GasPipelineSafetyOIR Plea WildGoose 20130628 280481 PDF

Operations and Maintenance Procedures Manual
Gas Pipeline
When equalizing the movement of air in both directions as indicated by the streamers, the
evacuation of the pipeline should continue for fifteen minutes.
Conduct gas test with a combustible gas indicator for the presence of gas in and around
the access opening or in the ends of the pipe. If no gas is indicated, the pipeline is
available for cutting cold operation.
The movement of air into the access hole of open ends of the pipe must be maintained
throughout the cutting and welding operation.
Prior to cutting out cylindrical piece of pipe, reduce the air mover rate so as to minimize
spark travel in the pipe. Before severing, the pipe should be restrained by clamps, side
boom or blocking.
When the cutting has been completed, the air mover may be adjusted to a rate required
for the next operation. The air mover should be adjusted to a rate that will minimize
welding problems on the replacement pipe. Control the pressure settings on the air
movers to control vacuum on the pipeline and eliminate blow in of welds as the pipeline
is closed to the atmosphere by welding.
Upon completion and acceptance of the welds, remove air mover equipment and return
pipeline to service after purging the pipeline with natural gas.
Air
Mover
Size
Inch
10
Gage
Pressure
PSIG
Compressed
Air SCFM
Discharge
Air
SCFM
Induced
Air
SCFM
20
19.0
274
255.0
30
40
26.4
33.4
397
496
370.6
462.6
50
40.8
561
520.2
60
70
80
49.8
60.0
72.4
614
681
736
561.2
621.0
663.6
20
48.0
900
852.0
30
40
91.0
141.0
1350
1800
1259.0
1658.0
50
60
70
30
42
55
70
81
192.0
242.0
293.0
149.0
214.0
262.0
342.0
398
2250
2700
3150
2900
3700
4240
5050
5560
2058.0
2458.0
2857.0
2751.0
3486.0
5879.0
4708.0
5162.0
10
12
Full size
access hole
w/ air supply
16
24
Plug Valve
with air
supply
20
30
36
Plug valve
with gas
supply
Source: AGA Purging Principle and Practice 1975.Table 8-2.

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2.17 Safety Related Condition Report

CODE REFERENCE: Title 49 CFR Sections 191.23, 191.25, 192.485 and 192.605(d)
PURPOSE: To define safety related conditions and establish responsibilities for
reporting safety related conditions on company pipelines.
GENERAL: Safety related conditions involving pipeline facilities shall be reported to
the Production Coordinator as soon as they are noted. The Production Coordinator will
determine if the condition is reportable under the provisions of CFR 49 Section 191.23.
Designated operating personnel will look for possible safety related conditions while
conducting routine operating functions and when following applicable procedures for
inspections and surveillance.
The Production Coordinator or designated operating personnel will complete the Safety
Related Conditions Report form. If completed by operating personnel, it must be
provided to the Production Coordinator as soon as possible, but not more than five (5)
working days after discovery.
The Production Coordinator is responsible for evaluating safety related conditions and
reporting to governing agencies. Reports must be received by the governing agencies no
later than five (5) working days after the day of determination or ten (10) days after the
day of discovery.
If a possible safety related condition is discovered which results in taking the facility out
of service due to an incident before determination and not more than five (5) working
days from discovery, the reporting requirements of this procedure are eliminated.
DEFINITIONS
Safety Related Condition as described in the criteria below is a condition, which lies
within 200 yards of any building intended for human occupancy or outdoor place of
assembly, or within the right-of-way of an active railroad, asphalt or concrete paved road,
street or highway.
Discovery Date is the date that a condition is identified that may be classified as a
safety related condition under this procedure, but requires additional evaluation or
analysis.
Determination Date is the date when a condition evaluation results in the conclusion
that is a safety related condition.
Working Days are Monday through Friday, except Federal holidays.
SAFETY RELATED CONDITION CRITERIA - The following are safety related
conditions reportable under CFR 49 Part 191.23, applicable to pipeline facilities:
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1.
On a pipeline that operates at hoop stress of 20% or more of its Specified

Minimum Yield Strength when:
General corrosion has reduced the wall thickness to less than that required
for the Maximum Allowable Operating Pressure, and
Localized corrosion pitting to a degree where leakage might result.
2.
Unintended movement or abnormal loading by environmental causes, such as

earthquake, landslide, or flood that impairs the serviceability of pipeline or the
structural integrity or reliability of a facility that contains, controls or processes
gas.
3.
Any material defect or physical damage that impairs the serviceability of a

pipeline that operates at a hoop stress 20% or more of its Specified Minimum
Yield Strength.
4.
Any malfunction or operating error that causes the pressure of a pipeline

containing gas to rise above its Maximum Allowable Operating Pressure plus the
build-up allowable for operation or pressure limiting or control devices.
5.
A leak in a pipeline that is characterized by the need for immediate corrective

action to protect the public or property and that constitutes an emergency.
6.
Any safety related condition that could lead to an imminent hazard and causes
(either directly or indirectly by remedial action of the Company ), for purposes
other than abandonment, a 20% more reduction in operating pressure or shutdown
of operation of a pipeline that contains or processes gas.
7.
Reduction in pressure as a precaution to avoid an unsafe condition for the

following activities is not reportable:
Abandonment of pipeline facilities,
Routine maintenance or construction,
Facilitate inspection for potential problems,
Avoid problems related to external loading from blasting or subsidence,
Provide for safe line movement.
Using the above listed criteria, personnel who perform operation and maintenance
activities should be able to recognize conditions that may be potentially safety related.
REPORTING OF SAFETY RELATED CONDITIONS- Report safety-related
conditions to PHMSA and CPUC for all safety related conditions resulting from defects
outlined above regardless of when the condition is repaired. Use WGS Form 108 Safety
Related Condition Report and provide the following information:
Name and principal address of Company
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Date of report
Name, job title, and business telephone number of person submitting the report
Name, job title, and business telephone number of person who determined that the
condition exists
Date condition was discovered and date condition was first determined to exist
Location of condition, with reference to the State (and town, city, or county), and
as appropriate, nearest street address, survey station number, milepost, landmark,
or name of pipeline.
Description of the condition, including circumstances leading to its discovery, any
significant effects of the condition on safety, and the name of the commodity
transported or stored.
The corrective action taken (including reduction of pressure or shutdown) before
the report is submitted and the planned follow-up or future corrective action,
including the anticipated schedule for starting and concluding such action.
A safety related condition is not reportable if:
It becomes an incident before the deadline for filing the safety related condition
report. Report the situation per Section 2.2 Incidents Reporting and Control
of this manual.
It exists on a pipeline that is more than 220 yards from any building intended for
human occupancy or outdoor place of assembly, except that reports are required
for conditions within the right-of-way of an active railroad, paved road, street, or
highway.
It is corrected by repair or replacement in accordance with applicable safety
standards before the deadline for filing the safety related condition report, except
that reports are required for the conditions in SAFETY RELATED CONDITION
CRITERIA above, other than localized corrosion pitting on an effectively coated
and cathodically protected pipeline.
Designated operating personnel shall contact the Production Coordinator promptly if a
possible safety related condition is discovered.
Operating personnel shall provide relevant information on an expedited schedule to
support the timely submission of report to the PHMSA. The Safety Related Condition
Report form is to be used as a communication tool by Operating Personnel to provide
proper information to the Production Coordinator. If the Production Coordinator
determines that a reportable safety related condition exists, then he/she shall complete the
form. In either case, the form must be completed and a report submitted within five (5)
working days after the condition is discovered, but not later than one (1) working day
after determination.
The Production Coordinator will evaluate and confirm the reportability of a condition. If
a condition is determined to be reportable, the Production Coordinator will submit the
necessary written report to the appropriate agencies and to the D.O.T./PHMSA within
five (5) working days (not including Saturday, Sunday or Federal holidays) of
determination, but not later than ten (10) working days after discovery of the condition, at
the following address:
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Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
U.S. Department of Transportation
Information Resources Manager PHP-10
1200 New Jersey Avenue, SE.
Washington, DC 20590-0001
Telephone 800-424-8802
CPUC Reporting:
Copies of all reports submitted to the Secretary of Transportation shall be submitted to
the Commission concurrently.
RECORDS: For intrastate pipelines, and in states where the state is an Agent for the
D.O.T., a report copy will be sent to the applicable state agency and CPUC.
Copies of Safety Related Conditions Report form and reports to the D.O.T./PHMSA and
other agencies will be sent to the applicable Company offices.
A copy of all correspondence related to reported conditions will be kept the office
experiencing the incident for five (5) years.
Reports on all corrective action taken will be kept by the local office for at least five
years.
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2.18 Security of Facilities

CODE REFERENCE: 192.179(b)(1), 192.605(a)
PURPOSE: To protect the health and well being of members of the public who may
trespass on a company pipeline facility.
GENERAL: Pipeline facilities can be very dangerous places to those untrained and
those oblivious of the danger. Security of a facility may not only keep these people out
but may also deter the saboteur or vandal.
SECURITY OF STORAGE AREAS - Jurisdictional facilities such as breakout storage
facilities, well pads, etc. on pipelines shall be secured by installing a fence around each
facility appropriate for the area. Normally this would include a fence approximately six
feet high around the perimeter of the facility or around the above ground components of
the facility not otherwise secured. All gates providing access to the facility shall be
equipped with locking devices and shall be kept locked when the facility is unmanned. If
a facility is manned continuously, locking gates are not required.
SECURITY OF BLOCK VALVES - All mainline block valves and any other valves
that has the potential of over pressuring or causing a release of the pipeline product if
opened or closed unexpectedly are located in secured areas with locked facilities and/or
24 hour security.
SECURITY OF PUMP STATIONS - Pump stations shall be secured in the same
manner as storage areas. In addition to the general security provided by the fencing,
additional security is recommended in the form of locking such things as the doors to
electrical switchgear buildings, offices, transformers and other electrical equipment
carrying voltages greater than 220 volts.
SECURITY OF RECTIFIERS - Rectifiers installed along the pipeline shall be installed
in an enclosure equipped for locking and be kept locked at all times.
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2.19 Tapping Pipelines under Pressure

CODE REFERENCE: Title 49 CFR Sections 192.151, 192.155, and 192.627
PURPOSE: To establish the requirements necessary for the installation of hot taps on
pipelines under pressure.
GENERAL: Hot tapping is the installation of a branch connection with a valve on an
existing pipeline while the facility is in service and under pressure.
The Production Coordinator or Engineer will be responsible for the design of the tap and
the maximum allowed pressure in the carrier pipe when welding and cutting the tap.
The tapping machine used and the fittings installed shall be designed to meet or exceed
the operating pressure of the line being tapped.
The Project Engineer will be responsible for procedures to be followed in making hot
taps and for installation of the tap.
Split tapping tees will normally be used for branch connections. Saddles will only be
used if tapping tees cannot be obtained.
The term saddle shall include reinforcing saddles, wrap around saddles, or wrap around
pipe, saddles, and proprietary fittings.
Only qualified welders and crewmembers will be utilized in the hot tapping procedure.
All welding performed in the installation of the tap shall be done in accordance with the
API 1104.
PROCEDURE:
CONDITION OF THE PARENT PIPE - If there is a question concerning the type of
existing pipe at a proposed tap location, the Production Coordinator will provide
assistance in identifying the type of pipe.
Visually inspect the external of the pipe in the area for the defects such as corrosion,
mechanical damage, etc.
The pipe to be tapped shall be free of laminations and free of any significant external or
internal corrosion.
The wall thickness of the pipe to be tapped must be 0.156 inch or greater, as determined
with an ultrasonic thickness gauge.
The pipe to be tapped shall not operate at a temperature above 200 Fahrenheit.
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TAP LOCATION - The tap location must be at least 5 feet from a bend on a straight
section of pipe so as to minimize secondary stresses due to shifting of the main line.
The outside edge of the hot tap nipple will be a minimum of two (2) inches from the
longitudinal seam of the parent pipe and shall be a minimum distance of six (6) inches
from a girth weld.
Generally, hot taps will be installed on the side; however, where prevailing circumstances
warrant, they may be installed on the top of the parent pipe.
The tap shall not be made through any weld circumferential or longitudinal seam weld, or
its heat - affected zone. If inspection reveals that the proposed location of the tap falls in
a bend or in a weld, another location shall be selected.
INSTALLATION OF HOT TAP NIPPLE AND VALVE
SPECIFICATIONS To provide added structural strength to the branch connection
point, unless otherwise specified, pre-tested heavy wall thickness pipe will be used for all
hot tap nipples as follows:
For tap sizes 8 and above, wall thickness minimum, a minimum of 35,000 psi
specified minimum yield strength (SYMS) up to SMYS of the carrier pipe,
seamless, minimum length 8-1/2.
For tap sizes 6 and under, use schedule 80 wall thickness, minimum of 35,000
psi SYMS, seamless, minimum length 6-1/2.
All hot tap nipples must be cut from pipe that has been pretested to a pressure specified
by the Production Engineer.
Nipple length will be a minimum of one diameter except in larger sizes where the length
is limited by tapping machine travel.
All valves used in tapping three (3) inches and larger pipe diameters will be flanged.
Valves smaller than three (3) inches pipe diameter may be threaded.
PREPARATION AND WELDING OF HOT TAP NIPPLE
FIT-UP WELDING - The hot tap nipple will be fitted, beveled and welded only by a
qualified welder.
The hot tap nipple will be fitted and beveled to provide equal spacing around the
circumference of the nipple. The nipple should be beveled at an exaggerated angle in the
throat area to allow sufficient clearance for filling in this area.
Complete penetration of the root bead is necessary; however, excessive penetration is
undesirable due to interference with the cutter head of the tapping machine. An inside
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pass of the weld joining the nipple to the parent pipe will not be permitted. For assurance
of proper nipple weld, the saddle tap nipple should be installed prior to installing the
valve.
Extreme care will be exercised to maintain a true 90-degree angle between the axis of the
parent pipe and to maintain a straight centerline between the nipple and valve in order to
maintain the proper position of the cutter head during the tapping operation.
All moisture and condensation shall be dried from the carrier pipe and the saddled end of
the hot tap nipple by heating immediately before welding commences.
TESTING AND INSPECTION
LEAK TEST Each hot tap fabrication shall be hydrostatically tested. Pretested pipe
may be used.
Prior to installation of the weld saddle or split tee, each hot tap installation will be
subjected to a leak test within the following pressure range:
Maximum Test Pressure - 10% above line pressure existing at point of tap.
Minimum Test Pressure - Line pressure existing at point of tap.
During the test, the weld and valve body will be closely examined for pinhole leaks and
other defects.
Radiographic inspection of butt welds is necessary. The fillet weld joining the hot tap
nipple to the carrier pipe is to be examined visually and, at the discretion of the welding
inspector, it can be inspected for surface defects utilizing the magnetic particle or
penetrant testing methods.
INSTALLATION OF SPLIT TAPPING TEE
INSTALLATION AND WELDING The split tee shall be installed using a chain and
jack or similar arrangement to insure a snug fit around the parent pipe.
The longitudinal welds shall be made first. The welder shall begin at the center of
saddle and work toward the ends. Each welder shall make each pass, including
stringer bead, for the entire length of the weld before successive passes are added.
connecting weld will be made between the split tee and the parent pipe along
longitudinal seam (using a backing piece when possible).
the
the
No
the
Weld the ends of the split tee to the parent pipe.

The extruded outlet of the split tee reinforcement will be butt welded to the hot tap nipple
or flange.
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COMPLETION OF HOT TAP The tapping machine will be bolted to the flange of
the valve. If a horizontal tap is being made, the tapping machine shall be supported so
that no stress will be placed on the hot tap nipple and valve. Extreme care is to be
exercised in properly aligning and operating the tapping machine. The hole will then be
cut in the carrier pipe to complete the hot tap.
Each hot tap fabrication with the connected tapping machine shall be hydrostatically leak
tested prior to cutting the hole. Pressure shall be limited to prevent overstressing the
carrier pipe from external pressure and overpressuring the tapping machine.
The hole will then be cut in the carrier pipe to complete the hot tap.
COATING ASSEMBLY Upon completion of the tap the entire assembly is to be
thoroughly cleaned, primed, and coated with a coating that is compatible with the coating
system on the carrier pipe.
INSTALLATION OF FULL ENCIRCLEMENT REINFORCING SADDLE
PREPARATION The effectiveness of a full encirclement reinforcing saddle depends
upon a snug fit around the carrier pipe. Maximum surface contact between the outside of
the carrier pipe and the inside of the saddle is necessary prior to welding the two halves
of the saddle together.
To accomplish the snug fit it might be necessary to grind a smooth groove inside the
saddle to fit the longitudinal weld of the carrier pipe. The saddle thickness shall not be
reduced to less than the thickness of the parent pipe. The groove in the saddle must be
such that the longitudinal parent pipe weld will not contact the bottom of the groove
before the inside of the saddle contacts the outside of the carrier pipe.
INSTALLATION AND WELDING The saddle shall be installed using a chain and
jack or similar arrangement to insure a snug fit around the carrier pipe and the hot tap
nipple.
The longitudinal welds shall be made first. The welder shall begin at the center of the
saddle and work toward the ends. The welder shall make each pass, including the
stringer bead, for the entire length of the weld before successive passes are added. No
connecting weld will be made between the reinforcement and the parent pipe (use a
backing piece when possible).
The extruded outlet of the reinforcement will be fillet welded to the hot tap nipple.
Do not weld the ends of the reinforcing saddle to the carrier pipe.
COMPLETION OF HOT TAP The tapping machine will be bolted to the flange of
the valve. If a horizontal tap is being made, the tapping machine shall be supported so
that no stress will be placed on the hot tap nipple and valve. Extreme care is to be
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exercised in the properly aligning and operating the tapping machine. The hole will then
be cut in the carrier pipe to complete the hot tap.
COATING ASSEMBLY Upon completion of the tap the entire assembly is to be
thoroughly cleaned, primed, and coated with a coating that is compatible with the coating
system on the parent pipe. Special care should be taken to effectively seal the ends of the
full encirclement saddle so that no moisture can penetrate and enter the area between the
saddle and parent pipe. This is extremely important since the ends of the saddle are not
welded to the parent pipe.
CONCRETE SUPPORT Horizontal tap installations will be supported by concrete
foundations extending back and under the line being tapped, placed on firm soil and
installed as soon as possible after the side connection is welded in place.
RECORDS: Submit as-built documentation for updating of drawings.
On buried pipeline, complete WGS Form 109 Pipeline Leak Repair Form.
A record shall be made of each hot tap installed on a pipeline, and records shall be
retained for the life of the pipeline in the appropriate file.
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SECTION 3.0 PIPELINE MAINTENANCE

Gas Pipeline
SECTION 3.0 PIPELINE MAINTENANCE

3.1
Abandonment or Inactivation of Facilities

CODE REFERENCE: Title 49 CFR Section 192.727
PURPOSE: To establish minimum requirements for the abandonment of natural
gas pipeline facilities.
DEFINITIONS - Abandoned facilities are those which have been determined to
have no present or future use, and have ceased operation, either due to
deterioration or because they are not needed for gas transportation use now or in
the future. An abandoned pipeline is a pipeline that is physically separated from
its source of gas and is no longer maintained under CFR 49 Part 192.
Inactive facilities are those that have ceased operation, but may be returned to
service in the future. An inactive pipeline is maintained under Part 192.
GENERAL: Facilities to be abandoned will be evaluated and handled on an
individual basis.
All applicable Federal, State, county, and local regulations or ordinances shall be
complied with in the abandonment of gas facilities.
Physically remove all abandoned facilities if practical. If this is not feasible,
sever below grade and remove all aboveground piping and equipment.
Pipeline facilities abandoned in place will not be maintained and should not be
considered for reactivation for service at a later date.
PROCEDURE ABANDONMENT: Facilities to be abandoned shall be
disconnected from all potential sources and supplies of gas, such as other pipeline
mains, producer's piping, crossovers, control lines, metering and regulating
stations, etc. by a physical separation. All associated valves shall be locked and
tagged closed and/or disconnected.
Abandoned facilities shall be purged of natural gas. If air is used as a purging
medium, precautions shall be taken to ensure that a combustible mixture is not
present after purging and that the mixture cannot ignite during purging.
After purging, the abandoned pipeline must be sealed at both ends, using one of
the following methods:
Normal end closures,
Welding steel plate to pipe ends,
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Pinching the ends closed and welding shut, or
Plugging the ends with a suitable material.
Abandoned pipelines may be filled with air, inert gas, inhibited water, Bentonite
Clay (drilling mud), sand slurry, lean cement slurry or other inert materials.
Any valves left in the abandoned segment should be closed. If there are few line
valves, and the segment is long, consideration should be given to cutting and
plugging the segment at intervals.
All aboveground piping, valves, meters, and risers should be removed from the
abandoned segment.
Any belowground valve boxes or vaults should be filled with compacted inert
material. Acceptable backfill material includes but is not limited to native
material, sand slurry or lean cement slurry.
PROCEDURE - INACTIVE PIPELINES: Protect inactive facilities using
cathodic protection or other means to prevent deterioration. Generally, pipelines
should remain filled with natural or inert gas and be pressurized above
atmospheric pressure.
Inactive facilities must be treated the same as active facilities and all requirements
of the Operating and Maintenance Procedure Manual for Gas Pipelines
requirements must be carried out on inactive facilities.
Inactive, unmaintained facilities may be returned to service after a thorough
engineering review, testing and conversion to service.
RECORDS: Complete a WGS Form 110 Pipeline Abandonment Form and
send to the Production Coordinator for filing and historical reference.
Update drawings with abandonments or removals.
Pipelines that have been removed, or abandoned in-place and sold, will be
eliminated from the drawings. Other in-place abandonments need to be indicated
on drawings as being abandoned-in-place.
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3.2
Blowdown of Pipelines
CODE REFERENCE: Title 49 CFR Sections 192.179, 192.629, and 192.751
PURPOSE: To establish criteria for identifying obstructions, which may be
present at blowdown locations, and to establish safety practices to follow when
purging or blowing down gas facilities.
GENERAL: Whenever a pipeline or pipeline facility filled with gas is blown
down as a result of a scheduled construction or maintenance project, it is
necessary for personnel to exercise extreme safety precautions during the blow
down activities.
The identification of blow-off locations that are close to overhead or other
obstruction (i.e. electrical lines, building, etc.) is necessary so that precautions can
be taken to provide safe conditions during blowdown operations.
When practical, the attempt should be made to prevent having electric
transmission lines installed near blowdown valves. If the electric transmission
lines cannot be moved and the blowdown connections cannot be employed to
direct the gas away from the electric transmission lines, then the blowdown must
be done at a location where the safety conditions can be met, possibly at another
blow off valve.
Affected compressor station compressor, suction and discharge piping shall be
isolated, blowndown, and purged prior to work on the compressor or piping.
Compressors and piping shall be purged of air per Section 2.16 of this manual
prior to recommissioning.
PROCEDURE:
IDENTIFICATION OF BLOW-OFF LOCATIONS - Identify blow-off
locations where precautions should be taken during a blowdown.
Mark each such location with a sign indicating Controlled Blowdown Required
Due to Overhead or Adjacent Facilities.
BLOWDOWN PLANNING - Prepare a plan and review it with the crew prior to
purging or blowing down a gas facility. Discuss any hazards involved, such as
power lines, public highways and railroads.
Use silencers in populated areas when necessary.
Post warning sign where appropriate.
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Notify the following regarding the time and place before blowing pipeline gas to
atmosphere:
People living/working in the area;
Public agencies such as the county sheriff, local police or fire department
as required;
Facilities supplying the pipeline and receiving from the pipeline which
will be interrupted.
Traffic control, if required, should be performed by local law enforcement
officials on all preplanned activities.
Ensure that appropriate fire extinguishing equipment is available at strategic
locations.
Do not begin work until communications have been established with personnel
diverting traffic and among personnel at the ends of pipeline sections being blown
down or purged.
BLOWDOWN OPERATIONS - Blow down of natural gas, which has been
odorized, should not be performed in a heavily populated area. If there is no
alternate location where the odorized gas can be vented to atmosphere,
consideration should be given to flaring (burning) the gas.
Employees and other personnel in the vicinity of the blowdown shall wear
adequate safety equipment, including eye and ear protection.
Be careful not to provide a source of ignition for the escaping gas, such as
smoking, electric tools, sparks, etc.
All valves should be opened and closed in a steady, controlled manner.
Do not exhaust gas, at any time, into overhead electrical wires or into the
atmosphere when an electrical storm is in the vicinity.
Prevent a hazardous mixture of gas and air in the pipeline.
Control gas pressure using experienced personnel. Do not allow unauthorized
contractor or Company employees to operate valves.
Locate personnel a safe distance upwind.
Block or divert traffic as gas may drift across public roadways.
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Locate vehicles or equipment, which might cause ignition, at least 500 feet
upwind from a horizontally severed pipeline. (Do not allow vehicles or
equipment anywhere except upwind of the severed pipeline.)
Do not allow vehicles closer than 100 feet upwind from a vertical blow-off. (Do
not allow vehicles anywhere except upwind of a blow-off.)
Continue using these precautions throughout the entire blow-off period, until all
valves are shut and flow has stopped, and until all gas has had time to disperse.
If required, a useful formula in estimating blowdown gas losses, is as follows:
V = (ID) 2 (Pressure) (Length) (1.97)
where V = Volume of gas blown down, standard cubic feet
(Divide by 1000 to obtain MCF)
ID = Pipe Inside Diameter, inches
(ID = OD - 2 times wall thickness)
Pressure = Initial Pipeline Pressure, PSIA
Length = Pipeline length, miles
(Divide feet by 5,280, if necessary)
RECORDS: File pre-job safety plan and tailgate meeting roster.
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3.3
Clearing Pipeline Freezes and Ice Blocks

