PHMSA has 
estimated there are roughly 2 million miles of distribution pipelines, 
most of which are intrastate pipelines. There are no hazardous liquid 
distribution pipelines. 

Figure 1: Pipeline System: 

[Refer to PDF for image: illustration] 

Depicted on the illustration: 

Wellheads; 
Gathering pipeline; 
Processing facility; 
Transmission pipeline; 
Distribution pipelines; 
Meters. 

Source: PHMSA. 

[End of figure] 

In recent years, shale oil and gas exploration and related development 
has led to the construction of new infrastructure, including gathering 
pipelines. Shale oil and gas refers to product that is trapped within 
underground shale formations; these fine-grain sedimentary rocks can 
be rich sources of oil and natural gas. Over the past decade, 
improvements in drilling technologies have allowed access to large 
volumes of shale oil and gas deposits in several states that were 
previously uneconomical to access. 

In terms of fatalities and injuries, pipelines are the safest mode for 
transporting hazardous liquids and natural gas. From 2004 to 2010, 
there was an average of about 16 fatalities per year for all incidents 
reported to PHMSA.[Footnote 6] In comparison, in 2009, over 3,000 
fatalities resulted from incidents involving large trucks carrying 
freight and about 700 additional fatalities resulted from freight 
railroad incidents. Yet, pipelines face a number of risks--such as 
corrosion and excavation damage--that can damage the pipeline's 
integrity and result in leaks and ruptures. A leak generally occurs 
with a slow release of product over a small area. A rupture involves 
the sometimes sudden development of a breach in the pipeline, which 
may cause hazardous liquids to spill or gas to spark and ignite, 
resulting in an explosion.[Footnote 7] Such an incident occurred in 
San Bruno, California, on September 9, 2010, damaging or destroying 
over 100 homes and killing 8 people. 

PHMSA administers the national regulatory program to ensure the safe 
transportation of hazardous liquid and gas by pipeline. PHMSA carries 
out its mission through regulation,[Footnote 8] national consensus 
standards, research, education, inspections, and enforcement when 
safety problems or regulatory violations are found. The agency employs 
over 200 staff in its pipeline safety program, about half of whom 
inspect hazardous liquid and gas pipelines for compliance with safety 
regulations. Besides PHMSA, over 300 state inspectors also help 
oversee pipelines and ensure safety. 

In general, PHMSA performs its oversight role using uniform, minimum 
safety standards that all pipeline operators regulated by PHMSA must 
meet, as well as a supplemental risk-based regulatory program termed 
"integrity management" for pipelines in "high-consequence areas" where 
an incident would have greater consequences for public safety or the 
environment. The uniform, minimum safety standards include 
specifications for the design, construction, testing, inspection, 
operation, and maintenance of pipelines. For example, operators are 
required to install and maintain pipeline markers to clearly show a 
pipeline's right-of-way. In addition, the risk-based integrity 
management programs for hazardous liquid and natural gas transmission 
pipelines and natural gas distribution pipelines require operators to 
systematically identify and mitigate risks to pipeline segments 
located in high-consequence areas, which are defined differently for 
three types of pipelines. 

* High-consequence areas for hazardous liquid pipelines include areas 
of highly populated areas, other populated areas, navigable waterways, 
and areas unusually sensitive to environmental damage. 

* High-consequence areas for natural gas transmission pipelines 
include highly populated or frequently used areas, such as parks. 

* Most natural gas distribution pipelines would generally be 
considered to be in high-consequence areas, as defined under the 
transmission pipelines regulations, since they are typically located 
in highly populated areas. 

PHMSA regulates hazardous liquid and natural gas gathering pipelines--
using uniform, minimum standards--based on their proximity to 
populated and environmentally sensitive areas. For natural gas 
gathering pipelines,[Footnote 9] PHMSA uses class locations--the same 
classification system used for natural gas transmission and 
distribution pipelines. (See table 1.) Under this system, PHMSA 
generally regulates onshore natural gas gathering pipelines in Class 
2, 3, or 4 locations. For hazardous liquid gathering pipelines, PHMSA 
regulates those pipelines in incorporated and unincorporated cities, 
towns, and villages; pipeline segments that cross a waterway currently 
used for commercial navigation; and certain rural gathering pipelines 
within one-quarter mile of environmentally sensitive areas. This 
includes high-consequence areas, as defined for the hazardous liquid 
integrity management program. High-consequence areas can also be in 
Class 1, 2, 3, or 4 locations, which can entail different reporting 
requirements. For example, gathering pipeline operators in high-
consequence areas that are in Class 1 locations are not required to 
report data on pipeline-related incidents, including fatality, injury, 
and property damage information. 

Table 1: PHMSA Class Designations for Gas Pipelines: 

Class designation: Class 1; 
Location features: An offshore area or any location with 10 or fewer 
buildings intended for human occupancy within 220 yards of the 
centerline of the pipeline. 

Class designation: Class 2; 
Location features: Any location with more than 10 but fewer than 46 
buildings intended for human occupancy within 220 yards of the 
centerline of the pipeline. 

Class designation: Class 3; 
Location features: Any location with more than 46 buildings intended 
for human occupancy within 220 yards of a pipeline, or an area where 
the pipeline lies within 100 yards of either a building or a small, 
well-defined outside area (such as a playground) that is occupied by 
20 or more persons at least 5 days a week for 10 weeks in any 12-month 
period. 

Class designation: Class 4; 
Location features: Any location where unit buildings with four or more 
stories above ground are prevalent. 

Source: 49 C.F.R. § 192.5. 

[End of table] 

Under the current regulatory system, PHMSA does not regulate most 
gathering pipelines in the United States based on their location. For 
example, out of the more than 200,000 estimated miles of natural gas 
gathering pipelines, PHMSA regulates roughly 20,000 miles. Similarly, 
of the 30,000 to 40,000 estimated miles of hazardous liquid gathering 
pipelines, PHMSA regulates about 4,000 miles.[Footnote 10] However, 
according to PHMSA officials, the agency has the authority to collect 
data on all onshore hazardous liquid and gas gathering pipelines, 
[Footnote 11] even though it generally does not regulate gas gathering 
pipelines in Class 1 locations or hazardous liquid gathering pipelines 
not located in high-consequence areas. 

Generally, PHMSA retains full responsibility for inspecting and 
enforcing regulations on interstate pipelines. However, states may be 
authorized to conduct inspections for interstate pipelines, as well as 
inspections and associated enforcement for intrastate pipelines. 
States can also promulgate regulations for intrastate pipelines, 
including gathering pipelines. PHMSA has arrangements with 48 states, 
the District of Columbia, and Puerto Rico to assist with overseeing 
interstate, intrastate, or both interstate and intrastate pipelines. 
These arrangements, in which states act as "agents" for PHMSA, can 
cover hazardous liquid pipelines only, gas pipelines only, or both 
(see figure 2). State pipeline safety offices are allowed to issue 
regulations supplementing or extending federal regulations, but these 
state regulations must be at least as stringent as the minimum federal 
regulations. If a state wants to issue regulations that apply to 
pipelines that PHMSA does not regulate, such as unregulated gathering 
pipelines, it must do so under its own (state) authority. 

