May 18, 2001
Dockets Facility
U.S. Department of Transportation
Room PL-401
400 Seventh Street, S.W.
Washington, DC 20590-001
Re: Docket No. RSPA-01-8663
As a group of students at Florida International University, who are deeply concerned for the environment and all eminent consequences for both our present and future, we are respectfully submitting proposed revisions we believe are of significant importance to our communities, companies, and the nation.
Although we are aware that the Office of Pipeline Safety is responsible for over two million miles of natural gas and hazardous liquid pipelines and its risks, we simultaneously understand the major economic role that companies regulated by the Office of Pipeline Safety play in our nation for its very survival. Therefore, we are proposing the following changes to the proposed rulemaking in regards to the above-mentioned docket:
Revision #1: Given the twofold environmental effect of hazardous liquid or carbon dioxide spills to not only the immediate ground but also the atmosphere (air), and therefore, consequences realistic on any property, the reporting requirement should be lowered from 5 barrels to 10 gallons (38 liters) for spills on any property whether from accident or maintenance.
Revision #2: Aggregate spills of hazardous liquid or carbon dioxide of a minimum of 10 gallons (38 liters) will pose sufficient damage to warrant immediate clean-up, and therefore, it should be mandated.
Revision #3: Lowering the reporting requirement for spills from 5 barrels to 5 gallons (19 liters) only when it is not readily cleaned up on any property.
Revision #4: Tools for Reporting Accidents (Section 195.50): Since technology has evolved and continues to do so, accident reporting should be done in a efficient, cost-effective, time-constrained manner in tune with the technology available to us today. Furthermore, electronic accident reporting is effective and productive for meaningful incident information. The DOT, Office of Public Safety, should establish a web site where different accident report-hazardous liquid pipeline forms could be electronically filled out in case of accident. Some of the benefits of electronic filing are:
(1) Instant information available, (2) Immediate dangers readily visible, (3) Reduced cost to companies.
It is obvious that the proposed changes would not interfere with the proposed Amend Section 195.50 to revise paragraph (b), to remove paragraph (c), and to redesignate paragraphs (d) through (f) as paragraphs (c) through (e), as given by authority 49 U.S.C. 5103, 60102, 60104, 60108, 60109, 60118; and 49 CFR 1.53.
Through above-proposed revisions we sincerely intend to positively impact the Department of Transportation and companies affected by the proposed rule, fully knowing that any rulemaking that enhances our environmental and economic arenas, will reap bountiful fruits for all.
We want to thank you in advance for considering them and allow us to impact individuals, our communities, and our nation.
Sincerely,
Rosa Maria Alvarez
Gary Niles
Natalia Diaz
Gustavo Eimil
Ellizabeth Armstrong
Carlos Del Moral
Jose Vazquez
cc: Mr. Roger Little
Office of Pipeline Safety
Room 7128
400 7th St. SW.
Washington, DC 20590
Rosa M. Alvarez - Comment
This is comment on Rule
U.S. DOT/RSPA - Notice of Proposed Rulemaking; Request for Comments on Revised Form
View Comment
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