PURPOSE: To establish safety practices to follow when clearing pipeline
freezes and ice blocks.
GENERAL: When it is suspected that a freeze exists in a line notify the
Production Coordinator of the freeze.
The Production Coordinator will send assistance, when necessary, and maintain
supervision throughout the operation.
Isolate the line. On high-pressure systems the well(s) should be shut in first to
prevent over pressuring the line.
Eliminate all sources of ignition in the immediate area where gas will be blown
(engines, heaters, etc.).
Park vehicles upwind of the operation at a distance to insure safety to personnel
and unit.
Open all valves cautiously; beware of any sudden pressure drop. There is always
the possibility of a freeze near any valve.
Reduce pressure on the high-pressure side of the freeze. This step should be
performed with extreme caution.
A one-inch or smaller valve should be cracked open and if a rapid decrease in
pressure is noted, either by gauge or sound, the valve should be closed
immediately. If no pressure decrease is noted, the valve may be opened slowly to
lower the pressure to design pressure - constantly watching for any rapid pressure
drop.
Attempt to locate freeze by checking pressures at available points, i.e., wells, tieins, and drips.
PROCEDURE - SOLID FREEZE: The information gathered in the steps
above, will determine the next procedure to be followed.
When freeze is located close to blowoff:
Blow down the long section of line without attempting to equalize
pressures across the freeze.
Blow down short section of line with one-inch or smaller valve.
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When freeze is located relatively near the center of the isolated section:
Blow down the high-pressure side of the freeze until it is 50 psi
less than the low-pressure side. This should be done through a
one-inch or smaller valve.
When a double freeze is encountered:
Reduce pressure on each side of the section maintaining a
differential of 50 psi or less across the freeze.
When freezes are not located close to either end, blow the line at each end
and between the freezes by means of one-inch or smaller valves. Maintain
a differential of 50 psi or less across the freezes.
When both freezes are located close to blowoffs at each end, blow the line
between the freezes and then the short sections at each end.
When one freeze is located close to a blowoff, blow the line between the
freezes and at the end away from the close freeze, maintaining a
differential of 50 psi or less. When these sections are blown down, blow
the short section.
Allow the line to air for several hours or overnight. A vent stack should
be used in hazardous areas (near roads, engines, etc.).
RETURNING LINE TO SERVICE - Install a gauge at the inlet end, give the
line a good blow maintaining between 25 psi and 150 psi while making certain
that there is no pressure buildup. (This will also act as a purge prior to putting the
line back in service.)
Stand well away from the outlet end during the blow. Wait until the blow
clears sufficiently before shutting in the outlet.
Notify the Production Coordinator that the freeze is cleared and line is
back in service.
PROCEDURE - PARTIAL FREEZES - Notify Production Coordinator of
freeze.
Attempt to clear freeze with methanol.
If freeze persists, shut in and blow down the line, maintaining a minimal
pressure differential across the freeze.
Depending upon conditions, either allow the line to vent or purge
methanol through the line to clear the partial freeze.
RETURNING LINE TO SERVICE - Return line to service as outlined
previously.
Notify Production Coordinator that freeze is cleared and line is back in service.
RECORDS: Document maintenance of the pipeline on the daily operating report
form.
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3.4
Compressor Stations
CODE REFERENCE: Title 49 CFR Sections 192.167, 192.169, 192.171,
192.729, 192.733, and 192.735
PURPOSE: To establish minimum requirement for the safe operation, inspection
and maintenance of compressor stations.
GENERAL: All Plant Personnel shall follow established detailed procedures.
The Plant Engineering Group will establish the startup and shutdown, ESD, and
isolation procedures. Inspection, Storage, Safety and reporting are established by
the Governing agencies. As a group the plant personnel creates a TIP sheet and
review as operations change. Each gas compressor unit will include:
Start-up/Shutdown
Inspection and Testing Relief Devices
Storage of Combustible Materials
Emergency Shutdown Systems
Safety Equipment
Isolation of Equipment for Maintenance
Report Requirements
STARTUP/SHUTDOWN PROCEDURES - The startup/shutdown procedures
shall give sufficient detail to assure that field operations personnel can clearly
understand the proper sequence necessary for the safe startup and loading of each
type of gas compressor unit.
Particular attention should be given to purging the air from the gas cylinders and
piping. This is extremely important as any air left in a compressor cylinder can
cause an explosion upon compression.
In addition, detailed procedures shall provide for the necessary steps to assure
shutdown of the unit in a safe manner and the proper method of blowing down
any gas within the compressor unit piping.
They shall differentiate whether the unit starts while still pressured up or after it
has been blown down completely.
The procedures shall provide for the proper valve sequencing required to start or
shutdown the unit. In addition, instructions concerning checking or bypassing
shutdowns on the Tattletale panel shall be clearly indicated to assure proper
startup/shutdown in accordance with the operator's manual.
The compressor manufacture's manual shall be reviewed by the Production
Coordinator to assure all procedures are in accordance with approved methods
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outlined by the manufacture and not harmful to the continued operation of the
unit.
The Production Coordinator and Lead Operator is responsible for assuring that
each person assigned the task of compressor operation has been given sufficient
instructions for operation and is familiar with the proper startup/shutdown method
for the respective type of units within the station.
INSPECTING AND TESTING OF RELIEF DEVICES (TITLE: CFR 49
SECTION 192.169)
GENERAL: Each compressor station must have pressure relief valves or other
suitable protective devices of sufficient capacity and sensitivity to ensure that the
maximum allowable operating pressure of the station piping and equipment is not
exceeded by more than 10 percent in the event of an equipment failure or
malfunction.
Each vent line that exhausts gas from the pressure relief valve of a compressor
station must extend to a location where the gas may be discharged without hazard.
Plant Operations shall maintain written records to ensure the periodic inspection
of compressor station relief valves has been properly performed and that
operating conditions have not changed the required relieving capacity.
The periodic inspection of relief devices shall be in accordance with the procedure
outlined in Section 3.10 Pressure Regulators and Relief Devices.
All incidents of over pressure shall be brought to the attention of the Production
Coordinator to assure continued safe operation of the system.
All incidents where an accidental ignition of gas vapors occur within a
compressor station limits shall be reported to the Production Coordinator.
The maintenance personnel shall contact the Production Coordinator whenever a
compressor unit is taken out of service for maintenance or repairs.
STORAGE OF COMBUSTIBLE MATERIALS (TITLE: CFR 49 SECTION
192.735)
GENERAL: Flammable or combustible materials in quantities beyond those
required for everyday use, or other than those normally used in the compressor
building, must be stored a safe distance from the compressor building.
Aboveground storage tanks must be protected in accordance with National Fire
Protection Association Standard No. 30.
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The Production Coordinator shall ensure periodic inspections of the compressor
locations are performed and notify Operations personnel concerning any
flammable material storage problems.
EMERGENCY SHUTDOWN SYSTEM (TITLE CFR 49 SECTION 192.167)
GENERAL: Each compressor station of more than 1,000 horsepower must have
an emergency shutdown system that complies with the minimum design
requirements provided by the Code of Federal Regulations. These regulations do
not apply to compressor stations that are unattended field stations with less than
1,000 horsepower installed on site, or stations which were constructed before
November 1970.
The emergency shutdown system must meet the following requirements:
It must be able to block pipeline gas out of the station and blow down the
station piping.
It must discharge gas from the blow down piping at a location where the
gas will not create a hazard.
It must provide means for the shutdown of gas compressing equipment,
gas fires, and electrical facilities in the vicinity of gas headers and in the
compressor building, except that:
Electrical circuits that provide emergency lighting required to
assist station personnel in evacuating the compressor building, and
the area in the vicinity of the gas headers, must remain energized;
and
Electrical circuits needed to protect equipment from damage may
remain energized.
It must be operable from at least two locations, each of which is:
Outside the gas area of the station;
Near the exit gates, if the station is fenced, or near emergency exits, if
not fenced; and
Not more than 500 feet from the limits of the station.
Remote control shutdown devices must be inspected and tested at least annually at
intervals not exceeding 15 months. Record this inspection on WGS Form 111
Remote Control Shutdown Device Test.
RESPONSIBILITIES - The Production Coordinator shall review the
maintenance reports of the emergency shutdown devices to assure proper
performance.
A record of the date and person performing the emergency shutdown testing shall
be recorded and a file kept at the Field Office. WGS Form 111 Remote Control
Shutdown Device Test
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Any required maintenance and inoperable shutdown shall be noted and remedial
action taken.
In the event an emergency shutdown system becomes inoperable, the Production
Coordinator shall be notified and necessary actions taken to assure the continued
operation of the station in a safe manner.
Plant Operations shall maintain a log of shutdowns to assure that the system is
functioning properly and causing a minimum of unintended outage.
SAFETY EQUIPMENT (TITLE: CFR 49 SECTION 192.171)
GENERAL: The Production Coordinator shall inspect the operation of his
compressor facilities to ensure their proper operation in accordance with the
following general requirements:
Each compressor station must have adequate fire protection facilities. If
fire pumps are a part of these facilities, their operation must not be
affected by activation of the emergency shutdown system.
Each compressor station prime mover, other than an electrical induction or
synchronous motor, must have an automatic device to shut down the unit
before the speed (RPM) of either the prime mover or the driven unit
exceeds a maximum safe speed.
Each compressor station engine that operates with pressure gas injection
must be equipped so that stoppage of the engine automatically shuts off
the fuel and vents the engine distribution manifold.
Each muffler for a gas engine in a compressor station must have vent slots
or holes in the baffles of each compartment to prevent gas from being
trapped in the muffler.
Each compressor control panel shall be inspected in accordance with
manufacturers guideline to assure proper operation of all shutdown
devices and their indicators. Any shutdowns found inoperable shall be
noted on the daily compressor report each day the shutdowns are
inoperable. The Production Coordinator shall give approval to bypass a
panel shutdown on a continuous basis.
Each compressor station building shall be properly ventilated to ensure
employees are not endangered by the accumulation of gas in rooms or
other enclosed places.
All gas detection devices within the compressor building shall be checked
for proper performance. WGS Form 123 Gas Detection and Alarm
System Test and Evaluation.
Any continuous bypass of alarm devices shall be brought to the attention
of the Production Coordinator. WGS Form 123 Gas Detection and
Alarm System Test and Evaluation.
The continuous safe operation of a compressor station requires that
sufficient maintenance functions be performed on pressure gauges,
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temperature gauges, coolers, and other performance measurement devices.
These shall be properly maintained to assure their proper operation in case
of emergency.
ISOLATION OF EQUIPMENT FOR MAINTENANCE OR
ALTERATIONS (TITLE: CFR 49 SECTION 192.733)
GENERAL: All personnel shall inspect and ensure a proper method for unit
isolation. During the maintenance or alternation of compressor units this method
of isolation is to be followed. The following will be included in any method:
Each compressor unit shall be installed with suction and discharge block
valves on the lead lines to provide for the isolation of the compressor unit
during maintenance.
The block valves shall be maintained and periodically inspected to ensure
proper operation in accordance with the Section 3.16 of this manual
concerning valve maintenance.
If gas leakage occurs across the isolation block valve seats, then blinds or
skillets shall be installed to assure proper isolation of the unit.
Each isolation valve shall be properly tagged to indicate its intended
position during the maintenance work.
A manual vent valve shall be provided within the unit piping to properly
provide for blow down and purging of the compressor unit to a safe
location.
Each compressor unit shall be properly purged of air with sufficient
quantities of gas to ensure no "mixing" will occur and that a hazardous
air/gas mixture does not remain within the compressor cylinder or unit gas
piping.
REPORT REQUIREMENTS
Plant Operations shall maintain reports of operation/maintenance activity for each
compressor station/system and emergency generator.
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3.5
Corrosion Control
ATMOSPHERIC CORROSION
192.491, 192.605, 192.613 and 192.709
PURPOSE: To establish the requirements for inspection and maintenance of
above ground pipeline systems for atmospheric corrosion.
GENERAL: A pipeline system includes all pipeline facilities used in the
transportation of gas, including, but not limited to, line pipe, valves and other
appurtenances connected to line pipe, fabricated assemblies, and metering
stations.
Pipeline systems or portions thereof, subject to atmospheric corrosion or moisture
penetration and retention, shall be inspected to assure detection of corrosion
before detrimental damage, Category 3 Corrosion (heavy, obvious pitting in
excess of 10% of new nominal wall thickness) is sustained.
The facilities operating history, future anticipated operating conditions, evidence
of possible corrosion found during routine observations, and actual inspection
results shall be considered when establishing inspection frequencies.
Inspection programs for atmospheric corrosion shall include, but not be limited to,
areas such as:
Under hold-down straps,
Between pipe and pipe supports,
Platform risers and riser clamps,
Pipe penetrations of building walls, and
Thermally insulated meter piping.
Periodically, not exceeding 3 years between inspections, check the condition of
Wear pads,
Supports or sleeves on a sample basis to confirm continued protection of
the pipe, especially in areas conductive to corrosion.
Such areas would typically be those where moisture is present on the pipe due to a
reason other than normal precipitation. The results of inspections, geographic
location, and pipe environment will be used to determine an appropriate
continuing inspection level.
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Corrosion, leaks, and defects may be Safety Related Conditions. Refer to Section
2.17 Safety Related Conditions Reporting procedure.
PROCEDURE: Inspect all bare aboveground piping at intervals not exceeding
three (3) years.
The primary method of inspection is visual. Further non-destructive testing
(NDT) techniques (such as ultrasonic thickness measurements, pit depth gauge
readings, radiography, etc.) may be implemented if visual evidence of corrosion
damage or other conditions warrant.
Maintain a continuing program of painting based upon results of the external
inspection program.
Inspect the transition zone of pipe entering the ground to confirm it is properly
coated whereby penetration of moisture between the pipe and coating is
prevented. Whenever a condition is observed where moisture may be retained
between the coating and pipe, remove the coating, inspect the pipe, evaluate
severity of corrosion if present, take remedial actions if necessary, and recoat the
pipe prior to the next inspection.
For thermally insulated systems, visual inspection of the external jacket to ensure
its integrity against moisture intrusion under the jacket is usually sufficient; if the
integrity of the external jacket has been breached and liquid water may be present
against the carrier pipe surface, additional inspection techniques may be required
to detect possible corrosion.
Areas where liquid water may accumulate or be trapped against the outside of the
pipeline (including, but not limited to, under pipe hold-down straps or at pie
supports) may require special attention. Caulks, mastics or other sealants should
be used to prevent water accumulation at these sites.
Repairs and preventive maintenance actions necessitated by these inspections
shall be completed prior to the next inspection.
In cases where pipe wall loss exceeds 10% of the nominal new pipe wall
thickness, an Engineer shall review the pipeline MAOP for possible revision
and/or recommend pipeline repair requirements.
References for determining the remaining strength of a pipeline are:
ASME/ANSI B31G (latest edition), Manual for Determining the Remaining
Strength of Corroded Pipelines.
AGA Pipeline Research Committee, Project PR-3-805, A Modified Criterion for
Evaluating the Remaining Strength of Corroded Pipe, (latest edition).
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RECORDS: Complete WGS Form 112 Corrosion Control Report to
document the external corrosion on aboveground facilities.
Complete WGS Form 103 Pipeline Inspection Report whenever external
corrosion is identified and a repair or a preventative maintenance action, other
than painting, is required.
Maintain the above records for at least five years.
INTERNAL CORROSION
192.491, 192.605 and 192.613
PURPOSE: To establish the requirements for the detection, monitoring, and
control of internal corrosion, and required corrective actions for pipeline facilities.
GENERAL: This procedure is required if liquids or corrosive gas are ever
allowed to flow through or remain in the pipeline.
A pipeline system includes all pipeline facilities used in the transportation of gas,
including, but not limited to, gathering lines, line pipe, valves and other
appurtenances connected to line pipe, fabricated assemblies, and metering
stations.
Corrosive gas shall not be transported unless the corrosive effect of the gas has
been investigated and measures have been taken to eliminate or minimize internal
corrosion.
Potential corrosive gas shall not be transported without monitoring equipment that
will detect the presence of internal corrosion. Where corrosive gas is being
transported, coupons or other suitable means shall be used to determine the
effectiveness of the steps taken to minimize internal corrosion.
If repair, replacement or operating pressure reduction is necessary, review Section
2.17, Safety Related Conditions Reporting, to see if a reportable safety related
condition exists.
CORROSIVE CONDITIONS: Gas containing water in liquid phase and at least
one of the following components is considered to be potentially corrosive. A
combination of two or more components is considered to be potentially corrosive.
A combination of two or more components with water in liquid phase may be
potentially corrosive at lower concentrations of each component. Gas having a
water vapor below the point of saturation may contain concentrations of H2S and
CO2 and O2 greater than those listed below and remain non-corrosive.
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Hydrogen sulfide (H2S) concentration greater than .05 psia partial pressure
for systems operating at or above 65 psia total pressure. For system
pressure less than 65 psia total pressure, H2S content of 50 ppm or greater
is considered corrosive.
Gas containing more than 0.25 gram of H2S per 100 SCF (4ppm) may not
be stored in pipe-type or bottle-type containers.
Carbon dioxide (CO2) concentration greater than 3 psia partial pressure
regardless of total pressure.
Oxygen (O2) concentration greater than 50 ppm or greater than 20 ppb
where dissolved in a liquid phase.
Review the gas source dew point history. Water dew points within 10 F
of the minimum ambient temperature to which the pipeline is exposed
may indicate the presence of liquid water in the pipeline.
Corrosion will be more severe if any of the following conditions are
present in conjunction with the conditions listed above.
Produced liquids containing sulfate-reducing (SRB) or acid-producing
microbiological colonies with culture test indicating over ten (10) colonies
per milliliter should be considered to be potentially corrosive.
Liquids or materials having a pH less than 5.5.
PROCEDURE:
INTERNAL INSPECTIONS
Whenever any pipe section is opened or removed from a pipeline system, that
pipe section and any adjacent pipe sections shall be inspected visually to
determine evidence and/or extent of internal corrosion. If internal corrosion is
noted visually, other Non-Destructive Testing (NDT) techniques such as
ultrasonic thickness measurements, pit depth gauge readings, radiography, etc.
shall be used to quantify the extent of the corrosion.
Vessels and other fabrications shall be visually internally inspected when the
opportunity to do so exists in conjunction with other maintenance activities or at
intervals dictated by code requirements.
When internal corrosion or metal loss is observed in piping not previously
monitored, remedial action and monitoring shall be initiated prior to the next
inspection.
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A sample of any foreign material recovered from inside the pipeline system shall
be submitted for analysis and any necessary remedial action indicated by the
analysis must be taken prior to the next inspection.
Electromagnetic flux leakage or ultrasonic smart pigs may be run in a pipeline
at intervals of two to five years, or as required, to supplement other inspection
techniques.
GAS ANALYSIS AND EVALUATION - Gas samples shall be taken at
applicable locations and tested for the presence and concentration of corrosive
components if there is a reasonable possibility that corrosive gas could occur in a
pipeline system. Testing shall be done at least twice each year with intervals not
exceeding 7-1/2 months.
Dew point (water content) analysis shall be performed on gas sources once each
month not to exceed 6 months between inspections. Where potentially corrosive
gas is found as a result of gas testing, initiate the remedial action prior to the next
test.
INSTALLATION AND MONITORING DEVICES - Identify checkpoint
locations at places most susceptible to internal corrosion such as low elevation
points, dead ends and drips.
Select and install monitoring devices such as weight loss coupons or electrical
probes, either resistance or polarization, giving consideration to size of pipe, type
of system, operating conditions, simplicity of installation and ease of gathering
information. Install liquid sampling facilities if applicable.
Prepare and maintain a schematic diagram showing physical and operating
characteristics of the pipeline system, the location of checkpoints and the type of
monitoring devices used.
Monitoring and Detection:
Monitor checkpoint and record the results at least twice each calendar year
with intervals not exceeding 7-1/2 months. Monitor more frequently if the
level of the corrosive component increases or the effectiveness of the anticorrosion measures needs to be confirmed.
If liquids are present, collect and analyze liquid samples semiannually
from the gas stream.
Remedial Action:
Make a study of the pipeline systems to determine the scope of the
possible internal corrosion if it is determined by inspection or analysis that
internal corrosion is occurring, or has occurred.
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AMSE/ANSI (latest edition) Manual for Determining the Remaining
Strength of Corroded Pipelines.
AGA Pipeline Research Committee, Project PR-3-805, A Modified
Criterion for Evaluating the Remaining Strength of Corroded Pipe, (latest
edition).
Apply at least one of the following mitigation measures prior to the next
inspection if inspection reveals internal corrosion to be occurring, or if previously
installed monitoring equipment shows corrosion to be occurring:
Eliminate free water in the pipeline by implementing an adequate pigging
program, or by other appropriate methods.
Remove corrosive components.
Inject corrosion inhibitors.
REPAIR - If internal corrosion has or may have reduced the wall thickness of a
segment of pipe to less than that required for the maximum allowable operating
pressure, pipe repair or replacement should be planned or the working pressure
reduced prior to the next inspection.
CONVERSION EQUATIONS
Partial pressure (psia) = PPM x Line Pressure (psia)/1,000,000
Partial pressure (psia) = Mole % x Line Pressure (psia)/100
ppm = parts per million
1/1,000,000
ppb = parts per billion
1/1,000,000,000
RECORDS: Complete the WGS Form 103 Pipeline Inspection Report and/or
WGS Form 112 Corrosion Control Report forms whenever pipeline is checked
internally, repaired, or replaced.
Retain all studies, reports, checks of monitoring devices and other data that may
be accumulated, at the local field office for the pipeline. Inspection reports are to
be retained for at least five years while smart pigging results are kept for the life
of the facility.
Maintain gas water dew point historical log for gas sources where dew points or
gas analysis are being performed for at least five years.
EXTERNAL PROTECTIVE COATING
192.461, 192.463, 192.483, 192.491, and 192.613.
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PURPOSE: To outline the practice for the installation of external protective
coating for all buried or submerged gas pipelines.
GENERAL: Buried or submerged natural gas pipelines installed after July 31,
1971 must have an external protective coating system unless:
It can be demonstrated by tests, investigation, or experience in the area of
application that a corrosive environment does not exist. This includes at a
minimum, soil resistivity measurements and tests for corrosion
accelerating bacteria. Within 6 months after installation, the line must be
further tested per 192.455(b) to evaluate the potential profile along the
entire pipeline. If these tests indicate that a corrosive condition exists, the
pipeline must be cathodically protected.
The pipeline is a temporary installation with an operating period of service
not to exceed 5 years beyond installation and any anticipated corrosion
will not be detrimental to public safety.
If any pipeline is externally coated (notwithstanding the criteria above), it must be
cathodically protected along the entire area that is effectively coated. A pipeline
does not have an effective external coating if its cathodic protection current
requirements are substantially the same as if it were bare.
When choosing the material to use for repairing a coating, every effort should be
made to choose the original material or to come as close to it as possible with
compatible coating material.
In all cases of coating repair, whether during construction or after the pipeline is
in service, the pipeline surface to be coated should be cleaned as well as possible
of all dirt, grease, weld splatter or other foreign material. Instructions for the
coating application prepared by the manufacturer should be followed.
COATING PROCEDURE
The purpose of external protective coating is to isolate the pipeline from its
environment and provide primary corrosion protection. Additionally, external
protective coatings facilitate the application of cathodic protection.
The external protective coating applied for corrosion control must have the
following characteristics and properties:
The coating must be applied on a properly prepared surface as
recommended by the coating system manufacturer.
The coating must have sufficient adhesion to the metal surface to
effectively resist underfilm migrations of moisture.
The coating must be sufficiently ductile to resist cracking.
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The coating must have sufficient strength to resist damage due to the
handling and in-service soil stress.
The coating must have properties compatible with the applications of
cathodic protection to the pipeline.
The coating must have low moisture absorption and high electrical
resistance.
Each external protective coating must be inspected by electrical test
methods just prior to lowering the pipe into the ditch and backfilling, and
any damage detrimental to effective corrosion control must be repaired.
Each external protective coating must be protected from damage, which
could result from adverse ditch conditions or from supporting blocks.
If coated pipe is installed by boring, driving, or other similar method,
precaution must be taken to minimize damage to the external coating
during installation.
Coated pipe sections connected by welding and/or mechanical coupling including
valves or other underground or submerged appurtenances will be considered field
joints. External coating of field joints must be equal to or better than the coating
of the pipeline.
Existing Coated Pipelines
Apply an external protective coating to:
Poorly coated or bare portions of pipeline segments that have been
exposed for repair of inspection.
Pipeline segments that replace existing pipe.
Inspect and repair all coating on replacement segments and coating repairs for
defects caused by installation activity.
Existing coating may require repair or upgrading in areas where criteria for
achieving cathodic protection is not being met.
New Pipelines
Apply an external protective coating to all new buried pipelines.
Inspect all coating on new pipeline segments and repair defects caused by
installation.
Surface Preparation
In removing coating to make tie-ins, care must be taken to avoid disbanding of the
adjacent coating. Edges of thick film coating must be tapered and enough of the
wrapper removed to ensure adhesion of the new coating to the existing coating.
The surface to be coated must be thoroughly cleaned with solvents to remove oil
and grease. All dust, dirt, rust, mill scale, loose shop coating, dead primer,
welding slag, and burrs must be removed with wire brushes or scrapers.
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Nicking the coating to bare the pipe surface must not be permitted.
Repair of Coating Defects
Inspection shall follow all coating applications. Any defects shall be repaired.
A sufficient portion of the coating must be carefully removed from defective areas
of pipe to ensure that the remaining coating is satisfactory and well bonded.
Edges of the area should be tapered to increase the strength of the patch.
Foreign matter must be removed from the area to be repaired.
Primer applied to the area, if required, must be allowed to dry properly before the
coating is applied.
The coating material used for patching must be such that proper adhesion will
occur between the existing coating material and the patching material.
RECORDS: Submit appropriate as-built information to the field office for
updating drawings and records.
Retain these records for as long as the pipeline is in service.
INTERNAL AND EXTERNAL EXAMINATION OF BURIED PIPELINES

192.491, 192.605, 192.613
PURPOSE: To establish a standard program of examination of buried pipelines
for evidence of internal or external corrosion.
GENERAL: A continuing program of examination and recording of the results
of the inspection of buried pipelines is mandatory for both internal and external
corrosion.
It is intended that examinations will monitor pipelines for the effectiveness of
both internal and external protective measures.
Corrosion, leaks, and defects shall be evaluated to determine if they are safetyrelated conditions.
PROCEDURE: Whenever buried piping is exposed for any reason, the exposed
portion of the coating must be visually examined to determine external coating
condition. Complete WGS Form 104 Pipeline Exposure and Inspection
Report.
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If a line is bare or the coating has deteriorated, or the coating is removed on a
well-coated line, inspect the pipe for external corrosion.
If corrosion is observed on a coated line, a condition may exist, warranting further
investigation (disbanded coating, unique soil environment, etc.).
Whenever any pipe section is opened or removed from a pipeline system that pipe
section and any adjacent pipe sections shall be inspected visually to determine
evidence and/or extent of internal corrosion. If internal corrosion is noted
visually, other NDT techniques shall be used to quantify the extent of the
corrosion.
Visually inspect the full circumference of piping if one or more of the following
conditions exist.
Continuing corrosion is observed
CP test, current requirements or surveys indicate corrosion may be
occurring
Previously unidentified coating deterioration is observed or suspected
Corrosion is observed on the piping, which is of a magnitude not
previously documented or which may require repair. If repair is required,
continue inspection longitudinally until pipe condition is satisfactory.
If visual examination indicates corrosion has occurred, initiate one or more of the
following actions:
Calculate the acceptable minimum wall thickness limit after corrosion. If wall
thickness is less than the calculated minimum, initiate a repair method as outlined
in Section 3.15 Repair Procedures or reduce the pipeline MAOP.
AMSE/ANSI (latest edition) Manual for Determining the Remaining
Strength of Corroded Pipelines
edition).
If repair is required, limit the operating pressure accordingly, until the repair is
made.
Apply coating and/or additional cathodic protection, as necessary, where active
external corrosion is present.
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If internal corrosion is noted, apply or confirm compliance with the requirements
of Internal Corrosion Procedure above.
Determine if a safety related condition exists.
RECORDS: Complete WGS Form103 Pipeline Inspection Report and/or
WGS Form 109 Pipeline Leak Repair Report. WGS Form 104 Pipeline
Exposure and Inspection Report.
Keep the records for the life of the pipeline.
CATHODIC PROTECTION/EXTERNAL CORROSION CONTROL
CODE REFERENCE: Title 49 CFR Sections 192.455, 192.457(a), 192.463,
192.465, 192.469, 192.471, 192.473, 192.491, and 192.613
PURPOSE: To prescribe the minimum installation, maintenance, survey and test
requirements to monitor and control external corrosion on buried or submerged
steel pipelines.
GENERAL: Buried or submerged gas pipelines installed after July 31, 1971
must have a cathodic protection system to protect the pipeline, installed and
placed in operation within one year after completion of pipeline construction
unless:
It can be demonstrated by tests, investigation, or experience in the area of
application that a corrosive environment does not exist. This includes at a
minimum, soil resistivity measurements, and tests for corrosion
accelerating bacteria. Within 6 months after installation, the line must be
further tested per 192.455(b) to evaluate the potential profile along the
entire pipeline. If these tests indicate that a corrosive condition exists, the
pipeline must be cathodically protected.
The pipeline is a temporary installation with an operating period of service
not to exceed 5 years beyond installation and any anticipated corrosion
will not be detrimental to public safety.
If any pipeline is externally coated (notwithstanding the above criteria), it must be
cathodically protected along the entire area that is effectively coated. A pipeline
does not have an effective external coating if its cathodic protection current
requirements are substantially the same as if it were bare.
Buried or submerged gas pipelines installed before August 1, 1971 must have a
cathodic protection system when active corrosion is found for the following:
Bare or ineffectively coated pipelines.
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Bare or coated pipes at compressor or regulator stations.
Active corrosion means continuing corrosion, which unless controlled, could
result in a condition that is detrimental to public safety.
The amount of cathodic protection must be controlled so as not do damage to the
protective coating or the pipe.
Cathodic protection test stations or contact points shall normally be located at
pipeline mile markers, cased crossings, and other convenient locations.
Recommended test station spacing should generally not exceed 1 mile.
For new construction after January 1, 1992, cathodic protection test leads shall be
anchored by wrapping around the pipe or providing a separate anchor to avoid
straining the pipe to wire cad-weld.
Pipelines receiving cathodic protection from a single CP source of current must be
electrically continuous with itself and the source of current. Additionally, the
structure to be protected must be electrically isolated from structures, which are
not intended to be protected.
Each impressed current type or galvanic anode CP system must be designed and
installed so as to minimize any adverse effects on existing adjacent underground
or submerged metallic structures.
Interference effects from impressed current CP systems on foreign structures shall
be minimized. Mitigation of interference effects may employ one or more of the
following techniques:
Installation of sacrificial anodes on the affected structure;
Bonding the affected structure to the offending CP system;
Coating the affected structure;
Providing sacrificial anodes connected to each pipeline and buried
immediately adjacent to each other in the same backfill.
PROCEDURE: The CP system provides a level of protection that complies with
one or more of the criteria listed below.
D.O.T. acceptable criteria to assure adequate cathodic protection for steel
pipelines are:
A negative polarized (current switched off) potential of at least 0.85 volt
relative to a saturated copper-copper sulfate reference electrode.
A minimum of 100 mV of cathodic polarization. The formation of decay
of polarization can be used to satisfy criterion.
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A negative (cathodic) potential of a least 850 mV with the cathodic
protection applied. This potential is measure with respect to a saturated
Cu/CuSo4 reference electrode containing the electrolyte. Voltage drops
other than those across the structure to electrolyte boundary must be
considered for valid interpretation of this voltage measurement (see
NACE RP0169-2002) without current interruption.
Special Conditions
For pipelines installed before August 1, 1971 which are bare or poorly
coated externally, the measurement of a net protective current from the
electrolyte to the pipe surface (as measured by the earth current technique)
at predetermined discharge points may be sufficient proof of adequate
cathodic protection.
In some situations, such as the presence of sulfides, bacteria, elevated
temperature, acid environments and dissimilar metals, the criteria in the
D.O.T. acceptable criteria section above may not be sufficient protection.
At pipeline locations where external corrosion-related leaks are discovered, a
measurement of the pipe-to-soil cathodic potential shall be taken. If the level is
less than that required by regulations, the Engineer shall reevaluate the CP system
capacity and upgrade it as necessary prior to the next inspection.
Test and survey of CP systems according to the frequency schedule listed in Table
3.5A.
Prompt remedial action, at least prior to the next required survey, must be taken to
correct condition which caused the pipeline to fail to meet the applicable criterion.
RECORDS: Record the location of cathodically protected pipeline, cathodic
protection facilities, and neighboring structures bonded to cathodic protection
system on WGS Form 113 Cathodic Protection System Record. (See pipeline
drawings.)
The pipe-to-soil surveys are to be recorded or plotted on the form or charts
provided for that purpose. The annual pipe-to-soil surveys, reports, and any
remedial action, are to be retained for the life of the facility.
Except for annual pipe-to-soil surveys, these records are to be maintained for at
least five years.
Annual pipe-to-soil surveys and reports, and remedial action reports, if any, shall
be retained for the life of the facility.
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TABLE 3.5A
REQUIRED TESTS FOR CATHODIC PROTECTION
SURVEY OR TEST
Pipe-to-Soil
Critical Bond
Non-critical Bonds
Insulation Test
Rectifier Inspection
Foreign Crossing Interference
Soil Resistivity
Current Requirement
Deep Ground Bed Data
Deep Well Anode Performance
Galvanic Anode Record
Rectifier Efficiency
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FREQUENCY
Once each calendar year, but with
intervals not exceeding 15 months.
Six times each calendar year, but with
intervals not exceeding 2-1/2 months.
Six times each calendar year, but with
intervals not exceeding 2-1/2 months.
SUPPLEMENTAL TESTING
Initially and as required, if survey done
on recurring basis indicated the need.
Initially for magnesium anode or
impressed current ground bed
installations.
Initially and as required to determine
current density, coating condition and
cathodic protection sizing.
Initially to record all ground bed data
during installation.
Initially and as required to record anode
current outputs and look for ground bed
deterioration.
Initially to record all data during
installation.
Initially and as required.
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ELECTRICAL ISOLATION
CODE REFERENCE: Title 49 CFR Sections 192.467 and 192.613
PURPOSE: To outline requirements for electrical isolation of buried or
submerged pipeline facilities.
GENERAL: In order to successfully and efficiently cathodically protect a buried
or submerged pipeline system, it is vital that the system be electrically isolated
from foreign structures.
Electrical isolating devices are installed on pipeline systems to control current
flow to or from foreign structures. Insulating devices are also used to isolate
sections of the same pipeline (which can facilitate the application of cathodic
protection) and to isolate the pipeline from a casing or structural supports attached
to other unprotected metallic structures.
No electrical isolating device shall be installed in a closed area that could retain
an explosive mixture unless provisions are made to prevent electrical arcing. This
includes situations similar to insulating flange kits in vaults.
STANDARD ELECTRICAL ISOLATION METHOD
FLANGE INSULATION An insulating kit consists of an electrically nonconductive gasket, non-conductive sleeves to encase the studs, and nonconductive washers for both nuts of a stud. Steel washers should also be placed
immediately under nuts to protect the insulating washer from being crushed
during torquing.
When welding the insulating flange unit or the weld type insulated coupling into
the line, care shall be exercised to be sure that the current arc, which could
occur from welding, does not damage the insulation. This can be achieved by
moving the ground cable to the same side of the flange set as the electrode cable
thus eliminating current arc across the insulating flange during welding.
MONOBLOCK INSULATING JOINTS Monoblock insulating joints are
factory-assembled insulating assemblies, which are welded into a pipeline; they
have no serviceable parts.
INSULATED UNIONS Insulating unions are usually used for small diameter
(3 inches or less) piping attachments, which required electrical insulation.
CASING CENTRALIZERS AND END SEALS Non-conductive centralizing
devices are attached to pipelines where the carrier pipe passes through a cased
crossing. Casing end seals prevent water or soil from entering the annular space
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between the carrier pipe and casing and causing an electrolytic short between
the casing and the pipe.
OTHER DEVICES Frequently, high pressure laminated (e.g. Micarta)
dielectric blocks or neoprene rubber pads are used to electrically isolate pipeline
from supports or other structural appurtenances, which are not a part of the
cathodically protected pipeline.
CASED CROSSINGS - Whenever possible, casing installations should be
avoided. In some cases, however, railroad or public highway regulations required
the installation of a casing for railway right-of-way or road crossings. When
casing are required, the carrier pipe must be electrically isolated from the casing.
PROCEDURE:
LOCATION AND INSULATING DEVICES Generally, insulating devices
should not be buried in the soil (or submerged), but located in pipe above ground
or in a vault. At the termination of a pipeline, the insulating device should be as
close as possible to the point where the pipeline comes above grade. Laterals,
pressure taps, etc. should have insulating devices located as close as possible to
the cathodically protected pipeline.
Electrical isolation equipment or devices should be installed to isolate structure
from the following locations:
At the termination points of a pipeline system and entering or leaving a
pump or compressor station;
At exchanges or interconnect point with other pipeline companies;
At connection points for gas operated control lines, electrical conduit
attachments or instrumentation connections;
At established above ground Company facilities;
On the downstream side of metering stations;
Between the casing and carrier pipe;
Between supporting structures and the carrier pipe on bridge crossings;
Between all metallic structures not requiring cathodic protection, such as
metal valve boxes, conduit, fences, etc. and a cathodically protected
pipeline;
Where fault currents or lightning can affect the pipeline, such as close to
electrical transmission tower footings or ground cables;
At point where dissimilar metals are attached to the pipeline, provided that
both the pipeline and the dissimilar metal are buried or submerged.
REPAIRS Prompt remedial action (at least prior to the next required test) shall
be taken where the loss of electrical isolation causes a failure to meet the
applicable cathodic protection criterion or causes detrimental effects to a foreign
structure.
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The remedial action should be restoration of electrical isolation; in some
cases, other measures (such as increasing the amount of cathodic
protection current applied to the pipeline) can be taken that will
adequately protect foreign structures.
If the loss of isolation does not require prompt action, the insulating
device should be repaired at the earliest opportunity in conjunction with
other scheduled maintenance or modifications to the piping system.
SHORTED CASING Pipeline, in casing where isolation was intended when
installed, shall be evaluated and acted upon as outlined below:
If casing-to-soil potential is within 100 millivolts of the carrier pipe-to-soil
potential, further testing is required to determine if electrical isolation
exists.
Determine whether the situation is an electrolytic condition or a
metallic shorted casing.
Electrolytic conditions in casings require no remedial action.
Retest the casing when a future survey indicates a significant decrease in
potential separation from the previous test, at a casing where the test
procedures previously indicated an electrolytic condition.
Attempt to clear a shorted casing promptly, within 6 months, after
discovery by implementing the following actions.
Inspect the test wires for possible direct shorts, and repair as
necessary;
If practical, excavate the ends of the casing and inspect the
clearance between the casing and carrier pipe. If contact exists,
reposition the carrier pipe and replace damaged insulators and end
seals;
When a shorted casing cannot be cleared by implementing the
above actions, consider installing new carrier pipe insulators when
the pipeline segment is out of service for other scheduled repair,
replacement, or modification; or consider filling the casing/pipe
annulus with high dielectric casing filler.
Remove shorted casing when convenient.
Electromagnetic flux leakage or ultrasonic smart pigs may confirm
pipe wall metal loss.
Casings that are determined to be shorted and impractical to promptly
correct, shall be monitored by using leak detection instruments as shown
in Table 3.5B. If a leak is found, it must be repaired immediately.
INSPECTION AND TESTING - Inspection and testing frequency requirements
for the electrical isolations and shorted casing are shown in Table 3.5B.
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TABLE 3.5B
TEST FREQUENCIES FOR ELECTRICAL ISOLATION AND SHORTED
CASINGS
TEST:
FREQUENCY:
Electrical Isolation
Once each calendar year at intervals not
exceeding fifteen (15) months.
Shorted Casings:
Class 1,2,3&4 locations
Twice each calendar year at intervals
not exceeding 7-1/2 months. (Flame
Ionization Inspection)
RECORDS: Document all electrical isolation and casing gas leak testing. Keep
these documents for at least five years.
Record the test on possible shorted casing. Retain the record for each shorted
casing until is it removed.
IMPRESSED CURRENT POWER SOURCE INSPECTION
CODE REFERENCE: Title 49 CFR, Sections 192.465, 192.491, and 192.613
PURPOSE: To establish the requirements for inspecting and checking impressed
current cathodic protection systems.
GENERAL: Rectifiers and ground beds provide a driving voltage and current
greater than can be produced by galvanic anodes. Compared to sacrificial anodes,
this type of protection covers a much larger area and gives greater flexibility to
the cathodic protection system by allowing control of the current output.
The rectifier ground bed method develops an electrolytic cell making the structure
to be protected the cathode, and the ground bed of the rectifier, the anode.
(Reversing the polarity will cause rapid corrosion of the pipeline.)
To gain the greatest benefit from corrosion control, it must be a continuous
process. The rectifier will not give protection if it has not been properly installed.
Therefore, proper installation of any rectifier is of utmost importance and will
serve to prevent trouble later.
PROCEDURE: Inspect each cathodic protection rectifier or other impressed
current power source at least six (6) times each calendar year, but at intervals not
Conduct the following tasks during each inspection:
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Inspect each impressed current power source and its components for
proper operation.
Determine the D.C volts and amperes as applicable.
Take prompt remedial action to correct any deficiencies indicated by the
monitoring. Any necessary remedial action must be taken prior to the next
inspection.
Determine if unusual current and voltage readings are the result of rectifier
malfunction or due to changed pipeline protection requirements.
Notify the Production Coordinator of malfunctioning rectifiers.
Notify the Production Coordinator of indications of changed pipeline
cathodic protection requirements.
RECORDS: Record all survey and test results on WGS Form 114 Rectifier
Readings.
Maintain the records of power source inspections and efficiency calculations for
at least five years.
CATHODIC PROTECTION MAPS AND RECORDS
CODE REFERENCE: Title 49 CFR, Section 192.491
PURPOSE: To establish the methods by which records will be maintained
showing the location and type of cathodic protection for all pipelines operated by
the Company.
PROCEDURE: Maintain drawings, plat sheets, maps, or other records for each
pipeline showing the location of cathodically protected piping, cathodic protection
facilities, and neighboring structures bonded to the system.
Show the location of the protection type, such as:
Sacrificial Anode Bed
Impressed Current Rectifier
Bonded Impressed Current
Show the location of the protective equipment, such as:
Rectifier
Insulation Flange
Insulating Joint
Bonds (critical, non-critical, and interference)
Ground bed - conventional (surface)
Ground bed well type (vertical)
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CP test stations (ETS and monitors)
RECORDS: Maintain the maps and records for the life of the facility, structure,
or the pipeline.
EVALUATION OF BARE, BURIED OR SUBMERGED UNPROTECTED

PIPELINES
CODE REFERENCE: Title 49 CFR 192.455, 192.457(b), 192.465(e), 192.491,
and 192.613
PURPOSE: To establish the inspection practices for bare unprotected pipelines.
GENERAL: A continuing program of examination and recording the results of
the inspection of bare, unprotected pipelines is mandatory for evaluating the
effects of external corrosion.
It is intended that examinations will monitor the effects of external corrosion and,
where necessary, to protect the integrity of the pipeline, dictate the installation of
cathodic protection equipment.
Corrosion, leaks, and defects may be safety related conditions.
PROCEDURE: After the initial evaluation, bare, belowground unprotected
pipelines shall be visually inspected where naturally accessible at intervals not
exceeding 3 years to determine if areas of possible active corrosion exist.
Areas of possible active corrosion shall be evaluated by electrical survey or by a
review of the leak history and leak surveys of the corrosively active areas.
Areas confirmed to be corrosively active shall be cathodically protected.
The pipeline MAOP shall be evaluated and revised if necessary or the appropriate
pipeline repairs performed.
Reference for determining the remaining strength of a pipeline are:
ASME/ANSI B31G (latest edition), Manual for Determining the
Remaining Strength of Corroded Pipelines.
edition).
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Review the pipeline per the criteria shown on WGS Form 112 Corrosion
Control Report. Areas with Category 3 corrosion shall be cleaned, coated,
and/or cathodically protected.
RECORDS: Complete the WGS Form 112 Corrosion Control Report.
Complete forms from related procedures wherever active corrosion is identified.
Retain records for the life of the pipeline.
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3.6
Leakage Surveys: Repairing and Reporting Leaks
CODE REFERENCE: Title 49 CFR Sections 192.706 and 192.709

PURPOSE: To establish the requirements and frequency for safe and efficient pipeline
operations through a program of leak detection and repair.
GENERAL: A gas leak detection survey is a survey with instrumentation conducted
with leak detector equipment (hydrogen flame ionization (HFI) gas detection instrument)
such as Heath Detecto Pack, Gastec, Century, or equivalent.
A leakage survey is any survey of the pipeline right of way without instrumentation to
identify leaks without use of gas leak detection devices. This type of survey could be a
ground patrol or aerial patrol.
A gas leak detection survey on casings that are determined to be shorted and impractical
to promptly correct is required two times per calendar year, not exceeding 7-1/2 months.
PROCEDURE: Conduct gas leak detection surveys on gas pipelines in accordance with
the schedule shown on Table 3.6A. Increased frequency should be scheduled if leak
history warrants. On odorized pipelines, the gas leak detection survey is not required.
Perform gas leak detection surveys during low-velocity wind and no-frost conditions to
insure valid surveys.
Check for gas specifically at the casing vents or above each casing end if there are not
vents whenever performing gas leak detection surveys at casings on cathodically
protected pipelines.
Conduct gas leak detection surveys across the entire right of way at uncased road
crossings of cathodically protected pipelines.
Use gas leak detection equipment at all joints and cracks in the surface between the
pipeline and the building whenever a pipeline is under a hard surface that adjoins a
building.
During pipeline patrols when the HFI instrument is not being used, personnel should be
alert to possible leak indications, such as dying or dead vegetation in the growing season;
unexplained bubbles in bodies of water near the pipeline; odor; etc.
HAZARDOUS LEAKS - A hazardous leak is a leak that represents an existing or
probable hazard to persons or property, and requires immediate repair or continuous
intermediate action until the situation is no longer considered hazardous. Any hazardous
leak discovered shall be repaired at the earliest practical time following detection. Refer
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Section 3.6 Leakage Surveys: Repairing and Reporting Leaks
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Gas Pipeline
to Table 3.6B for leak classification and action criteria. Examples of what constitutes a
hazardous leak are as follows:
Any leak which, in the judgment of Company personnel at the scene that is
regarded as an immediate hazard to people or property,
Escaping gas that has ignited,
Any indication that gas has migrated into or under a building or any other
confined space,
Any leak that can be seen, heard, or felt and is in a location that may endanger
people or property.
RESPONSIBILITIES - The Production Coordinator shall have the responsibility to
initiate a maintenance order for repair of all reported non-hazardous leaks without delay
in order to minimize system gas loss.
FREQUENCY - Leakage surveys of all Company pipelines must be performed at least
once each calendar year at intervals not exceeding 15 months. However, in Class 3 and 4
locations, more frequent leakage surveys are required, as follows:
TABLE 3.6A
GAS LEAK DETECTION SURVEY FREQUENCY
Pipeline:
Survey Frequency:
Short Casing in Class 1 and 2 locations
Twice each calendar year at intervals not
Class 3 Location including shorted casings Twice each calendar year, at intervals not
All Facilities:
Class 4 locations including shorted casings
All Facilities
Four times a year, not exceeding 4-1/2

months
Plant Piping
Each calendar year not to exceed 15
months.
Note: Plant means regulated piping within a facility such as compressor station,
dehydration plant, or gas treating plant that is manned or is considered operationally
significant.
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A leak that is recognized
Leaks should be repaired or cleared within one
The prompt action in some instances may

require one or more of the following:
Implementation of company emergency plan
(192.615).
Evacuating premises
Blocking an area
Rerouting traffic
Eliminating sources of ignition
Venting the area
Stopping the flow of gas by closing valves or
other means
Notifying police and fire departments
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GRADE DEFINITION
1
A leak that represents an
existing or probable
hazard to persons or
property, and requires
immediate repair or
continuous action until the
conditions are no longer
hazardous.
Escaping gas that has ignited.
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3. Any indication of gas, which has

migrated into or under a building, or
into a tunnel.
4. Any reading at the outside wall of a
building, or where gas would likely
migrate to an outside wall of a
building.
5. Any reading of 80% LEL, or greater,
in a confined space.
6. Any reading of 80% LEL, or greater,
in small substructures (other than gas
associated substructures) from which
gas would likely migrate to the
outside wall of a building.
7. Any leak that can be seen, heard, or
felt and which is in a location that
may endanger the general public or
property.
1. Leaks requiring action ahead of
2.
TABLE 3.6 B
LEAK CLASSIFICATION AND ACTION
ACTION CRITERIA
EXAMPLES
Requires prompt action* to protect life and
1. Any leak which, in the judgment of
property, and continuous action until the
operating personnel at the scene, is
conditions are no longer hazardous.
regarded as an immediate hazard.

