On September 13, 2000, the National Transportation Safety Board submitted its comments to the DOT/OPS concerning the proposed rulemaking for Pipeline Integrity Management in High Consequence Areas. The NTSB thinks that the proposed rule should be expanded in several areas, such as:
- this rulemaking should apply to liquid operators of all sizes, not just those that operate 500+ miles of pipe
- pipeline integrity management programs should be required of all hazardous liquid pipelines, not just those in HCAs
- the 7 year timeframe to perform baseline assessments is too long
- RSPA should be more specific concerning pipeline integrity program requirements
- RSPA "must establish an effective evaluation program and aggressively examine and monitor all operators' pipeline integrity programs"
The NTSB's entire comments can be found here