We have no revenue or segment profit or loss attributable to international activities.
REGULATORY AND ENVIRONMENTAL MATTERS
Safety and Maintenance Regulation
We are subject to regulation by the United States Department of Transportation, or DOT, under the
Hazardous Liquids Pipeline Safety Act of 1979, as amended, referred to as the Hazardous Liquid Pipeline
Safety Act, of 1979, as amended, or HLPSA, and comparable state statutes with respect to design, installation,
testing, construction, operation, replacement and management of pipeline facilities. HLPSA covers petroleum
and petroleum products, including NGLs and condensate, and requires any entity that owns or operates pipeline
facilities to comply with such regulations, to permit access to and copying of records and to file certain reports
and provide information as required by the United States Secretary of Transportation. These regulations include
potential fines and penalties for violations. We believe that we are in compliance in all material respects with
these HLPSA regulations.
We are also subject to the Natural Gas Pipeline Safety Act of 1968, as amended, or NGPSA, and the
Pipeline Safety Improvement Act of 2002. The NGPSA regulates safety requirements in the design,
construction, operation and maintenance of gas pipeline facilities while the Pipeline Safety Improvement Act
establishes mandatory inspections for all United States oil and natural gas transportation pipelines in high-
consequence areas within 10 years. The U.S. Department of Transportation, or DOT, has developed regulations
implementing the Pipeline Safety Improvement Act that requires pipeline operators to implement integrity
management programs, including more frequent inspections and other safety protections in areas where the
consequences of potential pipeline accidents pose the greatest risk to people and their property. We currently
estimate we will incur costs of up to $6.7 million between 2012 and 2016 to implement integrity management
program testing along certain segments of our natural gas transmission and NGL pipelines, including our
Wattenberg NGL pipeline acquired in January 2010. We believe that we are in compliance in all material
respects with the NGPSA and the Pipeline Safety Improvement Act of 2002.
States are largely preempted by federal law from regulating pipeline safety but may assume responsibility
for enforcing intrastate pipeline regulations at least as stringent as the federal standards. In practice, states vary
considerably in their authority and capacity to address pipeline safety. We do not anticipate any significant
problems in complying with applicable state laws and regulations in those states in which we or the entities in
which we own an interest operate. Our natural gas transmission and regulated gathering pipelines have ongoing
inspection and compliance programs designed to keep the facilities in compliance with pipeline safety and
pollution control requirements.
In addition, we are subject to the requirements of the federal Occupational Safety and Health Act, or
OSHA, and comparable state statutes, whose purpose is to protect the health and safety of workers, both
generally and within the pipeline industry. In addition, the OSHA hazard communication standard, the
Environmental Protection Agency, or EPA, community right-to-know regulations under Title III of the federal
Superfund Amendment and Reauthorization Act and comparable state statutes require that information be
maintained concerning hazardous materials used or produced in our operations and that this information be
provided to employees, state and local government authorities and citizens. We and the entities in which we
own an interest are also subject to OSHA Process Safety Management regulations, which are designed to
prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable or explosive
chemicals. These regulations apply to any process which involves a chemical at or above the specified
thresholds, or any process which involves flammable liquid or gas, pressurized tanks, caverns and wells in
excess of 10,000 pounds at various locations. Flammable liquids stored in atmospheric tanks below their normal
boiling point without the benefit of chilling or refrigeration are exempt. We have an internal program of
inspection designed to monitor and enforce compliance with worker safety requirements. We believe that we
are in compliance in all material respects with all applicable laws and regulations relating to worker health and
safety.
Propane Regulation
National Fire Protection Association Codes No. 54 and No. 58, which establish rules and procedures
governing the safe handling of propane, or comparable regulations, have been adopted as the industry standard
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