Figure 2: Interstate and Intrastate Agents for PHMSA: 

[Refer to PDF for image: illustrated U.S.map] 

State jurisdiction - interstate agents: 

Gas and hazardous liquid pipelines: 
Arizona: 
Minnesota: 
New York: 
Washington: 

Hazardous liquid pipelines only: 
California: 
Virginia: 

Gas pipelines only: 
Iowa: 
Michigan: 
Ohio: 
West Virginia: 

State jurisdiction - intrastate agents: 

Gas and hazardous liquid pipelines: 
Alabama: 
District of Columbia: 
Kentucky: 
Louisiana: 
Maryland: 
Mississippi: 
New Mexico: 
Oklahoma: 
Pennsylvania: 
South Carolina: 
Texas: 

Gas pipelines only: 
Arkansas: 
Colorado: 
Connecticut: 
Delaware: 
Florida: 
Georgia: 
Idaho: 
Illinois: 
Indiana: 
Iowa: 
Kansas: 
Maine: 
Massachusetts: 
Michigan: 
Missouri: 
Montana: 
Nebraska: 
Nevada: 
New Hampshire: 
New Jersey: 
North Carolina: 
North Dakota: 
Ohio: 
Oregon: 
Puerto Rico: 
Rhode Island: 
South Dakota: 
Tennessee: 
Utah: 
Vermont: 
Wisconsin: 
Wyoming: 

Not participating: 
Alaska: 
Hawaii: 
 
Sources: U.S. DOT (information) and Map Resources (map).  

[End of figure] 

Limited Information on Safety Risks and Changing Operational 
Environments Are Leading PHMSA to Consider Collecting Data: 

Limited Information: 

While gathering pipelines generally pose lower safety risks than other 
types of pipelines, PHMSA does not collect comprehensive data on 
safety risks associated with gathering pipelines. In response to GAO's 
survey, state pipeline safety agencies cited construction quality, 
maintenance practices, unknown or uncertain locations, and limited or 
no information on current pipeline integrity as safety risks for 
federally unregulated gathering pipelines.[Footnote 12] Operators of 
unregulated gathering pipelines are not required by federal law to 
report information on such risk factors. Consequently, federal and 
state pipeline safety officials do not know the extent to which 
individual operators collect such information and use it to monitor 
the safety of their pipelines. In our survey of 52 state agencies, 39 
agencies--10 monitoring hazardous liquid and 29 monitoring natural 
gas--responded that they had onshore gathering pipelines that PHMSA 
does not regulate located in their state. (See appendix II for a 
summary of our survey results.) For these 39 agencies, four of the 
five top responses cited the following risk factors for onshore 
unregulated gathering pipelines as among the highest public safety 
risks. 

* Construction quality. Eighteen state agencies reported that the 
quality of installation procedures and construction materials is a 
moderate or high safety risk for unregulated gathering pipelines. The 
construction phase of pipeline installation is critical to ensure the 
long-term integrity of the pipeline because the installation methods 
and materials used in pipeline construction affect the pipeline's 
resistance to deterioration over time. For example, one inspection 
requirement for regulated pipelines is that they may not be installed 
unless they have been visually inspected at the site of installation 
to ensure that they are not damaged in a manner that could impair 
their strength or reduce their serviceability.[Footnote 13] This 
requirement does not currently apply to unregulated gathering 
pipelines. 

* Maintenance practices. Sixteen state agencies reported that the 
extent to which pipeline operators maintain their pipelines is a 
moderate or high safety risk for unregulated gathering pipelines. 
According to agency officials, after a pipeline is installed and 
operational, periodic maintenance--such as inspecting and testing 
equipment--is important to prevent leaks and ruptures and could extend 
the operating life of a pipeline. Furthermore, preventive measures and 
repairs conducted on unregulated gathering pipelines, as well as a 
record of such activities, could provide useful information on the 
safety and history of a given gathering pipeline. 

* Location. Sixteen state agencies reported that the unknown or 
uncertain location of unregulated gathering pipelines presents a 
moderate or high safety risk. Although individual operators may know 
the locations of unregulated pipelines, state and local safety 
agencies may not know or may be uncertain about the locations and 
mileage of unregulated pipeline infrastructure in their communities. 
This information is particularly useful for "Call Before You Dig" 
programs operated by states and localities. If unregulated gathering 
pipelines are unmarked and program officials do not know the location 
of the pipelines, businesses and citizens may damage a pipeline during 
excavation, which could result in an incident--including fatalities, 
injuries, or damage to property or the environment--as well as the 
shutting down of the pipeline for repair. 

* Pipeline integrity. Sixteen state agencies reported that not knowing 
or having limited knowledge about the integrity--the current 
condition--of unregulated gathering pipelines is a moderate or high 
safety risk. Factors that affect the integrity of all pipelines--such 
as excavation damage and corrosion--also affect gathering pipelines. 
For example, excavation damage to a pipeline from nearby digging 
activities (see figure 3) is the leading cause of pipeline incidents 
and, as previously noted, the uncertain location of unregulated 
gathering pipelines may increase the potential for such damage. 
Furthermore, corrosion can occur on the inside and outside of metal 
pipelines and is not easily identified without appropriate pipeline 
assessments. From 2004 through 2010, corrosion was reported as the 
cause of about 60 percent--or nine incidents--of regulated gas 
gathering pipeline incidents. Generally, pipeline experts we spoke 
with said limited information on the integrity of unregulated 
gathering pipelines prevents analysis to assess the internal and 
external condition of these pipelines. 

Figure 3: Excavation Damage: 

[Refer to PDF for image: photograph] 

Source: Colorado Public Utilities Commission. 

[End of figure] 

Changing Operational Environments: 

According to responses to our survey and interviews with industry 
officials and representatives, land-use changes and the increased 
extraction of oil and natural gas from shale deposits are two changes 
in the operating environments that could increase the safety risks for 
unregulated gathering pipelines. 

* Land-use changes. The fifth top response reported by state pipeline 
safety agencies we surveyed was that increased urbanization has caused 
rural areas to become more densely populated and, in some cases, 
developments have encroached on existing pipeline rights-of-way. (See 
figure 4.) Nineteen state agencies reported land-use changes as a 
moderate or high risk for federally unregulated gathering pipelines. 
Federal and state pipeline safety officials we spoke with are 
concerned about the safety and proximity of people who work and live 
near pipeline rights-of-way. For example, one state official stated 
that although a new housing or business development can change a 
location's designation from Class 1 to a higher class that would then 
fall under PHMSA's jurisdiction, the operator may not be aware of the 
development and therefore would not monitor and apply more stringent 
regulations along that pipeline. 

Figure 4: Changing Land Use around Pipelines: 

[Refer to PDF for image: 2 photographs] 

1990 and 2002. 

Source: U.S. Geological Survey and National Geospatial-Intelligence 
Agency. 

[End of figure] 

* Increased extraction of oil and gas from shale deposits. According 
to pipeline industry officials and representatives we interviewed, the 
increased extraction of oil and natural gas from shale deposits poses 
an increased risk to the public, partly because of the development of 
new and larger gathering pipeline infrastructure. Deposits of oil and 
natural gas have become increasingly important energy sources in the 
United States over the past decade (see figure 5). According to the 
U.S. Energy Information Administration, shale gas accounted for 16 
percent of the total domestic natural gas supply in 2009 and is 
projected to increase to approximately 47 percent by 2035. This 
extraction has led to drilling and production in regions of the 
country that have previously seen little or no such activity. As a 
result of this ongoing activity, as well as future growth projections, 
state and federal safety officials we interviewed identified new 
gathering pipelines related to shale development as a potential public 
safety risk. The risk is primarily due to the characteristics and 
quantity of pipeline infrastructure required to support this new 
production. Specifically, some of these new gathering pipelines have 
larger diameters and operate at higher pressures that are equivalent 
to traditional transmission pipelines, but without the regulatory 
requirements.[Footnote 14] For instance, an October 2010 report 
[Footnote 15] on pipeline issues and concerns in Fort Worth stated 
that some gathering pipelines were as large as 24 inches in diameter 
with maximum allowable operating pressures similar to those for 
transmission pipelines. Those gathering pipelines were currently 
exempt from federal integrity management rules, which require some 
form of pipeline integrity assessment at least once every 7 years, and 
clearly define how and when problems found during these assessments 
are to be reported and repaired. 

