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Reauthorization of the Natural Gas Pipeline Safety Act and the Hazardous Liquid Pipeline Safety Act
Subcommittee on Energy and Air Quality
Mr. William Shea
Introduction
Mr. Chairman, Members of the Subcommittee, my name is Bill Shea.
I am President and CEO of Buckeye Pipe Line Company, L.P.
Buckeye owns and operates nearly 3,900 miles of pipelines carrying
refined petroleum products, including gasoline, jet fuel, diesel fuel, heating
oil and kerosene. We also operate
approximately 1,200 miles of pipeline for other owners.
We own or operate facilities in 10 states:
Illinois, Indiana, Ohio, New York, Pennsylvania, New Jersey, Connecticut,
Massachusetts, Texas, and Florida. Buckeye is headquartered in Emmaus, Pennsylvania. Currently I serve as Chairman of
the Executive Committee of the Association of Oil Pipe Lines (AOPL) and a member
of the Pipeline Committee of the American Petroleum Institute (API).
I am here today testifying on behalf of both AOPL and API. .
The Association of Oil Pipe Lines is a trade association of owners and
operators of crude oil and refined petroleum product pipelines.
AOPL's members move over 80% of the oil transported in this country.
The American Petroleum Institute represents over 400 companies involved
in all aspects of the oil and gas industry, including exploration, production,
transportation, refining, and marketing. Together,
these two organizations represent the vast majority of domestic oil pipelines. The Liquid Pipeline Industry
Mr. Chairman, the background information for my testimony is presented in
the information packet included with my testimony. I am also releasing to the Committee our most recent
publication, The U.S. Oil Pipeline Industry's Performance, an updated
report prepared by Cheryl J. Trench of Allegro Energy Group.
There are approximately 200,000 miles of crude oil and petroleum products
pipelines in this country. This
liquid pipeline infrastructure is an essential tool in keeping our economy
moving. On a barrel-mile basis, pipelines provide about 68% of the
crude oil and petroleum products transportation domestically.
Another 27% is moved by water and about 5% by truck or rail. (One barrel
transported one mile is a barrel-mile.)
The gasoline you put in your car most likely gets to you in large part by
pipeline. Pipelines deliver
directly to our nation's military bases and airports the jet fuel that powers
our air force and our aviation industry. The
trucking system relies on diesel fuel delivered by pipeline. Millions of heating oil and propane customers rely on
pipelines to bring fuel into their area. Industries
across America rely on pipelines to deliver the feedstock they use to make many
products that are essential to our homes and businesses, like plastics and
pharmaceuticals.
Pipelines are an extremely efficient petroleum transportation system.
While gasoline prices at the pump may vary considerably from time to time
and place to place, the pipeline transportation contribution to the cost is
consistently around 2-3 cents. We
accomplish our job so efficiently that America's oil pipelines transport 16.8%
of all U.S. freight, but represent only 1.9% of the nation's
freight bill. Pipelines also have very low air emissions compared
to other modes of transportation. Pipelines
move oil in a closed environment, usually underground, propelled by centrifugal
force motors, usually electric. For
this reason, pipelines are able to move huge amounts of fuel without
contributing to our ambient air pollution problems. The Industry's Safety Record
The U.S. liquid pipeline industry has a strong safety record. Yet it is a record that we in the industry are striving
constantly to improve. In the ten
years ending with 2001, there were 21 deaths and 117 injuries associated with
liquid pipeline accidents. In three
of those years, including 2001, there were no fatalities, and that is the goal
we seek. Pipeline transportation of
fuel is far and away the safest form of transportation. For example, on a per gallon basis, deaths are 60 times more
likely to occur when transportation is by truck rather than by pipeline.
Many industries would be envious of our record.
However, we industry members believe that pipeline incidents, especially
those that involve injury to persons or the environment, are unacceptable.
In this way, we are like those impacted by these incidents.
We would like to see them eliminated.
Our
efforts to improve safety have shown results over the long term.
Real trends in safety performance take a long time to see. As the chart
here demonstrates, over the last 30 years, our safety performance has improved
markedly, whether measured in number of spills or volumes released.
The number of pipeline incidents has decreased by 56% and the volume
released has gone down by more than 60%.
These improvements have occurred at the same time that the volume
transported to serve our nation's energy needs has increased.
