PHMSA Gas Transmission (GT) Integrity Management
Time: 11/27/2014 06:13 PM

Protocol Item H.02

H.02 Third Party Damage

Verify that the following preventive and mitigative requirements regarding threats due to third party damage have been addressed: [192.935(b)(1) and 192.935(e)]

  1. Verify implementation of enhancements to the 192.614-required Damage Prevention Program with respect to covered segments to prevent and minimize the consequences of a release, and that the enhanced measures include, at a minimum: [Note: As noted in Protocol H.03 and Protocol H.04, a subset of these enhancements are required for pipelines operating below 30% SMYS and for plastic transmission pipelines.] [192.935(b)(1)]
    1. Using qualified personnel (see Protocol L.02 - 192.915(c)) for work an operator is conducting that could adversely affect the integrity of a covered segment, such as marking, locating, and direct supervision of known excavation work. [192.935(b)(1)(i)]
    2. Collecting, in a central database, location-specific information on excavation damage that occurs in covered and non covered segments in the transmission system and the root cause analysis to support identification of targeted additional preventative and mitigative measures in the high consequence areas. This information must include recognized damage that is not required to be reported as an incident under Part 191. [192.935(b)(1)(ii)]
    3. Participating in one-call systems in locations where covered segments are present. [192.935(b)(1)(iii)]
    4. Monitoring of excavations conducted on covered pipeline segments by pipeline personnel. [192.935(b)(1)(iv)]
      1. When there is physical evidence of encroachment involving excavation that the operator did not monitor near a covered segment, verify that the area near the encroachment must be excavated or that an above ground survey using methods defined in NACE RP0502-2002 must be conducted. [192.935(b)(1)(iv)]
        1. If an above ground survey is conducted, verify that any indication of coating holidays or discontinuities warranting direct examination must be excavated and remediated in accordance with ASME B31.8S-2004, Section 7.5 and 192.933. [192.935(b)(1)(iv)]
  1. If the threat of third party damage is identified by results of the 192.917(b) (Protocol C.02) and ASME B31.8S-2004, Appendix A7 data integration processes, verify that comprehensive additional preventive measures are implemented. [192.917(e)(1)]

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