Gas Pipeline
calendar year, but no later than 15 months from

the date the leak was reported. In determining
the repair priority, criteria such as the following
should be considered:
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as being non-hazardous at
the time of detection, but
justifies scheduled repair
based on probable future
hazard.

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ground freezing or other adverse

changes in venting condition:
a. Any leak which, under frozen or
other adverse soil conditions,
would likely migrate to the
outside wall of a building.
2. Leaks Requiring action within 6
months
a.Any reading of 40% LEL, or
greater, under a sidewalk in a wallto-wall paved area that does not
qualify as Grade 1 leaks.
b.Any reading of 100% LEL, or
greater, under a street in a wall-towall paved area that has significant
gas migration and does not quality
as a Grade 1 leak.
c.Any reading less than 80% LEL in
small substructures (other than gas
associated substructures) from
which gas would likely migrate
creating a probable future hazard.
d. Any reading between 20% LEL
and 80% LEL in a confined space.
e.Any reading on a pipeline operating
at 30% SMYS, or greater, in a Class
3 or 4 locations, which does not
qualify as a Grade 1 leak.
f. Any reading of 80% LEL, or
greater, in gas associated
A leak that is nonhazardous at the time of

detection and can be
reasonably expected to
remain non-hazardous.
These leaks should be re-evaluated during the

next schedule survey, or within 15 months or
the date reported, whichever occurs first, until
the leak is regarded or no longer results in a
reading.
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substructures.
g. Any leak which, in the judgment of
operating personnel at the scene, is
sufficient magnitude to justify
scheduled repair.
Leaks Requiring Re-evaluation at periodic
intervals:
1. Any reading of less than 80% LEL in
small gas associated substructures.
2. Any reading under a street in areas
without wall-to-wall paving where it
is unlikely the gas could migrate to
the outside wall of a building.
3. Any reading of less than 20% LEL in
confined space.

Gas Pipeline

Gas Pipeline
RECORDS: Document all leakage surveys on WGS Form 115 Leak Investigation
Report. Include beginning and ending milepost or station numbers for each partial
segment of the pipeline requiring a survey.
Identify by unique number all indicated leak locations for making corrective action. Any
necessary corrective action must be taken prior to the next survey.
If a pipeline is exposed by excavation, fill out the information requested on the WGS
Form 104 Pipeline Exposure and Inspection Report.
Maintain the records for at least five years.
All repaired gas leaks are to be reported on WGS Form 109 Pipeline Leak Repair
Report.
All completed reports regarding gas leakage surveys and gas leak repairs are to be
reviewed by the Production Coordinator for inclusion in the D.O.T. files.
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3.7
Line Markers and Signs for Transmission and Gathering Lines

PURPOSE: To identify the location of Company pipelines, through the use of pipeline
markers, in order to reduce the possibility of damage or interference.
GENERAL: Plant Operations is responsible for the maintenance of all pipeline markers
and signs.
Markers, which are severely damaged, bent out of shape, or illegible, shall be scheduled
for replacement and replaced as soon as possible.
MARKER PLACEMENTS - Pipeline markers are to be installed over all Company
pipelines at each crossing of a public road, railroad, and water crossing. Additionally,
markers should be utilized when a pipeline crosses or lies in close proximity to an area
where, in the Production Coordinators judgment, the potential for future excavation is
substantial. These areas include, but are not limited to, the following:
Irrigation ditches and canals subject to periodic excavations for cleaning out or
deepening;
Drainage ditches subject to periodic grading, including those along roads;
Agricultural areas in which deep plowing is employed;
Active drilling and mining areas;
Other areas where interference with Company pipelines may occur.
The installation of permanent markers on private property may take place wherever the
party exerting control over the surface use of the land will permit such installations.
The placement of temporary markers is advisable in areas of known heavy construction
activity (particularly along highways and major excavations) during the period
construction is in progress.
The location of pipelines at a fence crossing should be identified by painting the fence
posts or by installing a standard pipeline marker. The permission of the landowner may
be required in these instances.
RECORDS: Maintain a list of where markers are placed and check periodically to
ensure they are still there and in good condition. Record pipeline markers on WGC
Form 104.
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Section 3.7 line Markers and Signs for Transmission and Gathering Lines
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3.8
Operating Pressure Limits During Maintenance and Repair
CODE REFERENCE: Title 49 CFR Sections 192.713, 192.715, and 192.717.

PURPOSE: To establish recommended maximum pressures at which a pipeline should
be operated while excavation, maintenance, repairs, or other such activities are being
performed.
GENERAL: A pipeline is considered to be damaged if a defect is believed to exist, or
has been identified, which requires repair.
A pipeline is considered undamaged if no defect exceeding the limits has been found, or
after all known defects have been repaired.
The pressure criteria in this procedure are based upon industry experience as opposed to
mathematical analysis or empirical expressions predicting pipeline behavior.
Such
experience indicates that a pipeline, which has been damaged and does not subsequently
fail (rupture), probably will not fail during the course of repair activities if the actual
pressure in the pipe is reduced; with this consideration, the greater the pressure reduction,
the lesser the probability that a pipe failure will occur.
To maximize the reduction of risk, activities should be accomplished at the lowest
operating pressure possible if the opportunity exists to do so without having to implement
extraordinary measures.
The pressures established by this procedure should be considered recommended
maximums. Operating pressures for listed activities should be limited to the minimum
necessary to maintain delivery requirements and be kept below the recommended values,
if possible.
Good judgment and common sense may indicate the need for higher or lower pressures
depending on the extent of damage to the pipeline, deliverability requirements or other
circumstances.
The Production Coordinator has the authority to use pressures above the recommended
levels after making appropriate evaluations with approval from the Pipeline Engineer.
The condition of the pipeline as referred to in Table 3.8A is the condition of that segment
of the line in the immediate surroundings where the described activities are taking place
or are expected to take place.
PROCEDURE: Select the lowest maximum operating pressure from Table 3.8A
corresponding to the activities planned with the presence or absence of damage.
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Pressures higher than those listed should not be maintained unless the activity can be
conducted without compromising the safe operation of the pipeline and the safety of
operating personnel.
TABLE 3.8A
MAXIMUM PIPELINE OPERATING PRESSURES DURING MAINTENANCE
OR REPAIR ACTIVITIES
Type of Activity
No Activity:
Pipe Back Filled
Pipe Exposed (2)
Excavation (3)
Welding
Hot Tapping (8)
Stoppling
Any Other Activity (7)
PERCENT OF MAOP (1)

Damage from External Force or
Corrosion
Not Damaged
Not Leaking
Leaking
100
100
80
100 (5)
100
65
80
65
65 (4)
65 (4)
(5) (6)
N/A
N/A
(4)
65
65 (4)
65 (4)
(5) (6)
N/A
N/A
(4)
NOTES:
1.
Values shown are percent of Maximum Allowable Operating Pressure.
2.
This is not intended to apply to creek crossings and similar normal instances
where pipe may be exposed. It applies when listed or similar activities are
discontinued or completed and the line has not been back filled.
3.
Excavation restrictions do not apply when the pipe is exposed for three feet or less
of pipe length, to allow for over or under crossings of utilities or drain tile, or
other similar operations.
4.
Not more than 80% of the actual pressure at time of damage or leak.
P = (2S(t-.100)) x E x F x T
D
P=
S=
T=
D=
F=
Where
E=
T=
5.
Pressure
Specified Minimum Yield Strength
Actual Wall Thickness (verify by U.T.)
Diameter
Design Safety Factor
Class 1: F = 0.72
Class 2: F = 0.60
Class 3: F = 0.50
Class 4: F = 0.40
Longitudinal Joint Factor Determined
Temperature De-rating Factor
Not more than 60% of the actual pressure at time of damage or leak.
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6.
7.
For lowering of in-service pipelines, contact the Production Coordinator.

Hot tapping should be done in compliance with Section 2.19 Tapping Pipelines
Under Pressure.
RECORDS: None required by this procedure.
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3.9
Pipeline Patrolling
CODE REFERENCE:
192.706, and 192.709
Title 49 CFR Sections 192.613, 192.703, 192.705,
PURPOSE: Purpose of pipeline patrolling is to observe surface conditions on,

and adjacent to, Company transmission and gathering right-of-way, which might
affect safe operation of the system.
GENERAL: The pipeline system shall be patrolled to observe surface conditions
on and adjacent to the pipeline right-of-way for indications of leaks, construction
activity, exposed pipe, erosion, and other factors that may affect the safety and
operation of the pipelines.
The leakage surveys without instrumentation required by 49 CFR Section 192.706
in Class 1 and 2 locations are satisfied by these patrol requirements, which
include observations for leaks. Leakage surveys for Class 3 and 4 locations in
odorized gas service are also satisfied.
Types of patrols include ground patrols by foot, by vehicle, or by any
combination of these methods and aircraft patrols for onshore pipeline locations.
All field personnel shall be responsible to observe, investigate and report any
activity noted during the performance of their normal duties and other pipeline
inspection activities that could adversely affect the safety, operation and
maintenance of the pipeline facilities.
Pipeline patrols may be used to detect possible changes of population density.
PROCEDURE: Establish a plan in each operating location area for patrolling
pipelines. Include inactive lines in the plan (except lines that are abandoned).
Review and update the plan as necessary.
An increase in frequency of patrols may be warranted by the size of line,
operating pressure, class location, terrain, weather and other relevant factors.
Minimum pipeline patrolling in accordance to the schedule shown in Table 3.9A.
All aerial patrol reports and other reports of activities or construction in the
vicinity of pipeline facilities shall be field investigated.
Aerial reports or other reports received that indicate that the safety, operation or
maintenance of the pipeline facilities could be in imminent danger, shall be
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transmitted by radio, telephone or other expedient means to the Production
Coordinator as soon as possible and an immediate investigation made.
Maintain pipeline patrol records for at least five years.
FREQUENCY - The required frequency of patrolling is determined by the class
location of the pipeline as follows:
TABLE 3.9A
MAXIMUM INTERVAL BETWEEN PIPELINE PATROLS
At Highway* and Railroad
Class Location
At All Other Places
Crossings
Class 1 & 2
Twice each calendar year with
Once each calendar year
intervals not exceeding 7-1/2
with intervals not
months
exceeding 15 months
Class 3
Four times each calendar year with Twice each calendar year
with intervals not
months
exceeding 7-1/2 months
Class 4
Four times each calendar year with Four times each calendar
year with intervals not
months
exceeding 4-1/2 months
Waterways
Four times each calendar year with
months
Note: * Highway is defined as any hard surface (concrete or asphalt) public road.
OBSERVATIONS - The personnel performing the patrol shall observe the
pipeline rights-of-way and adjacent areas for evidence of:
Possible leaks,
Washouts or exposed pipe,
Dead Vegetation,
Soil erosion,
Excavation or grading equipment working over or near pipeline,
New residential or commercial construction, which is located within 220
yards (660 feet) on either side of the pipeline centerline,
Missing or severely damaged pipeline marking signs, which require
replacement,
Any inaccuracies or discrepancies with the pipeline maps, which require
correction,
Any other unusual conditions or hazards near or approaching the pipeline
right-of-way.
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NOTIFICATION - The personnel performing the patrol shall immediately notify
the Production Coordinator of any activity or situation, which may adversely
affect the safe operation of the pipeline system.
ACTION: The Production Coordinator shall initiate a maintenance order to
correct any situations discovered during the patrol which require remedial action.
RECORDS: Record each item found during a patrol that requires further
investigation to provide a permanent record on the WGS Form 103 Pipeline
Inspection Report form and submit the report to the Production Coordinator.
This record will ultimately indicate the actual situation and its disposition.
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3.10 Pressure Regulators and Relief Devices

192.199, 192.201, 192.731, 192.739, and 192.743.
PURPOSE: To establish requirements for the inspection, testing, and capacity
verification of regulator and relief devices used in natural gas pipelines.
GENERAL: This procedure outlines inspection, test frequency, documentation,
and capacity verification requirements and specifies applicable records.
Disassembly of pressure regulators and relief valves for internal inspection is not
required to satisfy the requirements of this procedure.
Each compressor station must have pressure relief or other suitable devices of
sufficient capacity and sensitivity to ensure that the maximum allowable operating
pressure of the system is not exceeded by more than 10%.
Except for plastic valves, each valve must meet the minimum requirements, or
equivalent, of API 6D.
PROCEDURE:
FREQUENCY OF INSPECTION - Inspect and test regulators and relief
devices once each calendar year with intervals not to exceed fifteen (15) months.
If equipment or physical conditions change between scheduled inspections and
tests, perform the appropriate items required by this procedure to assure continued
compliance.
REGULATORS INSPECTION - Inspect and test each pressure regulator to
assure that:
It is in good mechanical condition,
It is adequate from the standpoint of capacity and reliability of operating
for the service in which it is employed,
It is set to function at the correct pressure,
It is properly protected from external conditions or environment that might
prevent proper operation,
Its control system lines are properly supported and protected,
Its vent line is terminated in a safe location to prevent a hazardous
condition and protected to minimize possible plugging with items such as
snow, ice, or insects.
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Repair or replace defective or inadequately sized equipment or components prior
to the next inspection. Document inspections using WGS Form 116 Regulator
Inspection Report form.
RELIEF DEVICE INSPECTION - Inspect and test each pressure relief device
to assure that:
It is in good mechanical condition,
It opens at the proper pressure,
Actuate the "pilot operated" valve piston (main valve) in addition to the
pilot,
Its vent line is free of obstructions and is protected to prevent entrance of
moisture, or plugging with items such as snow, ice, or insects,
Its control line is properly supported and protected,
It has adequate capacity.
If relief valve capacity test is not feasible, calculate the required capacity or
review past calculations. Indicate review on WGS Form 117 Relief Valve
Inspection Report form. Make an on-site review and verification of the facilities
and pressures at the time the relief valve is to be tested. Check to see that the
correct valve is installed, no changes have been made to the valve, and operating
and/or relief flows and pressures are still the same.
Initiate appropriate measures to increase relief capacity promptly if existing
capacity does not meet requirements.
Initiate appropriate measures promptly to provide overpressure protection if a
defective valve is observed.
Remedial work required on relief valves must be completed (prior to the next
inspection).
Secure isolating valves, when installed, in the open position after each relief valve
inspection and test. Lock each isolating valve not located within a locked
building to avoid accidental or malicious closing.
RELIEF DEVICES SET POINT - Establish relief valve set points so that the
maximum pressure shall not exceed the following in any part of the systems:
If the MAOP is 60 psig (414 kPa) or more: the lower of the MAOP plus
10% or the pressure that produces a hoop stress of 75% of specified
minimum yield strength.
If the MAOP is 12 psig (83 kPa) or more but less than 60 psig (414 kPa):
MAOP plus 6 psig, (42 kPa).
If the MAOP is less than 12 psig (83 kPa): MAOP plus 50%.
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RECORDS: Document inspection and testing of pressure regulators and relief
devices on WGS Form 116 Regulator Inspection Report and WGS 117 Form
Relief Valve Inspection Report.
Document capacity confirmations and verifications of calculations.
Document reasons for needed changes to set points.
Retain the above documents for at least five years.
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3.11 Prevention of Accidental Ignition

CODE REFERENCE: Title 49 CFR Sections 192.735 and 192.751.
PURPOSE: The purpose of this procedure is to establish safety practices to
minimize the danger of accidental ignition of combustible gas mixtures in the
areas where the presence of gas constitute a hazard of fire or explosion.
GENERAL: Continually implement and monitor this procedure to insure safe
operations.
Permit only the required personnel, vehicles and work equipment in the hazardous
work area.
Issue Hot Work Permits as required by type of jobs being performed.
Prohibit smoking materials within the hazardous areas.
Exercise precautions during venting operations and cutting, welding, and grinding
activities on pipelines, which could possibly contain an explosive gas-air mixture
or distillates.
Exercise precautions during pigging operations, the handling of flammable liquids
and when using or working with internal combustion equipment (welding
machines, etc.) in the vicinity of hazardous areas.
Do not install electrical isolation devices, such as insulating flange kits, to be
installed in vaults or other areas subject to the accumulation of explosive gas-air
mixtures.
PROCEDURE: Smoking, open flames and other sources of ignition are
prohibited around and near scrubbers, meter run areas, enclosures and other areas
where the possible leakage or presence of gas or flammable/combustible liquids
present a hazard of fire or explosion.
Post "No Smoking" signs to serve warning in hazardous areas.
During construction and maintenance of facilities, post temporary "No Smoking"
signs in the applicable areas. Advise construction employees they will be
expected to comply with these signs.
Prohibit smoking in any area where gas is being vented to atmosphere or where a
combustible mixture might be present.
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Locate and nullify all possible sources of ignition in an area before a hazardous
amount of gas is vented to the atmosphere. Prior to venting, review the potential
hazards involved when blowing down or purging facilities in congested areas,
streets, highways, residential areas, plants, and around electrical transmission
lines.
Do not use open flame devices such as heaters in hazardous areas.
Use explosion-proof, approved for Division 1 or 2, Group D locations, flashlights,
lighting fixtures, extension cords, and other electrical devices in hazardous areas.
Maintain these devices in good working condition.
Fire extinguishers shall be manned and ready for use at all times during venting,
cutting and welding operations.
Make a thorough check with a combustible gas indicator prior to welding in or
around a structure or area containing gas facilities to determine the possible
presence of a combustible mixture. If safe conditions are indicated, welding
and/or cutting may begin.
Make efforts to minimize the mixing of air with gas when welding or cutting on
or around gas piping.
Do not weld or cut on pipe or pipe components that contain a known combustible
mixture of gas and air.
Flammable or combustible materials are stored in accordance with local laws and
Fire Department requirements when near any compressor shelter or building.
Tanks storing liquid hydrocarbons shall be spaced and protected with fire
extinguishing devices per NFPA 30.
Where cutting or rejoining pipelines, use a wire jumper connected between the
line sections to prevent arcing caused by cathodic protection or induced currents.
RECORDS: None required by this procedure.
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3.12 Record Keeping

CODE REFERENCE: Title 49 CFR Section 192.491(c) and 192.709.
PURPOSE: To establish procedures for maintaining records.
GENERAL: Title 49 CFR 192.709 requires records to be kept on each leak
discovered, repair made, line break, leakage survey, line patrol, and inspection.
Specific documentation requirements will be defined in each related procedure
and not within this procedure.
PROCEDURE: Maintain records for each leak discovered, repair made, line
break, leakage survey, line patrol, and inspection on all gas pipelines. Such
records shall be kept on pipe, fittings, vessels, and related items for all pipeline
facilities.
Permanent operating and maintenance records for D.O.T. inspection purposes
shall be available in the Field Office or designated area for the life of the pipeline.
Complete all necessary forms and reports and maintain in permanent record file as
required by specific procedures.
Retain all studies, reports, checks of monitoring devices, and other data for the
life of the facility at the Field Office.
RECORDS: No records are required for this procedure
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3.13 Repair Procedures and Documentation for Gas Transmission

Pipelines
CODE REFERENCE: Title 49CFR Sections 192.150, 192.241, 192.309,
192.485, 192.605, 192.703, 192.711, 192.713, 192.715, and 192.717.
PURPOSE: To define defects in steel pipeline and specify the acceptable method
for their disposition.
GENERAL: Repair a pipeline as soon as possible whenever an injurious damage
condition is found.
An injurious damage condition (gouge, groove, dent, corrosion, or leak) is one
that impairs the safety and serviceability of a pipeline and requires repair. See
Table 3.13A for limits of damages.
Take immediate temporary measures to protect life and property from hazards
resulting from a leaking, defective or damaged pipeline with an injurious damage
condition.
Determine the repair method for an injurious condition according to the type of
damage of defect.
Use the unpressurized repair alternate if either of the following two conditions
exist (pipeline must be out of service and blown-down):
Pipe geometry is deformed so it prevents proper installation of a
pressurized repair.
Leakage makes pressurized repair unsafe.
A pressurized repair is one that is carried out while the pressure in the pipeline is
higher than atmospheric.
If a pressurized repair is made, reduce the pressure of the line to the limit
established by each repair method or as established in Section 3.8 Operating
Pressure Limits during Maintenance and Repair of this manual.
All repair methods established by this procedure are considered permanent. The
use of a leak clamp is considered a temporary measure that may be taken to
protect life and property.
After repairing a leak, verify that the leak has been contained and no additional
leaks exist in the immediate area.
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Except as provided in the next two paragraphs below, each new pipeline and each
line section of a pipeline where the line pipe, valve, fitting or other line
component is replaced, must be designed and constructed to accommodate the
passage of instrumented internal inspection devices.
The above paragraph does not apply to:
Manifolds
Station piping such as at compressor stations, meter stations, or regulator
stations
Piping associated with storage facilities, other than a continuous run of
pipeline between a compressor station and station facilities
Crossovers
Sizes of pipe for which an instrumented internal inspection device is not
commercially available
Transmission lines, operated in conjunction with a distribution system
which is installed in Class 4 locations
Other piping that, under 49CFR 190.9 finds in a particular case would be
impracticable to design and construct to accommodate the passage of
instrumented internal inspection devices.
An operator encountering emergencies, construction time constraints and other
unforeseen construction problems need not construct a new or replacement
segment of a transmission line if the operator determines and documents why it is
prohibitive to comply with design and construction requirements for each new
pipeline and each line section of a pipeline where the line pipe, valve, fitting or
other line component is replaced. Within 30 days after discovering the
emergency or construction problem the operator must petition, under Title 49
CFR 190.9, for approval that design and construction to accommodate passage of
instrumented internal inspection devices would be impracticable. If the petition is
denied, within 1 year after the date of the notice of the denial, the operator must
modify that segment to allow passage of instrumented internal inspection devices.
PROCEDURE: No operator may use any pipe, valve, or fitting for replacement
or repairing pipeline facilities unless it is designed and constructed as required by
Part 192.
PRELIMINARY INVESTIGATIONS - Inspect any exposed pipeline for leaks,
impact damage, coating conditions, and external corrosion.
Visually inspect buried welds whenever the coating has been removed for
any reason.
Make a preliminary assessment to determine the extent of the damage or
defect. In most cases a visual inspection is sufficient. Use X-ray or other
forms of inspection that could be considered helpful if conditions warrant.
Investigate to determine the cause of any leaks that are found.
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Determine if a safety related condition exists and whether it should be
reported.
Document investigation on WGS Form 115 Leak Investigation Report
Form.
EVALUATION OF DAMAGE EXTENT
Make a precise evaluation of the extent of any damage or defect.
Compare the extent of any damage or defect against the limits established in
Table 3.13A.
Confirm the damage as injurious if its extent exceeds the limits established.
REPAIR OF CORROSION CONDITION
General Corrosion:
Each segment of transmission line with general corrosion and with a
remaining wall thickness less than that required for the maximum
allowable operating pressure of the pipeline must be removed by cutting
out a cylindrical piece of pipe and replacing it with pipe of similar or
greater design strength or the operating pressure must be reduced
commensurate with the strength of the pipe based on the actual remaining
wall thickness. However, if the area of general corrosion is small, the
corroded pipe may be repaired. Corrosion pitting so closely grouped as to
affect the overall strength of the pipe is considered general corrosion.
ASME/ANSI B31G (Latest Edition), "Manual for Determining the
Remaining Strength of Corroded Pipelines."
AGA Pipeline Research Committee, Project PR-3-805, "A Modified
Criterion for Evaluating the Remaining Strength of Corroded Pipe", Latest
Edition.
Localized Corrosion Pitting:
Each segment of transmission line with localized corrosion pitting to a
degree where leakage might result must be repaired or removed by cutting
out a cylindrical piece of pipe and replacing it with pipe of similar or
greater design strength or the operating pressure must be reduced
commensurate with the strength of the pipe, based on the actual remaining
wall thickness in the pits. Inspect the interior of the cutout and the ends of
the remaining pipe for internal corrosion, record on WGS Form 112
Corrosion Control Report.
Repair of Imperfections and Damages
Except as provided below, each imperfection or damage that impairs the
serviceability of a segment of steel transmission line operating at or above
40 percent of specified minimum yield strength must be repaired as
follows:
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If it is feasible to take the segment out of service, the imperfection
or damage must be removed by cutting out a cylindrical piece of
pipe and replacing it with pipe of similar or greater design strength.
If it is not feasible to take the segment out of service, a full
encirclement welded split sleeve of appropriate design must be
applied over the imperfection or damage. Repair sleeves shall be
welded using a qualified procedure specifying low hydrogen rod.
Document on
Submerged pipelines in inland navigable waters may be repaired by
mechanically applying a full encirclement split sleeve of appropriate
design over the imperfection or damage.
Repair of Welds
If it is feasible to take the segment of transmission line out of service, the
weld must be repaired per Section 3.17 Welding of this manual.
A weld may be repaired in accordance with repair or removal of defective
welds per applicable code and standard while the segment of transmission
line is in service if:
The weld is not leaking;
The pressure in the segment is reduced so that it does not produce
a stress that is more than 20 percent of the specified minimum
yield strength (SMYS) of the pipe; and
Grinding of the defective area can be limited so that at least 1/8
inch (3.2 mm) thickness in the pipe weld remains.
A defective weld, which cannot be repaired in accordance with the above
paragraphs, must be repaired by installing a full encirclement welded split sleeve
of appropriate design.
Repair of Leaks
If feasible, the segment of transmission line must be taken out of service
and repaired by cutting out a cylindrical piece of pipe and replacing it with
pipe of similar or greater design strength.
If it is not feasible to take the segment of transmission line out of service,
repairs must be made by installing a full encirclement welded split sleeve
of appropriate design.
If the leak is due to a corrosion pit, the repair may be made temporarily by
installing a properly designed bolt-on-leak clamp.
Either the sleeve or the clamp is to be removed and replaced by a
cylindrical piece as soon as it is feasible to take the piping out of service.
All repairs performed must be tested and inspected.
Testing of Repairs
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Testing of replacement pipe:
The replacement pipe must be tested to the pressure required for a
new line installed in the same location. This test may be made on
the pipe before it is installed.
Inspection and test of welds:
Visual inspection of welding must be conducted to insure that the
welding is performed in accordance with the welding procedure
and the requirements of API Standard 1104, "Welding of Pipelines
and Related Facilities".
The welds on a pipeline to be operated at a pressure that produces
a hoop stress of 20% or more of SMYS must be nondestructively
tested in accordance with Section 3.15 Testing Requirements, of
this manual except that welds that are visually inspected and
approved by a qualified welder inspector need not be
nondestructively tested if:
The pipe has a nominal diameter of less than 6 inches (152
min); or
The pipeline is to be operated at a pressure that produces a
hoop stress of less than 40% of SMYS and the welds are
limited in number and nondestructive testing is impractical.
The acceptability of a weld that is nondestructively tested or
visually inspected is determined according to the standards in API
Standard 1104.
RECORDS: Complete WGS Form 109 Pipeline Leak Repair Report, WGS
Form 112 Corrosion Control Report, and WGS Form 115 Leak Investigation
Report as applicable.
Submit as-built sketches to the Production Coordinator if pipe is replaced.
Maintain the records for the life of the pipeline facility.
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Table 3.13A
PIPELINE REPAIR PIPE DAMAGE OR DEFECT
DAMAGE OR DEFECT
DISPOSITION OF CONDITION
Unpressurized
Pressurized
Dent on:
Welds
C
E, P
Body or pipe 12 (305 mm) or less nominal diameter:
Depth greater than (6.4)
C
E, P
Body or pipe 12 (305 mm) nominal diameter:
2% or more of nominal diameter
C
E, P
Groove, gouge or scratch with remaining wall thickness:
Less than design wall thickness
C
E, P
Welds:
No Leak
X
E, P
X
E, P
With Leak (see note 2)
General Corrosion:
No Leak
C
C, M
Localized Corrosion Pitting:
No Leak
C
E,C,M,P
C
With Leak (see note 2)
L,E,P
All Other Leaks (see note 2)
C
E, P
Legend:
C
Cutting out a cylindrical piece of pipe and replacing it with pretested pipe
of similar or greater design strength.
E
Full encirclement, welded split sleeve of appropriate design.
L
Leak clamp.
M
Establish new maximum operating pressure base on the actual remaining
wall thickness.
P
Plidco sleeve or equivalent (submerged).
R
Weld Repair (see note 1).
X
Cut out repair per applicable code and standard.
Notes:
A weld on a pressurized pipeline segment may be repaired if:
1.
The pressure in the segment is reduced so that it does not produce a stress
that is more than 20% of the specified minimum yield strength of the pipe;
and
2.
Grinding of the defective area can be limited so that at least 1/8 inch (3.2
mm) thickness in the pie weld remains.
3.
Either the sleeve or the leak clamp are to be removed and replaced by a
cylindrical piece as soon as it is feasible to take the piping out of service.
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3.14 Rights-of-Way, Inspection and Maintenance

CODE REFERENCE: Title 49 CFR Sections 192.613, 192.705
PURPOSE: To provide a visual inspection of pipeline rights-of-way and pipeline
facilities to determine potential hazards or to spot leaks in areas where other
detection methods are impossible.
GENERAL: The regular patrol of pipelines and facilities is the best method for
detecting activity on or near a pipeline and in some cases spotting small leaks that
may not otherwise be found. Generally pipelines are flown on a periodic basis
using a light aircraft, however this may be impractical on some lines therefore
walking or driving the line may be the only alternative. One example of this
situation would be the case of a short line that is D.O.T. jurisdictional but is not
economically feasible to fly. This line shall be inspected by other methods.
FREQUENCY OF INSPECTION - Aerial inspection or ground inspection shall
be performed on all D.O.T. jurisdictional pipelines. The frequency is determined
by the size of the line, the operating pressures, the class location, terrain, weather,
and other relevant factors, but intervals between patrols may not be longer as
follows:
Class location
of line
1,2
3
4
Maximum interval between patrols

At highway and railroad
At all other places
crossings
7-1/2 months, but at least twice
15 months; but at least once
each calendar year
each calendar year.
4-1/2 months, but at least four
7-1/2 months, but at least
times each calendar year
twice each calendar year
4-1/2 months, but at least four
4-1/2 months, but at least
four times each calendar
times each calendar year
year
Non-jurisdictional pipelines shall be inspected as directed by the Production

Coordinator.
ENCROACHMENT - An encroachment is defined as the unauthorized
infringement by an outside party of the right(s)-of-way associated with the
Company's pipelines or pipeline facilities. This infringement can be in the form
of construction (building, trailers, fences, culverts, etc.) or the removal or
redistribution of soil cover. The Company's right-of-way grant and easement
describes what activities are allowed on a specific right-of-way. Any other
infringement requires a release of right-of-way on the part of the Company. The
Company generally expects compensation when a release requires the Company
to lower or relocate a pipeline or associated facility. The Production Coordinator
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should be contacted at the earliest moment when a potential encroachment is
discovered and shall determine the appropriate course of action.
OBSERVATION REQUIREMENTS - The pipeline inspector shall look for at
least the following conditions to the extent possible:
Suspicious looking liquids on the rights-of-way;
Discolored or dead vegetation on or near the rights-of-way;
Survey flags or survey stakes that may indicate future construction
activity;
Construction activity that may parallel or intersect the rights-of-way in the
near future, such as power lines, underground cable, pipelines, road and
waterway construction, or improvements;
Building of farm ponds, watersheds, terraces, or leveling of land;
Drilling rigs, seismographic activity, or soil boring activity;
Strip mining, heavy traffic crossing the line, and other vehicular activity
such as erosion due to dirt bike, three or four-wheel All Terrain Vehicle
activity;
Pipeline washouts, sunken backfill, river or stream diversions or any form
of exposed pipe not previously exposed;
Conditions of signs and markers along the route (to the extent possible);
The construction of new homes or buildings or the location of mobile
homes on or very close to the rights-of-way;
Any other condition the inspector may think requires any further
investigation or action.
REPORTING - The pipeline inspector shall report any emergency conditions by
radio, if possible, or by telephoning the pipeline Field Office with the pertinent
information as soon as possible. When possible, contact should also be made with
the person or persons who are in danger or creating a dangerous situation. This is
simple in the case of someone walking the pipeline. If the inspection is being
done by plane it is more difficult to contact them. The pilot should notify the
Production Coordinator immediately by any means available with locations of
possible danger so that arrangements can be made for someone to go to the area
and perform line staking and depth determination.
Non-emergency events or incidents shall be reported on the Air Patrol Report and
mailed or delivered to the Field Office for the pipeline inspected as soon as is
practical after the inspection. If, in the judgment of the inspector, the nonemergency requires prompt, but not emergency, action the inspector shall
telephone or radio this to the Field Office at his earliest convenience.
FOLLOW-UP ACTION - The Production Coordinator shall initiate appropriate
action upon the receipt of all reports for the pipeline inspector. This action shall
be documented by work orders, line marking requests, leak report, or other
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appropriate forms. On a jurisdictional pipeline some follow-up action must be
taken and documented for each reported incident.
RECORD KEEPING Complete a WGS Form 103 Pipeline Inspection,
Right of Way and Marker Report after each right of way inspection and/or
maintenance.
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3.15 Testing Requirements