Viewed on a barrel-mile basis, volumes spilled have decreased by over
70%. The year 2000 set record lows for
both the number of incidents and the volumes spilled, and 2001 looks even
better. The low numbers have not
happened coincidently. They reflect
a concerted effort by the industry and its regulator to improve safety over the
long term. The records set in 2000
and 2001 are encouraging, but we are determined to do all we can to turn these
recent promising short-term results into a new long-term trend. No spill of any
size should be tolerated, and our goal must be to eliminate spills entirely. Goal for Today's Testimony
It is wise periodically to step back and review long term
objectives and our progress towards those objectives. Today I would like to review five major long-term objectives
the pipeline industry has undertaken and our progress toward meeting those
objectives. Those five objectives are:
As an oversight committee, it is your charge to evaluate the overall progress the industry has made and the role of the federal government through the Office of Pipeline Safety in policing the pipeline industry. Risk Reduction - Changing Our Expectations
Today's pipeline safety record
is the result of a long-range plan that had its inception back in the early
nineties. There were several
initiating events. In 1992, the
Congress reauthorized the pipeline safety program to add protection of the
environment to the mandate of the Department of Transportation's Office of
Pipeline Safety (OPS) pipeline safety program.
This was similar to mandates imposed on the maritime industry by the Oil
Pollution Act of 1990. The OPS is a relatively small agency that had previously been responsible primarily for public safety as it relates to pipeline operations. In addition to expanding the scope of the OPS's responsibilities, the 1992 act had also included a number of prescriptive directives to the agency and to the industry, each a specific solution to a single accident. After a number of proposed
rules were severely criticized, the OPS called a Pipeline Safety Summit in June
1994 to discuss with all stakeholders the state of pipeline safety.
The public, state and local regulators, and members of the pipeline
industry expressed significant concerns over the acceptability of then
operational practices, regulations, and their enforcement.
Participants also identified evolving environmental sensitivities and
priorities as a factor affecting pipeline risks and operations, and the limited
resources available to the agency and the industry to address the many
expectations of Congress and the public. The
OPS and the liquid pipeline industry recognized the need to address these
risk-related concerns in a thoughtful way, with an emphasis on reducing risks
while communicating and demonstrating to all stakeholders that industry and
government can work together in a responsible manner. The OPS and the API's General
Committee on Pipelines formed the Risk Assessment Quality Action Team as a
cooperative joint venture to explore the applicability and potential benefits to
the liquid pipeline industry of formalized risk management programs, such as
those that had been used successfully by the nuclear, chemical and refining
industries to improve safety performance. For
over a year, the Team sought input from many risk management experts including
those at the Harvard Center for Risk Analysis.
On June 20, 1995, the Team issued a formal report on the use of risk
management in the liquid pipeline industry, identifying a number of areas within
the OPS program and the liquid pipeline industry that would benefit from risk
management techniques and practices. The
Team adopted a number of action items aimed at improving the management of
pipeline risk, including development of industry guidelines on the application
of risk management, a decision to initiate training of OPS and industry
personnel in risk management techniques, and adoption of collaborative efforts
to improve the quality of risk models and pipeline failure and operating data
necessary to support these models. The
Team also agreed to move forward with risk management demonstration projects to
test the validity of using risk management in the administration of a pipeline
safety program. Risk-Based Integrity Management Rules
After Risk Assessment Quality Action Team finalized its recommendations,
OPS began considering how to incorporate the concept of risk reduction into the
pipeline regulatory program. OPS
began by developing a program for risk-based demonstration projects to test and
measure the application of these new concepts into pipeline safety.
Congress sanctioned these efforts through revisions to the pipeline
safety program adopted as part of the reauthorization of the pipeline safety act
in 1996. Ultimately, OPS approved
seven demonstration projects testing alternatives to the pipeline safety
regulations that offered equal or greater safety than the prescribed rules.
Under the program, companies volunteering to participate also agreed to
significant involvement in their operations by OPS inspectors and other
personnel. At the end of the
demonstration period, OPS found these projects had enhanced safety on the
individual systems and had enabled OPS to learn much about the operations of the
affected pipeline, as well as the pipeline operator, beyond the portion of the
pipeline involved in the demonstration project. OPS then focused on developing new
regulations around managing system integrity, and concentrated on four desired
outcomes: · Accelerating integrity assessment of pipelines in High Consequence Areas; · Improving integrity management systems within companies; · Improving the government's role in reviewing the adequacy of integrity plans; and ·
Providing increased public assurance that risks are being
effectively reduced. As now published, the hazardous
liquid integrity management rules propose initial, or baseline, inspections of
all pipeline systems that are in or could affect High Consequence Areas.