Figure 5: Current and Prospective Shale Gas Regions: 

[Refer to PDF for image: illustrated U.S. map] 

Depicted on the map: 

Basins (areas in which shale regions can be found); 
Current regions (shale formation containing significant known 
accumulations of natural gas); 
Prospective regions. 

Sources: Energy Information Administration (information) and Map 
Resources (map). 

Note: This map depicts shale gas regions, where shale gas is known or 
thought to exist, but does not indicate where extraction is actually 
occurring. 

[End of figure] 

PHMSA Is Considering Collecting Data: 

PHMSA officials stated that they are considering collecting data on 
federally unregulated onshore gathering pipelines to better understand 
and evaluate the safety risks posed by these pipelines. Although PHMSA 
has the legal authority to collect data on unregulated gathering 
pipelines, the agency is not required and has not yet exercised its 
authority to do so. PHMSA officials reported that, instead of 
collecting such data, the agency was focusing on the development of 
integrity management requirements and improved data collection for 
higher-risk transmission and distribution pipelines. However, PHMSA 
officials reported that there is value in having data for unregulated 
pipelines similar to what is currently collected on regulated 
pipelines, such as pipeline characteristics and reportable information 
on incidents--including the location, cause, and consequences of these 
incidents. 

In addition, PHMSA issued Advanced Notices of Proposed Rulemakings 
(ANPRM) for onshore hazardous liquid and gas pipelines in October 2010 
and August 2011, respectively.[Footnote 16] For these proposed 
rulemakings, PHMSA has sought comment on, among other things, whether 
to extend regulation or other requirements to currently federally 
unregulated gathering pipelines. Concerning potential data collection, 
the ANPRMs sought comment on whether to require the submission of 
annual, incident, and safety-related condition reports on federally 
unregulated gathering pipelines, as well as on whether to establish a 
new, risk-based regime of safety requirements for large-diameter, high-
pressure gas gathering pipelines, including those pipelines in rural 
locations.[Footnote 17] While the ANPRMs did not seek comment on 
exactly what new data to collect, PHMSA officials reported that the 
information would likely be similar to what is currently collected on 
regulated gathering pipelines and that they plan to issue final rules 
in late 2012. In the event that reporting requirements are adopted, 
PHMSA officials stated that gathering pipeline data would likely be 
collected on a state-by-state basis, which could later be expanded to 
the national level. However, PHMSA's plans for collecting data are 
preliminary, and the extent to which PHMSA will collect data 
sufficient to evaluate the potential safety risks associated with 
these pipelines is uncertain. 

Currently, PHMSA collects annual, incident, and safety-related 
condition data on regulated pipelines. The specific types of safety-
related data collected for regulated pipelines include the operator, 
pipeline system description, mileage by class location, diameter size, 
operating pressure, incident location, number of injuries and 
fatalities, property damage, and assessments conducted. These data 
help federal and state safety officials and pipeline operators 
increase the safety of these pipelines by better identifying and 
quantifying safety risks, as well as by implementing mitigation 
strategies, and addressing potential regulatory needs. It is for these 
same reasons that PHMSA, state, and some industry officials reported 
that collecting similar data for unregulated gathering pipelines would 
be beneficial. PHMSA officials also reported that in the event the 
agency started collecting data on unregulated onshore gathering 
pipelines, their current data reporting system could accommodate such 
a collection and not require large changes for regulators or 
operators. On the other hand, a few operators and industry groups we 
met with expressed concerns over the burden that new data reporting 
would represent. Before any potential data collection reporting 
requirements could be enacted, PHMSA and the Office of Management and 
Budget would review and evaluate the value of such information and 
associated burdens on industry. PHMSA officials said that while many 
operators should already have information on their gathering pipelines 
readily available, it would still be important to communicate with 
operators and take steps to minimize burdens in collecting new 
gathering pipeline data. 

Some benefits of collecting such pipeline data can be seen through 
additional analysis of currently collected data. For example, PHMSA's 
data on regulated pipelines indicate that more onshore reportable 
incidents, as well as total property damage, occur on transmission and 
distribution pipelines, than on regulated gathering pipelines (see 
figs. 6 and 7). Although the number of reportable incidents for 
regulated gas gathering pipelines is lower than for other regulated 
pipelines, the value of total property damage increased in the past 
few years. In 2010, these reportable incidents accounted for, on 
average, about $1.8 million in property damage per incident. 

Figure 6: Number of Incidents for All Federally Regulated Pipeline 
Systems, 2004 through 2010: 

[Refer to PDF for image: horizontal bar graph] 

Gas Gathering: 
Number of incidents: 26. 

Gas transmission: 
Number of incidents: 654. 

Gas distribution: 
Number of incidents: 1,034. 

Hazardous liquid: 
Number of incidents: 2,429. 

Source: GAO analysis of PHMSA data. 

Note: Regulated hazardous liquid data is not collected, segregated, 
and reported to PHMSA by type of pipeline (i.e., gathering and 
transmission). Also, there are no hazardous liquid distribution 
pipeline systems. Therefore, incident data for regulated hazardous 
liquid transmission and gathering pipelines is combined. 

[End of figure] 

Figure 7: Total Property Damage for All Regulated Pipeline Systems, 
2004 through 2010: 

[Refer to PDF for image: horizontal bar graph] 

Gas Gathering: 
Total property damage: $15,510,704,000. 

Gas transmission: 
Total property damage: $673,775,063,000. 

Gas distribution: 
Total property damage: $666,800,024,000. 

Hazardous liquid: 
Total property damage: $1,387,698,816,000. 

Source: GAO analysis of PHMSA data. 

Note: Regulated hazardous liquid data is not collected, segregated, 
and reported to PHMSA by type of pipeline (i.e., gathering and 
transmission). Also, there are no hazardous liquid distribution 
pipeline systems. Therefore, property damage data for regulated 
hazardous liquid transmission and gathering pipelines is combined. 

[End of figure] 

Another benefit of collecting annual, incident, and safety-related 
condition pipeline data is an increased ability to assess and manage 
risks. We have previously reported on the importance of assessing and 
managing risks, including quantifying those risks using data.[Footnote 
18] Data are instrumental in quantifying risks and can reduce 
uncertainty in assumptions and policy judgments (e.g., safety threats 
and the likelihood that they will be realized).[Footnote 19] PHMSA 
officials reported that collecting data could help to determine the 
safety risks associated with federally unregulated gathering 
pipelines, such as tracking injuries, fatalities, and property damage 
for new gathering pipelines associated with shale development, and 
whether current safety regulations are appropriate. Related to whether 
current regulations are appropriate, Congress recently mandated that 
DOT review the sufficiency of existing federal and state laws and 
regulations to ensure the safety of hazardous liquid and gas gathering 
pipelines.[Footnote 20] Two industry associations reported that such 
data collection could help better ensure that federal pipeline 
programs are appropriately targeted at mitigating safety risks, cost-
effective, and not unnecessarily broad in scope. Quantitatively 
assessing risks could also allow for a ranking and prioritizing of 
safety risks facing gathering pipelines in a manner that is currently 
not possible. 

