Landowner's Guide To - Pipeline Safety Trust

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landowner’sguide tosafetyresponsibilitiesyour rightsThird edition, 2016

September 2016Pipeline Safety Trust300 N. Comercial Street, Suite B, Bellingham, WA 98225360-543-5686 pipelinesafetytrust.org

ContentsPreface4Where to Find More Information?18Introduction to Pipelines520How Do Pipelines Work?Natural Gas PipelinesHazardous Liquid Pipelines6Preventing Damage to the PipelineRecognizing a Pipeline LeakResponding if a Leak OccursWho is Responsible forRegulating Pipeline Safety?Regulating the Construction, Operation,Inspection and MaintenanceRegulating DevelopmentNear PipelinesPipeline InspectionsEmergency Response and SpillResponse Planning7Who is Responsible forSiting New Pipelines?9Siting of New Interstate Natural GasPipelinesSiting of New Interstate Hazardous LiquidPipelinesSiting of Intrastate Natural Gas andHazardous Liquid PipelinesPipeline Safety RequirementsDuring Design and ConstructionChoosing PipePipe BurialWelding of Steel PipelinesCoatingsLowering and BackfillingValves and Valve PlacementOperating PressureTesting10Pipeline Safety RequirementsDuring Operation13Corrosion ProtectionSupervisory Control and Data AcquisitionSystem (SCADA)Right-of-way PatrolsLeakage SurveysOdorizationIntegrity ManagementWhat is the Risk of Havinga Pipeline Nearby?15Major Issues for PropertyOwners Near New Pipelines22When a Pipeline is Planned to Cross YourPropertyWhat Rights Will the Pipeline OperatorHave?How Will the Easement Limit Your Use ofthe Property?Specific Easement Issues for AgriculturalLandownersTemporary Construction Easement?What Will Be Put in the Right-of-way?What About Contractors Working for thePipeline Company?Cleanup, Restoration and AbandonmentDamages and LiabilityCosts of NegotiationValue of an EasementWhen Negotiation Fails:Eminent Domain25When Do Pipeline Operators Have EminentDomain Authority?Does the Operator Have to Negotiate Withthe Landowner Before Beginning an EminentDomain Proceeding?How is the Compensation Owed to theLandowner Measured in Eminent DomainProceedings?Are There Ways to Challenge an EminentDomain Proceeding?What is the Process for an Eminent DomainProceeding?Other Financial ConcernsInsuranceProperty ValuesMortgage and TitleResale27Pipeline Safety: a Shared Responsibility29Acknowledgements30Want More Information?31

PrefaceThis Guide is intended to provide alandowner basic information aboutthe pipeline system, how pipelines areoperated and regulated, what rights andresponsibilities you may have as a current or future landowner with a pipelineon your property, and where to find moreinformation. In this guide, we describe allthe different types of pipelines, thoughmuch of the discussion about propertyrights, easements, and eminent domain ismore pertinent to the large transmissionand gathering pipelines, than to the smalldistribution lines that deliver gas to ourhomes and businesses.These are complex issues in a very complicated regulatory system. If you havespecific questions about your legal rightsand responsibilities, please contact aqualified, experienced attorney in yourstate who is familiar with the issues involved. If you already have a pipeline onyour property, please familiarize yourselfwith the terms of the easement allowingthe pipeline’s presence. Understand whatlimitations the easement may impose onyour use of the property and what obligations it may impose on the pipeline company during construction and operationand after abandonment of the line.While we hope this guide provides youwith enough information to better understand pipelines so you can protectyourself, your family and your property,in many ways we are only scratching the4surface in this guide. If you find that youwant to know more, below are some greatplaces to start. The Pipeline Safety Trust website www.pipelinesafetytrust.org. The Pipeline and Hazardous Materials Safety Administration’s stakeholder communication website primis.phmsa.dot.gov/comm/. Or to join the discussion regardingpipeline safety nationwide, and learnabout news regarding pipelines fromacross the country, go to the following website to join the Safepipelinesnews and discussion group tech.groups.yahoo.com/group/safepipelines/.The original edition of this Landowner’sGuide and this revised edition were madepossible in part by Community TechnicalAssistance Grants from the U.S. Department of Transportation’s Pipeline andHazardous Materials Safety Administration. This annual grant program provides local governments and communitygroups with up to 50,000 “for technicalassistance in the form of engineering orother scientific analysis of pipeline safetyissues and to help promote public participation in official proceedings.” You canlearn more about this grant program andwhat other communities have done withthis grant money by visitinghttp://primis.phmsa.dot.gov/tag/.