These inspections, typically conducted using sophisticated electronic
in-line inspection tools or physical strength tests of the pipeline, will be
concentrated in areas where hazardous liquid pipeline releases could have more
severe consequences. Based on the initial assessment, operators will
be required to repair defects, take specific mitigative actions to protect
certain High Consequence Areas, reevaluate response plans, as well as integrate
other integrity improvement efforts and activities, such as the effectiveness of
one-call programs, into post assessment risk reduction actions. One of the major efforts under this rulemaking was defining those resources that require additional protective measures. OPS assembled a team of government and private stakeholders to develop definitions based on the guidance offered by Congress in the 1996 reauthorization. This multi-year effort resulted in the final rule defining specific areas based on their ecological sensitivity or their use as drinking water supplies. Under the integrity
management rules, operators of more than 500 miles of pipelines must develop a
baseline integrity plan by March 31, 2002.
Smaller operators are required to have their plan in place by February
13, 2003. In the baseline plan, an
operator must identify the highest risk 50% of segments covered under the rule
and schedule those segments for inspection and evaluation within three and a
half years. The remaining 50% must be evaluated within seven years.
Subsequent inspections must then occur on a cycle of no longer than five
years. Many operators are finding
that the efficient use of internal inspection tools and the tool vendors'
resources will lead to as much as 90% of the actual mileage being inspected in
the early period. OPS has already moved to
enforcement of the new rule and is conducting a series of "Quick Hit"
inspections to review operators' diligence in identifying High Consequence
Areas along their pipeline systems and taking a first look at baseline
assessment plans. These
inspections, generally conducted by three inspectors visiting the offices of the
affected pipeline, are more in-depth and require a better understanding of
pipeline operations than traditional pipeline inspections.
The Quick Hit inspection teams are not only identifying strengths and
weaknesses in the operators' baseline plans, but also are training inspectors
to conduct comprehensive reviews of pipeline systems. The Quick Hit inspections will be completed by the end of
April and comprehensive reviews of operator integrity management plans will
follow.
The comprehensive risk-based approach under the new rules requires a real
change in culture for many operators and inspectors.
OPS is stressing risk assessment, prioritization, data and information
integration from multiple sources and performance measurement and tracking.
Judging from other industries where this approach has been proven, real
risk reduction and improved system integrity will be the result.
However, the effectiveness of this approach can only be proven over time.
We hope that the significantly reduced number of incidents in 2000 and
2001 are the beginning of a long-term trend that shows a steady improvement in
pipeline integrity and a decrease in pipeline incidents. Using Data to Reduce Risk
The recommendations from the Risk
Assessment Quality Action team also formed the basis for a new set of
initiatives. Risk-based
decision-making is very much dependent on data that can be used to identify and
prioritize risk. The OPS and
industry began to look at existing data in new ways and tried to determine what
additional information might need to be collected.
OPS data was reviewed and analyzed to look for strengths, weaknesses, and
means to improve the data that would support analytical work. As a result, the industry (with
the encouragement of OPS) initiated in 1999 the Pipeline Performance Tracking
System (PPTS), a groundbreaking effort to collect more meaningful data on
spills, information that would first aid in understanding spills and thus in
preventing them. Participants in
this voluntary program (currently more than 50 oil pipeline operators) report
any spill of five gallons or more, and any smaller spills to water.