PRESSURE TESTING
192.507, 192.509, 192.515, 192.517, 192.619 and 192.719.
PURPOSE: To establish minimum requirements for pressure testing of all gas
piping facilities installations and repairs.
GENERAL: This procedure includes leak test and strength test requirements.
No operator may operate a new segment of pipeline or return to service a segment
of pipeline that has been relocated or replaced until:
It has been pressure tested per the requirements of this procedure and
those of Section 2.10 of this manual, to substantiate the maximum
allowable operating pressure.
Each potentially hazardous leak has been located and eliminated.
Test medium must be liquid, air, natural gas, or inert gas that is:
Compatible with the material of which the pipeline is constructed.
Relatively free of sedimentary materials.
Non-flammable, except when natural gas is used as the test medium.
HYDROSTATIC TESTING
Testing with liquid (water) is generally preferred because of the ease of
identifying leaks, correlating temperature and pressure changes, and the reduced
risk when catastrophic test failures occur.
Hydrostatic test pressures in excess of those required by D.O.T. to support a
pipeline's MAOP are recommended for some new construction. When possible,
pipeline facilities should be tested to 90% SMYS or to the limiting flange, fitting,
valve or equipment test pressure. Hydrostatic testing at low pressures does not
provide a strength test capable of identifying flawed pipe, fittings or welds.
PNEUMATIC TESTING
Pneumatic testing (testing with air, natural gas, or inert gas) is not recommended
because of the difficulty in identifying leaks and because of the hazards associated
with expanding gas when catastrophic leaks occur. Therefore the company does
not use this method.
DEFINITIONS
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Stabilization Time - The stabilization time is the time period, following the fill of
the system with the test medium, during which temperatures of the test medium,
pipe and backfill equalize to the extent necessary to conduct a valid leak test. The
time required to achieve stabilization will depend on individual test conditions but
must be sufficient to allow proper leak testing based on correlation of temperature
and pressure changes during the hold period.
Leak Test - For piping that is entirely visible during the test, the leak test will
consist of observation of the piping while under pressure to check for visible or
audible evidence of a leak.
For piping below ground or otherwise not visible, the leak test will consist of an
approved procedure whereby pressure variations during strength testing are
accounted for, taking into account the effects of temperature and pressure on the
test medium and pipe. Pressure loss that cannot be satisfactorily attributed to these
factors, measurement error, or other factors peculiar to the situation will be
considered evidence of a leak.
Strength Test - A strength test is the pressurization of piping to a minimum
predetermined stress level or pressure and maintaining this stress level or pressure
for a predetermined time interval or hold period.
The hold period for the strength test shall start after the stabilization period and
continue until the specified time has elapsed. During this time period the test
section may be repressured or depressured as required to maintain the test
pressure within the established limits. For piping below ground or otherwise not
visible, maintain accurate records including depressuring and repressuring times,
pressure and volumes during the hold period.
Maximum Test Pressure - The maximum test pressure is a pressure range above
the specified minimum test pressure to allow for such variables as change in
elevation in the test section, temperature changes, piping or equipment
limitations, etc., but shall not exceed the lowest of the following:
When water is used, the hoop stress at 100% SMYS of the pipe at the
lowest point on the test segment.
When air, nitrogen, or other inert gas is used to test natural gas systems,
hoop stress at 80% SMYS in Class 1, 75% SMYS in Class 2, 50% SMYS
in Class 3, and 40% SMYS in Class 4. Note Exception below.
When natural gas is used to test natural gas systems, hoop stress at 80%
SMYS in Class 1 and 30% SMYS in other classes. For pressure rated
components, 1.5 times the rating, or per manufacturer's specification.
Note exception below.
EXCEPTION: In a Class 1 or Class 2 location, if a building(s) intended for
human occupancy exists within 300 feet (91.4 meters) of a pipeline whose design
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hoop stress level is 30% or more of SMYS, the test pressure must be a minimum
of 1.25 times MAOP (see Section 2.10). In no event may the test section be less
than 600 feet (183 meters) unless the length of the newly installed or relocated
pipe is less than 600 feet (183 meters). If an inert gas or air test is to be conducted,
the building(s) must be evacuated while the hoop stress level exceeds 50% of
SMYS. If building(s) cannot be evacuated, the piping must be hydrostatically
tested.
In Class 1 or Class 2 each compressor station must be tested to at least Class 3 test
requirements.
Minimum Test Pressure - The minimum test pressure is the test pressure
required to substantiate the desired MAOP. Note that although the minimum test
pressure is acceptable, it is desirable to test to the maximum possible Maximum
Test Pressure above, to maximize identification of flawed pipe, welds, or other
components (i.e. leaks).
Pipeline Component - A pipeline component is a valve, flange, standard fitting,
prefabricated assembly, or similar item.
Prefabricated Assembly - A prefabricated assembly is one which is constructed
prior to installation and installed as a single unit.
Documented Test Pressure - The pressure used for record summaries and
determination of MAOP will be the minimum test pressure at the highest
elevation of the pipeline during the test period.
TEST REQUIREMENTS - See Table 3.15A for a summary of test
requirements.
Facilities and piping systems, except as excluded below, that are to operate at a
hoop stress of 30 percent or more of SMYS, require eight (8) hours strength
testing before being placed in service, regardless of whether they are installed as a
temporary or permanent installation. This includes all new, relocated, replaced,
and modified segments of a pipeline.
No pressure test is required for vent or drain lines, which are open to atmosphere
and do not include in-line items which could restrict or block flow, such as valves
or tanks.
If a component other than pipe is the only item being replaced or added to a
pipeline, a strength test after installation is not required if the manufacturer of the
component certifies that:
The component was tested to at least the pressure required for the pipeline
to which it is being added; or
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The component was manufactured under a quality control system that
ensures that each item manufactured is at least equal in strength to a
prototype and that the prototype was tested to at least the pressure required
for the pipeline to which it is being added.
Prefabricated assemblies and short segments of pipe are not required to be
retested at the time of installation if a post installation test is impractical and they
are pretested prior to installation by maintaining the pressure at or above the test
pressure for at least 4 hours.
Pipe used to tie-in a test segment of pipeline must have been pretested per this
testing procedure, and all tie-in welds shall be 100% radiographically inspected.
Sensitive components such as relief valves, regulators, instruments, control
valves, and related items, which may be damaged at elevated pressure shall either
be removed or isolated from the system during testing.
In a pipeline to be operated at a hoop stress of 20% SMYS or more, pipe having
an outer diameter to wall thickness ratio of 70 to 1 or more that has been
transported by railroad may not be used unless:
The transportation is performed in accordance with API RP 5L1.
In the case of pipe transported before November 12, 1970, the pipe is
tested in accordance with this procedure to at least 1.25 times the
maximum allowable operating pressure if it is to be installed in a Class 1
location and to at least 1.5 times the maximum allowable operating
pressure if it is to be installed in a Class 2, 3, or 4 location.
Notwithstanding any shorter time period permitted under this procedure,
the test pressure must be maintained for at least 8 hours.
Each segment of a pipeline that is to be operated at a hoop stress less than 30% of
SMYS and at or above 100 psig (689 kPa) must be tested in accordance with the
following:
The test procedure must ensure discovery of all potentially hazardous
leaks in the segment being tested.
If the segment is to be stressed to 20% or more of SMYS during the test,
and natural gas, inert gas, or air is the test medium:
o
A leak test must be made at a pressure between 100 psig (689 kPa)
and the pressure required to produce a hoop stress of 20% of
SMYS; or
o
The line must be walked to check for leaks while the hoop stress is
held at approximately 20% of SMYS.
The pressure must be maintained at or above the test pressure for at least
one hour.
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Each segment of a pipeline that is to be operated at or below 100 psig (689 kPa)
must be leak tested in accordance with the following:
The test procedure must ensure discovery of all potentially hazardous
leaks in the segment being tested.
Each line that is to be operated at less than 1 psig (6.9 kPa) must be tested
to at least 10 psig (69 kPa).
Each line that is to be operated at or above 1 psig (6.9 kPa) must be tested
to at least 90 psig (621 kPa).
PRETESTED PIPE - An unlimited length of pretested pipe may be used for
emergency replacement. Considerable care must be taken to maintain the
qualification of pretested pipe in the process of identification, handling, hauling,
stocking, and installation. If a sufficient length of pretested pipe is unavailable,
the remainder shall be tested at the job site.
For planned replacement of short sections, pretested pipe may be used. For
planned replacement of longer sections, pipe shall be tested at the job location
only. In-place testing is preferred, but on-site is acceptable.
Pipe stocked for emergency replacement shall be pretested for four (4) hours
duration.
PRESSURE & TEMPERATURE CHARTS
General Requirements - For test intervals exceeding two (2) hours, pressure and
temperature recording charts shall be used, except that fluid temperature
recording is not required on any test of aboveground piping that can visually be
inspected for leaks. A dead-weight tester is also required.
For test intervals less than or equal to two (2) hours, pressure and temperature
recording charts are not required if the following conditions are met:
Dead weight pressure is obtained at time intervals not exceeding 15 minutes, and
If a dead weight pressure is less than the minimum test pressure, the test is
restarted, and
The dead weight pressure, the corresponding time, and the ambient
temperature will be recorded.
Pressure Charts - The date and the time test is started and the time at which the
test period ends shall be noted on the chart.
Charts must show "pressure up" line and "bleed down" line, as well as recording
of pressure during the test interval.
Drastic deviations in the recorded pressure shall be noted and explained.
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Work Order number on the chart.
If more than one test section is involved in the Work Order or project, the test
section number and location by station number or mile post for pipelines or
drawing number for stations shall also be indicated.
Charts shall be signed by an authorized Company representative and Test
Contractor's representative or test technician.
Temperature Charts - Test Fluid - Temperature recordings shall be started prior
to the start of the fill operation when hydrostatic testing.
Identification information and signatures shall be the same as for pressure charts.
Temperature sensing device must be placed on the pipeline below grade and
shaded from the sun to prevent erroneous readings.
PROCEDURE: Determine test pressure and test medium based on the
considerations outlined in this procedure.
Establish a test plan in accordance with the requirements of this procedure.
Review and obtain approval of the plan prior to testing.
Do not test against closed valves, unless absolutely necessary. If testing against
closed valves, verify that the test pressure will not damage the valve.
Conduct a leak test concurrently with a strength test unless no strength test is
required.
Test fabricated assemblies, including line valve assemblies, cross connections,
river crossing headers, etc., which have been appropriately pretested shall be
tested in the same manner, to at least the same pressure as the pipeline on either
side of the assembly.
Leak test hot taps or stopple connection after welding to the header pipe and prior
to tapping at the operating pressure at the time of tapping and for 30 minutes
duration.
Use pigs and squeegees in good condition, where practical, to dry long test
sections.
Run pigs as many times as necessary to remove all free water. Normally, the test
section will be considered satisfactorily dry when no water or mist expelled ahead
of the pig and no water can be wrung from a poly foam pig.
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For test sections where water or water vapor remaining in this test section will
cause future operating problems, dry the test section further using dehydrated air
or other means deemed suitable and necessary. Methanol injection will not
normally be approved due to environmental restrictions.
RECORDS: Use WGS Form 118 Hydrostatic Strength Test Report. Record
of each test performed must contain at least the following information:
The operator's name, the name of the operator's employee responsible for
making the test, and the name of any test company used.
Date, time of test, and
Test instrument calibration data,
Test medium used,
Minimum pressure,
Test duration,
Pressure recording charts, or other record of pressure readings,
Elevation variations, whenever significant for the particular test,
Leaks and failures noted and their disposition,
Record make, model and serial number of dead weight tester, and date of
last certification,
Description of facilities tested and the test apparatus,
Prepare an explanation of any pressure discontinuities, including test
failures, that appear on the pressure recording charts,
Where elevation differences in the section under test exceed 100 feet (30
meters), a profile of the pipeline that shows the elevation and test sites
over the entire length of the test section.
All required test forms, pressure, and temperature charts shall be retained for the
life of the pipeline facilities.
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Table 3.15A
Test Conditions for Pipelines Other than Service Lines
Other Than Plastic
Less than 100 p.s.i.g.
Under 30%
30% SMYS
SMYS
and over
Maximum
Less than 1 1 p.s.i.g.
100 p.s.i.g. and
All pressures
Operating
p.s.i.g.
and over
over
Pressure
but less
than 100
p.s.i.g.
Test Medium
Water
Water
Water
Water
Air
Air
Air
Air
Natural gas Natural
Natural gas
Natural gas
Inert gas
gas
Inert gas
Inert gas
Inert gas
See note (1)
Maximum Test
See note (2) See note
See note (2)
See note (2)
Pressure
(2)
Minimum Test
10 p.s.i.g.
90 p.s.i.g. MAOP multiplied MAOP
by class location
Pressure
multiplied by
factor in
class location
192.619(a)(2)(ii). factor in
See notes (1) and 192.619(a)(2)
(3)
(ii). See
notes (3) and
(4)
Minimum Test
See Note(6) See Note
1 hour, see notes
8 hours, see
Duration
(5)
(3) and (5)
notes (5) and
(6)
NOTES:
1.
Whenever test pressure is 20 percent SMYS or greater and natural gas,
inert gas, or air is the test medium, the line must be checked for leaks
either by a leak test at pressure greater than 100 psig but less than 20
percent SMYS or by walking the line while the pressure is held at 20
percent of SMYS. The pressure must be maintained at or above the test
pressure for at least one hour.
2.
Refer to Maximum Test Pressure of this procedure for limitations when
testing with water, air, natural gas, or inert gas. For all test media,
pipeline components must be taken into consideration when determining
the maximum test pressure.
3.
Refer to Test Requirements of this procedure for pipe O.D. to wall
thickness ratio limitations for a pipeline to be operated at a hoop stress of
20% or more of SMYS.
4.
Refer to Test Requirements of this procedure for testing criteria covering
pipelines located within 300 feet of buildings intended for human
occupancy and compressor stations.
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5.
6.
Duration determined by volumetric content of test section and

instrumentation in order to ensure discovery of all potentially hazardous
leaks.
For short sections of pipe or pre-fab assembly, a test prior to installation in
the pipeline is acceptable.
VISUAL INSPECTION AND NONDESTRUCTIVE TESTING

CODE REFERENCE:
192.715 and 192.719.
Title 49 CFR Sections 192.241, 192.243, 192.245,
PURPOSE: To establish minimum requirements for visual inspection and

nondestructive testing of field-made butt welds in piping to be operated under
pressure.
GENERAL: All visual inspection and nondestructive testing of field-made butt
welds in pressurized gas facility piping shall be in accordance with the D.O.T.
referenced edition, API Standard 1104 "Welding of Pipelines and Related
Facilities."
Radiographic inspection or ultrasonic inspection shall be used to satisfy the
requirements for nondestructive testing of field-made girth welds.
Persons nondestructively testing welds shall be trained and qualified to perform
test and interpret results in the testing method employed, per written
nondestructive testing procedures, and be familiar with all requirements of the
D.O.T. referenced edition of API Standard 1104.
The acceptability of a weld that is nondestructively tested or visually inspected is
determined according to the standards of API Standard 1104.
If a girth weld is unacceptable under those standards for a reason other
than a crack, and if the appendix to API Standard 1104 applies to the weld,
the acceptability of the weld may be further determined under that
appendix.
Welding Inspector shall be qualified to perform visual weld inspection.
WELD NON-DESTRUCTIVE TESTING
Any process other than trepanning, that will clearly indicate defects that may
affect the integrity of the weld, must have nondestructive testing of welds.
Each weld that is found unacceptable must be removed or repaired, and then
found acceptable. A weld must be completely removed if it has a crack that is
more than 8% of the weld length.
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Each weld that is repaired must have the defect removed down to the sound metal
and the segment to be repaired must be preheated if conditions exist which would
adversely affect the quality of the weld repair.
After repair, the segment of the weld that was repaired must be inspected to insure
its acceptability.
Ensure the interpretation of all nondestructive test results by Nondestructive
Testing Contractor is correct.
Follow the schedule in Table 3.15B of this procedure for the minimum percentage
of each day's field butt welds to be nondestructively tested over the entire
circumference.
Ensure that girth welds on pressurized piping have been nondestructively tested in
the correct amount.
At least one of each welder's daily welds will be inspected when non-destructive
testing is required unless his work is isolated from the principal welding activity.
WELD VISUAL INSPECTION - A qualified inspector shall visually inspect
welding of a regulated pipeline to insure that:
The welding is performed in accordance with the welding procedures; and
The welds are acceptable to the standards of API Standard 1104
(Referenced Edition).
The welds conform to the requirements of Pipeline Welding Procedure
Section 3.17 of this manual and this Visual Inspection and Nondestructive
Testing Procedure.
Ensure that each joint of pipe is inspected for defects such as laminations, cracks,
dents, gouges, grooves, and notches.
Bevels shall be inspected for proper dimensions, cleanliness and angle.
Ensure that each joint of pipe is swabbed as necessary to remove all dirt and
foreign materials from the inside.
Ensure that the longitudinal seams are offset as stated in Section 3.17 of this
manual. The line up shall be inspected to ensure proper root spacing and
alignment.
The stringer (root) bead shall be inspected for proper grinding and cleaning.
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If more than one grade or weight of pipe or fittings are used, ensure that it is
according to the approved construction drawings.
Mark and ensure that all arc burns are removed and repaired according to Section
3.17 in this manual.
RECORDS: Develop a record keeping system for location of non-destructively
testing welds on stations (i.e., compressor stations, meter stations, etc.) piping to
ensure that girth welds on pressurized piping have been nondestructively tested in
the correct amount (show in station piping drawings).
Record to show by milepost, station plus, or by geographic feature, the location of
girth welds made, the number of girth welds made, the number of
nondestructively tested, the number rejected, and the disposition of the rejects.
Retain the above records for the life of the pipeline system.
Record radiograph films and ultrasonic testing results with a unique numbering
system allowing identification of the radiograph film or ultrasonic testing results
to its respective weld.
Radiographic film must be retained for at least one year. However, as indicated
above, the certification sheets and other records showing the disposition of the
welds must be retained for the life of the pipeline.
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TABLE 3.15B
Minimum Nondestructive Testing Requirements for Pressurized Piping
6 and
Less than
Larger
All Sizes
6 (152mm)
(152 mm)
20% to
<20%
<40%
SMYS
20%
SMYS
SMYS
40%
SMYS
Class Location
1
2
3&4
All Class Locations:
Major rivers
Navigable river
Railroads or Public highways (4)
Tie-ins (5)
Meter and Regulating Stations
Required Welds (6)
(1)
(1)
(1)
(1)
(1)
(1)
(2)
(2)
(2)
10%
15%
100%(3)
90%
90%
(1)
(1)(8)
(1)
100%(7)
90%
90%
(1)
(1)(8)
(1)
100%(7)
90%
90%
(2)
(2)(8)
(2)
100%(7)
100%(3)
100%(3)
100%(3)
100%
100%
100%(7)
Notes:
(1)
Visually inspected and approved by qualified welding inspection or nondestructive testing of the minimum percent shown in the right column.
(2)
Visual inspection only allowed if number of welds is so limited in number that
nondestructive testing is impractical.
(3)
100% non-destructive testing must be used if practicable, but in no case less than
90% Nondestructive testing must be impracticable for each girth weld not tested.
(4)
Within railroad or public highway rights of each way, including tunnels, bridges,
and overhead road crossing. Non-destructive testing may be subject to other
agency permit requirements.
(5)
Tie-in welds shall include the joining of two sections of pipeline, new or
replacement, in their final position and other welds where post pressure testing is
not practical if pretested material is used.
(6)
Welds repaired due to non-destructive testing rejection. Retest of entire weld
length is needed.
(7)
Inspection of repaired welds must be performed using the method of inspection
used to identify original defect.
(8)
Any tie-in weld not pressure tested shall be non-destructively tested.
(9)
Each circumferential weld which is located where the stress during bending
causes a permanent deformation in the pipe must be nondestructively tested either
before or after the bending process.
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3.16 Valve Inspection and Maintenance

CODE REFERENCE: Title 49 CFR Parts 192.145, 192.179, and 192.745.
PURPOSE: To provide guidelines for valve inspection and maintenance to
ensure the safe operation of any valve that may be required in an emergency.
GENERAL: Any valve that may be required in an emergency must be inspected
and partially operated at intervals not exceeding 15 months, but at least once each
calendar year.
The Production Coordinator shall determine valves that may be required in an
emergency but should give priority inspection to:
Maintain block valves on transmission lines;
Suction and discharge block valves at compressor stations;
Isolation valves for major laterals (gathering lines), and
All valves on above ground piping in populated areas. A list of designated
critical valves shall be included in the Field Office files and all employees
instructed in the location of the valves.
Necessary personnel shall be notified prior to operating any valve that may
significantly affect the normal operation of those locations. Other affected
personnel shall be notified when the inspection is complete.
The inspection and partial operation of all non-emergency valves will be at the
discretion of the Production Coordinator.
Inspections shall also verify valve locations meet the following spacing
requirements:
Each point on the pipeline in:
Class 4
Class 3
Class 2
Class 1
Must be within:
2-1/2 miles of a valve
4 miles of a valve
7-1/2 miles of a valve
10 miles of a valve
Except for plastic valves, each valve must meet the minimum requirements, or
equivalent, of API 6D.
PROCEDURE: The valve inspection and maintenance should include but not be
limited to:
Grease or lubricate valve if applicable.
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Fully operate the valve, if possible; if not, partially operate the valve to
check its operation.
Operate the power-operated valve by introducing the normal power source
to the operator.
Check aboveground valves for atmospheric corrosion.
Ensure the valve environment will not interfere with the operation of the
valve or prevent safe personnel access at any time of the year.
Check for possible blowdown obstructions and posted signs if applicable.
Maintain valves in operating condition. Any necessary repairs should be done
promptly, but must be done prior to the next inspection.
Protect normally closed valves from conditions that could affect proper operation
or cause deterioration.
Perform inspection and maintenance on frequently operated valves more often if
needed.
Secure valves requiring locking devices to prevent unauthorized operation. Areas
inaccessible to the public do not require chains and locks on valves. Inaccessible
areas could include locked vaults, and remote, fenced and gated fields, etc.
Inspect aboveground piping or fabrications associated with a valve outside of a
plant yard for atmospheric corrosion when the valve is given its inspection, and
maintain as appropriate.
When operating the valve, care should be taken to avoid a service outage or over
pressurization of the system.
When the inspection (or maintenance action) is completed, the inspector should
verify that the valves are in the proper position.
RECORDS: The Production Coordinator will schedule corrections or further
maintenance for and any problems detected during the annual inspection. Use
WGS Form 119 Valve Inspection Report form.
Valve maintenance and repair should be performed in accordance with the
manufacturer's recommendations. The Production Coordinator will provide
assistance where necessary should there be any questions regarding proper valve
maintenance.
Keep inspection records for at least five years.
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3.17 Welding
CODE REFERENCE: Title 49 CFR Part 192.221 through 192.245
PURPOSE: To establish the requirements for qualifying welding procedure and
welders for work on steel pipelines.
GENERAL: All welding performed by a qualified welder in accordance with
welding procedures must be qualified to produce welds meeting the requirements
specified. The quality of the tests used to qualify the procedure shall be
determined by destructive testing. Each welding procedure must be recorded in
detail, including the results of the qualifying tests. This record must be retained
and followed whenever the procedure is used.
A Welding Procedure Specification (WPS) is a written procedure prepared to
provide direction for making production welds to specific requirements. It
specifies the materials, consumables, and procedures to be used in making welds,
either for a variety, or for specific connection geometry, steel types and steel
thickness.
The Procedure Qualification Record (PQR) documents the welding materials,
consumables, and procedures defined by the WPS used to weld a test coupon. It
also contains the test results of the tested specimens. The PQR basically
establishes that the weldments specified by the WPS are capable of providing the
required properties for its intended application.
The Welder Performance Qualification (WPQ) documents the ability of the
welder being tested to produce a weld using a specific set of materials,
consumables, and procedures to meet certain quality requirements.
A weld map and weld location record shall be completed.
All visual inspection and nondestructive testing shall be in accordance with
Section 3.15 Testing Requirements, Visual Inspection and Nondestructive
Testing.
QUALIFICATION OF WELDING PROCEDURES AND WELDERS - All
welding performed on gas pipeline systems shall be completed using welding
procedures qualified in accordance with the D.O.T. referenced edition, API
Standard 1104 "Welding of Pipelines and Related Facilities", or Section IX
"Welding and Brazing Qualifications" of the ASME Boiler and Pressure Vessel
Code.
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Welders welding on pipelines that operate at less than 20% SMYS and two inches
(5.1 cm) or smaller in nominal diameter, shall qualify and test according to the
requirements for pipelines that operate at 20% SMYS or more.
Each welder shall be qualified in accordance with section 3 of API Standard 1104
"Welding of Pipelines and Related Facilities" (Referenced Edition) or Section IX
"Welding and Brazing Qualifications" (Latest Approved Edition) of the ASME
Boiler and Pressure Vessel Code.
No welder may weld with a particular welding process unless, within the
preceding 6 calendar months, he has engaged in welding with that process.
A welder may not weld unless within the preceding 6 calendar months the
welder has had one weld tested and found acceptable under API Standard
1104 Section 3 "Qualification of Welders" or Section 6 "Acceptance
Standards for Nondestructive Testing."
No welder whose qualification is based on nondestructive testing may
weld compressor station pipe and components.
When there is specific reason to question the welders ability to make
welds that meet the specification, the WPQ qualification, which supports
the welding he is doing, shall be retested. All other qualifications not
questioned remain in effect.
Contractors are responsible for the welding performed by their
organization. They will conduct the tests required to qualify their welding
procedures and each of their welders.
It is the contractors responsibility to furnish the Company with complete
copies of their welding procedure specification (WPS), procedure
qualification record (PQR), and welding performance qualifications record
(WPQ) for each welder, and any changes that occur thereto while working
for the Company. The contractor is also responsible for retaining and
maintaining complete documentation of same, and providing full access to
the Company as required.
PROCEDURE: Prior to the start of any welding, an appropriate weld procedure
shall be selected and qualified, if not presently qualified.
Each welder must be qualified to weld by the selected procedure.
All production welding must conform to the requirements of design drawings or
specifications, the selected qualified welding procedure specification (WPS), and
within the limits of the welder's performance qualification (WPQ).
The welding operation must be protected from the weather conditions that would
impair the quality of the completed weld.
Before beginning any welding:
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The welding to be performed shall be evaluated for hazards, which may
affect the safety and health of personnel working in the area or the general
public. Welding shall begin only when safe conditions are indicated.
A thorough check shall be made in or around a structure or area
containing gas facilities to determine the possible presence of a
combustible mixture.
Where welding is performed in a public area, a means to shield the
public from welding arcs shall be provided between welding and
public, or assure that public is not present during welding.
Welding surfaces must be free of defects such as laminations, cracks,
dents, gouges, grooves, and notches.
Welding surfaces must be clean and free of any material that may be
detrimental to the weld. Each joint of pipe may require swabbing to
remove all dirt and foreign materials from the inside.
Bevels shall be checked for proper dimensions and angle.
Ensure that the longitudinal seams are offset. The seams should be located
on the upper quadrant of the line and preferably within 30 degrees of top
center. Alternate joints shall be rotated to right or left at least 15 degrees to
avoid aligning the seams in adjacent joints. Exceptions to this requirement
shall be made for making bends, as the longitudinal seam must remain on
the neutral axis of the bend, and at other locations as may be indicated on
the design drawings.
The line-up shall be checked to ensure proper root spacing and alignment.
This alignment must be preserved while the root bead is being deposited.
Welding consumables shall be confirmed for correct type, proper use,
control, and handling prior to and during use. All welding rod stubs and
discarded rods shall be gathered and disposed of in a manner and place
authorized by the Company. No welding rods shall be left on or around the
working area or deposited in the ditch.
Preheated and interpass temperatures shall be maintained within the specified
ranges.
Preheating shall be required when the welding procedure indicated that
chemical composition, ambient and/or metal temperature, material
thickness, or weld-end geometry requires such treatment to produce
satisfactory welds.
The temperature shall be checked by the use of temperature-indicating
crayons, thermocouple pyrometers, or other suitable methods to assure
that the required preheat temperature is obtained prior to and maintained
during the welding operation.
Grinding and cleaning of the stringer (root) bead shall be completed prior to
depositing subsequent filler passes.
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Welds in carbon steels having a high carbon content which requires stress
relieving by the applicable code (API 1104, ANSI 31.3, 31.4, 31.8) shall be stress
relieved as prescribed in ASME Boiler and Pressure Vessel Code, Section VHL.
Stress relieving may also be advisable for welds in steel having lower carbon or
carbon equivalent when adverse conditions exist which cool the weld too rapidly.
Welds in carbon steels shall be stress relieved when the wall thickness
exceeds 1-1/4 in (3.81 cm).
Mark and ensure that all arc burns are removed and repaired. A ground may not
be welded to the pipe or fitting that is being welded.
A miter joint is not permitted (not including defections up to 3 degrees that are
caused by misalignment). Any weld, which is not at right angles to the axis of the
pipe, will be considered a mitered weld, unless the angle is specifically called for
on the design drawings.
Weld numbers and welder identification numbers shall be applied using
waterproof crayon, paint pens, or similar markers on the pipe coating adjacent to
the weld for temporary identification. Marks shall be made on the top of the pipe
approximately 1 foot (0.30 meters) from the cutbacks on the pipe coating, and
shall be visible after joint coating is complete.
A permanent record in the form of weld maps shall be made indicating the
location of all welds that can be cross-referenced to the weld's nondestructive
testing and to the welder making the weld.
REPAIR OR REMOVAL OF WELD DEFECTS - Qualified procedures and
currently qualified welders are required for all repair work.
Each weld that is found unacceptable must be removed or repaired. A weld must
be completely removed if it has a crack of any length in the weld.
Each weld that is repaired must have the defect removed down to sound metal and
the segment to be repaired must be preheated if conditions exist which would
adversely affect the quality of the weld repair. After repair, the segment of the
weld that was repaired must be inspected to ensure its acceptability.
Re-repair of welds is not permitted, except as outlined below. Defects found in
repair areas shall be removed by cutting out the weld as a whole.
Repair of a crack, or of any defect in a previously repaired area must be in
accordance with written weld repair procedures that have been specifically
qualified according to previously listed procedures for the re-repair.
Repair procedures must provide that the minimum mechanical properties
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specified for the welding procedure used to make the original weld are met
upon completion of the final weld repair.
An arc burn may be repaired by completely removing the notch by grinding, if the
grinding does not reduce the remaining wall thickness to less than the minimum
thickness required by the tolerances in the specification to which the pipe is
manufactured. If a notch is not repairable by grinding, a cylinder of the pipe
containing the entire notch must be removed.
RECORDS: Insert copies of the WGS Form 120 Weld Test Report that
identifies the welding procedures used, the location of the welds, the welders
used, and the results of all-nondestructive testing in the pipeline historical file.
Insert copies of pipe and fitting material qualifications, as-built drawings, and
hydrostatic test records in the pipeline historical file.
Maintain records for the life of the facility.
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Gas Pipeline
SECTION 4.0 ABNORMAL OPERATIONS

4.1
Checking Variations from Normal Operation after Abnormal

Operation
CODE REFERENCE: Title 49 CFR 192.605(c)(2)
PURPOSE: To insure the continued integrity and safe operation of the
pipeline(s) or facilities during and after an "abnormal" event by investigating
sufficient critical locations in the system, determining the cause and correcting the
problem as soon as practical.
GENERAL: Abnormal operation is defined as "the condition that exists when
operating design limits have been exceeded". These may be pressure limits or
some other occurrence that is outside the realm of normal operating limits. If
abnormal operating conditions are left uncorrected it could result in the unsafe
operation of the pipeline and possibly an accident. All pipeline operations will be
conducted with an increased level of awareness and care until the abnormal
condition is corrected. Documentation will insure that a record of the abnormality
is made and that subsequent shifts of operators will be informed of the
occurrence.
Abnormal events may be the result of sabotage or vandalism, personnel error,
mechanical or electrical failure of some equipment. The cause must be found and
corrected as soon as possible. The pipeline may continue operation if safeguards
are taken to prevent a recurrence.
PROCEDURE: Check variations from normal operation after abnormal
operation has ended by looking at critical locations in the pipeline system.
Ensure that all components of the operating system have been returned to normal
operating mode.
RECORDS: Document the abnormal event and how it was corrected on forms
WGS Form 101 Notice and Disposition of Reported Incident.
Inform all field personnel of the abnormal event and corrective actions taken.
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4.2
Flow Rate Increase

CODE REFERENCE: Title 49 CFR 192.605(c)(1)(ii)
PURPOSE: To identify examples of an increase in flow rates and establish
corrective actions to take for correcting the increase in flow rate.
GENERAL: An increase in flow rate above "normal limits" may not create a
problem unless accompanied by an increase in pressure above the normal limits.
Nevertheless, a flow rate can be "abnormal" and for the purpose of this section of
the Operating manual shall mean "any flow rate over 1 MMSCFD gas more or
less than the normally observed flow rates for the current operating conditions".
The cause must be found and corrected or accounted for as soon as possible. The
pipeline may continue operation if safeguards are taken to prevent over-pressuring
or exceeding the physical limits of equipment.
INDICATIONS OF INCREASED FLOW RATE - The occurrence of the
following items either separately or collectively may indicate an increase in flow
rate:
Abnormally high meter rates or tank fill rates
Abnormally high pressure will most likely accompany an excessive flow
rate
CORRECTIVE ACTION - The Production Coordinator, or in his absence the
next in command, shall be advised of the situation as soon as possible so that
immediate action may be taken to correct the situation. The Production
Coordinator shall begin an investigation to determine the cause of the abnormal
event. The Production Coordinator shall also take steps to prevent the recurrence
of the event.
Corrective actions include the following:
On lines fed by centrifugal pumps:
Check the hydraulic conditions on the pipeline, including oil characteristics;
Check the backpressure valve at the delivery meter facility for proper set
pressure and actuation;
Check for any change out of pumping equipment that has not been reported.
On lines fed by positive displacement pumps:
Check for change-out of any pumping equipment that has not been reported
yet;
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Check for change-out of metering equipment that may be giving erroneous
readings.
On lines fed by compressor:
Check for change out of any compressor equipment that has not been reported
yet;
Check for changes or damage to metering equipment that may be giving
erroneous readings;
Check gas engine driven compressors for RPM control and suction pressure
controls to the compressor inlet.
If no leakage is evident, then the line should be pressurized to the desired level
and held for a minimum of thirty minutes. If line pressure will not hold, the line
shall be patrolled for leakage or backflow into storage through leaking valves or
malfunctioning relief valves.
RECORDS: Plant Operations shall document the abnormal event and corrective
action taken on forms WGS Form 101 Notice and Disposition of Reported
Incident.
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4.3
Flow Rate Decrease

PURPOSE: To identify examples of a decrease in flow rates and establish
corrective actions to take for correcting the decrease in flow rate.
GENERAL: A decrease in flow rate below "normal limits" may be a result of a
leak, incorrect readings, equipment failure or other causes. The cause must be
found and corrected or accounted for as soon as possible. The pipeline may
continue operation if safeguards are taken to insure that a leak does not exist and
that equipment will not be damaged as a result of the low flow.
INDICATIONS OF DECREASED FLOW RATE - The occurrence of the
following items either separately or collectively may indicate a decrease in flow
rate:
Abnormally low meter rates or fill rates
Abnormally low pressure will most likely accompany a reduced flow rate
A report of a leak, (this constitutes an emergency event, see Section 5.0 of
this manual)
Shutdown on high levels or high at injection points
of the event.
On lines fed by positive displacement pumps:
Check for change-out of any pumping equipment that has not been
reported yet
Check for change-out of metering equipment that may be giving erroneous
readings
On lines fed by compressors:
Check that compressor is still up and running
Check for change out of any compression equipment that has not been
reported yet
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Check flow meters for malfunctions
Check RPM controllers on gas engine driven compressors
Check that compressor is loaded and not in bypass
On all lines:
Inspect for leaks
Check for clogged strainers or restricted piping on suction side of pumps
Compare injection meters with delivery meters
If no leakage is evident, then the line should be pressurized to the desired level
and held for a minimum of thirty minutes. If line pressure will not hold, the line
shall be patrolled for leakage or backflow into storage through leaking valves or
malfunctioning relief valves.
Incident.
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4.4
Pressure Increase In
PURPOSE: To identify examples of an increase in pressure and establish
corrective actions to take for correcting the pressure to normal operations mode.
GENERAL: An increase in pressure above the normal limit is defined as any
pressure more than 50 psi above the normally observed pressure for the current
operating conditions. The pipeline may continue operation if safeguards are taken
to prevent over pressuring of the line.
INDICATIONS OF INCREASED PRESSURE - The occurrence of the
following items either separately or collectively may indicate an increase in
pressure:
Abnormally high delivery pressure
Abnormally high pressure at any point along the pipeline
Observed pressure above the set point of a control valve
Observed pressure higher than the set point of any safety device
immediate action may be taken to correct the situation. If the pipeline pressure is
above normal the pipeline shall remain shutdown until supervisory personnel are
certain that the pipeline is structurally sound. The Production Coordinator shall
begin an investigation to determine the cause of the abnormal event. The
Production Coordinator shall also take steps to prevent the recurrence of the
event.
Check the hydraulic conditions on the pipeline, including oil and gas
characteristics
Check the position of block valves that may block the discharge of pumps
or compressors
Check for third party construction damage on the pipeline
Check maintenance records or personnel for changes made to pumps
In cold weather, check for possibility of hydrate blockages
If no other cause for the pressure increase is found, consider running a pig or pigs
to clean the line. If no leakage is evident, then the line should be pressurized to
the desired level and held for a minimum of thirty minutes as a test.
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Incident.
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4.5
Pressure Decrease In
PURPOSE: To identify examples of a decrease in pressure and establish
corrective actions to take for correcting the pressure to normal operations mode.
A decrease in pressure below the normal limit is defined as any pressure more
than 50 psi below the normally observed pressure for the current operating
conditions. The pipeline may continue operation if additional precautionary
measures are taken.
INDICATIONS OF DECREASE IN PRESSURE - The occurrence of the
following items either separately or collectively may indicate a decrease in
pressure:
Abnormally low delivery pressure
Abnormally low pressure at any point along the pipeline
Low flow rate at the delivery or shipping point
designee, shall be advised of the situation as soon as possible so that immediate
action may be taken to correct the situation. The Production Coordinator shall
begin an investigation to determine the cause of the abnormal event. The
Production Coordinator shall also take steps to prevent the recurrence of the
event.
Check the hydraulic conditions on the pipeline, including oil and gas
characteristics.
Check the position of block valves that may block the discharge of pumps
or compressors, particularly if low pressure on the delivery end of the
pipeline is coupled with normal or high pressure on the shipping end of
the line.
Check for third party construction damage or changes made to the
pipeline.
Check for clogged strainers or suction lines to pumps or compressors.
Check for failed meter equipment.
Check for simmering or non-reseating relief valves.
If no leakage is present, then the line should be pressurized to the desired level
and held for a minimum of thirty minutes as a test. If line pressure will not hold,
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the line shall be patrolled for leakage or back flow into storage through leaking
valves or malfunctioning relief valves.
Incident.
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4.6
Unintended Shutdown
CODE REFERENCE: Title 49 CFR 192.605(c)(1)(i)
PURPOSE: To identify examples of an unintended shutdown and establish
corrective actions to take for correcting the abnormal event and returning to
normal operations.
INDICATIONS OF AN UNINTENDED SHUTDOWN - The occurrence of the
following items either separately or collectively may indicate an unintended
shutdown:
Low or stopped flow rate at the delivery point
Reduced pressure at the delivery point
Decreased pressure at the shipping point
Pump(s) shutdown due to high pressure.
Witness to an event
of the event. The pipeline may continue operation if safeguards are taken to
prevent a recurrence.
Dispatch personnel to the scene of the shutdown
Check the pressure chart for excessive pressure
Check the pump's breakers and fuses
Look for signs of vandalism, sabotage, or accidental shutdown
Attempt to re-start the pump. If it will start, monitor the operation until the
line is in a steady state condition once more. Monitor the discharge
pressure gauge while the pump is running.
Check for high temperatures on engines, motors, and switchgear
Incident.
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4.7
Unintended Valve Closure

CODE REFERENCE: Title 49 CFR 192.605(c)(1)(i)
PURPOSE: To identify examples of an unintended valve closure and establish
normal operations.
INDICATIONS OF AN UNINTENDED VALVE CLOSURE - The occurrence
of the following items either separately or collectively may indicate an unintended
valve closure:
Low or stopped flow rate at the delivery point
Reduced pressure at the delivery point
Increased pressure at the shipping point
Pump(s) shutdown due to high pressure
Witness to the event
designee, shall be advised of the situation as soon as possible so that immediate
action may be taken to correct the situation. In the event of an inadvertent main
valve closure, the pipeline segment shall be shut down immediately. If the
pipeline pressure is above normal the pipeline shall remain shutdown until
supervisory personnel are certain that the pipeline is structurally sound. The
Production Coordinator shall begin an investigation to determine the cause of the
abnormal event. The Production Coordinator also shall take steps to prevent the
recurrence of the event.
Open the valve
If electrically actuated, cause the valve to be locked in the open position
by opening the breaker for the valve's power or the breaker switch on the
control circuit. Follow-up to see why the valve doesnt operate normally.
If manually actuated, secure the valve such that the valve cannot be closed
or will not vibrate closed.
Incident.
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4.8
Safety Device Actuation of

