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DOCKETS UNIT <br />PAGE TWENTY-THREE <br />MARCH 24, 1987 <br />regulated is designing and constructing a safe system if <br />measures aren't taken to certify the skills of the indivi- <br />viduals and organizations involved in pipeline design and <br />construction? How can UPS be sure the pipelines are <br />being properly designed and constructed if they don't <br />review the plans and aren't notified of pending construc- <br />tion? <br />Questions: <br />(a) What safety problems are there in design and <br />construction of pipeline that current federal standards <br />do not cover adequately? <br />Response: <br />How can anyone determine that safety problems do or do <br />not exist in design and construction of pipelines if no <br />exists? The industry or federal standards might be <br />adequate but how does OPS know if an operator is abiding <br />by them if OPS doesn't review the plans and Inspect the <br />construction? <br />(b) These problems involve the abilities of persons who <br />design or construct pipelines, could they be resolved <br />by amending or enlarging the scope of the current j <br />qualification requirements, or is a federal certifi- <br />cation program needed to control the problem? <br />Response: <br />Again, if adequate oversight doesn't exist, how can a <br />determination regarding the existence of a problem and <br />solution to it be made? It is common throughout the <br />nation that engineers and architects are licensed by <br />the states in which they practice. Since interstate <br />pipeline designers cannot be regulated by anyone other <br />than the federal govrnment, it would seem reasonable to <br />require their certification by UPS. <br />(c) Do state or local jurisdictions commonly require <br />review or certification of pipeline design plans <br />by a licensed professional engineer before granting <br />construction permits? <br />Response: <br />Except where superceded by federal law, such as is the <br />case with interstate pipelines, most states and <br />