Besides PHMSA, states may collect data on unregulated gathering 
pipelines, but the scope and nature of this data collection can vary. 
Although the federal government is responsible for setting minimum 
pipeline safety standards, states can adopt additional or stricter 
safety standards for intrastate pipeline facilities and transportation-
-including standards for data collection. For example, Texas's state 
regulation further defined that the state's safety jurisdiction for 
onshore gas gathering pipelines begins after the first point of 
measurement--where the product is first measured to determine the 
volume being extracted from the well--and is based on population, 
which is stricter than the federal standard.[Footnote 21] Our survey 
revealed that only 3 of the 39 state agencies reported that they 
collect and analyze comprehensive pipeline spill and release data on 
federally unregulated pipelines. Such information can be used to help 
reduce future incidents. Additionally, the National Association of 
Pipeline Safety Representatives (NAPSR) recently conducted a 
nationwide survey[Footnote 22] to determine which state requirements 
match or exceed federal pipeline safety requirements. The survey 
reported that neither states nor the District of Columbia collected 
comprehensive data on federally unregulated gathering pipelines, as is 
required for federally regulated pipelines. 

States Could Benefit from Sharing Safety Practices: 

State pipeline safety agencies reported using five safety practices 
most frequently to help ensure the safety of onshore hazardous liquid 
and gas gathering pipelines not regulated by PHMSA, according to our 
survey of state agencies[Footnote 23] (see figure 8). Several of these 
practices are designed to counter previously discussed safety risks; 
for example, implementing damage prevention programs can lower the 
risks of excavation damage.[Footnote 24] Although these practices were 
cited most frequently, one-third or less of the state pipeline safety 
agencies with unregulated gathering pipelines use any one of these 
practices. For instance, 13 of the 39 state pipeline safety agencies 
with unregulated gathering pipelines in their state reported using the 
most frequently cited safety practice--damage prevention programs. 
Additionally, some of the state agencies that reported using safety 
practices also responded that, overall, they had promulgated safety 
requirements for onshore gathering pipelines that were more stringent 
than those provided by PHMSA. 

Figure 8: Most Frequently Used Safety Practices by States for 
Gathering Pipelines: 

[Refer to PDF for image: vertical bar graph] 

Most frequently used safety practices: Damage prevention programs; 
Number of state agencies: 13. 

Most frequently used safety practices: Consider areas of highest risk; 
Number of state agencies: 10. 

Most frequently used safety practices: Safety inspections; 
Number of state agencies: 9. 

Most frequently used safety practices: Public outreach and 
communication; 
Number of state agencies: 7. 

Most frequently used safety practices: Enforcement; 
Number of state agencies: 6. 

Source: GAO. 

[End of figure] 

* Damage prevention programs. Thirteen state agencies[Footnote 25] 
reported that they implement and enforce a damage prevention program 
as a practice to help ensure pipeline safety. Damage prevention 
programs can help mitigate risks and increase safety through a number 
of activities. For example, damage prevention programs can help reduce 
the risk of excavation damage by encouraging citizens and other 
parties to collect information to help identify pipeline locations 
before digging begins. Damage prevention programs can also include 
marking the rights-of-way for pipelines--including gathering 
pipelines--above ground to further reduce the likelihood of excavation 
damage (see figure 9). States have developed or participated in damage 
prevention programs to help reduce instances of excavation damage, 
including damage to gathering pipelines. For example, Colorado has 
participated in the national One-Call program to reduce excavation 
damage. One-Call programs enable citizens and organizations to call an 
811 number to notify utilities, pipeline operators, and others about 
the location and nature of planned digging. Utility, pipeline, or 
other organization members can then mark where underground pipelines 
run before any digging begins. Colorado pipeline safety officials 
reported that some calls related to the marking of regulated and 
unregulated gathering pipelines. As to the effectiveness of One-Call 
programs, the Common Ground Alliance has reported that, in 2010, when 
an excavator notified a call center before digging, damage occurred 
less than 1 percent of the time.[Footnote 26] 

Figure 9: Pipeline Marker: 

[Refer to PDF for image: photograph] 

Source: GAO. 

[End of figure] 

* Considering areas of highest risk. Ten state agencies reported they 
consider the areas of highest risk to effectively target resources as 
a safety practice. This approach can help address risks, such as 
corrosion and a lack of periodic maintenance, by directing oversight 
to those pipelines that could have the most serious consequences in 
the event of an incident.[Footnote 27] In addition, considering the 
areas of highest risk could help address potential safety risks from 
new gathering pipeline infrastructure associated with shale 
development. For example, considering risk factors associated with 
larger pipelines, operating pressures, and location could help 
determine the actual risks posed by these new pipelines. Indeed, some 
of PHMSA's more recent pipeline safety regulations addressing 
integrity management and high-consequence areas account for risk 
factors to help determine which regulations might apply to a 
particular pipeline.[Footnote 28] Industry officials reported that it 
is more effective to target higher-risk areas than to allocate 
resources across all areas. Officials with the Texas Oil and Gas 
Association added that the risk of a pipeline incident in a heavily 
populated area warrants more attention than the risk of a similar 
incident in a sparsely populated area. This practice also acknowledges 
that gathering pipelines run through a wide variety of environments 
with varying risk levels (see figure 10). Some states are overseeing 
pipelines based on identified safety risks. For example, safety 
compliance and enforcement staff at the Texas Railroad 
Commission[Footnote 29] reported that inspecting pipeline systems 
based on identified risks allows the state to inspect some pipelines 
less frequently, such as pipelines made from newer and safer 
materials, have advanced monitoring technology, or are located away 
from populations--like some rural gathering pipelines. Using these 
risk-based safety evaluations also enables Texas Railroad Commission 
inspectors to concentrate on higher-risk pipeline systems. 

Figure 10: Examples of Rural and Residential Gathering Pipeline 
Operational Environments near Dallas-Fort Worth: 

[Refer to PDF for image: 4 photographs] 

Source: GAO. 

[End of figure] 

* Safety inspections. Nine state agencies reported they conduct 
recurring, scheduled, or unscheduled safety inspections of hazardous 
liquid and gas operators as another safety practice. NAPSR officials 
reported that safety inspections can be regularly scheduled 
inspections, during which inspectors check system components, 
specialized inspections (i.e., integrity management) aimed at higher-
risk areas, or random checks. These inspections can also help address 
risks related to the installation and construction quality of a 
pipeline by ensuring that the pipeline is structurally sound and shows 
no evidence of questionable materials or other problems, such as 
corrosion and excavation damage. PHMSA has recommended that state 
pipeline safety agencies perform periodic surprise inspections on new 
pipeline construction to determine whether operators are complying 
with construction requirements. Inspectors with the Texas Railroad 
Commission, in addition to sampling on-site pipeline facilities in the 
field, also review pipeline operators' records and documentation on 
selected pipeline systems for compliance with federal and state 
pipeline safety regulations. These risk-based safety evaluations have 
included the construction of gathering pipelines related to shale 
development and pipelines not regulated by PHMSA. Such evaluations 
also help ensure that operators maintain an up-to-date and consistent 
document records system for installation, operations, and emergency 
response (see figure 11). 

Figure 11: Gathering Pipeline Construction Documentation in Texas: 

[Refer to PDF for image: photograph] 

Source: GAO. 

[End of figure] 

* Public outreach and communication. Seven state agencies reported 
they engage in outreach or other communication with communities and 
citizens to boost awareness and knowledge of pipeline safety practices 
they use. The Common Ground Alliance has reported on the importance of 
outreach, including the use of structured education programs, targeted 
mailings, and paid advertising. These and other outreach methods can 
also underscore the importance of other safety practices, such as 
damage prevention and One-Call programs. These outreach efforts can 
involve a number of methods and include educating and engaging the 
public. In Colorado, Damage Prevention Councils have hosted monthly 
meetings and participated in local community events--such as 
educational seminars, parades, and trade shows--to help educate 
citizens on pipeline safety. Another Colorado entity active in damage 
prevention is the Colorado Pipeline Association, which comprises 
pipeline operators dedicated to promoting pipeline safety by providing 
information for excavators, state residents, businesses, emergency 
responders, and public officials. In one community, according to a 
PHMSA official, citizens viewed state safety officials as an objective 
and neutral party that provided information and perspectives on the 
planned construction of gathering pipelines. In tandem with private 
operators, the state officials were able to answer citizen questions 
and address concerns. 