For spills of five barrels or more, participants provide detailed data on
the incident's causes and consequences. In addition to accident information,
PPTS collects system-wide information once a year on mileage, commodities moved,
decade of construction, pipeline diameter and so forth that will allow industry
also to look at rates of incidents, not just total numbers. OPS has taken advantage of the
industry's experience with data collection to develop a new regulation
reducing the federal reporting threshold from 50 barrels (2100 gallons) to 5
gallons, requiring more concise cause differentiation, and providing greater
detail about specific accidents. The
final rule revising the pipeline incident reporting form - issued January 8,
2002 (FR Doc. 02-266) - is designed to gather much better information from
which the causes and consequences of accidents can be assessed. OPS is also planning to move
forward with a rule to collect infrastructure information about hazardous liquid
pipelines that will enable OPS to conduct accident evaluations, including trend
analysis. The hazardous liquid
pipeline industry supports this effort. A Holistic Approach to Underground Damage Prevention
Excavation damage is the cause of
the largest amounts of lost volumes on liquid pipelines and the greatest cause
of gas pipeline incidents. Pipeline
operators must often depend on the actions of others to reduce and eventually
eliminate excavation accidents. The
work on risk assessment and risk management provided a model for another major
joint OPS/industry effort - the Damage Prevention Quality Action Team.
OPS worked first with the liquid pipeline industry and then with all
stakeholders to develop recommendations on reducing excavation damage to
pipelines - and ultimately to all underground facilities.
The key to preventing excavation damage is to ensure that every party
does its job well, using proper procedures and understanding the impact of their
task. At the center of excavation
damage prevention is the "one-call" program.
Under a one-call program, an excavator (or homeowner) telephones the
state or regional one-call notification center to give notice of intent to dig
in a specific area. The center then
acts as a clearinghouse, informing the operator of any potentially-affected
underground facility: liquids and natural gas pipelines, utility and
telecommunications cables, and water and sewer lines. The facility operator then provides specific location
information to the excavator and marks its underground facility in the area of
the proposed digging. One-call
programs are generally governed by state law.
One-call centers are typically funded by the underground utility
operators, usually on a per call basis. The excavator must make a phone
call, the operator must understand whether its facilities are involved in the
area of work, the locating service must mark utilities accurately, and the
excavating contractor must dig with care. Any
breakdown in the chain can lead to accidents.
All parties to the damage
prevention effort also supported the passage of Subtitle C of Title VII of the
Transportation Equity Act for the 21st Century (P.L. 95-178), a
one-call notification program to promote enhancements in state underground
damage prevention programs. This
statute also authorized a multi-stakeholder study of underground damage
prevention best practices that came to be called the "Common Ground" study.
Building on the success of this study process in brining together the key
interests in underground damage prevention, OPS and the participants in the
damage prevention effort created the Common Ground Alliance to provide for an
ongoing private sector based focus on damage prevention best practices.
The purpose of this nonprofit organization is to ensure public safety,
environmental protection, and the integrity of services by promoting effective
damage prevention practices. The
Common Ground Alliance provides a forum where all affected interests can
participate as equals to address issues in underground damage prevention. The
Alliance's activities include the promotion of R&D efforts to develop new
damage prevention technologies, the identification and dissemination of best
practices, and acting as a clearinghouse for the collection, analysis and
dissemination of damage prevention data. The
Alliance has also taken responsibility for implementing the Dig Safely campaign. OPS and industry are also seeking
further improvements to underground damage prevention in the current
reauthorization of the pipeline safety program. Among these are increased penalties for those who fail to
contact their one-call system and damage a pipeline facility as a result.
We also seek broaden application of these proven one-call systems to all
excavation activities, including requiring use of one-call systems by state and
municipal excavators and their contractors.
In many states, government excavators and contractors are not required to
use the one-call system. Geographic Information - Creating the National Pipeline Mapping System
Critics of the pipeline industry, including the National Transportation
Safety Board, Congress, public safety advocates and communities expressed a
desire for much better geographic and system information about pipelines.
Building again on the team approach, the OPS formed a Mapping Quality
Action Team to determine how best to address these concerns and expectations.
The result of the multiyear team effort was the creation of the voluntary
National Pipeline Mapping System (NPMS). Under
this program, pipelines provide information in certain prescribed formats to
state-based pipeline mapping information depositories.
This information is then incorporated into a GIS-based National Pipeline
Mapping System.
The liquid pipeline industry (through its individual operators) has
voluntarily provided necessary information on 90% of systems to the NPMS. The natural gas industry, which has significantly more
mileage than the liquid pipelines, has supplied information on 50% of the
industry's mileage.
This information was available on-line until the events of September 11,
2001. The OPS has taken this
information off the publicly accessible internet based NPMS and now provides
access to emergency responders, local officials, industry members and others
upon a specific determination based on need.