CODE REFERENCE: Title 49 CFR 192.605(c)(1)(iv)
PURPOSE: To identify examples of an unintended shutdown and establish
normal operations.
GENERAL: The actuation of a safety device includes the use or actuation of any
safety device, such as relief valves, rupture disc, fire alarms, emergency stop
switches, pressure shutdown devices on centrifugal pumping equipment, etc.
The Production Coordinator shall be advised of the actuation of any safety device
as soon as possible so that immediate action may be taken to correct the situation.
The Production Coordinator shall begin an investigation to determine the cause of
the abnormal event. The Production Coordinator shall also take steps to prevent
the recurrence of the event.
If an event caused personnel to actuate some safety device the Production
Coordinator shall be notified and the person actuating the safety device shall
make a written report of his actions to the Production Coordinator.
RECORDS: Upon notification of a safety device actuation, the Production
Coordinator shall document the abnormal event and corrective action taken on
forms WGS Form 101 Notice and Disposition of Reported Incident.
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4.9
Loss of Communications
CODE REFERENCE: Title 49 CFR 192.605(c)(1)(iii)
PURPOSE: To establish a procedure for communication when normal means are
not available.
GENERAL: The field office location utilizes cellular telephones and radios so
communication is essentially always available. When either a conventional
telephone or radio outage exists, the control center will inform the responsible
parties for repair/maintenance. If telephone service is not restored in a reasonable
time, radios can be used at critical locations for communication. If radio
communications are not restored in a reasonable time, then the control center
should investigate other means of communication to ensure critical areas are
covered.
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4.10 Notifying Operating Personnel of Abnormal Event

PURPOSE: To establish notification procedure for abnormal events.
GENERAL: Immediately upon discovery of an abnormal event, the initial
witness shall notify appropriate operating personnel via cellular phone, and/or
radio so that response procedures can be activated and corrective action taken.
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4.11 Personnel Error

CODE REFERENCE: Title 49 CFR 192.605(c)(1)(v)
PURPOSE:
errors.
To establish procedure for identifying and correcting personnel
GENERAL: Events caused by personnel are to be handled in the same manner

as described in Section 4.12 with additional emphasis being placed on training of
the personnel that work on tasks with potential for causing errors.
Such events shall be reported to the Production Coordinator who shall see that an
investigation is made and corrections made as necessary.
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4.12 Review of Personnel Actions During Abnormal Event

PURPOSE: To determine the adequacy of personnel responses and actions to
abnormal operating conditions.
GENERAL: These procedures are mandatory for all gas pipelines operated
and/or owned by Wild Goose Storag that are governed by 49 CFR Part 192. On
non-jurisdictional pipelines, these procedures should be utilized but are not
mandatory.
REVIEW OF PERSONNEL ACTIONS: Following each abnormal event the
actions of those personnel involved in the event should be reviewed for the
following:
Was the action timely?
Was the action proper?
Were there alternatives to the action taken?
If so, would they have been more effective?
Was the action taken with "safety first" in mind?
Could the incident have been prevented through the actions or reactions of
the personnel?
Are there any other pertinent areas concerning the event that should be
reviewed?
The Production Coordinator shall perform this review and the results shall be
entered and/or attached to the documentation initiated for this event.
RECORDS: Document findings from the review and discuss with personnel to
correct and improve areas where the response was lacking or give positive
feedback for appropriate actions.
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4.13 Review of Written Procedures for Abnormal Events

CODE REFERENCE: Title 49 CFR Part 192.605(c)(2)
PURPOSE: To determine if written procedures are adequate in addressing
abnormal operating conditions and to take corrective action where deficiencies are
found.
GENERAL: These procedures are mandatory for all gas pipelines operated
and/or owned by Wild Goose Storage that are governed by 49 Code of Federal
Regulations Part 192. On non-jurisdictional pipelines, these procedures should be
utilized but are not mandatory.
REVIEW OF ABNORMAL EVENT PROCEDURES - Following each
abnormal event the Production Coordinator shall review the procedures used in
the detection, investigation, and correction of the abnormal event for their
effectiveness. To aide in this review the following questions may serve as a
guide:
Did a procedure exist for this incident?
Was it used?
Was it effective?
What, if any, were its shortcomings?
What, if any, recommendations would you make for changing or creating
new procedures?
RECORDS: The Production Coordinator shall perform this review and the
results shall be entered and/or attached to the documentation initiated for this
event. Recommendations shall be incorporated into this manual and immediately
reviewed with operations personnel in a meeting.
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SECTION 5.0 EMERGENCY PROCEDURES
Operations, Maintenance and Emergency Procedures Manual

Gas Pipelines
SECTION 5.0 EMERGENCY PROCEDURES

5.1
Emergency Response Plan

CODE REFERENCE: Title 49 CFR Part 192.615
PURPOSE: To establish procedures for taking action in the event of an
emergency. NOTE: There is a separate Emergency Response Plan that has more
detail for responding to a release or other emergency. This procedure is a basic
guideline.
GENERAL: No emergency plan can cover all situations and is no substitute for
the application of good judgment by persons involved in emergency situations.
The specific provisions of the Emergency Plan shall be reviewed annually to
ensure that it continues to provide proper guidance for Company employees.
PROCEDURE: During an emergency, the field office shall serve as the incident
command center and all activities shall be coordinated through that office.
Operating personnel in the field shall keep the Niska Operation & Engineering
office advised of the progress of the work, and the Production Coordinator shall
keep concerned personnel advised of the current status of the emergency.
All operating personnel shall be familiar with the emergency response procedures.
These procedures shall be discussed at periodic Company safety meetings as part
of a training and continuing education program. Appropriate procedures shall be
reviewed for various hypothetical and past emergencies.
COMMUNICATION - Communication is one of the most important elements in
any emergency. When an emergency arises, the field office shall establish
communication with each operating area of the emergency, with the operations
employees, and with other concerned personnel. Public and cellular telephones
shall also be used as required. If necessary, phone lines shall be kept open for the
duration of the emergency. A log shall be kept of all communications concerning
the emergency.
MAPS - In order to quickly respond to an emergency, all operating personnel
shall be thoroughly familiar with the system. Suitable maps and drawings shall be
available showing the location of all valves and other key facilities. All operating
personnel shall be familiar with the valve locations at the plant and along the
pipeline. Operating personnel shall be instructed as to the operation of valves and
emergency equipment, and be familiar with the properties and hazards of natural
gas.
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LANDOWNERS - Landowners adjacent to the pipeline right-of-way shall be
informed of the pipeline's location, and shall be provided with stickers, cards, etc.
with the Company's name and emergency phone number.
EQUIPMENT - Frequent inspections shall be made of all emergency equipment,
tools, materials, and safety devices to ensure that such equipment is in satisfactory
condition and available for use in an emergency.
Company-owned safety equipment shall be maintained in good working order at
all times. This equipment typically includes:
First aid kits,
Gas detectors,
Fire extinguishers,
PPE - Hard hats, safety glasses, boots, gloves, hearing protection
The use of emergency loan equipment owned by construction Contractors located
in the general area is often necessary or expedient to most efficiently cope with an
emergency. Examples of such equipment are tractors, cranes, backhoes, air
compressors, welding machines, etc. The Production Coordinator shall determine
what equipment is available from these sources and maintain a record.
NOTIFICATION - The Company representative receiving notice of events that
may require an immediate response by the Company shall request and note any
appropriate information about the event and should include the following:
Name and telephone number of the person reporting the event,
Exact location and nature of event,
Any additional names and telephone numbers of persons who may be able
to supply additional information about the event or may be able to assist in
responding to the events.
As necessary, the Production Coordinator or Incident Commander shall send
written notification to each public agency listed on the Emergency Notification
List that the Company operates a gas system within that agencys area of
responsibility. The nature of the systems operation shall be described and a
request be made for a meeting with the public agency to review potential
emergency response by the agency. A current list of names and telephone
numbers of Company personnel associated with the gas system shall be included.
The WGS Form 121 Emergency Call List will be used for this purpose. In
addition this form will be posted at the Niska Operation and Engineering office
and the Field Office for immediate reference during an emergency. Records of
contacts with public agencies shall be retained in the Company D.O.T. records.
WGS Form 122 General Report-Meetings/Contacts, will be used for this
purpose.
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Gas Pipelines
Participation in volunteer fire and civil defense meetings may be useful in
developing the liaison.
EMERGENCY CONDITIONS - The Production Coordinator or Incident
Commander, based on the information received, shall determine if an emergency
condition exists and whether extraordinary procedures, equipment, manpower,
and/or materials are needed to protect the public from actual or potential hazards.
Emergency conditions may include, but are not limited to:
Facility failures that may result in:
Under pressure in the system
Over pressure in the system
Large amounts of escaping gas
Fire or explosion
Any leak considered hazardous
Exposure to outside forces, which could create danger to the integrity of
the system and to the public
Natural disasters (floods, tornadoes, earthquakes, fires from lightening
strikes, etc.)
Civil disturbances (riot, etc.).
Upon establishing that an emergency condition exists the Production Coordinator
or Incident Commander shall notify the appropriate persons on the WGS Form
121 Emergency Call List and refer to these emergency procedures and those in
the Wild Goose Facility ERP manual or other company policies for response
actions.
EMERGENCY ACTION - An employees first awareness of an emergency
shall prompt him to make notification to the Production Coordinator and Lead
Operator so that an Incident Command Structure can be initiated if necessary.
Next, take immediate action to prevent injury or death to all persons at the scene
of the emergency within the level of training and experience of the responder.
The action taken depends on the nature of the emergency and may include, but is
not limited to, such steps as
Closing valves to stop flow toward a fire;
Venting gas to relieve excess pressure; and
Activating fire fighting equipment.
Steps should then be taken to minimize damage to the property of the Company
and others.
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Gas Pipelines
A list of available equipment, material, and contractor personnel that may be
useful in responding to an emergency is included on the WGS Form 121
Emergency Call List. This list is to be reviewed at least annually. Immediately
after the emergency is brought under control, the accident site must be secured
and all evidence preserved to allow a comprehensive investigation.
SYSTEM MAPS In the event of a gas emergency, personnel responding to the
emergency should refer to the system map.
Company field employees shall be provided system maps with the location of key
valves, meters, pumps, and other related equipment, which may require operation
during an emergency. This shall be considered part of the emergency response
training program.
The system map shall be reviewed on an annual basis to verify that the map
accurately reflects the location of the systems and action shall be taken to revise
the system map should it require revisions.
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5.2
Control Room Management and Human Factors

CODE REFERENCE: Title 49 CFR Part 192.3, .605, .615, 192.631
PURPOSE: This program applies to the operator of a pipeline facility with a
controller working in a control room that monitors and controls all or part of a
pipeline facility through a SCADA system.
SCOPE: Wild Goose Storage must have and follow written control room
management procedures that implement the requirements of the regulations,
except that for each control room where an operator's activities are limited to
either or both of:
1.
2.
Distribution with less than 250,000 services, or

Transmission without a compressor station, the operator must have and
follow written procedures that implement procedures for fatigue,
compliance validation, and compliance and deviations of the regulatory
requirements for control room management and human factors.
GENERAL: The required procedures must be integrated, as appropriate, with

operating and emergency procedures required by Sec. Sec. 192.605 and 192.615.
Procedures must be developed no later than August 1, 2011 and implemented no
later than February 1, 2013. The full program can be found as a separate
document from this O&M manual.
ROLES AND RESPONSIBILITIES: Roles and responsibilities must be
defined for a controller during normal, abnormal, and emergency operating
conditions. To provide for a controller's prompt and appropriate response to
operating conditions, the Company must define each of the following:
1.
2.
3.
4.
A controller's authority and responsibility to make decisions and take

actions during normal operations;
A controller's role when an abnormal operating condition is detected, even
if the controller is not the first to detect the condition, including the
controller's responsibility to take specific actions and to communicate with
others;
A controller's role during an emergency, even if the controller is not the
first to detect the emergency, including the controller's responsibility to
take specific actions and to communicate with others; and
A method of recording controller shift-changes and any hand-over of
responsibility between controllers.
PROVIDE ADEQUATE INFORMATION: The Company must provide its

controllers with the information, tools, processes and procedures necessary for the
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169
controllers to carry out the roles and responsibilities the Company has defined by
performing each of the following:
1.
2.
3.
4.
5.
Implement sections 1, 4, 8, 9, 11.1, and 11.3 of API RP 1165

(incorporated by reference, see Sec. 192.7) whenever a SCADA system is
added, expanded or replaced, unless the operator demonstrates that certain
provisions of sections 1, 4, 8, 9, 11.1, and 11.3 of API RP 1165 are not
practical for the SCADA system used;
Conduct a point-to-point verification between SCADA displays and
related field equipment when field equipment is added or moved and when
other changes that affect pipeline safety are made to field equipment or
SCADA displays;
Test and verify an internal communication plan to provide adequate
means for manual operation of the pipeline safely, at least once each
calendar year, but at intervals not to exceed 15 months;
Test any backup SCADA systems at least once each calendar year, but at
intervals not to exceed 15 months; and
Establish and implement procedures for when a different controller
assumes responsibility, including the content of information to be
exchanged.
FATIGUE MITIGATION: The Company must implement the following

methods to reduce the risk associated with controller fatigue that could inhibit a
controller's ability to carry out the roles and responsibilities the operator has
defined:
1.
2.
3.
4.
Establish shift lengths and schedule rotations that provide controllers offduty time sufficient to achieve eight hours of continuous sleep;
Educate controllers and supervisors in fatigue mitigation strategies and
how off-duty activities contribute to fatigue;
Train controllers and supervisors to recognize the effects of fatigue; and
Establish a maximum limit on controller hours-of-service, which may
provide for an emergency deviation from the maximum limit if necessary
for the safe operation of a pipeline facility.
ALARM MANAGEMENT: The Company must have a written alarm

management plan to provide for effective controller response to alarms. An
operator's plan must include provisions to:
1.
2.
Review SCADA safety-related alarm operations using a process that

ensures alarms are accurate and support safe pipeline operations;
Identify at least once each calendar month points affecting safety that have
been taken off scan in the SCADA host, have had alarms inhibited,
generated false alarms, or that have had forced or manual values for
periods of time exceeding that required for associated maintenance or
operating activities.
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3.
4.
5.
6.
Verify the correct safety-related alarm set-point values and alarm

descriptions at least once each calendar year, but at intervals not to exceed
15 months;
Review the alarm management plan required by this paragraph at least
once each calendar year, but at intervals not exceeding 15 months, to
determine the effectiveness of the plan;
Monitor the content and volume of general activity being directed to and
required of each controller at least once each calendar year, but at intervals
not to exceed 15 months, that will assure controllers have sufficient time
to analyze and react to incoming alarms; and
Address deficiencies identified through the implementation of these
procedures.
CHANGE MANAGEMENT: The Company must assure that changes that

could affect control room operations are coordinated with the control room
personnel by performing each of the following and documenting on WGS Form
124 Management of Change:
1.
2.
3.
Establish communications between control room representatives,

operator's management, and associated field personnel when planning and
implementing physical changes to pipeline equipment or configuration;
Require its field personnel to contact the control room when emergency
conditions exist and when making field changes that affect control room
operations; and
Seek control room or control room management participation in planning
prior to implementation of significant pipeline hydraulic or configuration
changes.
OPERATING EXPERIENCE: The Company must assure that lessons learned

from its operating experience are incorporated, as appropriate, into its control
room management procedures by performing each of the following:
1.
Review incidents that must be reported pursuant to 49 CFR part 191 to

determine if control room actions contributed to the event and, if so,
correct, where necessary, deficiencies related to:
a.
b.
c.
d.
e.
f.
2.
Controller fatigue;
Field equipment;
The operation of any relief device;
Procedures;
SCADA system configuration; and
SCADA system performance.
Include lessons learned from the operator's experience in the training

program.
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TRAINING: The Company must establish a controller training program and

review the training program content to identify potential improvements at least
once each calendar year, but at intervals not to exceed 15 months. An operator's
program must provide for training each controller to carry out the roles and
responsibilities defined by the operator. In addition, the training program must
include the following elements:
1.
2.
3.
4.
5.
Responding to abnormal operating conditions likely to occur

simultaneously or in sequence;
Use of a computerized simulator or non-computerized (tabletop) method
for training controllers to recognize abnormal operating conditions;
Training controllers on their responsibilities for communication under the
operator's emergency response procedures;
Training that will provide a controller a working knowledge of the
pipeline system, especially during the development of abnormal operating
conditions; and
For pipeline operating setups that are periodically, but infrequently used,
providing an opportunity for controllers to review relevant procedures in
advance of their application.
COMPLIANCE VALIDATION: Upon request, the Company must submit their

procedures to PHMSA or, in the case of an intrastate pipeline facility regulated by
a State, to the appropriate State agency.
RECORD KEEPING - COMPLIANCE AND DEVIATIONS: The Company
must maintain for review during inspection:
1.
2.
3.
Records that demonstrate compliance with these requirements; and

Documentation to demonstrate that any deviation from the procedures
required by this section was necessary for the safe operation of a pipeline
facility.
Any change to the facility is documented on WGS Form 124
Management of Change.
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SECTION 6.0 TRAINING

Gas Pipelines
SECTION 6.0 TRAINING

6.1
Training
CODE REFERENCE: Title 49 CFR Parts 192.605
PURPOSE: To ensure that each employee is capable of performing his/her job
safely and efficiently.
GENERAL: Training of personnel is important to the safe and efficient
operation of pipelines and their facilities. Training may take on several different
forms in order to be effectively used. Training may be formal classroom training,
on-the-job training with close supervision, schools and seminars outside the
company, and simulated condition training both within and outside of the
company.
TRAINING RESPONSIBILITES - The Corporate Office has the ultimate
responsibility for the training program and shall review the overall program and
its effectiveness at least once each calendar year, at intervals not exceeding 15
months. Specific training responsibilities shall be delegated to others as
necessary.
LESSON PLAN - The lesson plan shall contain at least the following
information:
Name of the training subject.
Name of the training instructor.
The D.O.T. paragraph number that applies to this training.
The objective of the training.
A detailed description of the training, including names of training films,
books, section of operating manuals, and/or text to be presented to the
trainees.
A copy of all handout materials to be presented in the sessions.
Once developed these lesson plans shall serve as the basis for future training.
New plans need not be developed for each session on the same subject as long as
the plan is still applicable and correct.
DESCRIPTION OF TRAINING PROGRAM - The training program shall use
all available resources such as the Operations and Maintenance Manual,
Emergency Response Procedures Manual, videos, outside seminars and schools,
and on-the-job training supervised by the Production Coordinator, the Lead
Operator or Qualified Designate.
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Gas Pipelines
SCHEDULING OF TRAINING - The Production Coordinator and EH&S
Coordinator shall develop an annual schedule of training for the coming year.
Employees shall be scheduled for training required of their position, and Federal
and State laws. These sessions may be combined with other training efforts
conducted by the company.
New employees shall receive the regularly scheduled training as well as specific
training in their job area on an intensified basis until that person can adequately
perform the job. Much of this training will be on-the-job training (OJT), but each
session should be planned and documented with a Training Plan.
TRAINING PROGRAMS - The training programs shall address the six major
categories required by the U.S. Department of Transportation, Office of Pipeline
Safety. The categories and the personnel to whom each is applicable are:
1.
Carrying out the operating, maintenance, and emergency procedures

established in the O&M Manual.
Applicable for all operations and maintenance personnel. Each person
must receive at a minimum, training specific to his job duties.
2.
Knowing the characteristics and hazards of natural or other gas transported

including such things as: flammability, vaporizing characteristics, and
reactions with water.
Applicable to all personnel whose duties involve handling or contact with
situations where the need for this training might arise. Also includes
those personnel on the Emergency Response Team or involved in the
cleanup and repair of leaks.
3.
Recognizing conditions that are likely to cause emergencies, predicting the

consequences of facility malfunctions or failures and natural gas releases
or leaks, and taking appropriate corrective action.
Applies to all field personnel.
4.
Taking steps necessary to control any accidental release of natural or other

gas and to minimize the potential for fire, explosion, toxicity, or
environmental damage.
Applies to those personnel on the Emergency Response Team and those
who may be actively involved in the cleanup of a release or leak.
5.
Learning the proper use of fire fighting procedures, equipment, and

breathing apparatus by utilizing, where feasible, a simulated pipeline
emergency condition.
Applicable to all field personnel.
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Gas Pipelines
6.
In the case of maintenance personnel, learning to safely repair facilities

using appropriate special precautions such as isolating and purging when
highly volatile liquids are involved.
Applicable to all maintenance personnel, such as the Pipeline Operator,
Mechanic, Corrosion Technician, Electrical Technician, the Pipeline
Inspector, and the Production Coordinator.
RECORDS: All training shall be documented and include the following:

Name of trainee
Date
Type of training
Objective of training
Means of testing trainees knowledge of material
Instructor(s)
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Gas Pipelines
6.2
Qualification Program
PURPOSE: To ensure that each employee working on a D.O.T. regulated
pipeline is qualified to perform his/her covered job tasks safely and efficiently.
GENERAL: Operators must follow a written qualification program that is in
place by April 27, 2001. Operators must complete the qualification of individuals
performing covered tasks by October 28, 2002. A work performance history
review may be used as a sole evaluation method for individuals who were
performing a covered task prior to August 27, 1999. However, after October 28,
2002 work performance history may not be used as a sole evaluation method.
D.O.T. Operator Qualification forms are located in the OQ program separate from
this manual and can be used in conjunction with the written qualification
program.
PROGRAM ELEMENTS The written operator qualification program shall
include the following:
Identification of covered tasks;
Evaluation that individuals performing covered tasks are qualified;
Allows individuals that are not qualified to perform a covered task if
directed and observed by an individual that is qualified;
Evaluate an individual if the operator has reason to believe that the
individuals performance of a covered task contributed to an incident as
defined in Part 191;
Evaluate an individual if the operator has reason to believe that the
individual is no longer qualified to perform a covered task;
Communicate changes that affect covered tasks to individuals performing
those covered tasks; and
Identify those covered tasks and the intervals at which evaluation of the
individuals qualifications is needed.
RECORDS: The Production Coordinator shall maintain records of qualification
training. The records shall include:
Identification of qualified individuals;
Identification of the covered tasks the individual is qualified to perform;
Dates of current qualifications; and
Qualification methods.
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Gas Pipelines
Records supporting an individuals current qualification shall be maintained while
the individual is performing the covered task. Records of prior qualification and
records of individuals no longer performing covered tasks shall be retained for
five (5) years.
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Gas Pipelines
6.3
Control Room Management Training

See Section 5.2 of this manual for training details
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GLOSSARY OF TERMS

Gas Pipelines
GLOSSARY OF TERMS
Administrator means the Administrator of the Research and Special Programs
Administration or any person to whom authority in the matter concerned has been
delegated by the Secretary of Transportation.
Distribution line means a pipeline other than a gathering or transmission line.
Exposed underwater pipeline means a pipeline where the top of the pipe is protruding
above the seabed in water less than 15 feet deep, as measured from the mean low water.
Gas means natural gas, flammable gas, or gas which is toxic or corrosive.
Gathering line means a pipeline that transports gas from a current production facility
to a transmission line or main.
Hazard to navigation means, for the purpose of this part, a pipeline where the top of
the pipeline is less than 12 inches below the seabed in water less than 15 feet deep, as
measured from the mean low water.
High-pressure distribution system means a distribution system in which the gas
pressure in the main is higher than the pressure provided to the customer.
Line section means a continuous run of transmission line between adjacent compressor
stations, between a compressor station and storage facilities, between a compressor
station and a block valve, or between adjacent block valves.
Low-pressure distribution system means a distribution system in which the gas
pressure in the main is substantially the same as the pressure provided to the customer.
Main means a distribution line that serves as a common source of supply for more than
one service line.
Maximum actual operating pressure means the maximum pressure that occurs during
normal operations over a period of 1 year.
Maximum allowable operating pressure (MAOP) means the maximum pressure at
which a pipeline or segment of a pipeline may be operated under this part.
Municipality means a city, county, or any other political subdivision of a State.
Operator means a person who engages in the transportation of gas.
Person means any individual, firm, joint venture, partnership, corporation, association,
State, municipality, cooperative association, or joint stock association, and including any
trustee, receiver, assignee, or personal representative thereof.
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Gas Pipelines
Petroleum Gas means propane, propylene, butane, (normal butane or isobutanes), and
butylenes (including isomers), or mixtures composed predominantly or these gases,
having a vapor pressure not exceeding 1434 kPa (208 psig) at 38 deg. C (100 deg. F).
Pipe means any pipe or tubing used in the transportation of gas, including pipe-type
holders.
Pipeline means all parts of those physical facilities through which gas moves in
transportation, including pipe, valves, and other appurtenance attached to pipe,
compressor units, metering stations, regulator stations, delivery stations, holders, and
fabricated assemblies.
Pipeline facility means new and existing pipelines, rights-of-way, and any equipment,
facility, or building used in the transportation of gas or in the treatment of gas during the
course of transportation.
Service Line means a distribution line that transports gas from a common source of
supply to (1) a customer meter or the connection to a customers piping, whichever is
farther downstream, or (2) the connection to a customers piping if there is no customer
meter. A customer meter is the meter that measures the transfer of gas from an operator
to a consumer.
SMYS means specified minimum yield strength is: (1) for steel pipe manufactured in
accordance with a listed specification, the yield strength specified as a minimum in that
specification or (2) for steel pipe manufactured in accordance with an unknown or
unlisted specification, the yield strength determined in accordance with Section
192.107(b).
Transmission line means a pipeline, other than a gathering line, that: (a) transports gas
from a gathering line or storage facility to a distribution center, storage facility, or large
volume customer that is not downstream from a distribution center; (b) operates at a hoop
stress of 20 percent or more of SMYS; or (c) transports gas within a storage field. A
large volume customer may receive similar volumes of gas as a distribution center, and
includes factories, power plants, and institutional user of gas.
Transportation of gas means the gathering, transmission, or distribution of gas by
pipeline or the storage of gas, in or affecting interstate or foreign commerce.
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182
APPENDIX 1 WGS FORMS AND REPORTING REQUIREMENTS

Gas Pipelines
APPENDIX 1 WGS FORMS
FORM
Incident and Service Interruption Report
O&M MANUAL SECTION

REFERENCE
2.2; 2.3
Notice and Disposition of Reported Incident
NUMBER
WGS Form 100
WGS Form 101
Class Location Survey
WGS Form 102
2.4
Pipeline Inspection Report
WGS Form 103
2.8; 3.5; 3.6; 3.7; 3.9; 3.14
Pipeline Exposure and Inspection Report

Maximum Allowable Operating Pressure
Exceedence
Conversion of Service
WGS Form 104
2.9; 3.5; 3.6
WGS Form 105
2.10
WGS Form 106
2.13
DOT Pipeline Liaison Record of Meeting
WGS Form 107
2.15
Safety Related Condition Report
WGS Form 108
2.17
Pipeline Leak Repair Report
WGS Form 109
2.19; 3.5; 3.6; 3.13
Pipeline Abandonment Report
WGS Form 110
3.1
Remote Control Shutdown Device Test Form
WGS Form 111
3.4
Corrosion Control Report
WGS Form 112
3.5; 3.13
Cathodic Protection System Record
WGS Form 113
3.5
Rectifier Readings
WGS Form 114
3.5
Leak Investigation Report

Regulator Report
WGS Form 115
3.6; 3.13
WGS Form 116
3.10
Relief Valve Report
WGS Form 117
3.10
Hydrostatic Test Report
WGS Form 118
3.15
Valve Inspection Report
WGS Form 119
3.16
Weld Test Report
WGS Form 120
3.17
Emergency Call List
WGS Form 121
5.1
General Report Contacts and Meetings

Gas Detection and Alarm System Test and
Evaluation
Management of Change
WGS Form 122
5.1
WGS Form 123
3.4
WGS Form 124
5.2
7100.2
2.1; 2.2; 2.3
7100.2.1
2.1; 2.2; 2.3
CPUC Form
2.2
D.O.T. Form PHMSA 7100.2

D.O.T. Form PHMSA 7100.2.1
Report of Gas Leak of Interuption
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2.2, 2.3, 4.1 thru 4.8
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184
2.2 Incidents Reporting and

Control;
2.3 Investigation of Failures and
Serious Incidents
2.2 Incidents Reporting and
Control;
Serious Incidents;
4.1 Checking Variations from Normal
Operation after Abnormal
Operation;
4.2 Flow Rate- Increase;
4.3 Flow Rate Decrease;
4.4 Pressure Increase;
4.5 Pressure Decrease;
4.6 Unintended Shutdown;

Serious Incidents
2.3 Incidents Reporting and Control

Serious Incidents
2.2 Incidents Reporting and Control
Gas
2.1 Annual Pipeline Report
O&M Section
WGS Form 100
WGS Form 101
Notice and Disposition of

Reported Incident
OSHA Forms No.

300 and 300A
CPUC File No.
420.
OSHA Form No.

101
DOT Form
PHMSA 7100.2.1
DOT Form
PHMSA F 7100.2
Form number
Incident and Service

Interruption Report
Report of Gas Leak or

Interruption
OSHA Annual Summary
WGS Reports
Annual Gas Transmission &
Gathering System
Incident Report Gas
Transmission and Gathering
Lines
O.S.H.A. Individual Incident
Report
Reporting Requirements
Frequency
As needed. Refer to each

section for details.
At time of incident. If fatality

or hospitalization, then
telephonic notice is required
within 48 hours
Annually posted Feb. 1
April 30.
As needed within 2 hours if
during operating hours or 4
hours outside operating hours.
Due March 15 each calendar

year
As needed within 30 days of
detecting reportable incident

Gas Pipelines
Production
Coordinator or
designee
Production
Coordinator or
designee
Production
Coordinator
WGS EH&S
WGS EH&S
Production
Coordinator
Production
Coordinator
Whom
Responsible
Compressor Stations
3.6 Leakage Surveys: Repairing and

Reporting Leaks;
3.5 Corrosion Control
3.4
WGS Form 110

WGS Form 119
Pipeline Abandonment Form

Valve Inspection Report
Leak Investigation Report
WGS Form 115
Gas Compressor Operating

WGS Form 123
Report
Gas Detection and Alarm WGS Form 124
System Test and Evaluation
Corrosion Control Report
WGS Form 112
WGS Form 109
Pipeline Leak Repair

As needed
Weekly/Monthly
Anytime part or all of pipeline

is abandoned.
section for detail

WGS Form 108
Safety Related Condition

Report
2.19 Tapping Pipelines Under Pressure;

3.5 Corrosion Control;
3.6 Leakage Surveys
3.13 Repair Procedures and
Documentation
3.1 Abandonment or Inactivation of
Facilities
3.2 Blowdown of Pipelines
3.16 Valve Inspection and
Maintenance;
3.4 Compressor Stations
Anytime MAOP is tested or

hydrostatic tests are conducted
See each respective section for
details.
N/A
MAOP Test Records
2.10 Maximum Allowable Operating

Pressures
2.17 Safety Related Condition Report;

Once per calendar year
Various frequencies, refer to

manual
WGS Form 103
WGS Form 102
Pipeline Inspection Report
Class Location Survey
2.8 Damage Prevention Program;

3.9 Pipeline Patrolling
3.14 Rights of Way Inspection and
Maintenance
4.7 Unintended Valve Closure

2.4 Class Locations

Gas Pipelines
Person completing
work
Person completing
work
Person completing
work
Person completing
work
Person completing
work
Person completing
work
Production
Coordinator, WGS
EH&S, or designee
Operator or Tech
responding to
Underground
Service Alert
North; Person
completing work
Person completing
work
Production
Coordinator or
designee
Person performing
work
General Report (contacts and

meetings)
Management of Change
5.1 Emergency Response Plan
5.2 Control Room Management /

Human Factors
5.1 Emergency Response Plan
Weld Test Report for

Qualifying Procedure or
Welders
Emergency Call List
3.17 Welding
WGS Form 118
Hydrostatic Test Report
WGS Form 124
WGS Form 122
WGS Form 121
WGS Form 120
N/A
WGS Form 116
Regulator Inspection Report
Pressure Tests and Other

Nondestructive Testing
WGS Form 117
Relief Valve Inspection Report
3.13 Repair Procedures and

Documentation for Gas
Transmission Pipelines
3.10 Pressure Regulators and Relief
Devices
3.10 Pressure Regulators and Relief
Devices
When making contact with

government agencies during
emergencies
When making changes
Update annually with current

names and phone numbers
Anytime hydrostatic tests are

performed
Anytime pressure or
nondestructive testing is
conducted, maintain records of
results
As needed.

section for detail
At each inspection

Gas Pipelines
Production
Coordinator, WGS
EH&S, or designee
Production
Coordinator, WGS
EH&S, or designee
Person completing
work Production
Coordinator
Person completing
work
Person completing
work
Person completing
work
Person completing
work
Pipeline Engineer
APPENDIX 2 - D.O.T. and CPUC FORMS

Gas Pipelines
APPENDIX 2 D.O.T. / CPUC REPORTING REQUIREMENTS / FORMS
FORM
NUMBER
Incident Report Gas Distribution System______
PHMSA F 7100.1 (3-84)
Annual Report for Gas Distribution System______

Incident Report Gas Transmission and Gathering
Systems___________________________________
Annual Report Gas Transmission & Gathering Systems
__________________________________
PHMSA F 7100.1-1 (11-85)

PHMSA F 7100.2 (3-84)
PHMSA F 7100.2-1 (11-85)
Current copies of D.O.T. reporting forms can be obtained from

http://www.phmsa.dot.gov/pipeline/library/forms
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Appendix 2 D.O.T. Forms
6/20/13
189
Description
Additional CPUC Requirements

CPUC General
Order 112-E
Reporting to CPUC
122, Gas Incident

Reports
Report of Gas Leak
122(c) Gas Incident

Reports
Quarterly Gas Leak Summary Reports
122(e) Gas Incident

Reports
New Construction Notification
125, Proposed
Installation Report
Report of Change in Maximum Allowable

Operating Pressure
126, Change in
MAOP
Leak Survey, Aerial
CPUC Email
correspondence
Requirements
All reports required by DOT (annual reports,

incident reports, safety related condition
reports) must also be submitted to CPUC.
Report of Gas Leak, use CPUC Form 420.
This report is for leaks of escaping gas
causing property damage, including loss of
gas, in excess of $1,000.
NOTE: DOT incident report level is $50,000,
death, injury requiring hospitalization or 3 or
more people, or significant event in the
judgment of the operator.
Quarterly Summary Reports are required
by CPUC which summarize all reportable
leaks and incidents as required by the
DOT/CPUC. Additionally, this report must
include information o incidents that include
property damage between $0 and $1,000 and
involve fire, explosion, or underground digs.
Report of New Construction / Installation
must be filed with the CPUC at least 30 days
prior to construction of a new pipeline. This
report shall include the seven requirements
listed in the CPUC regulations.
Report of Change in MAOP must be filed
with the CPUC at least 30 days prior to
increase in MAOP. This report shall include:
New MAOP
Reasons for change
Steps taken to determine the
capability of the pipeline to withstand
such an increase
NOTE: DOT requires same process but not
the reporting. DOT would verify during
normally scheduled audits.
NISKA has authority from CPUC to perform
leak survey on sections of pipeline
inaccessible by walking and leak survey
instruments due to flooded rice fields. Refer
to email from Julian Ajello, April 1, 2004
Current copy of the CPUC File No. 420 can be obtained by calling the local CPUC
and requesting the form. It is currently not available online.
APPENDIX 3 - INSPECTION AND MAINTENANCE CHECKLIST
WGS Form
Number
Required Function Brief Description
Monitoring Frequency
J
A
N
F
E
B
M
A
R
A
P
R
M
A
Y
J
U
N
Gas O&M.doc
Appendix 3 Inspection and Maintenance Checklist
GAS PIPELINES
Part 191
(PHMSA 7100.2-1)
Annual report submittal
By March 15th
X
191.17
Exposed pipe inspection
Whenever pipe is exposed
192.459/475
WGS Form 113
Cathodic Protection monitoring
1x/year NTE 15 mos.
192.465(a)
WGS Form 113
Pipe-to-Soil
1x/year NTE 15 mos.
192.465
WGS Form 113
Critical Bond
6x/year NTE 2-1/2 mos.
X
X
X
192.465
WGS Form 113
Non-Critical bond
Once per year NTE 15 mos.
192.465
WGS Form 113
Electrical Isolation
Once per year NTE 15 mos.
192.465
WGS Form 114
CP Rectifier inspection
6x/year NTE 2
X
X
X
192.465(b)
WGS Form 114
CP Diode & switch inspection
6x/year NTE 2
X
X
X
192.465(c)
WGS Form 104
Unprotected pipe inspection
Every three years
192.465(e)
WGS Form 103
Internal inspection
Twice per year
X
192.477
WGS Form 112
Atmospheric corrosion inspection
Every three years
192.481
192.465-481 Supplemental Testing
Foreign Crossing Interference
Initially and as required, if survey done on recurring basis indicates the need
Soil Resistivity
Initially for magnesium anode or impressed current ground bed installations.
Current Requirement
Initially and as required to determine current density, coating condition and cathodic protection sizing.
Deep Ground Bed Date
Initially to record all ground bed data during installation.
Deep Well Anode Performance
Initially and as required to record anode current outputs and look for ground bed deterioration.
Galvanic Anode Record
Initially to record all data during installation.
Rectifier Efficiency
Initially and as required.
NA
O&M Manual review
1x/year NTE 15 mos.
X
192.605
Review O&M tasks performed by operator for
1x/year NTE 15 mos.
192.605(b)(8)
accuracy; revise as needed
WGS Form 102
Population Density/Class Location Survey
Initially / As needed
192.609
NA
Emergency Response Drill / Training
1x / year
192.615(b)
WGS Mailers
Public Awareness Program mailers
2x / year
X
192.616
Test and verify an internal communication
NA
plan to provide adequate means for manual
1x/year NTE 15 mos.
192.631
operation of the pipeline safely
NA
Test any backup SCADA systems
1x/year NTE 15 mos.
192.631
DOT Rule
Number
49 CFR - Department of Transportation - Yearly Check List
6/20/13
192
X
X
X
X
S
E
P
A
U
G
J
U
L
X
X
O
C
T
X
X
N
O
V
D
E
C
PSV inspection
PSV testing or review & calculation
Valve maintenance
WGS Form 117
WGS Form 117
By Vendor
WGS Form 119
CPUC Form
192.731
192.739
192.743
192.745
CPUC Gen.
Orders 112-E
Depends on class*
Depends on class*
As generated
1x/year NTE 15
mos.
1x/year NTE 15
mos.
1x/year NTE 15
mos.
1x/year NTE 15
mos.
Quarterly for
previous ending
quarter
1x/year NTE 15
mos.
1x/year NTE 15
mos.
1x/year NTE 15
mos.
Once per month
X
X
Gas O&M.doc
Appendix 3 Inspection and Maintenance Checklist
DOT MIS = Department of Transportation Management Information System
* 192.705 Class 1 & 2 locations twice per year. Class 3 & 4 locations 4 times per year.
* 192.706 Class 3 locations twice per year. Class 4 locations 4 times per year.
Part 199 Drug and Alcohol Testing
199.119
DOT MIS*
Anti-Drug testing results
By March 15th
199.229
DOT MIS*
Alcohol testing results
By March 15th
Quarterly Reportable/Non-Reportable
leak report
PRD in compressor stations
WGS Form 103