* Enforcement. Six state agencies reported a safety practice of 
establishing a system of escalated enforcement to enhance and increase 
regulatory attention on operators that have experienced incidents. A 
pipeline expert we interviewed said that promoting an effective 
enforcement program was necessary to help ensure pipeline safety. A 
system of escalated enforcement can enhance and increase regulatory 
attention on pipeline operators with safety violations. One state 
pipeline safety official reported that making such attention public 
can bring additional pressure on and provide incentives for a company 
to maintain and operate its infrastructure safely. One PHMSA official 
reported that although many states do not have an enforcement program 
as elaborate as PHMSA, states with stronger enforcement programs have 
more of an impact on the operators to increase safety. Pipeline 
operators may have procedures and established contacts with local 
enforcement personnel in order to act appropriately to halt dangerous 
excavation activities that may damage pipelines and potentially cause 
an immediate threat to life or property. Regarding federally 
unregulated gathering pipelines, one Colorado official reported that 
because gathering pipeline companies operate pipelines and conduct 
excavation work, they would be subject to any necessary enforcement 
due to safety violations. 

However, sharing of information among states on the safety practices 
they use for unregulated gathering pipelines appears to be limited. 
Some state and PHMSA officials we interviewed had limited awareness of 
what other states were doing to help ensure the safety of gathering 
pipelines not regulated by PHMSA. For example, pipeline safety 
officials we interviewed had limited awareness of other state 
programs--sometimes even for an adjacent state--even if those programs 
were intended to address common risks, such as reducing excavation 
damage and corrosion. PHMSA officials were likewise unable to report 
on the safety practices that many states use or on states' regulations 
that were more stringent than federal requirements. PHMSA's website 
holds a wealth of information on various pipeline safety topics, 
including recent pipeline forums and industry research, incident 
investigations, and other information. However, information targeted 
at gathering pipelines, including relevant safety practices and state 
activities, is limited.[Footnote 30] In addition, all related 
information could be grouped to decrease time spent searching and 
scanning. Currently, there is no central PHMSA web page or resource 
for gathering pipelines, regulated or unregulated--possibly due, in 
part, to the lower safety risks that regulated gathering pipelines 
have posed to people and property when compared with other pipelines, 
like transmission pipelines. PHMSA officials said that its website 
also focuses on pipelines that PHMSA regulates but excludes most 
gathering pipelines. PHMSA has considered the development of a website 
to help facilitate sharing information among states. While this 
project is still in the planning stages and not targeted at gathering 
pipelines, it could be a resource to share program and safety 
practices among states and PHMSA. 

Increased communication and information sharing about pipeline safety 
practices could boost the use of those practices in states with 
unregulated gathering pipelines. As previously discussed, even the 
safety practice that our survey respondents reported using most 
frequently--implementing a damage prevention program--was used by just 
13 of the 39 responding state pipeline safety agencies with 
unregulated gathering pipelines in their state. The other four safety 
practices cited are reportedly used even less. Improved information 
sharing among states and PHMSA could help spread information on how 
these safety practices--which are also used for regulated pipelines--
could be applied to unregulated gathering pipelines, thereby 
benefiting other states with unregulated gathering pipelines. We have 
previously reported on the value of organizations reporting and 
sharing safety information as part of encouraging a wider safety 
culture.[Footnote 31] Safety culture can include organizational 
awareness of safety and open communication. The benefits of a strong 
safety culture have widespread applicability, including in other 
transportation areas--such as aviation and transit. PHMSA could serve 
to facilitate feedback and evaluate safety information related to 
unregulated gathering pipelines in states. By collecting information 
on safety practices and other information relevant to unregulated 
gathering pipelines, PHMSA could increase the potential for 
identifying systemic issues, disseminating lessons learned, and 
improving pipeline safety across the country. PHMSA officials reported 
that, in the past, similar online and educational efforts in other 
areas have resulted in increasing education and information sharing 
among state pipeline safety officials. 

Conclusions: 

While the safety risks of federally unregulated, onshore hazardous 
liquid and gas gathering pipelines are generally considered to be 
lower than other types of pipelines, PHMSA is currently not able to 
determine the performance and safety of these gathering pipelines 
because it does not collect the necessary pipeline operator data. The 
agency is considering options to collect such information, which could 
facilitate quantitatively assessing the safety risks posed by 
unregulated gathering pipelines. Furthermore, these data would be 
critical in helping PHMSA to evaluate the sufficiency of safety 
regulations for gathering pipelines as required by the congressional 
mandate or that increasing shale development across the country might 
necessitate. Making data-driven, evidence-based decisions about the 
risks of federally unregulated gathering pipelines is especially 
important in a time of limited resources. 

The absence of an information-sharing resource focused on federally 
unregulated gathering pipelines means that both states and PHMSA could 
miss opportunities to share lessons learned and successful practices 
for helping to ensure pipeline safety. Sharing such lessons and 
related safety reporting can help support a safety culture and 
increase state officials' awareness of possible safety practices or 
strategies that they can use to enhance pipeline safety. Lessons 
learned can also help states avoid the mistakes of others. 
Additionally, increased information sharing through such a resource 
would help PHMSA become more aware of state pipeline safety practices 
and initiatives--which in turn would assist PHMSA in sharing and 
supporting these safety practices, as well as in considering what 
state efforts may have applicability for federal programs, regulation, 
and guidance. 

Recommendations for Executive Action: 

To enhance the safety of unregulated onshore hazardous liquid and gas 
gathering pipelines, we recommend that the Secretary of Transportation 
direct the PHMSA Administrator to take the following two actions: 

* Collect data from operators of federally unregulated onshore 
hazardous liquid and gas gathering pipelines, subsequent to an 
analysis of the benefits and industry burdens associated with such 
data collection. Data collected should be comparable to what PHMSA 
collects annually from operators of regulated gathering pipelines 
(e.g., fatalities, injuries, property damage, location, mileage, size, 
operating pressure, maintenance history, and the causes of incidents 
and consequences). 

* Establish an online clearinghouse or other resource for states to 
share information on practices that can help ensure the safety of 
federally unregulated onshore hazardous liquid and gas gathering 
pipelines. This resource could include updates on related PHMSA and 
industry initiatives, guidance, related PHMSA rulemakings, and other 
information collected or shared by states. 

Agency Comments: 

We provided the Department of Transportation with a draft of this 
report for review and comment. The department provided technical 
corrections, which we incorporated as appropriate. 

We are sending copies of this report to interested congressional 
committees and the Secretary of Transportation. In addition, the 
report is available at no charge on the GAO website at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-2834 or flemings@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix III. 

Signed by: 

Susan A. Fleming: 
Director Physical Infrastructure Issues: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

The objectives of our review were to determine (1) the safety risks 
that exist, if any, with onshore hazardous liquid and natural gas 
gathering pipelines that are not currently under the Pipeline and 
Hazardous Materials Safety Administration (PHMSA) regulation and (2) 
the practices states are using to help ensure the safety of 
unregulated onshore gathering pipelines. To address our objectives, we 
reviewed PHMSA and other federal agency regulations, as well as 
available safety data on regulated pipelines. We also interviewed 
officials at PHMSA, state pipeline safety agencies, pipeline companies 
and other industry stakeholders, and related associations. We obtained 
data on pipelines regulated by PHMSA to understand the types of 
pipeline data currently collected, as well as to compare and analyze 
accident, injury, fatality, and other trends. We reviewed the data and 
conducted follow-up work as necessary to determine that the data were 
complete, reasonable, and sufficiently reliable for the purposes of 
this report. We also conducted site visits--selecting locations based 
on geography, pipeline infrastructure, and other factors--to interview 
pipeline officials and representatives in Denver, Pittsburgh, and 
Dallas-Fort Worth. We later identified an initial list of safety risks 
and safety practices through information collection and document 
review processes. 