Introduction to PipelinesThere are over 2.6 million miles of pipelines in the United States. Who regulatespipelines and under what set of regulations depends on what the pipelinecarries, how much it carries, and whereit goes. Pipelines are categorized intoseveral types: Hazardous Liquid pipelines carrycrude oil and refined fuels such asgasoline, diesel and jet fuel. Natural Gas pipelines carrynatural gas. Transmission pipelines are the largelines that move gas and liquids longdistances around the country, often athigh pressures. Distribution pipelines are smallerlines that deliver natural gas to ourindividual homes and businesses. Gathering pipelines transport gas andcrude oil away from the point of production (wellhead) to another facilityfor further refinement or to transmission pipelines. Interstate pipelines are lines thatcross state boundaries. Intrastate pipelines are those thatoperate entirely within one state.Some large pipelines that cross stateboundaries are classified as intrastateif the pipeline ownership changes atthe state line.Th e C urrent U. S .Pipeline S yste m 185,000 miles of onshore andoffshore Hazardous Liquidpipelines;320,000 miles of onshore andoffshore Gas Transmission andGathering pipelines;2,138,000 miles of Natural GasDistribution mains and servicepipelinesTHE NATURAL GAS DELIVERY NETWORKFrom origin to consumption — how different types ofpipelines and processing facilities deliver natural gas tohomes and businesses.small manufactureror industrial plantelectrical powerplant or largeindustrial userproductionfacilitygas processingand treatment plantcompressorstationcity gatecommercialcustomerGATHERING LINESproductionfacilityTRANSMISSION LINESDISTRIBUTION LINESresidentialcustomerLandowner’s Guide - Pipeline Safety Trust5

How Do Pipelines Work?Natural Gas PipelinesHazardous Liquid PipelinesNatural gas is moved through transmission pipelines as a result of a series ofcompressors creating pressure differentials – the gas flows from an area of highpressure to an area of relatively lowerpressure. Compressors are powered byelectric or natural gas fired engines thatcompress or squeeze incoming gas andpush it out at a higher pressure. Natural gas is compressed in transmissionpipelines to pressures typically rangingfrom 500 to 1400 pounds of pressureper square inch. Compressor stationsare generally built every 50 to 100 milesalong the length of a transmission pipeline, allowing pressure to be increased asneeded to keep the gas moving. The “citygate” is where a transmission systemfeeds into a lower pressure distributionsystem that brings natural gas directly tohomes and businesses. The city gate istypically the location where odorant isadded to the gas, giving it the characteristic smell of rotten eggs.Gathering lines bring crude oil out ofproduction areas and to larger transmission lines that often take the crude oilto refineries. Once the crude oil hasbeen refined, transmission lines carrythe refined products to end-users orto storage and distribution facilitiesfor transportation to consumers. Theproduct is pushed through the pipelineby large pump stations situated every20-100 miles along the line dependingon the product, terrain and pressure atwhich the pipeline is operating. Mostliquid fuels move through the pipelineat between 3 to 8 miles per hour. It is estimated that the cost of transporting thecrude oil and then the refined productsthrough the pipeline network adds abouttwo and a half cents to the cost of a gallon of gas at the pump. HAZARDOUS LIQUID AND GASTRANSMISSION PIPELINESA national network of transmissionpipelines moves fuel to millions ofpeople every day.6