WGS Form 103
WGS Form 109
Review the alarm management plan
192.705
192.706
192.709
192.631
NA
NA
NA
Identify points affecting safety that

have been taken off scan in the
SCADA host, have had alarms
inhibited, generated false alarms, or
that have had forced or manual values
for periods of time exceeding that
required for associated maintenance
or operating activities
Verify the correct safety-related alarm
set-point values and alarm
descriptions
Monitor the content and volume of
general activity being directed to and
required of each controller that will
assure controllers have sufficient time
to analyze and react to incoming
alarms.
Pipeline patrolling
Leak survey
Leak repair records
192.631
192.631
192.631
NA
X
X
49 CFR - Department of Transportation - Yearly Check List
X
X
X
X
6/20/13
193

Gas Pipelines
APPENDIX 4 NISKA GAS PIPELINE DESCRIPTION
Gas O&M.doc
Appendix 4 .Sansinena Pipeline
6/20/13
194

Gas Pipelines
APPENDIX 6 PIPELINE MAPS
Gas O&M.doc
Appendix 6 . Pipeline Maps
6/20/13
195
Wild Goose Storage, LLC

Control Room Management Plan

Table of Contents
References ....................................................................................................................................... 3
I.
General ................................................................................................................................ 3
II.
Definitions........................................................................................................................... 3
III.
Roles and Responsibilities .................................................................................................. 4
IV.
Shift Change........................................................................................................................ 6
V.
Provide Adequate Information ............................................................................................ 6
VI.
Fatigue Mitigation ............................................................................................................. 12
VII. Alarm management ........................................................................................................... 16
VIII. Change management ......................................................................................................... 20
IX.
Operating Experience........................................................................................................ 21
X.
Training ............................................................................................................................. 22
XI.
Compliance validation....................................................................................................... 23
XII. Compliance and deviations ............................................................................................... 23
Control Room Mgmt Plan.com

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References
49 CFR Subpart N, 192.631 (Revised Final Rule published June 16, 2011)
API Recommended Practice Pub. 1165
I.
General
A.
This Control Room Management Plan applies to the Wild Goose Storage, LLC
pipeline facility and the controllers working in the control room who monitor and
control the pipeline facility through the SCADA system. The SCADA consists of
one control console with monitors and several RTU (Remote Terminal Units).
The control room is located at 2780 West Liberty Rd. Gridley Ca.95948 with
storage facilities at Wild Goose Club 519 Cherokee Canal Rd. Live Oak, Ca.
95953.
B.
Implementation Timelines
The plans and procedures must be established by August 1, 2011
Certain program elements need to be implemented by October 1, 2011
Implementation of remaining program elements are due August 1, 2012
Implementation of procedural elements are due on October 1, 2011, examples:
C.
Implementation of remaining program elements are due August 1, 2012,

examples:
II.
Shift Change Process

Change Management
Fatigue Awareness/Mitigation Training
Operating Experience
Hours of Service
Alarm Management
Data Point Validation
Display Standards
D.
Training must be completed as each one of these elements are deployed.
E.
The procedures required by this section must be integrated, as appropriate, with

operating, maintenance and emergency procedures required by Sec. 192.605 and
192.615. The site specific O&M Manual and Emergency Response Plan are
located at the Gridley address.
Definitions

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III.
A.
Control Center Physical location where controllers monitor and control the
pipeline systems. A control center typically consists of one or more controllers
monitoring the Scada system 24 hours a day, 365 days a year.
B.
Controller a person responsible to monitor and control the pipeline.
C.
Human Factors Engineering (HFE) The science of designing systems that are
safe, comfortable, effective, and usable. The goal is to design systems so end
users can avoid frustration, make few mistakes, and experience an increase in
productivity.
D.
Operator the company that monitors and controls a pipeline system.
E.
Pipeline Facility pipelines, pipeline systems, valves, rights-of-way, buildings,

compressors, pumps, or other equipment along the pipeline used in the
transportation of gas.
F.
PHMSA Pipeline and Hazardous Materials Safety Administration the ruling

regulatory body for oil and gas pipelines.
G.
Remote A field device, such as a Remote Terminal Unit (RTU), Programmable

Logic Controller (PLC) or Flow Computer, that communicates data and field
information to and from the SCADA host.
H.
Safety-Related Operations and Parameters For the purposes of Control Room

Management, PHMSA considers safety-related to mean any operational factor
that is necessary to maintain pipeline integrity or that could lead to the recognition
of a condition that could impact the integrity of the pipeline, or a developing
abnormal or emergency situation.
I.
SCADA Supervisory Control and Data Acquisition Systems (SCADA) a

system which is a combination of computer hardware and software used to send
command and acquire data for the purpose of monitoring and controlling
pipelines, process systems, etc.
Roles and Responsibilities

A.
Qualified Controller - responsibilities during normal, abnormal, and emergency

operating conditions for a controller's prompt and appropriate response to
operating conditions include the actions below. This is not an all inclusive list,
given the many different events that may occur during the above mentioned
operating conditions. The controller may have to determine actions based on
current operating situations and his knowledge and experience for that particular
situation. The responsibilities below are general and should cover most
situations.

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B.
1.
The controller has the full authority and responsibility to make decisions
and take actions during normal operations. This includes directing
technicians in the field to perform tasks appropriate to the operation.
2.
The controller responsible for monitoring the SCADA system is

responsible for contacting others to initiate corrective action such as
manipulate a valve or take other actions.
3.
The controller responsible for monitoring the SCADA may initiate

corrective action via the SCADA.
4.
The controller has the full authority and responsibility, when an abnormal
operating condition is detected, even if the controller is not the first to
detect the condition, to take specific actions and to communicate with
others in order to stop the abnormal operating condition.
5.
The controller has the full authority and responsibility during an

emergency, even if the controller is not the first to detect the emergency,
to take specific actions and to communicate with others on actions to take.
6.
Controllers must be qualified in all aspects of the control room for which
they will monitor and control.
7.
In emergency operations the company will allow special limited

responsibilities for individuals qualified only to return a line segment to
normal or shutdown status.
8.
The controller must document in a log book events occurring during the
shift and record controller shift-changes and any hand-over of
responsibility between controllers at the end of the shift, or anytime the
pipeline is transferred from one person to another even is there is a portion
of time when the control room is planned to be unattended.
Control Room Supervisor

1.
Control Room Supervisors may direct or advise a controller on specific

actions to take to complete a safety-related task, if and only if, the
supervisor is also a qualified controller.
2.
If the supervisor is not a qualified controller (administrative supervisor),

then the supervisor may only advise the controller on what general tasks to
accomplish, but not the precise actions that would otherwise come from a
controller-qualified supervisor.

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IV.
Shift Change
A.
Coverage for the controller is based on the controllers proximity to the console,
duration of absence, and the type of alarm interface (e.g. audible vs. visual
alarms) in use.
B.
All controllers are trained to operate on any of the three monitors or RTU in the
control room to enhance flexibility for controller backup.
C.
Short Breaks
1. Controllers will have another qualified employee monitor the SCADA system
during any absence.
D.
Shift Change
1.
E.
Unmanned overnight
1.
V.
Shift change occurs once a week. Controllers enter all operational

concerns or changes in the log book and also verbally relay this
information to the next controller.
Controller puts the call out system on overnight. Any call out alarm will
notify the controller, if not answered it will page the back-up controller.
Provide Adequate Information

A.
Wild Goose Storage (Operator) must implement sections 1, 4, 8, 9, 11.1, and 11.3
of API RP 1165 (incorporated by reference, see Sec. 192.7) whenever a SCADA
system is added, expanded or replaced, unless the operator demonstrates that
certain provisions of sections 1, 4, 8, 9, 11.1, and 11.3 of API RP 1165 are not
practical for the SCADA system used;
B.
The Operator must provide its controllers with the information, tools, processes
and procedures necessary for the controllers to carry out the roles and
responsibilities as defined by performing each of the following:
1.
Conduct a point-to-point verification between SCADA displays and

related field equipment when field equipment is added or moved and when
other changes that affect pipeline safety are made to field equipment or
SCADA displays.
2.
Conduct a point-to-point verification of all safety-related points in the

SCADA system. This includes calculated (software generated) points that
are safety-related. Safety related points often, but do not necessarily, have

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alarms associated with them. Examples of points that may be considered
safety-related (and therefore would need to be verified when changes are
made to field equipment of SCADA displays) include, but may not be
limited to:
a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
l.
m.
n.
o.
p.
q.
3.
Status to main line valve

Mainline pressures and flow rates
Tank levels
Station in local Control
Personnel in normally unmanned station
Station inlet and discharge pressures
Pump/compressor status
Leak detection
Pressure regulator inlet and outlet pressures
PLC/RTU Communication status
Emergency shutdown status
Odorant alarms
Composition alarms, such as H2S and water content
Filtering equipment levels-scrubbers/dehydration
Flame, gas and vapor detectors
Power supply indications (low battery, AC power failure, UPS
failure)
Security monitoring
An adequate point-to-point verification should verify the:

a.
b.
Actual physical location and sequence among other devices and

equipment at the location;
Data, information and any control or alarm functions to/from the
point being represented on the SCADA displays on which they
reside.
4.
When changes are made to the SCADA display or field equipment, a

point-to-point verification between the SCADA display and related field
equipment must be conducted for any associated safety-related points.
This verification ensures any unintended errors that may have occurred
during changes in SCADA displays or field equipment are identified and
corrected.
5.
Requirements for a point-to-point verification between SCADA displays

and related field equipment includes:
a.

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Confirming that the input or output of each field instrument is

accurately and reliably reflected in the SCADA information
presented to the controller.
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b.
c.
d.
Documenting the actual field parameters, as measured in the field,

and the correcponding SCADA display information, to record that
the SCADA information displays accurately reflect field
measurements.
The date and names of individuals involved in the verification
should also be recorded as a means to help demonstrate
thoroughness and authenticity.
Alarm set-point values should also be checked at the same time.
Keep in mind that this may also apply to changes that are the result
of pressure restrictions.
6.
If possible operate field devices during point-to-point verification between

SCADA displays and related field equipment. This may not always be
feasible if doing so would be too disruptive to the system operation. In
this case, it may be justified to apply a simulated signal at the field
instrumentation. The point-point verification will be for the most rigorous
and all encompassing verification approach that is practical. The
application of simulated signals will be used sparingly and be configured
as close to the actual field devices as possible.
7.
All points that have changed must be verified and cannot be done with a
sampling process.
8.
Testing and verifying an internal communication plan for manual pipeline

operation includes performing exercises or drills to assure that the
communication plans will be effective during an actual emergency
involving loss of all SCADA system functions or other systems relying on
SCADA data such as leak detections. All of the following, but not limited
to these functions, must be verified during testing :
a.
b.
c.
d.
e.
f.

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Communication between and among operational and maintenance

personnel using voice, fax, messaging, radio, etc.
Communication of pipeline operational data such as dial-in polling
of field equipment, manually reading gauges and field
instrumentation, etc.
Equipment and modes of communication that are likely to be
inoperable during a manual operation scenario should not be used
during the test.
Problems identified during exercises/drills should be corrected
promptly and the effectiveness of corrective actions should be
explicitly verified at the next exercise/drill.
Document and review related tasks required of controllers and
field personnel during these events.
Verify that training and operator qualification programs include
these tasks.
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9.
Backup SCADA systems, regardless of the nature, extent or location need

to have all of the specified functional capabilities verified annually.
10.
The Operator may incorporate automatic SCADA safety actions into their
SCADA systems even though it is not required by the Control Room
Management rule. If these features are built in then they should be
considered when testing and verification requirements are reviewed.
11.
In the event of SCADA failure it must be determined whether all, or

portions, of the pipeline will continue operating.
a.
b.
c.
If the Operator does not intend to continue operating the pipeline

during the SCADA failure, then only procedures to safely perform
a controlled shutdown and maintain and monitor pipeline integrity
need to be in place.
If an Operator chooses to continue all, or partial, pipeline
operations in the event of SCADA failure, then the Operator must
have reliable means to monitor and operate the pipeline system
manually.
The nature and extent of the means used to monitor and operate the
pipeline under such circumstances must be commensurate with the:
i.
ii.
iii.
iv.
d.
12.
Level of operational performance being maintained during

the SCADA outage (e.g. reduced operational capabilities,
continued full pressure operation, etc.)
Functional capability of the command-and-control
infrastructure that would be available during a SCADA
outage (e.g. disaster recover center, local station manning,
emergency communications systems, etc.)
Availability and location of field personnel to monitor and
operate the pipeline,
Logistics for manual overrides of equipment.
If the Operator experiences an actual SCADA failure that results in

the back-up SCADA system being pressed into service the
operator can claim this event as testing and verifying the back-up
system as long as an adequate representative sampling of functions
are performed, verified and documented during back-up
operations. Operators may be able to use alarm and event logs
generated during back up operations to help demonstrate that an
adequate representative sampling of functions were tested.
Establish and implement procedures for when a different controller

assumes responsibility, including the content of information to be
exchanged.

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13.
Information to be turned over during a hand-over procedure would

include, but not be limited to the following:
a.
b.
Controllers will relay all the current plant conditions, including the
nomination, current flow rate, which equipment is in service and
any abnormal operating conditions.
Controllers will also keep a written log in the control room.
14.
Even if the same person is scheduled to return, the controller may

unexpectedly have to be replaced as the result of illness or other
circumstance that prevents the controller from returning to duty the next
day. Even if the same individual returns the next day, the shift hand-over
process will help ensure no critical information has been forgotten.
15.
If the Operator upgrades or modifies a portion of its SCADA system that

results in some changes to the SCADA display, and the display symbols
unaffected by the upgrade/modification are different than those
recommended by API RP 1165 then a standard, consistent set of symbols
is essential to efficient and understandable display design. However, if
such changes impacted only a certain group of consoles in the control
room, and assigned controllers and qualified control room supervisors do
not cross-train on or move from these consoles to unchanged consoles,
then the changes symbols may be appropriately limited to the affected
group of consoles.
(NOTE: The Operator / Controllers do not make changes to the SCADA system
or make modifications. They only have access to pressure and flow controls. The
Operator does not have access to any MOP, OSD or ESD settings. The only
person to have access to hard set values is the system programmer, through a
work order signed by the Production Coordinator or Plant Engineer and
supporting MOC paper work sign off. The same is true for items for 15,16,17 and
18).
16.
If the Operator upgrades or modifies a portion of an existing SCADA

system (e.g. later version of SCADA software, larger/faster hard drives)
then the Operator must delineate what does and does not constitute the
need to implement API RP 1165 within their plans and procedures.
Routine upgrades or modifications of existing SCADA systems that do not
impact display parameters, such as operating system, application software
or had drive upgrades do not necessarily require implementation of API
RP 1165. However, changes that impact display parameters (such as
display symbols, color palettes, or anything that affects the controllermachine interface) would require implementation of API RP 1165.
17.
If the Operator expands or replaces a SCADA system and it is not

practical for the SCADA system to be in immediate compliance with the

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Control Room Management requirements, the Operator must document
the deviation as to why immediate compliance is not practical, how the
deviation is necessary for safe operation, and include a justified project
timeline that includes an indication when full compliance is to be attained.
18.
A point-to-point verification must be completed following field changes or

SCADA display changes. PHMSA inspectors will assess an operators
plans, procedures and associated records to evaluate the operators process
for completing point-to-point verification in a timely manner. Operators
may include multiple timing criteria within their procedures for
completing point-to-point verifications. Although there may be others,
two examples of timing criteria are:
a.
b.
c.
Data points already being used in the control room. Those date
points already being used by controllers should be verified the
same day a verification process became necessary.
Data points being added or checked out as a part of a systems
enhancement or replacement. Those data points being added or
checked out as a part of a major system enhancement or
replacement should be verified before those data points are turned
over to controllers for use.
This system check is performed before any new SCADA control is
turned over to Operation. Operators do not make these kinds of
changes.
19.
Test and verify an internal communication plan to provide adequate means

for manual operation of the pipeline safely, at least once each calendar
year, but at intervals not to exceed 15 months;
20.
Test any backup SCADA systems at least once each calendar year, but at
intervals not to exceed 15 months.
a.
b.
21.
To ensure that the backup SCADA system will function as

designed to support the safe operation of the pipeline in the event
the primary SCADA system being unavailable, it is expected that
the test include restoration of, and transfer of control back to, the
primary SCADA system.
The Server1 or Server2 SCADA is considered a backup system
and should be tested annually to verify it is capable of performing
its designed capabilities.
Test and verify backup manual operations to ensure internal

communications plans can effectually implement backup manual
operation in the event of a SCADA system failure. The test and
verification process must be designed to confirm that the operator has
adequate personnel, procedures, processes, communications infrastructure,

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and manual command-and-control capabilities to assure safe, reliable
operations and pipeline integrity when operating manually. Such testing
should:
a.
b.
c.
d.
VI.
Verify the sufficient and timely deployment of qualified personnel

to field locations necessary to adequately operate equipment and
monitor pipeline integrity,
Establish, supplement, and /or verify performance of its
communications or command center, and
Exercise critical decision-making processes.
Testing and verification should address all types of actions
necessary to mobilize manual operations.
Fatigue Mitigation
A.
The Operator must implement the following methods to reduce the risk associated
with controller fatigue that could inhibit a controller's ability to carry out their
roles and responsibilities:
1.
Establish shift lengths and schedule rotations that provide controllers offduty time sufficient to achieve eight hours of continuous sleep;
a.
b.
c.

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Hours of service include time while an individual is performing

controller activities, including shift-change and overlap, on-call
duties, events, emergency or spill drills, meetings, training,
receiving or providing performance reviews and all other time the
individual performs activities for the operator. Any and all noncontroller type duties a controller performs for the operator are
considered on-duty time for fatigue mitigation purposes. Note that
on-duty time must also be tracked and tabulated for individuals
that are not normally performing controller duties, but that might
be called on to perform controller duties on short notice if needed
(such as qualified supervisors or others who are maintaining their
qualified controller status).
Off-duty is defined as time in which the controller is not
performing any work, duties, meetings, training, or other
assignments for the operator. The controllers commute time to and
from work, and any time which the controller is not working for
the operator is considered off-duty time.
Controllers must have an opportunity for eight hours of continuous
sleep between shifts. PHMSA encourages at least ten continuous
hours of off-duty time to allow for commutes and other personal
activities prior to going to sleep or after waking up. Shorter/longer
commute times or the availability of nearby sleep facilities may
influence the appropriate amount of off-duty time.
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2. Educate controllers and supervisors in fatigue mitigation strategies and how
off-duty activities contribute to fatigue. The following are examples of
elements that should be considered as part of fatigue mitigation training
and education:
Sleep physiology, sleep hygiene and sleep pathologies
Sleep deprivation effects on work performance
Circadian rhythm effects on work performance
Time on task fatigue effects on work performance
The effects of prescription and over-the-counter drugs on sleep and
performance
Fatigue countermeasures
Fatigue modeling
Quantifying the potential contribution of fatigue to incidents and
accidents
How off-duty activities contribute to fatigue
Fatigue effects on highway driving performance
Employer-specific policies and procedures related to fatigue
management
Individual-specific employee differences that may impact fatigue
Fatigue mitigation strategies based upon the preceding information
3.
Train controllers and supervisors to recognize the effects of fatigue.
4.
Establish a maximum limit on controller hours-of-service, which may

provide for an emergency deviation from the maximum limit if necessary
for the safe operation of a pipeline facility.
a.

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The Operator is responsible for determining the fatigue risks that

exist in its program, and appropriate mitigation tactics to
implement given the operating environment (schedule, control
room set-up, etc.) to reduce those risks. In general, fatigue
mitigation tactics may include provisions for on-the-job napping,
provisions for tactical caffeine use, standing (e.g., use of sit/stand
workstations) procedures for double-checking checklist
completions, task rotations to reduce the effects of task-specific
fatigue, exercise areas, activities intentionally injected at specific
times in the shifts when the risk of fatigue is high, and mechanisms
in place to help deal with controllers who are self-identified or
identified by supervisors as being fatigued. The Operator should be
aware that certain mitigation tactics may or may not work for
certain individuals. There should be some flexibility to allow for
January 2012
Page 13 of 24

b.
countermeasures based on individual differences, and

communication amongst the appropriate stakeholders within the
organization to know what typically does or does not work best for
certain individuals.
Given that good quality sleep is capable of being obtained every
night for a traditional day job, 5 days a week, controllers should
be able to work to up 15 hours (plus 1 hour for shift hand-over) per
day across a week with a modest risk of fatigue. To keep risk
minimal, and reduce the need for a more elaborate fatigue
mitigation program, the following parameters should be followed:
i.
ii.
iii.
iv.
v.
vi.
vii.
viii.
ix.

Revision: 0
Keep total continuous hours worked within 8 hours with a

30 minute break for lunch, with additional normal and
shorter breaks throughout the day (such as bio breaks.)
Fatigue mitigation measures are implemented (for day only
work, this typically would just include additional breaks).
Typical work day is an 8 hour shift including travel time
one way and 16 hours on call. Maximum shift hours is 16
and then another Operator assumes Control Room
responsibility.
Keep days worked to 7 consecutive days, with 3
consecutive days off, and avoid excessive on-call duties.
If the individual incurs excessive on-call duties, this may
drive the need for a more elaborate Fatigue Management
program.
Limit total hours worked per week to 112 (maximum
allowed by law assuming 16 hour work days).
Operators must still provide the opportunity for individuals
to get 8 hours of continuous sleep between shifts.
Training and education are required to maintain Operator
Qualification.
Even with a relatively low-risk scenario, operators should
be aware that fatigue can still set in and should be vigilant
of the potential for increased fatigue, and consider if
countermeasures are needed, especially during the 9th
through 16th hour of 16 hour shifts. For day only work, this
typically only requires measures such as additional breaks
throughout the day, but operators should consider
additional measures as needed given the individual
differences of its employees.
Operators should also be vigilant for chronic fatigue, and
the potential need for related fatigue countermeasures. For
day only work, this typically only requires measures such
as additional breaks throughout the day, but operators
January 2012
Page 14 of 24

x.
5.
Fatigue Mitigation Strategies

a.
b.
c.
6.
should consider additional measures as needed given the

individual differences of its employees.
Operators who vary from these parameters should be able
to demonstrate why the variation does not elevate the risk
of fatigue.
Repeated and/or demanding work causes task-specific fatigue and

the need for recovery. Operators should consider the impact of
various interactions and plan ahead because the combination of
multiple factors may not be obvious.
Sometimes habituation and/or boredom occur in these situations.
Generally, task-specific fatigue of this nature can be dealt with by
rotating the worker from one task to another several times within
the shift.
Another task-specific phenomenon that operators should be aware
of is "Technostress, which can be one effect of automation that
may be seen in a control room. Work that is assisted by automation
often requires specific, fine-motor and visual functions, vigilance,
and repetitive operations. This kind of work produces task-specific
fine-motor fatigue, visual fatigue, vigilance failures, monotony,
and potentially repetitive-stress injuries.
Emergency Deviations from the Maximum Limit on Controller Hours of

Service
a.
b.

Revision: 0
The Operator must maintain documentation that demonstrates any

deviation from the maximum limit on controller hours of service
necessary for the safe operation of the pipeline facility. Operators
should plan for anticipated emergency deviations in advance and
evaluate their potential for additional risks of controller fatigue. If
additional risks exist as a result of any deviation, the operator
would be expected to have or develop a corresponding plan to
employ appropriate countermeasures, and demonstrate how those
measures offset the additional risks. Frequent occurrence of the
same type of deviation should prompt the operator to review
policies and procedures to minimize their occurrence.
The operator has the flexibility to determine how best to
demonstrate adequacy of deviation management through the
structure and content of its processes and procedures. Implement
an exception review/approval process that includes analysis of
events leading to the deviation, actions taken, as well as review
following the deviation.
January 2012
Page 15 of 24

c.
PHMSA encourages a process to take place with provisions for

written approval in advance of anticipated deviations (PHMSA
recognizes some deviations cannot be forecasted). For such a
process and form, PHMSA would expect to see items such as:
Reason for exception (i.e. which portion(s) of the Hours of
Service schedule/procedures to be exceeded)
Why is the exception needed for the safe operation of a
pipeline facility
Date and time work schedule will be impacted
Deviation will affect the following employee(s)
Work schedule before and after the exception
Any additional fatigue risks associated with the exception
Countermeasures to be employed to offset any additional
risks for fatigue
Date, time and by whom the deviation is being
reviewed/approved
d.
PHMSA understands that unforeseen circumstances do occur

which may make written approval in advance impractical. In such
instances written documentation should be completed at the first
practical moment after the event.
VII. Alarm management

A.
Each operator using a SCADA system must have a written alarm management
plan to provide for effective controller response to alarms. An operator's plan
must include provisions to:
1.
Review SCADA safety-related alarm operations using a process that

ensures alarms are accurate and support safe pipeline operations.
a.
2.
If the Operator acquires a new SCADA system with integral alarm

management capabilities after all the compliance deadlines have
passed, the alarm management capabilities must be fully functional
whenever the new SCADA system becomes operational. The
required periodic review of alarms would likely reveal
opportunities to improve the initial alarm management capabilities
over time.
Identify at least once each calendar month points affecting safety that have
been taken off scan in the SCADA host, have had alarms inhibited,
generated false alarms, or that have had forced or manual values for
periods of time exceeding that required for associated maintenance or
operating activities.

Revision: 0
January 2012
Page 16 of 24

a.
b.
c.
3.
Any alarm that is presented to the controller that did not accurately
reflect the actual operational parameter or condition, or an alarm
that can mislead a controller to believe a condition exists, but that
does not exist, is considered a false alarm.
Testing and maintenance activities should be planned in advance
except during emergency situations. A controller should be aware
in advance to avoid confusion. If a controller is aware of ongoing
work, then such alarms would not be considered false alarms as
they would accurately reflect activities in progress. If, however, the
controller is not aware of testing activities or that the alarms are a
result of the testing, then such testing could produce false alarms
and should be considered as such.
The Operator must identify points that have been taken off scan in
the SCADA host, have had alarms inhibited, generated false
alarms, or that have had forced or manual values for periods of
time exceeding that required for associated maintenance or
operating activities, on a monthly basis. The Operator should
troubleshoot the cause of non-functional alarms, take appropriate
corrective actions in a timely manner, and endeavor to return alarm
points to service in an expedited manner.
Verify the correct safety-related alarm set-point values and alarm

descriptions at least once each calendar year, but at intervals not to exceed
15 months;
a.
b.
c.

Revision: 0
Safety-related alarm setpoint values are thresholds, which if

achieved or exceeded, will present an indication to the controller
that equipment or processes are outside of the operator-defined
normal parameters.
With respect to the verification of the correct safety-related alarm
set-point values and alarm descriptions when associated field
instruments are calibrated or changed, verification must be
completed at the time of the calibration or change. Verification of
safety-related alarm set-points and descriptions is an integral part
of the work package whenever changes are made to field
equipment or whenever field equipment is calibrated. Such
calibration or field change tasks are not complete until the
verification is successfully accomplished.
Many alarms points have been established that represent the
absolute critical maximum or minimum for process variables, for
which controllers should not be able to change set-points.
However, the Operator has incorporated operational alarms. These
type alarms typically warn controllers of approaching conditions
before they become critical and are considered operational tools.
Controllers can adjust these alarm set-points. The Operators
January 2012
Page 17 of 24

procedures and training must reflect their specific alarm
management practices.
4.
Review the alarm management plan at least once each calendar year, but
at intervals not exceeding 15 months, to determine the effectiveness of the
plan;
5.
Monitor the content and volume of general activity being directed to, and
required of, each controller at least once each calendar year, but at
intervals not to exceed 15 months, that will assure controllers have
sufficient time to analyze and react to incoming alarms.
a.
b.
c.
d.
e.

Revision: 0
This section of the CRM rule is not limited to alarms. While this
requirement is located in the alarm section, this element of the rule
requires that the Operator reviews all required activities of a
controller. For example, this should include manual calculations,
alarms, training, setpoints or control manual entries, phone calls,
etc. The Operator must monitor the overall content and volume of
activity for a controller. The process by which this monitoring is to
be done is not specified, but is expected to have a sufficient degree
of formality and documentation. The Operator must monitor the
content and volume of activity being directed to a controller to
substantiate any conclusions about maintaining or changing
assigned duties.
If the controllers workload has not changed for several years the
Operator cannot assume the current workload represents an
acceptable benchmark or basis for future comparisons. Current
operating practices alone may not be used as a sole basis or
justification to maintain the status quo.
The rule does not establish a uniform benchmark for controller
workload. PHMSA expects operators to establish, annually
evaluate, and document the substantive adequacy of controller
workload criteria. Job task analysis or related evaluations are
encouraged. Periodic analysis, annually and whenever significant
changes are being made, will help operators recognize and react to
changes.
In regards to monitoring the content and volume of general activity
directed to and required of each controller, there is not an
established uniform limit on controller time for analyzing and
responding/reacting to alarms. No one answer fits all, as the
conditions specific to a pipeline facility and specific console may
vary.
In regard to monitoring the content and volume of general activity
directed to and required of each controller general activity means
any activity that is required of the controller. This includes, but is
not limited to, pipeline operations, handling SCADA alarms,
January 2012
Page 18 of 24

f.
g.
h.
6.
conducting shift change, greeting and responding to visitors,

administrative tasks, impromptu requests, telephone calls, faxes, or
other activities such as monitoring weather and news reports,
checking security and video surveillance systems, using the
internet, and interacting with colleagues, supervisors, and
managers.
Since every pipeline system is unique, PHMSA has not established
a set criterion for the number of alarms per shift that is considered
acceptable. The Operator must have an alarm management plan
and monitor/evaluate its alarms periodically in accordance with the
rule. The Operator is encouraged to review and apply similar
concepts as those presented in the International Society of
Automation (ISA) Management of Alarm Systems for the Process
Industries (ANSI/ISA-18.2), The Engineering Equipment and
Materials Users Association (EEMUA) 191 Alarm Systems - A
Guide to Design, Management and Procurement (EEMUA 191),
or other applicable guidance when establishing alarm handling
practices and considering a maximum number of alarms.
The number of alarm priority categories (e.g., low, medium, high,
urgent, etc.) should be sufficient for the controller to easily
distinguish between operational, control limit restrictions and
higher critical priorities, but should not exceed those
recommendations found in the National Transportation Safety
Board (NTSB) presentation regarding SCADA Safety Study of
2005. Operators are expected to document the basis for selected
alarm priorities and to periodically monitor the alarm priority
scheme to achieve and maintain effectiveness.
When analyzing and reacting to alarms, the Operator must
determine if controllers are expected to acknowledge alarms first
and then analyze/react to them; or that controllers will analyze and
react to alarms first, and then acknowledge the alarm. The
Operator must determine and establish alarm response strategies in
their procedures.
Since there are numerous variations of
conditions that may create any individual alarm, regimented alarm
handling procedures may be inappropriate. However, controller
training and guidance material is expected to help controllers
quickly analyze alarm situations in order to promptly determine a
course of action.
Address deficiencies identified through the implementation of paragraphs

1 through 5 above.
a.

Revision: 0
The Operator is expected to promptly correct specific issues

commensurate with their importance to safety. Operators should
maintain an itemized list of deficiencies and their date of
discovery, the corrective action to be taken, and the completion
January 2012
Page 19 of 24

date (or schedule) for corrective actions. The Operators
documentation should also record the basis for the selection and
scheduling of corrective action. In addition, the operators alarm
management plan should include provisions to analyze its specific
deficiencies to identify root cause, common cause, trends, etc., that
are indicative of systemic deficiencies that need to be identified
and corrected.
VIII. Change management

A.
The Operator must assure that changes that could affect control room operations
are coordinated with the control room personnel by performing each of the
following:
1.
Establish communications between control room representatives,

operator's management, and associated field personnel when planning and
implementing physical changes to pipeline equipment or configuration.
2.
Require its field personnel to contact the control room when emergency
conditions exist and when making field changes that affect control room
operations.
a.
b.
c.

Revision: 0
Emergency procedures are not sufficient as means of compliance

with this section of the CRM regulation. This requirement is
broader than emergency conditions and also requires that field
personnel contact the control room when making changes that
effect control room operations or supportive systems in nonemergency situations (such as routine transmitter calibrations).
The Operator should develop documentation that identifies when
and under what conditions the control room has been contacted by
field personnel. In addition, the Operator should review data
available internally (such as near miss or incident/accident data) to
confirm that emergency contact to the control has been made as
required.
If piping changes are being considered at a field location that do
not impact any SCADA data, the control room must still be
involved in change management discussions. Even though
SCADA data may not be impacted, the hydraulics performance of
the pipeline system could be affected in a way that impacts control
room operations. SCADA data is not the only thing that could
impact control room operations. For example, replacing a
mainline valve may not change any SCADA data, but such a
change may impact valve cycle time which can be a very critical
factor for controllers. The Operator must define what impending
January 2012
Page 20 of 24

field changes will be included in the management of change
process.
3.
IX.
Seek control room or control room management participation in planning

prior to implementation of significant pipeline hydraulic or configuration
changes.
Operating Experience
A.
Each operator must assure that lessons learned from its operating experience are
incorporated, as appropriate, into its control room management procedures after
reviewing reportable incidents/accidents by performing each of the following:
1.
Review incidents that must be reported pursuant to 49 CFR part 191 to

determine if control room actions contributed to the event and, if so,
correct, where necessary, deficiencies related to:
a.
b.
c.
d.
e.
f.
2.
Review reportable incidents/accidents to determine any deficiencies

related to field equipment. Some examples of field equipment that the
Operator must consider in relation to control room management include,
but not limited to:
a.
b.
c.
d.
3.
Controller fatigue;
Field equipment;
The operation of any relief device;
Procedures;
SCADA system configuration; and
SCADA system performance.
Instrumentation that is out of calibration that results in a false

alarm or inaccurate display of operational parameters such as
pressure or flow,
Valve limit switches that provide incorrect valve status,
Inappropriate setting for relief equipment compared to alarm setpoints, and
The discovery of a manual mainline valve previously unknown to
the controllers.
Include lessons learned from the operator's experience in the training

program.
a.

Revision: 0
This requirement applies to reportable accidents/incidents as well

as other experience such as near misses, non-reportable events
such as small leaks, audit findings, and any other source of
operating experience that could better inform and better train
January 2012
Page 21 of 24

b.
X.
controllers to safely control the pipeline and recognize and

correctly respond to abnormal, unusual, or emergency conditions.
This requirement applies to all accidents, incidents, events, and
circumstances that could better inform and better train controllers
to safely control the pipeline and recognize and correctly respond
to abnormal, unusual, or emergency conditions. Events in which
controllers caused or contributed to the event are important to
preclude recurrence of controller mistakes. However, proper
controller reaction is an important aspect in precluding recurrence
of other types of incidents as well.
Training
A.
Each operator must establish a controller training program and review the training
program content to identify potential improvements at least once each calendar
year, but at intervals not to exceed 15 months. An operator's program must
provide for training each controller to carry out the roles and responsibilities
defined by the operator. In addition, the training program must include the
following elements:
1.
Responding to abnormal operating

simultaneously or in sequence;
2.
Use of a computerized simulator or non-computerized (tabletop) method

for training controllers to recognize abnormal operating conditions;
3.
Training controllers on their responsibilities for communication under the

operator's emergency response procedures;
4.
Training that will provide a controller a working knowledge of the

pipeline system, especially during the development of abnormal operating
conditions; and
5.
For pipeline operating setups that are periodically, but infrequently used,
providing an opportunity for controllers to review relevant procedures in
advance of their application.
a.
likely
to
occur
The Operator must address, in its training program, all reasonably

foreseeable operational configurations (i.e., setups), not just the
routine setups. Examples, among many others, could be:
i.
ii.
iii.