To determine what safety risks may be associated with federally 
unregulated gathering pipelines--in addition to reviewing federal 
agency regulations, regulated pipeline safety data, and conducting 
various interviews--and because of the lack of historical and 
nationwide data, we developed and administered a web-based survey to 
state pipeline safety agencies in all 50 states and the District of 
Columbia.[Footnote 32] Our survey was intended to collect information 
otherwise not available from PHMSA, states, industry, or other sources 
on safety risks associated with onshore, federally unregulated 
hazardous liquid and gas gathering pipelines and related safety 
practices to help address those risks and ensure safety. We used the 
survey to identify which states had unregulated, onshore gathering 
pipelines and what perceived pipeline safety risks were associated 
with those pipelines. To identify safety practices states are using, 
we reviewed industry documents and conducted interviews with public 
and private experts and officials. Then, as part of our survey of 
state pipeline safety agencies, we asked officials to identify the 
practices they used to ensure the safety of onshore, federally 
unregulated hazardous liquid and gas gathering pipelines. From our 
survey results, we identified the most frequently cited safety 
practices, including additional state programs, activities, and other 
practices. 

To develop the survey questions, we conducted initial interviews with 
state officials and other pipeline safety stakeholders to identify 
safety issues regarding unregulated gathering pipelines. We also 
reviewed key literature to ascertain pipeline safety practices and 
other issues. We consulted with PHMSA officials and reviewed PHMSA 
documentation to identify the proper terminology for use in the survey. 

The survey was pretested with potential respondents from state 
pipeline safety agencies, as well as with the Congressional Research 
Service and National Association of Pipeline Safety Representatives. 
[Footnote 33] We did this to ensure that (1) the questions were clear 
and unambiguous, (2) the terms we used were precise, (3) the survey 
did not place an undue burden on the agency officials completing it, 
and (4) the survey was independent and unbiased. In addition, the 
survey was reviewed by an internal, independent survey expert. We took 
steps in survey design, data collection, and analysis to minimize 
nonsampling errors. For example, we worked with PHMSA officials to 
identify the appropriate survey respondents--state pipeline safety 
agencies. To minimize measurement error that might occur from 
respondents interpreting our questions differently from our intended 
purpose, we extensively pretested the survey and followed up with 
nonresponding units and with units whose responses violated certain 
validity checks. We identified only two cases where the respondents 
had slightly varied responses from our intended question, although the 
majority understood our questions as intended. Finally, to eliminate 
data-processing errors, we independently verified the computer program 
that generated the survey results. Our results are not subject to 
sampling error because we administered our survey to all 50 state 
pipeline safety agencies and the District of Columbia. 

The survey was conducted using self-administered electronic 
questionnaires posted on the World Wide Web. We sent e-mail 
notifications to 52 agencies responding to our survey. We also e-
mailed each potential respondent a unique password and username to 
ensure that only members of the target population could participate in 
the survey. To encourage respondents to complete the survey, we sent 
an e-mail reminder to each nonrespondent about 2 weeks after our 
initial e-mail message. The survey data were collected from July 
through September 2011. We received responses from all 50 states and 
the District of Columbia, for an overall response rate of 100 percent. 
This "collective perspective" obtained from each of the agencies helps 
to mitigate individual respondent bias by aggregating information 
across the range of different viewpoints. For purposes of 
characterizing the results of our survey, we identified specific 
meanings for the words we used to quantify the results, as follows: "a 
few" means between 1 percent and 24 percent of respondents, "some" 
means between 25 percent and 44 percent of respondents, "about half" 
means between 45 percent and 55 percent of respondents, "a majority" 
means between 56 percent and 74 percent of respondents, "most" means 
between 75 percent and 94 percent of respondents, and "nearly all" 
means 95 percent or more of respondents. This report contains the 
central results from the survey (see appendix II). 

We conducted this performance audit from February 2011 to March 2012 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Summary Results, GAO Pipeline Safety Regulations Survey: 

General Pipeline Safety Regulation Survey Questions: 

Yes Responses; 

General Pipeline Safety Regulation Survey Questions: Does your state 
have any onshore gathering pipelines outside of high consequence areas 
that PHMSA does not regulate? 
Hazardous Liquid; Frequency: 10; 
Natural Gas; Frequency: 29. 

General Pipeline Safety Regulation Survey Questions: Does your agency 
collect any data for onshore gathering pipelines that PHMSA does not 
regulate? 
Hazardous Liquid; Frequency: 4; 
Natural Gas; Frequency: 7. 

General Pipeline Safety Regulation Survey Questions: Does your state 
have safety requirements for onshore gathering pipelines that are more 
stringent than those provided by PHMSA? 
Hazardous Liquid; Frequency: 1; 
Natural Gas: 7. 

General Pipeline Safety Regulation Survey Questions: Subpopulation 
Total; 
Hazardous Liquid; Frequency: 18; 
Natural Gas; Frequency: 52. 

How great a safety risk, if at all, are the following factors for 
onshore hazardous liquid and gas gathering pipelines in your state 
that PHMSA does not regulate? 

Moderate and High Safety Risk Responses: 

A. Limited or no annual reporting data (similar to PHMSA's) available 
on these pipelines (e.g., mileage, leaks); 
Hazardous Liquid, Frequency: 1; 
Natural Gas, Frequency: 9. 

B. Limited or no incident data available on these pipelines (e.g., 
spills, releases); 
Hazardous Liquid, Frequency: 2; 
Natural Gas, Frequency: 11. 

C. Limited or no information on the integrity of these pipelines[A]; 
Hazardous Liquid, Frequency: 2; 
Natural Gas, Frequency: 13. 

D. Unknown or uncertain locations of pipelines; 
Hazardous Liquid, Frequency: 3; 
Natural Gas, Frequency: 13. 

E. Location of these pipelines in high consequence areas[B]; 
Hazardous Liquid, Frequency: 4; 
Natural Gas, Frequency: 15. 

F. Limited or no inspections conducted on these pipelines[A]; 
Hazardous Liquid, Frequency: 3; 
Natural Gas, Frequency: 13. 

G. Limited or no information on the pipe size; 
Hazardous Liquid, Frequency: 2; 
Natural Gas, Frequency: 7. 

H. Limited or no information on operating pressure[A]; 
Hazardous Liquid, Frequency: 3; 
Natural Gas, Frequency: 13. 

I. Installation/construction quality; 
Hazardous Liquid, Frequency: 3; 
Natural Gas, Frequency: 15. 

J. Periodic maintenance not conducted on these pipelines; 
Hazardous Liquid, Frequency: 3; 
Natural Gas, Frequency: 13. 

K. Quality of product (sour or non-sour, corrosive, abrasive, etc.); 
Hazardous Liquid, Frequency: 3; 
Natural Gas, Frequency: 11. 

L. Limited information on reporting damages; 
Hazardous Liquid, Frequency: 2; 
Natural Gas, Frequency: 9. 

M. Other (Please specify); 
Hazardous Liquid, Frequency: 1; 
Natural Gas, Frequency: 1. 

Subpopulation Total; 
Hazardous Liquid, Frequency: 10; 
Natural Gas, Frequency: 29. 

