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DOCKETS UNIT <br />PAGE TWENTY <br />MARCH 24, 1987 <br />(b) What would be the paperwork burdens/costs of filing the <br />proposed information with UPS. <br />Response: <br />As has been the City's position in response to previous <br />questions of this nature, any concern over cost <br />considerations or the burden of additional paperwork <br />needs to be balanced against the value of a human life <br />and our environment. <br />16. Proposal: <br />Since seam failures on Electric Resistance Welded (ERW) pipe <br />have caused a number of accients, a study should be conducted <br />to learn with ERW pipe is susceptible to seam degradation <br />(Minn. Rep., Rec. 4.5). <br />Response: <br />There comes a time when a reasonable person would conclude <br />that a problem exists because of the increasing frequency of <br />occurrence. In the case of ERW pipe, the frequency and <br />severity of accidents would lead a reasonable person to <br />conclude that a possible problem exists and further analysis <br />of the data developed as a result of those accidents needs to <br />be made. The UPS is obligated by the purpose for which it <br />exists to investigate this issue and determine whether a <br />public safety hazard exists. <br />Questions: <br />(a) Because accident data shows the rate of ERW failures <br />as diminishing, will the expected benefits of any <br />generally applied remedy be expected to exceed costs? <br />Response: <br />Why must efforts to improve the level of operational <br />safety for pipelines be put in terms of cost? How many <br />people must die or be greviously injured and how much <br />damage must our environment suffer before we recognize <br />that these are irreplaceable resources and all <br />reasonable efforts must be expended to protect them? <br />(b) Should particular ERW pipelines that have experienced <br />ERW - related ruptures be replaced or tested frequently <br />in densely populated areas? <br />