Who is Responsible forRegulating Pipeline Safety?Regulating the Construction,Operation, Inspection andMaintenanceThe U.S. Congress has ultimate responsibility for setting the framework underwhich pipeline safety regulations operate. The U.S. Department of Transportation through the Pipeline and HazardousMaterials Safety Administration (PHMSA) is primarily responsible for issuingand enforcing pipeline safety regulations.Federal pipeline safety laws do allowfor states to accept the responsibility toregulate, inspect, and enforce safety rulesover intrastate pipelines within their borders under an annual certification fromPHMSA. If a state receives such intrastate authority, that state can set regulations that are more stringent than whatPHMSA sets as long as the state rules donot conflict with the federal regulations.PHMSA can also enter into an agreementwith the state pipeline regulator to allowthe state to carry out inspections, but notenforcement of regulations, on interstatepipelines. Unlike states, local governments may not enact regulationsregarding the safety aspects ofpipeline operations that are regulated by the federal government.consultation with the pipeline operator,establishing setbacks or a variety of other land use permit requirements. Veryfew local governments have used theirplanning, permitting and zoning authorities to try to increase safety aroundpipelines, but as more and more neighborhoods grow up around pipelinesthis authority will become increasinglyimportant. In 2010, the Pipelines andInformed Planning Alliance released anational report providing local governments with recommended practices forconsidering the use of their land useauthorities with regard to new development near existing pipelines. Thatreport can be found at: ningnear-pipelines. Many of these recommended practices encourage reducingrisks, and could also be applied to theconstruction of new pipelines.Pipeline InspectionsPipeline inspections are done by boththe pipeline company and by the pipeline regulators. The majority of physicalTh e Regul at ionsThe overarching pipeline safetystatutes that Congress has passedcan be found in:U.S. Code, Title 49, Subtitle VIII,Chapter 601The minimum federal regulationsadopted by PHMSA can be foundin: Title 49 of the Code of FederalRegulations (CFR), Parts 190-199Want to know w hatA GENC Y IN Y O UR S TAT EREGUL ATE S PIPELINE S ,A ND WHAT AU T HORI T YTHEY HAV E?Go to s/statepipeline-safety-policy to find outRegulating DevelopmentNear PipelinesState and local governmentscan regulate development nearpipelines with their land useauthority. When pipelines needto cross government lands,state and local governments cannegotiate terms of the easementor franchise relating to pipelinelocations, availability of information and maintenance of theright-of-way. They can also enactregulations governing the typesof structures that can be builtnear existing pipelines, requiringLandowner’s Guide - Pipeline Safety TrustMARKERS IN A RESIDENTIALSETTINGEasily identifiable markershelp homeowners knowwhere major pipelines areplaced, and where pipelineoperator permission maybe needed to do almostany type of construction,excavation, or landscaping.7

inspections are done by the pipelinecompanies. The requirements governingsuch pipeline inspections vary depending on the pipeline’s contents, locationand other factors. Inspections by pipelinecompanies take many forms, each with adifferent purpose. Some of those inspection techniques include: aerial fly-overs looking for leaksand activities that might damage thepipeline; trucks driving the right-of way or aninspector on foot with leak detectionequipment; internal inspections performed bya “smart pig” (see photo below) – amachine that travels through thepipeline, loaded with a variety ofsensors that can detect corrosion,dents, scratches or other weaknessesin the pipes; and physically digging up the pipelineand inspecting it.Emergency Response andSpill Response PlanningFederal regulations require emergencyresponse plans for both liquid and gaspipelines, and also require that operators share those plans with local firstresponders. These emergency responseplans contain information about whatthe pipelines contain, and how pipeline company personnel and emergencyresponse agencies such as fire and policedepartments will implement pre-plannedresponses in case of an emergency.Hazardous liquid pipeline operators arealso required to have spill response plansthat detail how they will clean up a spillif one should happen. The Oil PollutionAct of 1990 expressly allows states andlocal governments to institute additionalspill response planning requirements foroil pipelines and facilities, but only a fewhave done so.State and federal regulators also performinspections, but these regulatory inspections mainly involve review of the company’s paperwork to see if they are followingthe regulations, as well as some spot-checking of facilities and construction work.For more information about the types ofinspections undertaken by regulators, rator/OperatorInspGlossary.html. kentucky spillOver the ten years from 2003through 2012, an average of overfour and a half million (4,860,000)gallons of hazardous liquids havespilled from pipelines each year, andmore than fifty-six percent of thatwas never recovered. This pictureshows the result of one such spill intothe Kentucky River.8