Does your agency use any of the following practices to ensure onshore 
hazardous liquid and gas pipeline safety in your state? 

Yes Responses: 

A. Considering the areas of highest risk to effectively target 
resources; 
Hazardous Liquid: Regulated Pipelines, Frequency: 14; 
Hazardous Liquid: Unregulated Gathering, Frequency: 3; 
Natural Gas: Regulated Pipelines, Frequency: 47; 
Natural Gas: Unregulated Gathering, Frequency: 7. 

B. Collecting and analyzing comprehensive pipeline spill/release data 
on various types of pipelines; 
Hazardous Liquid: Regulated Pipelines, Frequency: 6; 
Hazardous Liquid: Unregulated Gathering, Frequency: 1; 
Natural Gas: Regulated Pipelines, Frequency: 27; 
Natural Gas: Unregulated Gathering, Frequency: 2. 

C. Standardizing spill/release data collection in order to better 
assess trends or common causes of spills/releases so that prevention 
measures can be targeted and evaluated to reduce future incidents; 
Hazardous Liquid: Regulated Pipelines, Frequency: 5; 
Hazardous Liquid: Unregulated Gathering, Frequency: 1; 
Natural Gas: Regulated Pipelines, Frequency: 22; 
Natural Gas: Unregulated Gathering, Frequency: 2. 

D. Engaging in outreach or other communication with communities and 
citizens to boost awareness or knowledge of pipelines, including their 
locations; 
Hazardous Liquid: Regulated Pipelines, Frequency: 10; 
Hazardous Liquid: Unregulated Gathering, Frequency: 3; 
Natural Gas: Regulated Pipelines, Frequency: 37; 
Natural Gas: Unregulated Gathering, Frequency: 4. 

E. Coordinating with operators to understand new technologies, 
including computer software, pipeline inspection devices, and other 
tools to report on pipelines; 
Hazardous Liquid: Regulated Pipelines, Frequency: 11; 
Hazardous Liquid: Unregulated Gathering, Frequency: 2; 
Natural Gas: Regulated Pipelines, Frequency: 34; 
Natural Gas: Unregulated Gathering, Frequency: 2. 

F. Using existing or emerging technologies to reduce the time required 
to detect pipeline leaks; 
Hazardous Liquid: Regulated Pipelines, Frequency: 8; 
Hazardous Liquid: Unregulated Gathering, Frequency: 1; 
Natural Gas: Regulated Pipelines, Frequency: 21; 
Natural Gas: Unregulated Gathering, Frequency: 3. 

G. Working to increase construction quality to ensure a long life for 
pipeline infrastructure; 
Hazardous Liquid: Regulated Pipelines, Frequency: 11; 
Hazardous Liquid: Unregulated Gathering, Frequency: 2; 
Natural Gas: Regulated Pipelines, Frequency: 40; 
Natural Gas: Unregulated Gathering, Frequency: 3. 

H. Prioritizing the replacement or repair of aging or otherwise 
limited infrastructure; 
Hazardous Liquid: Regulated Pipelines, Frequency: 9; 
Hazardous Liquid: Unregulated Gathering, Frequency: 1; 
Natural Gas: Regulated Pipelines, Frequency: 37; 
Natural Gas: Unregulated Gathering, Frequency: 2. 

I. Conducting recurring, scheduled or unscheduled safety inspections 
of operators; 
Hazardous Liquid: Regulated Pipelines, Frequency: 14; 
Hazardous Liquid: Unregulated Gathering, Frequency: 3; 
Natural Gas: Regulated Pipelines, Frequency: 47; 
Natural Gas: Unregulated Gathering, Frequency: 6. 

J. Establishing a system of escalated enforcement to enhance and 
increase regulatory attention on operators that have spills/releases; 
Hazardous Liquid: Regulated Pipelines, Frequency: 11; 
Hazardous Liquid: Unregulated Gathering, Frequency: 2;
Natural Gas: Regulated Pipelines, Frequency: 29; 
Natural Gas: Unregulated Gathering, Frequency: 4. 

K. Developing standards or other bench marks to measure and evaluate 
performance in encouraging safety; 
Hazardous Liquid: Regulated Pipelines, Frequency: 7; 
Hazardous Liquid: Unregulated Gathering, Frequency: 2; 
Natural Gas: Regulated Pipelines, Frequency: 28; 
Natural Gas: Unregulated Gathering, Frequency: 2. 

L. Monitoring implementation of corrective or preventive measures to 
evaluate their impact or effectiveness; 
Hazardous Liquid: Regulated Pipelines, Frequency: 13; 
Hazardous Liquid: Unregulated Gathering, Frequency: 0; 
Natural Gas: Regulated Pipelines, Frequency: 40; 
Natural Gas: Unregulated Gathering, Frequency: 4. 

M. Using existing integrity management practices for PHMSA unregulated 
lines; 
Hazardous Liquid: Regulated Pipelines, Frequency: 8; 
Hazardous Liquid: Unregulated Gathering, Frequency: 2; 
Natural Gas: Regulated Pipelines, Frequency: 15; 
Natural Gas: Unregulated Gathering, Frequency: 2. 

N. Implementing and enforcing a damage prevention program; 
Hazardous Liquid: Regulated Pipelines, Frequency: 13; 
Hazardous Liquid: Unregulated Gathering, Frequency: 3; 
Natural Gas: Regulated Pipelines, Frequency: 38; 
Natural Gas: Unregulated Gathering, Frequency: 10. 

O. Other (Please specify); 
Hazardous Liquid: Regulated Pipelines, Frequency: 0; 
Hazardous Liquid: Unregulated Gathering, Frequency: 1; 
Natural Gas: Regulated Pipelines, Frequency: 7; 
Natural Gas: Unregulated Gathering, Frequency: 2. 

Subpopulation Total; 
Hazardous Liquid: Regulated Pipelines, Frequency: 18; 
Hazardous Liquid: Unregulated Gathering, Frequency: 10; 
Natural Gas: Regulated Pipelines, Frequency: 52; 
Natural Gas: Unregulated Gathering, Frequency: 29. 

Source: GAO. 

[A] This response category was combined to represent an overall 
category of "Limited or no information of the pipeline integrity." 

[B] A survey follow up found that the majority of respondents also 
understood the question as it was intended to mean Class 1 unregulated 
gathering pipelines previously located in rural areas that may have 
transitioned to be located in either (Class 2, 3 or 4) high 
consequence areas due to changing land use. 

[End of table] 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Susan A. Fleming, (202) 512-2834 or flemings@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, other key contributors to this 
report were Sara Vermillion (Assistant Director), Matt Cail (Analyst-
in-Charge), Aisha Cabrer, Dave Hooper, Stuart Kaufman, Josh Ormond, 
Jerome Sandau, Jeremy Sebest, Rebecca Shea, Don Watson, and Adam Yu. 

[End of section] 

Footnotes: 

[1] PHMSA has limited statutory authority to regulate such pipelines 
under 49 U.S.C. § 60101(b). 

[2] Two state pipeline safety officials from separate agencies in 
Arkansas that are responsible for overseeing pipeline safety in that 
state responded to our survey. Also, Alaska and Hawaii have chosen not 
to participate in pipeline arrangements with PHMSA. Therefore, a PHMSA 
official who conducts state pipeline safety inspections in these 
states responded to those states' surveys. 

[3] For the purposes of this report, we use the term transmission 
pipeline to refer to both hazardous liquid and natural gas pipelines 
carrying product over long distances to users. 