As appropriate security measures are put in place, OPS expects to make
more of this information available upon request, if not on-line. Improved and Updated Corrosion Rules
A detailed review of incident data revealed that corrosion (internal,
external, micro-biological) is the leading cause liquid pipeline incidents
(although more volume is released through third party damage). Industry engages in a number of different activities to
combat corrosion ranging from the application of enhanced coatings to cathodic
protection, and from the performance of close interval surveys to internal
inspections. Corrosion control is a
challenge for the entire pipeline industry.
OPS also initiated a number of different approaches focused on reducing
corrosion on pipelines, with mixed success.
In 1998, OPS began a coordinated rulemaking process seeking input from
corrosion experts, particularly the National Association of Corrosion Engineers,
and all stakeholders. The resulting
rule, issued December 27, 2001, updates and expands OPS regulations designed to
prevent pipeline incidents involving corrosion. Operator Qualifications
Today's pipeline workforce is very well qualified.
Operator error is not a significant contributor to accidents when
compared with excavation damage or corrosion, for example.
Even so, we recognize OPS needs to be able to assure the public that
operators do have a qualified workforce and that federal inspectors are
routinely evaluating employee capabilities and knowledge.
Under rules promulgated several years ago, OPS crafted a set of
requirements based on specific tasks required to be performed under the pipeline
safety regulations.
OPS has not mandated a single procedure or test by which operators are
qualified. Instead, OPS's rule
requires the operator to demonstrate that its employees and/or contractors are
qualified to perform specific tasks and that they can recognize and respond to
conditions that may be abnormal. These
skills must be demonstrated using various types of evaluations, including
written and performance testing. The
burden is on the operator to demonstrate to OPS that employees or contractors
will be able to perform as expected.
The pipeline industry, through the API Subcommittee on Training and the
Consortium on Operator Qualifications, has developed guidance materials, a
recommended practice, and standardized assessments, and is developing supporting
curricula for all the pipeline safety and maintenance tasks that fall under the
operator qualifications requirements. Pipeline Security
In the aftermath of the terrorist attacks of September 11, 2001, liquid
pipeline operators took prompt action to protect the public, employees and
facilities. Employees were made
aware of the severity of the threat and the operator's commitment to address
this newly defined risk. Operators
went on alert and remain on alert. Operators
began reviewing procedures, reducing and restricting access to facilities,
tightening security procedures, rerouting transportation patterns near key
facilities, closely monitoring visitors and activities near key facilities and
making capital improvements to harden facilities.
These actions were undertaken without direction from government but in
coordination with the Office of Pipeline Safety and later, the Department of
Energy and the Office of Homeland Security.
Pipeline operators, like other industries, are looking to government to
provide information about threats wherever possible, to deploy police power
quickly and intelligently, and to assist in recovery in the event of an attack.
The federal government could provide additional assistance in the
aftermath of an attack to ensure quick restoration of critical pipeline services
and to minimize the disruption of energy supplies to consumers.
With regard to recovery, we believe there is a particular need for the
government to review its emergency authorities and develop workable plans for
emergency access to provide alternate rights-of-way around attack sites.
After a successful terrorist attack, the attack site may be inaccessible
to the pipeline operator for some time due to contamination or because it has
become a crime scene. Yet the public interest will be in the earliest resumption of
service possible. Without emergency
rerouting authority, service resumption may be unnecessarily delayed.
With respect to pipeline security, there is little question in our minds
that planning for and putting deterrence in place against potential terrorist
attacks, and planning for recovery from such attacks fit well into a risk based
approach to pipeline integrity. Without
government mandate, the pipeline industry is developing specific guidance for
incorporating security planning into operator pipeline integrity plans.
This is being done in consultation with the Office of Pipeline Safety and
other federal agencies with experience and expertise in security planning and
implementation. Liquid pipeline operators are familiar with the techniques of
risk management in safety planning, so it seems to us entirely appropriate and
natural to extend these techniques to security planning. Industry Initiatives
The development and implementation of all of these rulemakings and
standards have absorbed significant resources over the last several years.
But industry recognizes that progress has been made in pipeline integrity
management and that there have been significant advancements in the
understanding of pipeline performance. The
liquid pipeline industry is determined to continue the effort.
Thus, chief executive officers of leadership operators in the liquid
pipeline industry began in December 2000 and recently expanded an Environmental
and Safety Initiative. The Environmental and Safety Initiative is guided
by a shared vision of the oil pipeline industry.