Revision: 0
conditions
seasonal operating parameters,

start-up and shutdown,
line reversals,
January 2012
Page 22 of 24

iv.
v.
vi.
vii.
viii.
ix.
b.
XI.
combining pipelines through valving to run in common

versus split,
bleed valve operations,
power loss failure modes,
slack line conditions,
purging, and
running ILI tools.
Note that this requirement applies to all controllers subject to

training of the CRM rule, even if their SCADA system only
provides monitoring functionality and control functions are
provided by controller interaction with field personnel.
B.
Certain procedures and operating practices of the Operator need to be

incorporated into the Operator Qualification program. If any prior qualification
includes and meets all applicable requirements of the CRM plan and associated
activities, the controller does not need to re-qualify.
C.
An operator should continue to implement the OQ regulations through the

application of the four part test for covered tasks, and determine whether any new
tasks will be added to their program as a result of their actions under the CRM
rule. The Operator is expected to define both generic and task-specific covered
tasks for controllers.
Compliance validation
A.
Upon request, the Operator must submit their procedures to PHMSA or, in the
case of an intrastate pipeline facility regulated by a State, to the appropriate State
agency.
B.
PHMSA expects operators to have and maintain records to demonstrate that

required activities were satisfactorily accomplished. Upon request, the operator
must provide CRM procedures and associated documentation and records to
PHMSA or the appropriate state agency for review to validate compliance.
C.
Any records intended to demonstrate compliance should include sufficient details

as a means to help demonstrate thoroughness and authenticity. Only annotating
work performed/completed on a certain date would usually be deemed as
inadequate.
XII. Compliance and deviations

A.
An operator must maintain for review during inspection:

Revision: 0
January 2012
Page 23 of 24

1.
2.
Records that demonstrate compliance with the requirements of this

section; and
Documentation to demonstrate that any deviation from the procedures
required by this section was necessary for the safe operation of a pipeline
facility.
B.
The CRM rule for maintaining records to demonstrate compliance with each of
the code requirements, (e.g., routine shift turnovers, and exceptions to controller
HOS limits) does not have established specific record retention periods.
However, sufficient documentation will be maintained and generally, such
records will include at least one year, or the last two periodic tests or validations,
whichever is longer.
C.
The CRM rule requires that operators document deviations from the operators
procedures. The operator needs to develop and document a technical justification
for its course of action and demonstrate that the level of safety is consistent with
the regulatory requirements.
D.
An operator acquiring pipeline assets is responsible to demonstrate compliance

with the CRM rule. Records from the former operator may assist the new operator
in demonstrating compliance. If an operators records do not demonstrate full
compliance, the operator would be expected to promptly initiate actions to
achieve full compliance.
E.
In general, records kept electronically are acceptable if they are maintained in a

format that ensures the integrity, authenticity, and date of the records, and that
they are readily retrievable and accessible for inspection. The Operator must
assure that changes or upgrades in technology do not make the media used to
store prior electronic records unreadable.

Revision: 0
January 2012
Page 24 of 24
California Public Utilities Commission Whistleblower Notice
Any employee or independent contractor of Wild Goose, who in good faith, believes that unsafe
conditions, services or facilities of the utility threaten the health or safety of its patrons, the
employees or the public, has the right to report the conditions to the California Public Utilities
Commission. The employee can report the conditions by calling the Commissions
Whistleblower Hotline at 1(800) 649-7570, either anonymously or by giving the employees
name, or by sending an e-mail with the pertinent facts and / or documentation to
fraudhotline@cpuc.ca.gov. This requirement shall be in addition to any right the employee has to
contact any other State or Federal agency, if the employee has reasonable cause to believe that
the information discloses a violation of a state or federal statute, or a violation or noncompliance
with a state or federal rule or regulations. The California Public Utilities Commission prohibits
California natural gas utilities from retaliating against any employee, who reports, in good faith,
unsafe conditions to the Commission.
ENVIRONMENTAL
HEALTH & SAFETY
SAFE
Handbook
United States Operations

Version 1 February 2008
-1-
24-HOUR EMERGENCY
CONTACT TELEPHONE NUMBERS
California Contacts
Telephone
Butte County Environmental Health Division (EHD)
1-530-691-2727
Butte County Air Quality Management District

(AQM)
1-530-691-2727
CAL-OSHA
1-530-895-4761
California Fish and Game Department (CFGD)
1-530-868-5722
California Office of Emergency Services (COES)
1-800-852-7550
California Public Utilities Commission (CPUC)
1-800-235-1076
or
1-800-235-7128
Central Valley Regional Water Board
1-530-224-4788
Division of Oil, Gas and Geothermal Resources

(DOGGR)
1-916-322-1110
Gridley Fire Department
911
or
1-530-846-5711
US Department of Transportation
1-800-424-8802
US National Response Center (NRC)
1-800-424-8802
Central Valley Regional Water Quality Control Board

(WQB) Redding Office
1-530 224-4788
Wild Goose Facility Contact
WG Control
Room:
(530) 846-7351
After Hours:
(530) 869-8450
-2-
Oklahoma Contacts
Telephone Number
Salt Plains Facility Contact
SPS Control Room:

(580) 694-2249
After Hours:
(866) 832-7356
Occupational Safety & Health

Administration
Oklahoma Corporation Commission
US Fish & Wildlife Service, Oklahoma
US Department of Transportation
US National Response Centre (NRC)
1-800-321-6742 or
1-405-278-9560
1-405-375-5570
1-580-626-4794
1-800-424-8802
1-800-424-8802
Oklahoma Department of Environmental

Quality
Air Quality
Management Division:
(405) 702-4157
Water Quality Division:
(405) 702-8187
Environmental Protection Agency-Region 6

Oklahoma Corporation Commission
Manchester Fire Department
Manchester Police Department
1-800-887-6063
(405) 521-2211
(580) 694-2300
(580) 395-2356
NON-EMERGENCY TELEPHONE NUMBERS

Person & Position
Location
Kelly Baltimore EHSS

Coordinator
Calgary
Simon Dupr Chief

Operations Officer
Calgary
Glen Thauberger - Plant

Superintendent
Gary Theberge Manager

E&O (SPS &WGS)
Salt Plains
Wild Goose
Calgary
-1-
Non-Emergency
Ph: (403) 513-8663
Cell: (403) 988-7041
Wk: (403) 513-8709
Cell: (403) 803-8904
Wk: (580) 694-2249
Cell: (580) 554-6113
Wk: (530) 846-7386
Cell: (530) 624-0112
Wk: (403) 513-8631
Cell: (403) 580-8586
TABLE OF CONTENTS
1.0 Introduction ............................................................................... 6
1.1
Deviation Requests ...........................................................................6
2.0 Health and Safety Responsibilities............................................... 8
2.1
Contractors, Subcontractors and Consultants ..............................8
2.2
Inspectors (Niska Employee or Contracted) ................................9
2.3
Workers...............................................................................................9
2.4
Visitors .............................................................................................10
2.5
OSHA General Duty Clause .........................................................11
2.6
Refusing to Work Because Conditions are Dangerous .............11
2.7 Workers Compensation...............................................................................12
3.0 Environmental Responsibilities................................................... 14
3.1
Storm Water Runoff .......................................................................14
3.2
Compressor Facility Storm Water Discharge Procedure ..........14
3.3
Well Pad Storm Water Discharge Procedure ..............................15
General Well Pad Area ...................................................................15
Well Pad Caissons............................................................................15
Spill Response Procedures.............................................................15
3.4
Underground Storage Tanks .........................................................16
In California: ....................................................................................16
3.5
Waste Management .........................................................................17
3.6
Water Crossing and Diversion.......................................................17
4.0 Master Service & Supply Agreement (MSSA) ............................. 18
4.1
Service Provider Notification Guideline .....................................18
5.0 Emergency Response Planning and Reporting ..........................20
5.1
Niska Emergency Response Plan (ERP).....................................20
5.2
Incident Reporting and Legislative Requirements .....................21
5.3
Near Miss Reporting.......................................................................22
6.0 Hazard Identification, Assessment and Control .........................24
6.1
Hazard Assessment.........................................................................24
7.0 EH&S Orientations and Meetings ..............................................28
7.1
Site-Specific Orientations...............................................................28
7.2
EH&S Meetings ..............................................................................28
8.0 General Personal Safety Practices................................................30
8.1
Health Considerations ....................................................................30
8.1.1 Bloodborne Pathogens ....................................................30
8.1.2 Bloodborne Pathogen Exposure Control.....................30
8.1.3 Handling Bloodborne Pathogens...................................30
8.1.4 Cleaning Procedures.........................................................32
8.1.5 Contaminated Materials...................................................32
8.1.6 Hepatitis B Vaccination ...................................................32
8.1.7 Exposure Incident - Medical Evaluation ......................33
8.1.8 Training ..............................................................................34
-1-
8.1.9 Recordkeeping...................................................................34
8.2
First Aid............................................................................................35
8.3
Extreme Weather Working Condition Responsibilities.............35
8.4
Heat Stress........................................................................................35
8.5
UV Index and Sun Protection Messages.....................................37
Table 1 - Heat Index Chart ................................................................37
Table 2 - UV Index Risk...................................................................37
8.6
Working in the Cold........................................................................38
Table 3 - Wind Chill Chart ................................................................40
Table 4 - Wind Hazards Chart ..........................................................40
8.7
West Nile Virus (WNv) ..................................................................41
8.8
Hantavirus ........................................................................................41
8.9
Personal Protective Equipment (PPE).........................................42
8.10 Flame Resistant Clothing (FRC) ...................................................42
8.11 Protective Eyewear..........................................................................43
8.12 Protective Footwear ........................................................................44
8.13 Head Protection ..............................................................................45
8.14 Hearing Protection..........................................................................45
8.14.1 Audiometric Testing.........................................................46
8.14.2 Training ..............................................................................46
8.14.3 Record Keeping ................................................................46
Table 5 - OSHA Permissible Noise Exposures ..................................47
8.15 Hair, Jewelry and Loose Fitting Clothing....................................47
8.16 Intoxicating Beverages and Medications .....................................47
8.17 Smoking ............................................................................................48
8.18 Firearms............................................................................................48
8.19 Photographic Equipment ..............................................................48
8.20 Pets
.............................................................................................48
8.21 Special Health Considerations.......................................................48
8.22 Training Requirements ...................................................................49
8.23 Working Alone.................................................................................50
8.24 Visitor Guidelines ...........................................................................51
9.0 Work Site Safe Work Practices .....................................................52
9.1
Access and Egress...........................................................................52
9.1.1 Alarm Systems for Explosive Gases & Fire .................52
9.1.2 Building Entry...................................................................52
9.2
Cathodic Protection (CP)...............................................................53
9.3
Confined Space Entry ....................................................................53
9.3.1 OSHA General Industry Standards...............................53
9.3.2 Basic Rules of Confined Space Entry: ..........................54
9.3.3 Two Types of Confined Spaces .....................................54
Permit-Required Confined Spaces .................................54
Non-Permit Confined Spaces.........................................55
9.4
Drilling and Completions Rig Hazards and Control .................56
9.5
Electrical Equipment ......................................................................56
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9.6
9.7
9.8
9.9
9.10
9.11
9.12
9.13
9.14
9.15
9.16
General Electrical Safety Practices ...............................................57

Elevating Platforms, Man Baskets and Man Lifts......................58
Elevated Workspace........................................................................58
Table 6 - Summary of Scaffold Inspection Tag Requirements...............59
Energy Isolation & Lock-Out Tag Out .......................................59
Excavation and Trenching (Ground Disturbance) ....................60
Table 7 - Soil Characteristics ...............................................................62
9.10.1 Training Requirements.....................................................63
9.10.2 Soil Conservation .............................................................63
Fall Protection .................................................................................63
9.11.1 Application ........................................................................63
9.11.2 General Information........................................................64
9.11.3 Fall Protection Equipment..............................................64
9.11.4 Component Compatibility...............................................64
9.11.5 Design/Performance Requirements/Test Methods ...64
9.11.6 Rescue Considerations.....................................................65
9.11.7 Free Fall Considerations..................................................65
Fall Protection Equipment Checklist ............................65
Fuel Gas as Instrument Gas..........................................................66
Gas and Liquid Sampling...............................................................66
Hazardous Waste Management and Transportation .................67
9.14.1 List of Hazardous Wastes ...............................................67
9.14.2 Empty Container Disposal Guideline ...........................67
9.14.3 Less than 5 gallon containers..........................................68
9.14.4 Greater than 5 gallon sized containers..........................68
9.14.5 Safe Handling of Hazardous Wastes.............................68
9.14.6 Storage Areas for Hazardous Wastes ............................68
9.14.7 Container & Disposal for Hazardous Wastes ..............69
Table 8 - Hazardous Wastes Containment and Disposal .....................69
9.14.8 Container Labels of Hazardous Wastes........................70
9.14.9 Satellite Accumulation Area Label Requirements .......70
9.14.10 Hazardous Waste Storage Area Label Requirements..70
9.14.11 Weekly Inspection of Storage Area ...............................70
9.14.12 Transporter and Manifests ..............................................70
9.14.13 Hazard Communication Program..................................70
9.14.14 Responsibilities..................................................................70
9.14.15 Requirements.....................................................................71
9.14.16 Labeling of Pipes..............................................................71
9.14.17 Working with Unlabeled Pipes .......................................71
9.14.18 Non-Routine Tasks Using Chemicals............................71
9.14.19 Contractors and Visitors .................................................72
9.14.20 NFPA Warning Sign.........................................................72
Table 9 - NFPA Warning Sign ..........................................................72
Hot Work..........................................................................................73
Ladders .............................................................................................74
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9.17
9.18
9.19
9.20
9.21
9.22
9.23
9.24
Livestock Protection .......................................................................75

Manual Lifting..................................................................................75
Pipeline Pigging & Pigging Valves................................................76
Pipeline Isolation.............................................................................76
Portable and Fixed Grinders .........................................................77
Overhead Work ...............................................................................77
Overhead Power Lines ...................................................................77
Mechanical Contact with an Energized Underground
Overhead Power Line.....................................................................79
Table 10 - Safe Minimum Clearances - Overhead Power Lines ............80
9.25 Safe Welding Practices....................................................................80
9.26 Safe Work Permit (SWP)................................................................82
9.27 Walkways and Steps ........................................................................82
10.0 Chemicals and Materials .............................................................84
10.1 Work Site Housekeeping Behavior...............................................84
10.2 Respiratory Protection....................................................................84
10.3 Compressed Gas Cylinders............................................................85
10.4 Compressors and Compressed Air...............................................86
10.5 Compressed Air Receivers .............................................................86
10.6 Static Electrical Charge in Hydrocarbons ...................................87
10.7 Bonding Requirements for Decanting of Liquids .....................88
Table 8 - Bonding Requirements for Decanting of Liquids...................88
10.8 Handling and Storage of Line Pipe..............................................89
10.9 Equipment, Tools and Materials...................................................89
10.10 Fire prevention ................................................................................90
10.11 Fired Equipment .............................................................................91
10.12 Fire Safety Guidelines.....................................................................92
10.13 Fire Prevention and Protection Equipment................................93
10.14 Monthly Portable Fire Extinguisher Inspections......................93
10.15 Annual Inspections ........................................................................94
10.16 Fire Classifications ..........................................................................95
Table 11 - Fire Classifications .............................................................95
11.0 Other Safety Practices..................................................................96
11.1 Defensive Driving/Motor Vehicle Operation ............................96
11.2 Vehicle Rescue Practices ................................................................97
11.3 Vehicles and Heavy Equipment ....................................................98
11.4 Cranes, Hoists and Lifting Devices ..............................................99
11.4.1 Annual Testing and Inspection.......................................99
11.4.2 Pre-Use and Operational Inspections ........................ 100
Table 13 - Hand Signals for Directing Vehicles................................ 101
11.5 Truck Mounted Cranes ............................................................... 102
11.6 Truck Loading and Unloading of Hazardous Materials ........ 102
11.7 Industrial Trucks .......................................................................... 102
12.0 Definitions ............................................................................ 104
User Comments ......................................................................... 110
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Environmental Health & Safety Policy Statement

Impact to the environment, protection against harm to the public or its
workers, prevention of damage to company materials and property are core
business values of Niska Gas Storage (Niska).
Every Niska employee has the right to a safe work place. Niska embraces a
100% safe culture and places the protection of people from injury or illness
above all other management considerations and is dedicated to continuing
our commitment of operating our facilities to the highest standard of
environmental, health and safety compliance.
Niska will conduct and treat people fairly and communicate promptly,
completely and accurately with our customers, employees, suppliers,
community members, shareholders, regulators and all others with whom we
do business. Niska is obligated to our employees to provide the resources
and training necessary to provide a safe work place and Niska employees
have the obligation to adhere to safety regulations and safe work procedures.
Niska will ensure that:
Safety and environmental compliance come first, regardless of the
magnitude or urgency of the job.
Personnel are available to provide the resources and guidance
necessary for continuous improvement to safety procedures.
Personal Protective Equipment is available and used when required.
Safe work procedures are developed, reviewed by all affected workers
prior to the commencement of work and adhered to.
Our employees are provided with the tools and training necessary to
allow them to conduct their work in a safe and productive manner.
Workers on Niska work sites adhere to government laws and
regulations.
Our facilities are operated in an economical, environmentally
sustainable and socially responsible manner and to reduce waste,
emissions and discharges from our operations.
Niska Gas Storages safety program also contributes to worker morale and
quality of work as a result of our employees participating in identifying work
place hazards and the development of safe work practices and procedures.
Niska Gas Storage is committed to ensuring that all relevant legislation is
incorporated into the Niska Gas Storage safety program and that all workers
comply with those requirements.
The success of the Niska Environmental, Health & Safety program depends
on the adherence and cooperation of all Niska Gas Storage employees and
contractors. We must all strive to protect the environment and the health
and safety of ourselves, fellow workers and the general public.
No job is so important that we cannot take the time to do it safely.

David Pope
President, Niska Gas Storage
October, 2006
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1.0 INTRODUCTION
This Environmental Health and Safety (EH&S) Handbook (the
Handbook) outlines minimum EH&S expectations for all workers
and visitors working or visiting a Niska Gas Storage (hereafter
referred to as Niska) United States operations work site. It
supplements the OSHA Regulations and Codes, other applicable
laws, and various industry codes and documents. Niska standards
will be followed for all work. In the event of a conflict between
the language of a contract and the language of this document, the
contract will dictate the required work specification.
This Handbook meets the requirements of Californias Injury
and Illness Prevention Plan: 8 CCR sec. 3202 (1) Authority and
Responsibility; 8 CCR sec. 3202 (2) Employee Compliance; 8
CCR sec. 3202 (3) Communication with Employees; 8 CCR sec.
3202 (4) Identify and Evaluate Workplace Hazards; 8 CCR sec.
3202 (5) Accident Investigations; 8 CCR sec.. 3202 (6) Correcting
Workplace Hazards; 8 CCR sec. 3202 (7) Employee Training; and
8 CCR sec. 3202 (8) Recordkeeping.
For questions on any policy or procedure, contact your Niska
representative or facility Production Coordinator to bring the issue to
the attention of Environmental Health & Safety (EH&S) personnel.
It is the Responsibility of all Production Coordinators, Lead
Operators, and Field Project Coordinators to ensure that all workers
working for them are familiar with and have access to the Handbook
and are able to produce a signed Orientation Acknowledgement Card
prior to commencing work on Niska work sites or facilities. This
Handbook shall be reviewed annually by all workers employed on a
Niska work site.
Important:
Throughout this Handbook, the use of the words shall,
must, and will indicates a mandatory requirement. The
word should indicates a recommendation, and the word
may is used to express permissible alternatives.
1.1
Deviation Requests
Any deviation from this Handbook requires approval from the

Niska Environmental Health Safety & Security Coordinator. Before
submitting a deviation request, discussions should be conducted with
the applicable Niska representative. Deviation Requests require a
written submission to the EHS&S Department and must include the
following information:
a) Your name, date, facility;
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b) What section and subsection of the Handbook you are
requesting a deviation from;

c) Your reason for requesting the deviation; and
d) How you plan on addressing and mitigating the risks of the
activity (e.g. an alternate Safe Work Practice).
All deviations granted by the Environmental Health Safety
& Security (EHS&S) Coordinator require, as a minimum,
two signatures, one being the Manager of the EHS&S
Department or their designate and the other being the
Operations Superintendent or their designate. Deviations
from the Handbook will not be considered as granted until a
written response to the request has been issued by the EHS&S
Coordinator and has been received by the requester.
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2.0 HEALTH AND SAFETY

RESPONSIBILITIES
Three Obligations:
As a worker on a Niska work site, you have three basic
obligations:
1. You are obligated to refuse to take any action you
consider to be unsafe, may cause property damage or to

perform a task for which you are not properly trained or do
not have the proper tools and to report your concerns to your
Supervisor.
2. You are obligated to confront anyone performing or
about to perform an unsafe act or a task for which they are

not properly trained.
3. You are obligated, if confronted by someone who is
pointing out to you an unsafe act or condition, to immediately

stop what you are doing and resolve the concern, even if it
requires others being contacted to help resolve the issue.
2.1
Contractors, Subcontractors and

Consultants
Contractors, Subcontractors and Consultants are responsible for:

a) Having an effective environmental, health and safety program
in place;
b) Insisting on safe performance throughout their operations by
ensuring their workers are competent to perform their work
correctly;
c) Ensuring their employees and subcontractors meet the
contractors and Niskas environmental, health and safety
expectations;
d) Ensuring their safety programs and operations comply with
Niskas contractual and OHSA regulatory requirements;
e) Providing the required time and resources to allow
subcontractors and their employees to perform their work
correctly and safely;
f) Ensuring that workers under their supervision know and are
prepared to deal with the hazards associated with their work
and any specific hazards on the work site;
g) Ensuring that PPE is available, properly used, stored,
maintained, and replaced when necessary;
h) Reporting all accidents and/or incidents to Niska as soon as
possible;
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i) Complying with their responsibilities as stated in the OSHA
Act, Regulations and/or Codes by ensuring:

i. Unsafe conditions and behavior are corrected immediately.
ii. Daily Tailgate meetings, Pre-job Hazard Assessments
and Job-specific Hazard Assessments are conducted,
and documented safe work practices or procedures are
developed by the contractor and are being adhered to.
iii. The correct equipment or tools to conduct the task are
available and maintained.
iv. Hazards are identified and removed where practicable.
2.2
Inspectors (Niska Employee or Contracted)
When acting as a Niska representative, Inspectors are responsible for

ensuring that safety on the work site is maintained in compliance to
Niska standards.
Where a construction project is taking place on a Niska work site the
Lead or Chief Inspector is the on-site authority on EH&S matters.
The Inspector shall not direct work, unless he has been designated as
the job supervisor.
The Inspector is responsible for ensuring that:
a) An immediate work stoppage is initiated when any reportable
or serious event occurs;
b) All work stoppages as identified in Section 5.3 and 5.4 are
reported immediately to the Niska project coordinator;
c) Preliminary Incident Announcement Reports forms are
completed and submitted to the Niska project coordinator
within 24 hours should a Level 2 or 3 incident occur;
d) First aid services (including first aid training), equipment and
supplies required by the OSHA regulations are available at the
work site;
e) An Emergency Response Plan (ERP) exists for project work,
is reviewed by all workers prior to the commencement of the
project, is made available to all workers and is followed in the
event of an emergency;
f) Safe Work Permits are issued to contractors authorizing work
to be done;
g) Regular site inspections are conducted and documented; and
h) All workers and visitors entering the work site are informed of
site hazards and are accounted for.
2.3
Workers
All workers, Niska and contracted, are responsible for:

a) Being aware of their environmental, health and safety
responsibilities;
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b) Taking reasonable care to protect themselves, their co-workers,

c)
d)
e)
f)
g)
h)
i)
j)
k)
l)
2.4
the public, the environment and company property;

Knowing the emergency response plan, where emergency
equipment, alarms and emergency response numbers are
located, and how and where to evacuate when working at
facilities or work sites;
Participating in all required training, including health and safety
training;
Correctly using all required protective and safety equipment;
Following safety standards and safe work procedures as set out
by Niska or their employer;
Consulting their immediate supervisor if there is any doubt
regarding the job procedure or the safety requirements before
proceeding with an assigned task;
Refusing to conduct work for which they are not trained or
when unsafe conditions exist;
Immediately reporting injuries, near misses, or other incidents
to their supervisor;
Conducting inspections of safety equipment, tools and
equipment, and PPE prior to using them;
Knowing the type, location and operation of emergency
equipment; and
Reporting directly to the Lead or Chief Inspector or Niska
Representative in charge of the site where project work is
taking place in order to be advised of any site-specific hazards
that may affect their health or safety.
Visitors
All visitors to a Niska work site are responsible for:

a) Following the instructions of the Niska representative;
b) Wearing the specified PPE where required;
c) Staying in close proximity to the Niska representative; and
d) Reporting directly to the Lead or Chief Inspector or Niska
representative in charge of the site where construction or
project work is taking place in order to be advised of any sitespecific hazards that may affect their health or safety
Note:
Due to the inherent hazards found on active construction
work sites, visitors without the training requirements stated
in Section 8.21 may not be permitted access
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2.5
OSHA General Duty Clause
The OSHA Occupational Safety and Health Act states:

Each employer shall furnish to each of his employees employment
and a place of employment which are free from recognized hazards
that are causing or are likely to cause death or serious physical harm
to his employees.
2.6
Refusing to Work Because Conditions are

Dangerous
When you believe working conditions are unsafe or unhealthful,

you should call your employers attention to the problem. If your
employer does not correct the hazard or disagrees with you about the
extent of the hazard, you also may file a complaint with OSHA.
Refusing to do a job because of potentially unsafe workplace
conditions is not ordinarily an employees right under the
Occupational Safety Health Administration (OSHA) Act. (A union
contract or state law may, however, give you this right, but OSHA
cannot enforce it.) Refusing to work may result in disciplinary action
by the employer. However, employees do have the right to refuse
to do a job if they believe in good faith that they are exposed to an
imminent danger. Good faith means that even if an imminent
danger is not found to exist, the worker had reasonable grounds to
believe that it did exist.
But, as a general rule, you do not have the right to walk off the job
because of unsafe conditions. If you do and your employer fires or
disciplines you, OSHA may not be able to protect you. So, stay on the
job until the problem can be resolved.
Your right to refuse to do a task is protected if all of the following
conditions are met:
Where possible, you have asked the employer to eliminate the
danger, and the employer failed to do so; and
You refused to work in good faith. This means that you must
genuinely believe that an imminent danger exists. Your refusal
cannot be a disguised attempt to harass your employer or
disrupt business; and
A reasonable person would agree that there is a real danger of
death or serious injury; and
There isnt enough time, due to the urgency of the hazard, to
get it corrected through regular enforcement channels, such as
requesting an OSHA inspection.
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When all of these conditions are met, you take the following
steps:
Ask your employer to correct the hazard;
Ask your employer for other work;
Tell your employer that you wont perform the work unless and
until the hazard is corrected; and
Remain at the worksite until ordered to leave by your employer.
2.7
Workers Compensation
All US employees are covered under Workers Compensation law. All

injuries and illnesses are covered providing they are work related and
include everything from first-aid type injuries to serious accidents.
What you need to do if you sustain an injury while working for
Niska:
Seek treatment as soon as possible
Immediately notify your supervisor.
Complete the Workers Compensation form that describes the
injury, and how, when, and where it happened.
Return the form to your supervisor as soon as possible.
Prompt reporting is the key to prompt benefits.
Benefits in California
The California Workers Compensation law guarantees four
types of benefits:
Medical treatment to cure an injury with no deductibles.
Tax-free payments to replace lost wages while temporarily
disabled. Additional payments may be made if the injury results
in permanent handicap or death.
Rehabilitation services necessary to get back to work will be
provided if required.
Death benefits.
All benefits are set by the California State Legislature: The
amount of the payments, and when and how they are paid,
are part of State law. Only the State Legislature can change
the amounts.
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3.0 ENVIRONMENTAL
RESPONSIBILITIES
There are many regulations that govern the release of substances
into the air and water by industry. Niska obtains all of the permits
required by these regulations and follows the procedures specified in
each permit. Niska renews the permits according to the regulatory
requirement and complies with air and water requirements that are
not associated with a permit.
3.1
Storm Water Runoff
The Federal Water Pollution Control Act (also known as the Clean
Water Act) covers two major categories of discharges. Point source
discharges, or pollutants that are emitted from a discrete source such
as a pipe, and storm-water discharges, that result from the runoff of
precipitation from natural and/or constructed storm-water systems.
WGS LLC does not have any Point Source discharges.
The Clean Water Act requires National Pollution Discharge
Elimination System (NPDES) permits for storm water discharges
associated with industrial activity. Niska is exempt from the NPDES
permit requirements. The regulation, 40CFR 122.26(c) (1) (iii), states
that the operator of an existing or new discharge composed entirely
of storm water from oil or gas exploration, production, processing,
or treatment operation, or transmission facility is not required to
submit a permit application unless it will contribute to a water quality
standard violation or has a discharge of a reportable quantity for
which notification is required.
3.2
Compressor Facility Storm Water Discharge

Procedure
Rainwater accumulates in secondary containment structures. The

following guideline is to be followed before any rainwater is released:
1. When an Operator determines one or more of the secondary
containment structures are in need of rainwater release, the
Operator will first visually inspect the water for signs of oil or
any other pollutant.
2. If an operator observes an oily sheen an oil absorbent pad will
be placed on the water to absorb the oil.
3. Once the oil sheen has been removed, the Operator will obtain
a water sample from the secondary containment structure
and have it analyzed for the suspected contaminant(s). A
water sample should be taken from each of the secondary
containment structures before the first release of the season.
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No rainwater will be released until the laboratory results are

known.
4. If the laboratory results show there is no detectable amount
or an amount considered of minimal concern, the rainwater
will be released onto facility property. If the laboratory results
show contamination that is of concern, the water will either
be pumped into the underground storage tank that holds brine
water or a vacuum truck will be scheduled to come and pump
out the contents of the secondary structure1. WGS LLC
follows the Central Valley Regional Water Quality Control
Board recommendations as an example < 1ppm of oil or
grease.
5. The volume of water discharged is documented each time.
6. There will be a weekly account of water volumes of all
secondary containments or vaults and will be recorded and
kept on file at each facility.
3.3
Well Pad Storm Water Discharge Procedure
Rainwater may accumulate into the general well pad area and/or into
the caissons. The following guideline is to be followed before any
rainwater is released.
General Well Pad Area
1. Before the first rain, the valve on the discharge pipe needs to
be closed.
2. After the first rain, the Operator should visually check the
accumulated water at the well pad for oil. If no oil sheen is
observed, the valve is opened for the remainder of the wet
season.
3. If an oil sheen is observed the Operator will arrange for a
vacuum truck to vacuum out the oil contaminated rainwater.
Well Pad Caissons
1. When the Operator determines one or all of the caissons needs
to have the rainwater released, the Operator will first visually
inspect the water for any oil.
2. If no oil is observed, the rainwater will be released onto the
well pad property.
3. If oil is observed, the Operator will call a vacuum truck to
vacuum out the oil contaminated rainwater.
4. The volume of water discharged is documented each time.
In California only:
In California, Wild Goose Storage LLC is under a Statewide General
National Pollutant Discharge Elimination System (NPDES) Permit
for discharges from utility vaults and underground structures
to surface waters (General Permit) CAG990002. This permit is
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automatically reissued as long as Wild Goose Storage Inc. submits

a Notice of Intent to the State Water Resources Control Board,
NPDES Regulations Unit. Wild Goose Storage Inc. follows
the requirements in the permit (WDID identification number
9000U000059) issued by the Central Valley Regional Water Quality
Control Board.
Spill Response Procedures
Storage facilities containing hazardous materials including fuels
and solvents must have secondary containment. The location of
temporary storage tanks must be approved by your supervisor and
must comply with the secondary containment requirements.
Leaks from storage tanks and associated piping are a major source of
soil and groundwater contamination. Storage of flammable and/or
toxic liquids and gases can potentially be a hazard to public safety.
Selecting appropriate tanks, placing these tanks in an appropriate
location, and using proper secondary containment facilities can
reduce these hazards.
All spills must be reported to your supervisor immediately and be
managed in accordance with regulatory requirements.
Refer to the facility Emergency Response Plan.
3.4
Underground Storage Tanks
You are required to comply with either the Federal or State

underground storage tank regulations depending upon the location
of the facility. The purpose of the regulations is to prevent
groundwater and surface water contamination. The requirements
are:
Maintain a Permit to Operate for the tanks.
Pay the annual tank fee.
Comply with the construction standards.
Comply with the leak detection standards.
Report releases to the appropriate agencies.
In California:
Designate an Underground Storage Tank System Operator.

