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DOCKETS UNIT <br />PAGE NINETEEN <br />MARCH 24, 1987 <br />(c) What would be the result in terms of accidents prevented <br />if the current safety margin were increased? <br />Response: <br />It would be premature to conclude that increased safety <br />margins would have an impact on the frequency of J <br />accidents without ample opportunity being given to <br />evaluate the results of an increase in the safety <br />margin over time. <br />(d) What would be the incremental cost of increasing the <br />margin? <br />Response: <br />The City is not in a position to address the issue of <br />cost to increase the required safety margin, however, <br />any cost considerations need to be balanced' against the <br />value of a human life and our environment. <br />15. Proposal: <br />Require submission of four year comprehensive reports on <br />the condition of pipelines (corrosion, leaks, etc.). Use <br />these as basis for remedial action, i.e. pigs, pressure <br />tests, replacement. (Min.. Rep., Rec. 42.) <br />Response: <br />It is the experience of the City of Mounds View that either <br />the operators nor OPS maintain detailed data on the condition <br />of pipeline systems. Also, it is shown by the evidence <br />developed after the Mounds View incident that operators are <br />not prone to voluntarily provide such data. In order to <br />ensure Lhat the nation's pipeline systems are properly <br />maintained, operators should be required to maintain and <br />report such data and take appropriate action to invesitgate <br />and repair deficiencies identified by the data. <br />Questions: <br />(a) What additional information about a pipeline's <br />condition, besides what is now or will be required to be <br />reported or recorded, would be useful in determining the <br />need for integrity testing? <br />Response: <br />Any information base should include the results of <br />required pipe -to -soil ration surveys as well as <br />regular close interval surveys. <br />