The Accountable Pipeline Safety and Partnership Act of 1996 authorizes the Secretary of Transportation to establish risk management demonstration projects. Tennessee Gas Pipeline Company (TGP) is one of the companies participating in this demonstration program. TGP has identified a portion of its system where it believes performing alternative risk control activities in lieu of compliance with current regulations would result in a comparable margin of safety and environmental protection. On December 11, 2000, OPS announced their intent to consider granting a waiver to allow TGP to perform the proposed alternative risk control activities.

TGP identified four pipeline segments in its system that have changed from Class Location 2 to Class Location 3. Under current regulations, TGP would have to either re-test these segments at a higher pressure, or reduce the maximum allowable operating pressure. TGP proposed to conduct risk control alternative activities (the "Activities") in lieu of the class location change requirements. These activities include:

1. Internally inspect the waiver segments using geometry and magnetic flux leakage in-line inspection tools.
2. Internally inspect an extended length of pipe (the "extended segments") bordering each waiver segment to further extend the benefits of the integrity analysis.
3. Repair indications of corrosion, existing construction damage, and existing outside force damage identified by the internal inspection.
4. Perform close-interval surveys on the waiver segments and extended segments, as an additional method to detect possible pipeline corrosion.