Who is Responsible forSiting New Pipelines?Siting of New InterstateNatural Gas PipelinesFor new interstate gas lines, once thepipeline company has a pipeline proposal and route in mind they mustapply to the Federal Energy Regulatory Commission (FERC) for approval.That approval comes in the form ofa Certificate of Public Convenienceand Necessity. Before approval isgranted, FERC undertakes a completeenvironmental review that normallyincludes development of an environmental impact statement. The process is quite extensive and includesmany opportunities for landowners to become involved. Many whohave been through the FERC processquestion whether FERC’s mission toprovide energy to consumers acrossthe nation sometimes trumps individual property owners’ concernsand protection of the environment.There is a citizen’s guide to the FERCprocess on its website: g of New InterstateHazardous Liquid PipelinesThere is no complete federal permitting process for the routing of interstate hazardous liquids pipelines. Ifa pipeline crosses an internationalborder (Canada or Mexico), then theU.S. State Department takes the leadon the proposal in a process similarto the one described for FERC above.If the pipeline does not cross aninternational border then the responsibility for approval of the pipelineroute falls on the individual states. Ifthe state has no agency in charge ofpipeline siting then the responsibilityfalls to the regular land use authority of local governments along theproposed route. The federal government plays norole in the siting of pipelines that areentirely within the borders of a singlestate. Several states have agenciescharged with siting various energyfacilities; in some instances that includes intrastate pipelines. If the statehas no agency in charge of pipelinesiting then the responsibility falls tothe regular land use authority of local governments along the proposedroute.The Federal Energy RegulatoryCommission (FERC) provides a guideto help citizens understand andbecome involved in the process tolocate and construct new interstatenatural gas pipelines.SOURCEs OFINFORMATIONSiting of Intrastate NaturalGas and Hazardous LiquidPipelines For nearly all new pipeline siting,the pipeline company decides on ageneral route for their proposed pipeline, and possibly some alternativeroutes. Once they feel confident withthe feasibility of their chosen route,the more formal review and approvalprocess with various governmentagencies begins. That process is notconsistent for all types of pipelines,but varies greatly based on the typeof pipeline and where it is to run.Pipelines that will cross internationalor state boundaries (interstate lines)have different siting processes thanthose that will stay within just onestate (intrastate lines).Independent attorney, CarolynElefant, has published a guide tohelp citizens understand their rightswhen an interstate gas pipeline isproposed in their area.The Pipeline Safety Trust also publishes a Local Government Guideto Pipelines, which contains moreinformation about which states haveenergy facility siting agencies, andwho has authority over pipeline siting t/uploads/2010/06/FINALTAGguide.pdfLandowner’s Guide - Pipeline Safety Trust9

Pipeline Safety RequirementsDuring Design and ConstructionAs a landowner, the best way to protectyour interests is to learn what you canabout pipelines, what your pipeline easement agreement requires, how to recognize something that is not as it shouldbe, and who to call if there is a problem.The construction phase of pipelineinstallation is a critically important timeto ensure the long-term integrity of thepipeline. This section outlines a few ofthe issues dealt with during the construction phase that affect pipeline safety.These various safety precautions pertainmainly to gas transmission and regulatedgathering pipelines. Some gathering andproduction lines are not required to follow these standards.Choosing PipePipe sections are fabricated in steel rolling mills and inspected to assure theymeet government and industry safetystandards. Generally between 40 and 80feet in length, they are designed specifically for their intended location in thepipeline. A variety of soil conditionsand geographic or population characteristics of the route will dictate differentrequirements for pipe size, strength,wall thickness and coating material.Not all pipe is steel. Some low pressuregathering, transmission and distributionpipelines use other materials such asother metals, plastic or composites.Pipe BurialMechanical equipment, such as a wheeltrencher or backhoe, is used to dig thepipe trench. Occasionally, rock drillingand blasting is required to break rock ina controlled manner. The material thatis excavated during trenching operationsis temporarily stockpiled on the nonworking side of the trench. This materialwill be used again in the backfill operation. In some limited locations, horizontal directional drilling (HDD) as well asboring is used to place pipe.10Pipeline trenches are dug deep enoughto allow for an adequate amount of coverwhen the pipe is buried. Federal regulations require that hazardous liquidpipelines be buried between 18 and 48inches below the surface, and that buriedgas transmission and regulated gatheringlines be between 18 and 36 inches belowthe surface, depending on location andsoil properties. For example, more depthis required in normal soil conditions nearresidential or developed areas (36 inches)and certain water body crossings (48inches for liquid lines), and less depthwhere rock excavation is required. Thedepth of burial must adhere to regulations at the time of burial, but is not required to be maintained over time. Riverscouring and other circumstances that result in reduced depth of cover over timecall into question whether obligations toprotect pipe are adequately addressed bythe current regulations.Welding of Steel PipelinesTo carry out the welding process, thepipe sections are temporarily supported along the edge of the trench andaligned. The various pipe sections arethen welded together into one continuous length, using manual, semiautomatic or automatic welding procedures. Aspart of the quality-assurance process,each welder must pass qualificationtests to work on a particular pipelinejob, and each weld procedure must beapproved for use on that job in accordance with federally adopted weldingstandards. Welder qualification takesplace before the project begins. Eachwelder must complete several welds using the same type of pipe to be used inthe project. The welds are then evaluated by placing the welded material ina machine and measuring the force required to pull the weld apart. Interestingly, a proper weld is actually strongerthan the pipe itself.