We use the vision as a preface to communications with the public and
internally in our companies to communicate at all levels a clear statement of
purpose and priority for our work on a day-to-day basis. Our vision is an oil pipeline industry that -
We commit to fulfill this vision
by: ·
supporting effective federal oversight of pipeline operations
in cooperation with states and local communities; ·
promoting cooperation among
communities, public officials, employees and companies by sharing information on
pipelines and pipeline safety;
The Initiative is made up of multiple teams, each captained
by a CEO and focusing on one aspect of pipeline safety and performance.
The Initiative in 2002 consists of multiple teams with the purposes
stated below: 1. Pipeline Safety Reauthorization and Pipeline Integrity:
Promote strong, effective and credible federal
regulation of the liquid pipeline industry by the Office of Pipeline Safety
(OPS); understand the agenda of OPS and be proactive in cooperating with the
OPS, its stakeholders and its regulatory oversight of liquid pipelines; support
fair and effective enforcement of OPS regulations to establish a floor of
performance for all companies; and improve procedures for permitting necessary
to perform pipeline inspections and repairs. 2. Data Management and Performance Metrics
Continue efforts begun in 1999 to
improve OPS incident reporting; continue to expand and refine the voluntary
Pipeline Performance Tracking System incident and infrastructure database; use
both industry and OPS databases to foster credible analyses of important
data-driven policy issues; develop metrics for evaluating changes in pipeline
performance upon implementation of the integrity management rules; and evaluate
and set leading (as opposed to lagging) performance measures for the pipeline
industry. 3. Underground Damage Prevention/Rights-of-Way
Assume a full and enthusiastic
role in the Common Ground Alliance (CGA) in cooperation with other industries
with interest in underground damage prevention; foster enhanced data collection
and analysis by CGA to better target improvements in damage prevention; help
develop land use best practices and industry standards on setbacks; and work to
improve zoning ordinances to protect pipeline rights-of-way from encroachment. 4. Research and Development Help design and identify funding for a liquid pipeline integrity
technology research and development program and establish an appropriate
organizational home for the program; work with the Department of Transportation
and the Department of Energy to facilitate collaboration in research and
development on pipeline integrity issues; and identify liquid pipeline integrity
research and development projects of the highest priority. 5. Public Information and Communication
As part of an industry-wide
communications plan, develop guidance for activities that each member company
would deploy to communicate with elected officials and the public to foster
understanding of pipeline operations; make maximum use of the internet to make
information available; establish outreach and active liaison with key state and
local groups; exceed OPS requirements for availability of information and
communication with need-to-know constituencies; and establish mechanisms to
assess the effectiveness of communications efforts on a continuous basis. 6. Liquid and Natural Gas Pipeline Coordination
Continue to use industry
connections at the company level to increase communications between liquid and
gas industries on the issues of integrity management, corrosion control,
communications and other pipeline safety initiatives. 7. Pipeline Security
Finalize drafted security
conditions and countermeasures and industry guidance document on security;
conduct an evaluation of the vulnerability of the industry to escalating levels
of threats resulting from possible terrorist activity; work with OPS and other
federal agencies on security issues (background checks, critical facilities,
threat information, etc); and address other security issues as they arise.
Promote inter-company learning to
improve pipeline operations and integrity; develop integrity and operational
best practices for adoption by the industry drawing upon the resources of the
Pipeline Performance Tracking System, the OPS audits of Integrity Management
Programs and company experience in implementing risk-based integrity management
programs. These team efforts are direct progeny of that initial Risk
Assessment Quality Action Team begun in 1995 and the primary focus of the
industry in 2002. All are aimed at finding the necessary tools to constantly
improve pipeline safety and environmental performance. Summary
We believe the movement to a risk-based approach to
new pipeline safety regulations since the early 1990s has resulted in
significant advancements and enhancements in the DOT's pipeline safety
program, improvements in pipeline management by operators and what we believe is
a trend in an improved safety record. Risk
management has at times been controversial in Congress.
We hope many of these concerns are behind us, because risk assessment,
risk-based decision-making and risk management are essential to addressing the
risks of pipeline operation under normal times and are vital in preparing for
the never-to-be-normal-again world we are part of since September 11th.
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One
of the keys to preventing excavation damage to underground facilities through
one-call centers is