[4] However, there are transmission pipelines smaller than 12 inches 
in diameter and other pipelines that operate at pressures greater than 
1440 psi. In addition, we have reported on safety regulations for 
certain transmission pipelines that operate at lower stress. For more 
information, see GAO, Safety Effects of Less Prescriptive Requirements 
for Low-Stress Natural Gas Transmission Pipelines Are Uncertain, 
[hyperlink, http://www.gao.gov/products/GAO-12-389R] (Washington, 
D.C.: Feb. 16, 2012). 

[5] However, some distribution pipelines can be as large as 24 inches 
in diameter and operate at higher pressures (i.e., over 350 psi). 

[6] In its regulations, PHMSA refers to the release of natural gas 
from a pipeline as an "incident" and a spill from a hazardous liquid 
pipeline as an "accident." (49 CFR Part 195, Subpart B). For 
simplicity, this report will refer to both as "incidents." PHMSA 
tracks summary level statistics for pipeline incidents that meet 
certain reporting criteria, such as those incidents resulting in a 
fatality. 

[7] The risks and consequences posed by gas and hazardous liquids 
incidents also differ. Gas tends to ignite more easily, resulting in 
more explosions. Hazardous liquids ignite less easily, but can spill 
onto and pollute the environment. 

[8] Part 191 (Gas Reporting), Part 192 (Gas), Part 193 (Liquid Natural 
Gas), Part 194 (Liquid Facility Response Plans), and Part 195 
(Hazardous Liquid) of Title 49 of the Code of Federal Regulations. 

[9] 49 C.F.R. §192.5. 

[10] According to PHMSA officials, Alaska, California, Louisiana, and 
Oklahoma have the majority of federally unregulated gathering pipeline 
mileage in the United States. 

[11] 49 U.S.C. §60102(b).This report refers to gathering pipelines 
that are not regulated by PHMSA but that PHMSA is not prohibited by 
law from regulating. Nonregulated gathering pipelines are typically 
unregulated Class 1 pipelines found in rural locations where there are 
no or low populations. 

[12] Risk is defined by PHMSA as the combination of the likelihood and 
the consequence of a specified hazard being realized. 

[13] 49 C.F.R. §195.206 (Hazardous Liquid) and 49 C.F.R. §192.307 
(Gas). 

[14] 49 C.F.R. § 195.452 (Hazardous Materials) & 49 C.F.R. Part 192 
Subpart O (Gas). 

[15] Accufacts Inc. and Pipeline Safety Trust, The State of Natural 
Gas Pipelines in Fort Worth, a special report prepared at the request 
of the Fort Worth League of Neighborhoods, Fort Worth, October 2010. 

[16] 75 Fed. Reg. 63774 (Oct. 18, 2010) and 76 Fed. Reg. 53086 (Aug. 
25, 2011). 

[17] PHMSA granted extensions to the comment period for both of these 
ANPRMs (see 76 Fed. Reg. 303 (Jan. 4, 2011) and 76 Fed. Reg. 70953 
(Nov. 16, 2011)). The ANPRM related to hazardous liquids closed for 
comment in February 2011 and the ANPRM for gas in January 2012. 

[18] GAO, Risk Management: Strengthening the Use of Risk Management 
Principles in Homeland Security, [hyperlink, 
http://www.gao.gov/products/GAO-08-904T] (Washington, D.C.: June 25, 
2008). 

[19] GAO, Homeland Security: DHS Risk-Based Grant Methodology Is 
Reasonable, But Current Version's Measure of Vulnerability is Limited, 
[hyperlink, http://www.gao.gov/products/GAO-08-852] (Washington, D.C.: 
June 27, 2008) 

[20] Pipeline Safety, Regulatory Certainty, and Job Creation Act of 
2011, Pub. L. No. 112-90, §21, 125 Stat. 1904, 1917 (2011). 

[21] Texas Administrative Code, Title 16, Part 1, Chapter 8 Subchapter 
A, Rule Section 8.5. Although the federal government is responsible 
for setting minimum pipeline safety standards, Texas, and other 
certified states, can adopt additional or more stringent safety 
standards for intrastate pipeline facilities and intrastate pipeline 
transportation. (49 U.S.C. §60104(c)). However, any intrastate safety 
standards adopted by Texas and other certified states must be 
compatible with the federal standards. 

[22] National Association of Pipeline Safety Representatives and the 
National Association of Regulatory Utility Commissioners, Compendium 
of State Pipeline Safety Requirements & Initiatives Providing 
Increased Public Safety Levels compared to Code of Federal 
Regulations, 1st Edition 2011 (Sept. 30, 2011). 

[23] These practices refer to state pipeline safety practices that are 
more stringent than PHMSA's regulatory requirements and to central 
activities, programs, or other policies that can help ensure the 
safety of various onshore pipelines. We recognize that in some states 
a practice may be part of the state's regulations, while in other 
states, such practices are separate from regulations. 

[24] When we discuss safety practices, we refer to those safety 
practices that state agencies described as being relevant for helping 
ensure the safety of gathering pipelines. Some of these same practices 
may also be applied to other types of pipelines. 

[25] When discussing the number of state agencies that reported using 
a given safety practice, these 13 agencies are a subset of the 39 
state agencies that reported having unregulated gathering pipelines. 

[26] Common Ground Alliance, DIRT Annual Report for 2010 (Alexandria, 
VA, 2011). The Common Ground Alliance is an association dedicated to 
ensuring public safety, environmental protection, and the integrity of 
services by promoting effective damage prevention practices. 

[27] While data are helpful for assessing risks, PHMSA and state 
agency officials mentioned using other information sources to 
qualitatively assess risks, such as guidance and protocols and general 
pipeline traits like location. 

[28] PHMSA's integrity management program for transmission pipelines 
already requires operators to systematically manage risks to their 
pipelines in areas where an accident could have the highest 
consequences. In our past work on pipeline safety, we have supported 
the use of risk-based methodologies for PHMSA's regulation of the 
pipeline industry. See GAO, Natural Gas Pipeline Safety: Risk-Based 
Standards Should Allow Operators to Better Tailor Reassessments to 
Pipeline Threats, [hyperlink, http://www.gao.gov/products/GAO-06-945] 
(Washington, D.C.: Sept. 8, 2006). 

[29] Formed in 1891, the Texas Railroad Commission regulates the 
safety of intrastate natural gas pipelines and hazardous liquids 
pipelines in Texas. Commission staff conduct safety inspections of 
pipeline operators, issue compliance guidance, and enforce rules for 
Texas's pipeline excavation damage prevention program. 

[30] Websites that are limited tend to be less usable. Usable 
websites--that is, those that are planned and designed to collect data 
on what users need and include various user-centered design methods, 
among other things--ensure that needed information is available and 
clearly displayed. These standards are based on guidance posted on the 
U.S. Department of Health and Human Services' websites, [hyperlink,  
http://www.usability.gov], a source for information on usability and 
user-centered design. It provides guidance and tools on how to make 
websites and other communication systems more usable and useful. 

[31] GAO, Rail Transit: FTA Programs Are Helping Address Transit 
Agencies' Safety Challenges, but Improved Performance Goals and 
Measures Could Better Focus Efforts, [hyperlink, 
http://www.gao.gov/products/GAO-11-199] (Washington, D.C.: Jan. 31, 
2011). 

[32] Alaska and Hawaii have chosen not to participate in pipeline 
arrangements with PHMSA. Therefore, a PHMSA official who conducts 
state pipeline safety inspections in these states responded to those 
states' surveys. 

[33] The National Association of Pipeline Safety Representatives is a 
national association representing the state pipeline safety inspectors 
in the contiguous United States, as well as the District of Columbia 
and Puerto Rico. 

[End of section] 

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