For higher stress pipelines over 6 inchesin diameter, a second level of quality-assurance occurs, wherein qualified technicians sample a certain number of thewelds (the sample number varies basedon the population near the pipeline) using radiological techniques (i.e., X-ray orultrasonic inspection) to ensure the completed welds meet federally prescribedquality standards. The technician processes and analyzes the film on site, using– depending on the technique chosen– either digital equipment or a portable orvan-equipped darkroom. If the techniciandetects certain flaws, the weld is repairedor cut out, and a new weld is made. Another method of weld quality inspectionemploys ultrasonic technology.CoatingsSeveral different types of coatings maybe used to coat the pipe at the factoryand the joints made in the field. Themost common coating used at this timeis fusion bond epoxy or polyethyleneheat-shrink sleeves. Prior to application,the bare pipe is thoroughly cleaned toremove any dirt, mill scale or debris.The coating is then applied and allowedto dry. After field coating and before thepipe is lowered into the trench, the entirecoating of the pipe is inspected to ensurethat it is free from defects.Lowering and BackfillingOnce the pipeline is welded and coated,it is lowered into the trench. Lowering isdone with multiple pieces of specializedconstruction equipment called sidebooms.This equipment acts in tandem to lift andlower segments of the assembled pipelineinto the trench in a smooth and uniformmanner to prevent damaging the pipe.Once the pipeline is lowered into theground, the trench is backfilled to ensure that the pipe and its coating are notdamaged. This is generally accomplishedwith either a backhoe or padding machine depending on the soil makeup.Care is taken to protect the pipe andcoating from sharp rocks and abrasionas the backfill is returned to the trench.In areas where the ground is rocky andcoarse, the backfill material is screenedto remove rocks or the pipe is coveredLandowner’s Guide - Pipeline Safety Trustwith a material to protect it from sharprocks and abrasion. Alternatively, cleanfill may be brought in to cover the pipe.Once the pipe is sufficiently covered, thecoarser soil and rock can then be used tocomplete the backfill.As the backfill operations begin, theexcavated material is returned to thetrench in reverse order, with the subsoilput back first, followed by the topsoil.This ensures the topsoil is returned to itsoriginal position.Valves and Valve PlacementA valve is a mechanical device installedin a pipeline and used to control theflow of gas. Some valves have to be operated manually by pipeline personnel,some valves can be operated remotelyfrom a control room, and some valvesare designed to operate automaticallyif a certain condition occurs on thepipeline. If a pipeline should fail, howquickly the valves can be closed and thedistance between the valves can oftendetermine how much fuel is released.Operating PressureEvery pipeline has a maximum internalpressure at which it may be continually operated. The Maximum AllowableOperating Pressure (MAOP) for naturalgas pipelines, and Maximum OperatingPressure (MOP) for liquid pipelines, areset at levels meant to ensure safety by requiring that the pressure does not causeundue stress on the pipeline. Federalregulations determine MAOP and MOPbased on a number of factors such as thelocation of the pipeline, pipe wall thickness, previous pressure tests, and thepressure ratings of various components.TestingGenerally, but with certain exceptions, allnewly constructed transmission pipelinesmust be hydrostatically tested before theycan be placed into service. Hydrostaticpressure testing consists of filling thepipeline with water, and raising and sustaining the internal pressure to a specifiedlevel above the intended operating pressure. The purpose of a hydrostatic pressure test is to identify and eliminate anydefect that might threaten the pipeline’sability to sustain its maximum operating11

pressure. Any added safety margin forhydrostatic testing above 100% MAOP orMOP is determined by the pipeline location, type, and other factors. A pipeline isdesigned to a specified strength based onits intended operating pressure. Criticaldefects that cannot withstand the pressurewill fail. Upon detection of such failures,the defects are repaired or the affectedsection of the pipeline is replaced and thetest resumed until the pipeline “passes.”to find types of imperfections that arenot currently detected by ILI technology,hydrostatic testing is an accepted methodfor demonstrating that a pipe segment isready to be placed in service.Hydrostatic testing is not the only meansfor detecting pipe defects. For example,inline inspection (ILI) technologies areused that permit the identification of specific types of defects, such as corrosion.But because not all lines can be inspectedwith ILI tools and because of the needTHE “SMART PIG”Photo courtesy Nord Stream AG12There are a variety of types of in-line inspection devices that specialize in findingparticular problems in pipelines such as corrosion, dents and gouges. The name “pig”is used because some of the early versions made a squealing noise as they movedthrough the pipeline.

Pipeline Safety RequirementsDuring OperationCorrosion ProtectionUnprotected steel pipelines are susceptible to corrosion. Without corrosionprotection every steel pipeline will eventually deteriorate. Corrosion can weakenthe pipeline and make it unsafe. Luckily,technology has been developed to allow corrosion to be controlled in manycases if applied correctly and maintainedconsistently.Here are the three common methods usedto control corrosion on pipelines: Cathodic protection (CP) uses directelectrical current to counteract thenormal external corrosion of a metalpipeline. CP is used where all or partof a pipeline is buried undergroundor submerged in water. On new pipelines, CP can help prevent corrosionfrom starting; on existing pipelines,CP can help stop existing corrosionfrom getting worse. Pipeline coatings and linings defendagainst corrosion by protecting thebare steel. Corrosion inhibitors are substancesthat can be added to a pipeline todecrease the rate of attack of internalcorrosion on the steel since CP cannot protect against internal corrosion.Supervisory Control and DataAcquisition System (SCADA)A SCADA is a pipeline computer systemdesigned to gather information such asflow rate through the pipeline, operational status, pressure, and temperaturereadings. Depending on the pipeline,this information allows pipeline operators to know what is happening along thepipeline, and allows quicker reactionsfor normal operations, and to equipmentmalfunctions, failures and releases. SomeSCADA systems also incorporate theability to remotely operate certain equipment, including compressors, pumpLandowner’s Guide - Pipeline Safety Truststations, and valves. This allows operators in a control center to adjust flowrates in the pipeline as well as to isolatecertain sections of a pipeline. ManySCADA systems also include leak detection systems based on the pressure andmass balance in the pipelines. Unfortunately, leak detection systems are not yetcapable of identifying all leaks; PHMSAdata through 2013 shows that only about11% of hazardous liquid and gas transmission pipeline incidents were initiallydetected by SCADA or other computerized leak detection.Right-of-way PatrolsRegulations require regular patrols ofpipeline right-of-ways to check for indications of leaks and to ensure that noexcavation activities are taking place onor near the right-of-way that may compromise pipeline safety. For transmissionpipelines, these patrols are often accomplished by aerial patrols, but federal regulations do not require aerial inspection.Leakage SurveysRegulations also require regular leakagesurveys for all types of natural gas pipelines along the pipeline routes. Personnelwalk or drive the route using specializedequipment to determine if any gas is leaking and to then quantify the size of theleak. Very small leaks are a typical part ofmost gas pipeline systems.OdorizationAll distribution pipelines, and some natural gas transmission and gathering lines(mainly those in highly populated areas),are required to be odorized so leaking gasis readily detectable by a person with anormal sense of smell.Integrity ManagementIntegrity Management refers to a set offederal rules that specify how pipelineoperators must identify, prioritize, assess,13

evaluate, repair and validate the integrity of their pipelines. Operators of bothtransmission and distribution pipelinesare required to have some form of integritymanagement. Gathering lines are exemptfrom these requirements. For gas transmission pipelines, integrity managementrules require lines that are located withinHigh Consequence Areas (mainly morepopulated areas) to be re-inspected by theiroperators every seven years. For hazardous liquid pipelines, integrity management rules require lines that could affect

which pipeline safety regulations oper-ate. The U.S. Department of Transporta-tion through the Pipeline and Hazardous Materials Safety Administration (PHM-SA) is primarily responsible for issuing and enforcing pipeline safety regulations. Federal pipeline safety laws do allow for states to accept the responsibility to

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