Pay a quarterly fee to Butte County based on amounts of
stored oils in tanks 302 and 302-2.
The Underground Storage Tank System Operator is certified
by the International Code Council by taking a test once every
two years.
The Underground Storage Tank System Operator maintains
the leak detection system and ensures it is working properly.
The Underground Storage Tank System Operator trains the
employees annually.
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2.5
Waste Management
Wastes generated at Niska facilities must be managed in

accordance with the regulatory requirements.
Waste materials shall be stored in a safe and environmentally
responsible manner.
Records must be kept of all wastes generated, stored, and
disposed of.
Waste management starts with material and process
selection. When selecting a material (i.e. a degreaser) plan
for disposal or recycling of the excess and the waste material
prior to ordering.
When waste materials are generated, they should be
segregated in a way that minimizes the need to dispose and
that minimizes the costs of disposal.
Recyclables should be separated from non-recyclable
materials. Mixing (i.e. mixing of waste oil with a nonrecyclable liquid) may reduce disposal options and increase
the disposal costs.
For further information regarding hazardous waste management

procedures, go to Section 9.14 Hazardous Waste Management and
Transportation.
2.6
Water Crossing and Diversion
Water crossings include, but are not limited to, temporary and
permanent bridges, road crossings using culverts, pipeline crossings
and cable crossings. Water crossings are regulated under State and/or
Federal legislation. Ensure that you have proper authorization to
construct any water crossings and understand and comply with any
and all conditions associated with the crossing authorization.
The State and/or Federal legislation requires that an approval or
license be obtained prior to undertaking a construction activity in a
water body or diverting or using water from a surface water body or
groundwater source. Ensure that proper authorization is obtained to
withdraw and use surface water from any location.
(Footnotes)
(Consult with Central Valley Regional Water Quality Control
Board, California Department of Fish and Game and Butte
County Environmental Health)
1
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4.0 MASTER SERVICE & SUPPLY

AGREEMENT (MSSA)
a) Prior to undertaking any work on a Niska work site, all
contracted employers must have an approved and current

MSSA or other management-approved agreement in place.
b) Prior to authorizing any work on a Niska work site, each Niska
project coordinator is responsible for ensuring that every
contracted employer contracted by them has a signed MSSA or
similar service/construction agreement in place and on file.
Note:
Employing a contracted employer without a signed MSSA or
contract is not permitted without managerial approval.
4.1
Service Provider Notification Guideline
a) Service providers shall give, as a minimum, 24 hours notice to
the Niska representative as to their intended arrival to the work

site.
b) Service providers working on a system that could effect
production must call into the Niska Control Center when
arriving and/or leaving the work site.
c) Contractors must obtain a Safe Work Permit from a Niska
representative prior to the commencement of any work.
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5.0 EMERGENCY RESPONSE PLANNING

AND REPORTING
5.1
Niska Emergency Response Plan (ERP)
The Niska ERP utilizes the Incident Command System (ICS) which
allows for the effective coordination among local, state and federal
emergency responders at the scene of an incident thereby ensuring
successful responses to major incidents. Consult the ERP for your
facility for further information.
a) Any Serious or Major incident as identified in the Niska
Risk Matrix will initiate the Niska ERP. Refer to the facility
Emergency Response Plan for details.
1. Emergency Preparation
Workers at each work site must know the following:

a) Pre-arranged emergency signals and evacuation procedures;
b) Where the ERP and telephone numbers are kept;
c) Which employees have a hearing impairment that could affect
their ability to communicate with their co-worker;
d) How many workers are on site; and
e) Where the first aid kit, eye wash stations, showers, firefighting
and spill response equipment are located.
2. Handling Emergency Calls
If you are the receiver of an emergency call, document as neatly as

possible the following information:
a) Name, phone number, location of caller;
b) Nature of the incident;
c) Cause of incident and how serious it is;
d) Specific location and time of incident;
e) Others that are affected or likely to be affected; and
f) Time and date you received the call/information.
3. At The Scene
a) Resist the urge to rush into an incident scene. Assess
b)
c)
d)
e)
the scene to determine what happened, how many people are

injured and ensure that there is no further danger to yourself
or to injured personnel.
If required, all personnel must evacuate the site and meet at the
main gate or at a designated evacuation point.
Call for help. Contact 911 and advise them of the incident.
Enlist the aid of others and if safe to do so, attempt to prevent
further injury and/or damage.
Perform first aid as required.
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f) Secure the area to unauthorized personnel and control ong)

h)
i)
j)
going hazards.
Contact the local police department, fire department, and/or
ambulance if required.
In the event of an uncontrolled incident activate the
Emergency Shutdown (ESD) of the system and advise the
Niska Control Center.
Call your Supervisor. If the incident involves injury, ensure the
employer (Niska or Contracted employers office) is contacted
immediately.
If able, be prepared to provide assistance to emergency
response personnel and arrange the transportation of injured
personnel.
Important:
All Safe Work Permits are immediately rescinded when an
emergency, incident, unanticipated gas detector alarm,
station alarm or shutdown occurs at a Niska work site.
5.2
Incident Reporting and Legislative

Requirements
An incident occurs when a person or object receives an amount of

energy or hazardous material that cannot be absorbed or handled
safely. The energy or hazardous material is the direct cause of the
incident. The direct cause is usually the result of one or more unsafe
acts, unsafe conditions, or both. These unsafe acts and conditions
are the indirect causes. A good incident investigation is designed
to discover the basic causes of the incident. The basic cause of the
incident is the action or condition that resulted in an undesired event.
The purpose of reporting incidents is so that an investigation and
analysis of the immediate and basic causes can be conducted in such
a way that it encourages learning and so that recurrence of a similar
event can be prevented and opportunities for improvement can be
maximized.
a) Any worker involved in or witness to any incident including
personal injury, damage to equipment, loss of production,
unanticipated gas detector alarm, or other hazards involving
environmental, health or safety shall, as a minimum, verbally
report the details to a Niska Representative as soon as practical
on the same day.
b) By law, an employer shall report fatalities or serious incidents
forthwith to regulatory agencies and make every reasonable
effort to prevent alteration of the incident scene and/or stop
work until unsafe conditions are resolved.
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c) Any occurrence involving an injury to a worker(s), significant
property loss or damage, a reportable incident that requires

reporting to any regulatory agencies, or injury to a third
party, shall be investigated and a written report immediately
forwarded to a Niska representative or at a time agreed to by
Niska management.
d) The employer is responsible for any notifications to the nearest
Workplace Health and Safety office for employee work-related
illnesses, injuries and reportable incidents.
5.3
Near Miss Reporting
In addition to reporting and investigating incidents where

harm occurred to a worker, property, process/operations or
the environment, near miss incident must also be reported and
investigated. The value in capturing these in a report is to allow for
shared communications so others can take the necessary precautions
or modify their activities to prevent similar reoccurrences.
A near miss is an incident that, under slightly different circumstances,
could have resulted in personal harm, property damage, process or
environmental loss.
Reporting near miss incidents is an excellent opportunity to improve
safety and reduce losses gained from observing a condition or event
that has the potential for more serious consequences.
Like any incident investigation, reporting near miss incidents is not
conducted to lay blame or for fault-finding. Reporting near miss
incidents in strongly encouraged by Niska management and there is
no disciplinary action when you submit a report.
Near miss incidents include, for example:
Unsafe conditions (e.g. tripping hazard or a bull plug was left
out of a drain valve of a toxic chemical)
Unsafe behavior (e.g. not wearing the specified PPE as required
by this Handbook)
Events where injury or damage could have occurred but did
not (e.g. while backing up your truck you failed to see someone
walking by)
Events where a safety barrier was challenged or alarm was
sounded. (e.g. gas detector alarm for explosive gases)
Potential wildlife encounters while driving to and from or while
at work.
For further information, review the Niska Incident Reporting
and Investigation Guideline.
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6.0 HAZARD IDENTIFICATION,

ASSESSMENT AND CONTROL
Hazards can be defined as a physical situation with a potential for
personal injury, damage to equipment or materials, or harm to the
environment. While a work site may contain many hazards, the risk
of injury or loss can be managed by identifying the hazard, assessing
the risk and implementing effective control measures such as using
equipment guarding, safe work procedures, wearing appropriate
personal protective equipment, etc.
Hazards can be classed in the following categories:
Physical hazards: contact hazards that can cause injury such as
cuts, burns, abrasions, etc.;
Chemical hazards: fumes, gases, aerosols, corrosives, alkalis,
chemicals, solvents, sprays, heavy metals, poisons, and
pesticides, etc.;
Environmental hazards: hazards such as noise, heat, cold, etc.;
Biological hazards: hazards that can cause illness, such as
hantavirus, allergies, etc.;
Psycho-social hazards: stress, fatigue, boredom, long term
effects of shift work, etc.
Ergonomic hazards: cramped workspaces, improperly adjusted
equipment, repetitive tasks, etc.
6.1
Hazard Assessment
Hazards are addressed by using the hierarchy of controls in the

following highest-to-lowest priority:
1. Isolation, substitution or elimination;
2. Engineering;
3. Administrative; and
4. Personal Protective Equipment.
a) In order to control and manage hazards found on the work
site, whether conducting a low hazard job, a non-routine
job or accessing a work site a hazard assessment must be
conducted.
b) Hazard assessments must be conducted, documented, dated
and relayed to all affected workers by a competent person:
When non-routine jobs are to be performed on a Niska
work site;
Prior to the commencement of work; and
When the scope of work changes, a new work process is
introduced, or a work process or operation changes.
c) For low hazard jobs perform an informal hazard assessment
before accessing a work site to ensure that the site is safe to
enter.
- 24 -
d) When conducting a non-routine job, the hazard assessment

and control consists of the following five steps:
1. Performing an Informal Hazard Assessment before
accessing a work site to ensure that the site is safe to
enter;
2. Conducting a Tailgate Safety Meeting before the job
starts with all affected workers on the work site in order
to:
i. Inform all parties of the planned work for that day
and any site-specific hazards that those workers
should be aware of, as hazards may be posed by
other work activities on the work site;
ii. Determine what the control measures will be for
those hazards; and
iii. Determine who is responsible for implementing
those control measures.
3. Conducting a Pre-Job Hazard Assessment
to identify the hazards, the controls, and who is
responsible for controlling those hazards when dealing
with a specific task. For most work the Niska Safe
Work Permit incorporates the requirements of a
Pre-Job Hazard Assessment. However, the on-site
supervisor may require, on a discretionary basis, a
detailed Job Task Analysis (JTA) for any job.
4. Developing and reviewing a written JTA would
for complex activities involving higher risk work
or when close supervision is required for assessing
the competency of workers or contractors who are
unfamiliar or new to the job or work site. Developing
or reviewing a JTA must also be conducted:
i. For each non-routine job if deemed warranted by
the competent person on the work site. The JTA
must be reviewed by all affected workers so that
fully comprehend all facets of the task. A JTA
may exist already for a certain job task. In such
cases the JTA needs to be reviewed for site-specific
hazards;
ii. At intervals that reasonably and practicably prevent
the development of unsafe working conditions;
iii. When a new work process is introduced; or
iv. If conditions change in the work area.
- 25 -
Note:
The JTA must be documented and kept on site by the
recipient of the Safe Work Permit for the duration of the work
activity
5. Issuing a Safe Work Permit (SWP), authorizing work
to be performed is required for all non-routine tasks,

regardless of who the workers are employed by.
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7.0 ENVIRONMENTAL, HEALTH AND

SAFETY (EH&S) ORIENTATIONS
AND MEETINGS
7.1
Site-Specific Orientations
When a contracted worker reports to a Niska work site, a sitespecific orientation for that particular site must be conducted and
documented by a Niska Representative or by an authorized and
competent person outlining the following:
a) Workers responsibilities for environment, health and safety;
b) Verification of worker competency and core training
certification, (first aid, Hazardous Waste Operations
Emergency Response - HAZWOPPER);
c) Site specific hazards that may be encountered, including fire,
first aid, prohibited or restricted areas at the site, flammable or
chemical hazards;
d) Safe work procedures/ Job Task Analysis;
e) Emergency response and rescue procedures;
f) Work attire;
g) PPE and the expectations around provision and use;
h) Assignment of job duties;
i) Specific job conditions;
j) The expectation to report an incident, a near miss or a job
hazard; and
k) Any other safety or environmental particulars about the site
that the worker may be unfamiliar with or has not encountered
before.
7.2
EH&S Meetings
All EH&S Meeting reports, minutes or forms applicable to a project

must be forwarded to the Niska Project Coordinator or district office
within 7 working days of the meeting.
1. Pre-Project Meeting
This meeting is conducted prior to the commencement of field
activities on a project, led by the project coordinator and with
operations and EH&S review and consultation.
2. Project Safety Meeting
This meeting is held immediately prior to the commencement
of the field activity portion of the project by reviewing the
hazard assessment and the conditions of the Safe Work Permit.
Doing so will:
a) Ensure workers know and understand the job requirements
and their responsibilities.
- 28 -
b) Ensure workers have the required PPE, equipment, and
tools to perform the work safely.

c) Remind workers that if they are uncertain about any
aspect of the job, it is their responsibility to learn the
procedure before continuing. Every worker should know
it is always okay to ask, if in doubt.
d) Test the workers knowledge of the job procedure by the
supervisor asking questions (particularly useful for new
workers).
e) Ensure workers are familiar with the emergency response
and rescue procedures.
3. Tailgate Safety Meeting
This meeting is held to make workers aware of the potential
hazards at the work site or for specific tasks for a specific job.
A tailgate meeting will:
Alert workers of unsafe work practices or when work site
conditions change;
Discuss a specific task or set of instructions; and
Ensure workers and equipment operators who missed the
Project Safety Meeting are briefed on the hazard assessment
and all meeting discussions prior to starting any work.
4. Monthly Safety Meetings
Safety meetings are usually held on a regular basis (e.g.
monthly). This is an opportunity for all workers to gather to
discuss general safety concerns which can result from incidents
or changing conditions at the work site or to introduce
improvements to maintain safe work conditions. This time may
also be used as a safety training or orientation session. Speakers
or trainers may also be asked to make a presentation.
The following business Safety Meeting agenda should be
used:
a) Previous business arising from minutes;

b) Old hazards: solutions, safety training, incident/near miss
review;
c) New concerns or hazards, required training, action
assignment;
d) Educational segment: regulations review, procedures review,
safety equipment review;
e) Schedule next meeting date; and
f) Minutes are to be recorded, posted and distributed to the
EHS department in Calgary for review and retention.
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- 31 -
8.0 GENERAL PERSONAL SAFETY

PRACTICES
8.1
Health Considerations
8.1.1
Bloodborne Pathogens
Occupational Safety and Health Administration (OSHA) issued the

Bloodborne Pathogens Standard to reduce the risk of employees
being exposed to bloodborne pathogens, such as, Hepatitis B virus,
Hepatitis C virus, and Human Immunodeficiency Virus (HIV).
This standard applies only to employees that might be exposed to
blood or other potentially infectious materials based on their job
responsibilities.
8.1.2
Bloodborne Pathogen Exposure Control
Bloodborne pathogens are microorganisms present in human blood

and other potentially infectious materials and can cause disease in
humans. These pathogens include, but are not limited to, Hepatitis B
virus, Hepatitis C virus, and HIV.
All employees whose job responsibilities include providing first aid or
emergency response are considered to have a potential occupational
exposure to bloodborne pathogens. Occupational exposure is the
reasonably anticipated contact of skin, eye, or mucous membrane
with blood or other potentially infectious materials, (for example,
saliva contaminated with blood or any other body fluid).
You are not required to provide first aid and do so under the Good
Samaritan clause. Good Samaritans require post-exposure follow
up as specified by this procedure. Supervision is to advise you if you
are not designated to provide first aid that your response to medical
emergencies is as a Good Samaritan and that you have the potential
to be exposed to bloodborne pathogens.
8.1.3
Handling Bloodborne Pathogens
The following outlines compliance methods to handle bloodborne

pathogens:
1. Treat all human blood and human body fluids as if they
are infected with Hepatitis B, Hepatitis C, HIV, and other
bloodborne pathogens.
2. When an exposure or potential exposure to blood or body
fluids has occurred, immediately wash the area with soap and
water and rinse thoroughly. The person should be taken to a
hospital for medical evaluation and treated immediately (at least
within 2 hours). Medical treatment involves taking medication
- 30 -
for 28 days. Treatment may include Zidovudine (AZT), an

antiviral agent that reduces the risk of HIV infection by
approximately 79%. In addition to AZT, Lamivudine (3TC) will
usually be recommended for increased antiviral activity against
many AZT resistant strains. A third drug, a protease inhibitor,
(Indinavir) may be offered under certain circumstances, where
there is increase risk of infection.
3. Provide hand-washing facilities. When this is not feasible,
provide either an appropriate antiseptic hand cleanser and clean
paper towels or antiseptic towelettes. Hands must be washed
with soap and running water as soon as feasible after cleaning
with an antiseptic hand cleanser and clean paper towels or
antiseptic towelettes.
4. Before responding to an incident where exposure to human
blood or body fluids is likely or possible, put on Personal
Protective Equipment including Nitrile gloves, goggles, face
masks, and CPR face shield, as appropriate to prevent direct
contact with skin or mucous membranes.
5. Wash hands immediately (or as soon as feasible) after removing
gloves or other Personal Protective Equipment. Supervisors
must ensure that you wash hands and other skin with soap and
water or flush mucous membranes with water immediately
(or as soon as feasible) following contact with blood or other
potentially infections materials.
6. Provide Nitrile gloves, hypoallergenic gloves, powderless gloves,
or other similar alternatives for employees who are allergic to
the gloves normally provided (notify your supervisor if you
require hypoallergenic gloves).
7. Remove garment penetrated by blood or other potentially
infectious materials immediately (or as soon as feasible) and
place in a labeled plastic bag.
8. Replace disposable gloves as soon as feasible if they are
torn, punctured or when their functional ability as a barrier
is compromised. Do not wash or decontaminate disposable
(single-use) gloves for re-use.
9. Use engineering and work practice controls to eliminate or
minimize employee exposure.
10. Do not eat, drink, smoke, apply cosmetics or handle contacts in
areas where medical services are rendered.
11. Perform all medical or first aid procedures involving blood
or other potentially infectious materials in a manner that
minimizes splashing, spraying, spattering, etc. of these
substances. Do not suction blood or other potentially
infectious materials by mouth.
- 31 -
8.1.4
Cleaning Procedures
Clean and decontaminate all equipment, and other surfaces

contaminated with blood or potentially infectious materials
using household bleach (1 part bleach to 9 parts water).
Begin cleanup immediately (or as soon as feasible) following a
spill of blood or other potentially infectious material and after
completing first aid procedures.
Repeat cleanup at the end of the work shift if possibly
contaminated since the last cleaning.
Personnel doing cleanup must be trained and use protection
specified in this exposure control plan including PPE.
8.1.5
Contaminated Materials
Provide biohazard trash bags in or near first aid kits to contain

or dispose of contaminated materials.
Once contaminated items are placed in a biohazard bag, close
the bag immediately, or as soon as feasible. If the outside of
the bag becomes contaminated, place it in another biohazard
bag and close it.
Store used biohazard bags in an area not normally accessible to
workers. Only authorized personnel must collect and dispose
of bio-hazardous materials.
Place warning labels on containers used to store, transport
or ship blood or potentially infectious materials, and
on contaminated equipment, stating which portion is
contaminated.
8.1.6
Hepatitis B Vaccination
Hepatitis B is a serious infection of the liver caused by a virus found

in blood or other bodily fluids. After receiving the bloodborne
pathogen training, and within 10 working days of initial assignment
to work involving the potential for occupational exposure to
bloodborne pathogens, offer the Hepatitis B vaccination to the
employee at no cost, unless:
1. The employee has previously received the complete Hepatitis B
vaccination series (3 injections over 6 months);
2. Antibody testing has revealed that the employee is immune; or
3. The vaccine is contraindicated for medical reasons.
If you decline the Hepatitis B vaccination you must sign a
copy of the Hepatitis B Vaccine Declaration. If the employee
initially declines the Hepatitis B vaccination but at a later
date, while still covered under this procedure, decides to
accept the vaccination, the Hepatitis B vaccination will be
made available at that time at no cost.
- 32 -
If the U.S. Public Health Service recommends a routine

booster of Hepatitis B vaccine at a future date, such booster
dose(s) must be made available.
Note: At this time, there is no vaccine for Hepatitis C.
8.1.7
Exposure Incident - Medical Evaluation
Following the report of an exposure incident, immediately provide

the exposed employee a confidential medical evaluation to determine
exposure to Hepatitis B, and Hepatitis C, HIV, and follow-up at no
cost to the employee. The immediate supervisor is responsible to
conduct an incident investigation immediately (or as soon as feasible)
at the site of the exposure incident.
Employees will be offered a repeat Hepatitis B, and Hepatitis C, HIV,
testing to exposed employees 6 weeks after exposure and periodically
thereafter (12 weeks and 6 months after exposure). If the employee
consents to baseline blood collection but does not give consent at
that time for HIV serologic testing, preserve the sample for at least
90 days. If the employee elects to have the baseline sample tested
within 90 days of an exposure incident, provide such testing as soon
as feasible.
When the source individuals consent is not required by law, test
the source individuals blood for Hepatitis B, and Hepatitis C, HIV
and document the results. If consent is needed, provide testing as
soon as feasible after obtaining written consent. If consent is not
obtained, document that the legally required consent cannot be
obtained. Consult with the Legal Department prior to determining
whether to test the source individuals blood.
The medical provider must provide the results of the individuals
testing to the exposed employee, and inform the employee of
applicable laws and regulations on disclosing the identity and
infectious status of the source individual.
The health care professional evaluating an employee after an
exposure incident, and the health care professional who is responsible
for the employee getting the Hepatitis B vaccination, is provided the
following information:
1. A copy of 29 CFR 1910.1030, for California 8 CCR 5193
(California only);
2. A description of the exposed employees duties as they relate to
the exposure incident;
3. Documentation of the exposure route(s) and circumstances
under which exposure occurred;
- 33 -
4. Results of the source individuals blood testing, if available; and

5. All medical records the company is responsible to maintain
(including vaccination status) relevant to the employees

treatment.
6. The health care professionals written opinion for postexposure evaluation and follow-up must be limited to the
following:
That the employee has been informed of the evaluation
results, and
That the employee has been told about any medical
conditions resulting from the exposure that requires further
evaluation or treatment.
All other findings or diagnoses must remain confidential and
must not be included in the written report.
8.1.8
Training
Bloodborne pathogen training must be conducted initially as part of

a regular safety meeting. Thereafter, an annual refresher class will be
provided during a normal safety meeting. A copy of the regulation is
available to any employee at any time.
8.1.9
Recordkeeping
Keep documentation on first aid, CPR, AED and bloodborne

pathogen training for at least 3 years from the training date.
Keep records for each employee with occupational exposure for the
duration of employment plus 30 years. In California, employers are
required to keep an Exposure Log. If an employee is exposed or
potentially exposed to a bloodborne pathogen, it must be recorded in
an Exposure Log.
Medical records are to be kept confidential, except for information
allowed and required to be reported to Niska. Include the following
in the record:
Name and social security number;
A copy of employees Hepatitis B vaccination status, including
the dates of all
Hepatitis B vaccinations and any medical records relative to the
employees ability to receive vaccination (i.e., the employee has
previously received the complete Hepatitis B vaccination series,
antibody testing has revealed that the employee is immune, or
the vaccine is contraindicated for medical reasons);
A copy of all results of examinations, medical testing, and
follow-up procedures;
A copy of the information provided to the health care
professional;
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8.2
A copy of the health care professionals written opinion;

Hepatitis B Vaccine Declination Form; and
Incident Investigation Report Form.
First Aid
The immediate treatment of injured workers and proper first aid

coverage on a Niska worksite is essential to the health and well being
of all employees and contracted workers.
Every Niska field employee will be trained and keep current
certification in Standard First Aid and Cardiopulmonary
resuscitation (CPR);
Note: if the facility is equipped with an Automated External

Defibrillator (AED) each employee will be trained to the
American Heart Association standard of every 3 years.
All facilities will be equipped or provided with first aid supplies;

First aid incidents must be documented using the First
Aid Report form as well as reported using the Incident
Investigation Report form. These reports must be kept for 3
years and must not be posted or distributed for public review;
One first aid kit will be conspicuously located and maintained
in each field office and in each company vehicle;
8.3
Extreme Weather Working Condition

Responsibilities
a) Niska Management and contracted employers working on
Niska work sites shall ensure that their employees are properly
equipped to deal with extreme weather hazards, special
requirements, and the limitations on activities when working in
extreme weather conditions.
b) Niska employees shall assess the work environment in extreme
weather conditions, identify the controls to address those
hazards and implement those controls.
8.4
Heat Stress
In general, an environment is hot if it is very humid and above

85oF. Environmental factors of temperature, humidity, and air
movement affect the bodys ability to dissipate heat. This combined
with human factors, such as clothing and body weight, and job
factors, such as heat generation from work activity, can result in a
heat imbalance thereby elevating the bodys core temperature and
causing heat stress.
The following are examples of actions that can be taken to
reduce heat stress:
- 35 -
Workers must adapt to working in the heat by pacing

themselves until they become adequately acclimatized to the
hot environment.
Drink plenty of fluids in order to replenish the fluids the body
loses through perspiration and evaporation from the skin.
Avoid caffeine, alcohol, large amounts of sugar, and very cold
drinks; this can cause cramps.
Take rest breaks as appropriate for the work being done. If a
worker is feeling faint, experiencing cramping, or becoming
fatigued, the body is warning of potential heat stress.
The worker should move to a cooler area to rest (work-rest
cycle). If required, schedule work for the coolest periods of
the day.
If workers will be working in an enclosed or confined area
without natural air movement, obtain fans or other means of
ventilating the work area to provide for cooling.
Workers should recognize the potential physical disorders
possible from exposure to heat. They include:
a) Heat stroke: total shutdown or failure of the bodys
thermal regulatory system (life threatening - red, hot, dry
skin, sweating has stopped).
b) Heat exhaustion and heat cramps: excessive loss of salt
from the body and water imbalance.
c) Heat fatigue: behavioral change (confusion, distractibility).
d) Heat rash: disorder and blockage of the sweat glands.
Personal protective approaches that can reduce heat stress
include:
a) Absorptive undergarments (removes perspiration from the
skin promoting cooling),
b) Shirt or light skin cover in preference to bare skin
(lightweight, loose-fitting clothing), and
c) Cooling vests in extreme cases.
Minimize Sun Exposure
Too much ultraviolet (UV) radiation can damage skin cells,
which may lead to sunburn, premature aging of the skin, or
even skin cancer. UV radiation can also damage your eyes and
weaken your immune system.
These basic precautions will help reduce the damaging effects of UV:
Reduce your time in the sun, especially between 11 A.M. and
4 P.M.
Protect your eyes with ANSI approved UV-rated sunglasses
with side-shields or wrap-around frames;
Keep hardhat on;
Apply sunscreen to uncovered skin. Use a sun protection
factor of at least 15 (SPF 15). Sunscreen should protect
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from both UVA and UVB. Reapply sunscreen frequently,

especially if youve been in the water or if sweating.
Be especially careful about UV protection when near water
and sand, as they can reflect UV radiation.
Be aware of the daily UV index, which can be found in
weather reports or on the Internet.
8.5
UV Index and Sun Protection Messages

Heat Index Chart
Temperature (F) vs. Relative Humidity
10% 15% 20% 25% 30% 35% 40% 45% 50% 55% 60% 65% 70% 75% 80%
115 111 115 120 127 135 143 151
110 105 108 112 117 123 130 137 143 151
105 100 102 105 109 113 118 123 129 135 142 149
100
95
97
99
101 104 107 110 115 120 126 132 136 144
95
90
91
93
94
96
98
101 104 107 110 114 119 124 130 136
90
85
86
87
88
90
91
93
95
96
98
100 102 106 109 113
85
80
81
82
83
84
85
86
87
88
89
90
91
93
95
97
80
75
76
77
77
78
79
79
80
81
81
82
83
85
86
86
75
70
71
72
72
73
73
74
74
75
75
76
76
77
77
78
Heat Index/Heat Disorders

Heat Index
Possible heat disorders for people in higher risk groups
130 or higher
Heatstroke/sunstroke highly likely with continued exposure.
90-105
Sunstroke, heat cramps or heat exhaustion likely, and heat stroke possible with
prolonged exposure and/or physical activity.
Sunstroke, heat cramps and heat exhaustion possible with prolonged exposure and/or
physical activity.
80-90
Fatigue possible with prolonged exposure and/or physical activity
105-130
Table 1 - Heat Index Chart

UV Index
Description
0-2
Low
3-5
Moderate
6-7
High
8-10
Very High
Sun Protection Actions
Wear sunglasses on bright days

If outside for more than one hour, cover
up and use sunscreen
Take precautions cover up, wear a hat,
sunglasses and sunscreen especially if
you will be outside for 30 minutes or more.
Look for shade near midday when sun is
strongest.
Reduce time in the sun between 11 AM and
4 PM and take full precautions (as above)
Extra precautions required unprotected
skill will be damaged and can burn quickly.
Table 2 - UV Index Risks

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8.6
Working in the Cold
Working in the cold is a fact of life for Niska workers in Oklahoma.

Every year people die from over-exposure to the cold, and many
more suffer injuries from hypothermia and frostbite. Wind chill can
play a major role in such health hazards because it speeds up the rate
at which your body loses heat.
How much heat you lose depends not only on the wind chill, but
on other factors as well. Good quality clothing with high insulating
properties traps air, creating a thicker boundary layer around the body
which keeps in the heat. Wet clothing or footwear loses its insulated
value, resulting in body-heat loss nearly equal to that of exposed skin.
Your body type also determines how quickly you lose heat-- people
with a tall slim build become cold much faster than those that are
shorter and heavier.
The best way to avoid the hazards of wind chill is to check the
weather forecast before going outside, and be prepared by dressing
warmly. As a guideline, keep in mind that the average persons skin
begins to freeze at a wind chill of -130 F, and freezes in minutes at
-310 F.
A simple way to avoid wind chill is to get out of the wind. The
National Weather Service wind chill forecasts are based on the wind
you would experience on open ground. Taking shelter from the wind
can reduce or even eliminate the wind chill factor. However, you
would still feel cold from the outside temperature alone.
In a cold environment, body heat must be conserved to maintain
a core temperature at normal levels and to ensure adequate blood
flow to the brain and extremities. Environmental factors affecting
conservation of body heat are temperature and wind chill. This
combined with human factors, such as protective layers of clothing,
and job factors, such as work activity, determine whether one is
adequately protected from the extremes of cold weather.
The following are examples of actions that can be taken to
reduce cold stress:
Workers must adapt to working in the cold by pacing
themselves until they become adequately acclimatized to the
cold environment.
Prior to working outside (includes operating a snowmobile)
or in unheated buildings, determine the wind chill index and
check the weather forecast for possible changes.
Ensure a means of communication is available when working
in a wind chill below -22o F, so that a rescue can be affected
in case of an accident.
Plan work so that a heated location, such as a vehicle, is
available for warm-up if needed.
Schedule rest breaks regularly, so workers can warm up and
- 38 -
replenish their fluids.

Provide thermal cushioned insulation on tool handles.
Workers should recognize the potential health problems from
working in cold environments.
They include:
a) Frostbite: freezing of the skin, loss of sensation, cold pale
and waxy skin.
b) Trench foot/Immersion foot: intense pain in foot with
swelling. Discoloration of the skin may be caused by long
immersion in cold water. Water temperature does not need
to be below freezing to cause trench foot.
c) Hypothermia: cold extremities which are numb and
clumsy; severe shivering along with reduced mental alertness
with irritability and lack of concentration. The normal
shivering process stops in severe hypothermia.
Personal protective approaches that can reduce cold stress
include:
a) Mittens and gloves should have removable insulated liners.
Liners that cannot be removed and dried every day will
gradually absorb moisture, which will speed up the loss of
body heat.
b) Boots should be of the insulated type and have a removable
insole. They should be worn with wool or nylon blend
socks.
c) Cold weather mask or woolen toque and scarf should be
worn during severe wind chill conditions; check facial skin
frequently for frostbite.
d) Have a spare change of clothing available during cold
weather. Clothing that has become wet from perspiration or
weather-related precipitation should be changed as soon as
possible. If heavy perspiration has taken place, the worker
should exercise caution before removing outer clothing
while resting outdoors in order to prevent chilling and
possible hypothermia.
Three layers of clothing have been found to be effective in
managing cold stress.
1. An inner layer such as long, cotton underwear to absorb
moisture.
2. The second layer is an insulating one, which keeps a
layer of air trapped around the body. Use wool, synthetic
insulation, or down for thermal insulation.
3. The third layer protects the previous layers from dust,
dirt, wind, and moisture. Waterproof cotton twill is ideal
for this layer. Although nylon and/or other synthetics are
also suitable for thermal use, they can develop electrostatic
- 39 -
charge and therefore fire-retardant outwear (Nomex) may

still be required.
The potential for accidental exposure to severe cold must be included
in plans to control exposures. If a worker complains of symptoms of
cold stress, they must be removed from the exposure and assessed by
appropriate medical personnel.
Wind Speed (mph)
Temperature (0F)
40
35
30
25
20
15
10
36
31
25
19
13
10
34
27
21
15
-4
-10 -16 -22 -28 -35 -41 -47 -53 -59 -66 -72
15
32
25
19
13
-7
-13 -19 -26 -32 -39 -45 -51 -58 -64 -71 -77
20
30
24
17
11
-2
-9
-15 -22 -29 -35 -42 -48 -55 -61 -68 -74 -81
25
29
23
16
-4
-11 -17 -24 -31 -37 -44 -51 -58 -64 -71 -78 -84
-5
-5
-10 -15 -20 -25 -30 -35 -40 -45
-11 -16 -22 -28 -34 -40 -46 -52 -57 -63
30
28
22
15
-5
-12 -19 -26 -33 -39 -46 -53 -60 -67 -73 -80 -87
35
28
21
14
-7
-14 -21 -27 -34 -41 -48 -55 -62 -69 -76 -82 -89
40
27
20
13
-1
-8
-15 -22 -29 -36 -43 -50 -57 -64 -71 -78 -84 -91
45
26
19
12
-2
-9
-16 -23 -30 -37 -44 -51 -58 -65 -72 -79 -86 -93
50
26
19
12
-3
-10 -17 -24 -31 -38 -45 -52 -60 -67 -74 -81 -88 -95
55
25
18
11
-3
-11 -18 -25 -32 -39 -46 -54 -61 -68 -75 -82 -89 -97
60
25
17
10
-4
-11 -19 -26 -33 -40 -48 -55
Frostbite
Times
30 minutes
10 minutes
62
-69 -76 -84 -91 -98
5 minutes
Table 3 - Wind Chill Chart
Wind Chill Hazards

Wind Chill
Description
320 F to 160 F
Low
14 0 F to -110 F
-120 F to -440 F
-450 F and colder
Hazard
Slight increase in discomfort
Moderate
Uncomfortable
Exposed skin feels cold
Risk of hypothermia if outside
for long periods
Cold
Risk of skin freezing (frostbite)

Check face, finger, toes, ears and
nose for numbness or whiteness
Risk of hypothermia if outside
for long periods
Extreme
Danger
Outdoor activities are hazardous,
be ready to cut short or cancel
Exposed skin may freeze in
minutes
Check face, finger, toes, ears and
nose for numbness or whiteness
Serious risk of hypothermia if
outside for long periods
Table 4 - Wind Chill Hazards Chart

- 40 -
8.7
West Nile Virus (WNv)
West Nile Virus (WNv) is a mosquito-borne virus that causes

swelling and inflammation of the brain and spinal cord in horses,
birds, and humans. Humans can become infected after being bitten
by an infected mosquito with WNv.
Most persons infected with WNv have either mild symptoms or no
symptoms at all. Symptoms typically include fever, fatigue, headache
and muscle or joint pain. Any worker who suspects they have
symptoms of WNv should seek medical attention.
General Safety Precautions
If possible, eliminate sources of standing water at the work
site as mosquito breeding takes place in standing water.
Use insect repellent containing DEET and apply to
exposed, unbroken skin according to the manufacturers
instructions.
Wear light-colored, long-sleeved shirts, long trousers, and
socks.
Conditions may warrant wearing bug hats/jackets or
wearing two layers of clothing.
Wear rubber gloves when handling dead wildlife.
8.8
Hantavirus
Hantavirus is a rare but serious (can be fatal) illness. Deer mice are
the main carriers of Hantavirus, although it is possible that other
rodent species such as field mice, voles and rats may carry the disease.
Hantavirus can cause a serious lung infection called Hantavirus
Pulmonary Syndrome (HPS).
Exposure to the virus may occur through inhalation of dust
contaminated with dried mouse droppings, and urine and saliva from
infected rodents. Other possible means of infection include contact
with the eyes, contact with open wounds, rodent bites, and eating or
drinking contaminated food. There is no evidence that household
pets or infected humans can transmit the disease.
First stage symptoms include fever, fatigue, weakness and chills,
muscle aches (lower back and thighs), abdominal pain, headaches and
nausea, mild diarrhea and possible cough. The second stage starts
with shortness of breath. This is due to the collection of fluid in the
lungs. Do not delay medical treatment if you experience the above
symptoms. If you have had recent contact with rodents or their
droppings, make sure the doctor is aware of exposure history.
- 41 -
8.9
Personal Protective Equipment (PPE)
a) Niska will provide all required PPE to their employees. However,
b)
c)
d)
e)
PPE for non-Niska employees will not be supplied by Niska

unless approved by the Niska Superintendent of Operations.
PPE shall be used wherever indicated by Niska. Any worker who
does not comply with Niskas PPE requirements will be removed
from the Niska work site.
All workers must:
Use their PPE in accordance with the training and instruction
received;
Inspect their PPE prior to use; and
Not perform the task or use the PPE if the equipments
condition makes it unable to perform the function for which it
was designed.
Basic PPE that must be utilized by Niska employees at all Niska
work sites includes:
ANSI approved hardhats;
ANSI approved Grade 1 safety boots;
ANSI approved eye protection (safety glasses or goggles as
appropriate) prescription safety glasses must have side shields;
ANSI approved hearing protection (plugs or muffs) is required
if there is a risk of exposure to noise equal to or greater than
85 dBA; and
Flame resistant outer wear, whenever there is the potential
for flash fires (i.e. whenever you are working in proximity to
hydrocarbons).
The following information outlines Niskas PPE requirements
for all workers and visitors, unless a workplace hazard assessment
has been completed, which indicates that the specified PPE is
not necessary. The Production Coordinator or their designate is
responsible for ensuring completion of this assessment.
8.10
Flame Resistant Clothing (FRC)
a) FRC outerwear, which meets or exceeds NFPA 2112 Standard

on Flame Resistant Garments for Protection of Industrial
Personnel Against Flash Fire, is mandatory for all Niska
employees working on or visiting a Niska work site.
b) FRC outer wear for electricians must meet the requirements as
identified in NFPA 70E and ASTM F1506-12 standards.
c) FRC must be worn as the outer layer of clothing.
d) All clothing worn beneath flame-resistant outerwear must be
made of 100% natural fibers such as wool, silk, and cotton,
which do not melt when exposed to heat. Nylon clothing,
including nylon ski jackets and fleece, are strictly prohibited.
e) Cotton or linen underclothing is recommended by Niska as
- 42 -
f)
g)
g)
h)
i)
j)
h)
they will produce less static electricity than clothing made of

wool or silk.
Outerwear excessively contaminated or soiled with
hydrocarbons must be changed and laundered, as it will pose
a fire hazard. Do not clean clothing by washing in gasoline,
kerosene or solvent.
Compressed air must NEVER be used for blowing dirt or dust
from a worker or their clothing.
FRC raingear must meet the ASTM (American Society for
Testing and Materials) Standard F1930.
Cotton hoodies must be covered by flame resistant clothing
and must not be exposed to potential flash fire.
FRC hoodies must not be worn between a workers head and
their hard hat.
FRC parka hoods or hoodies worn over a workers hard hat
must be worn in such a way that they do not restrict a workers
peripheral vision.
High-visibility apparel must be worn by all workers on a Niska
work site when there is a potential hazard of being struck by
mobile equipment or other type of vehicle. This includes new
construction projects as well as maintenance and repairs on
existing facilities where there is a high volume of equipment
traffic.
Note:
Non- FRC vests are not allowed on Niska work sites.
8.11
Protective Eyewear
All workers and visitors accessing Niska process plants, property,

pipeline rights-of-way property, work sites, construction, and/or
maintenance projects are required to wear protective eyewear (safety
glasses) that meets or exceed the latest ANSI Standard, regarding
industrial eye and face protection.
a) As a guideline, safety glasses are not specifically required in:
Offices
Break rooms
Enclosed cabs of motor vehicles
Control rooms
Parking lots
b) Other forms of eye and face protection such: as goggles, face
shields, shaded lenses, chipping goggles, welding helmets,
welding goggles, etc. are required for specific jobs, where
safety glasses with side shields alone do not provide adequate
protection.
- 43 -
c) Wearing safety glasses is recommended while driving on
d)
e)
f)
g)
h)
i)
8.12
gravel roads to minimize the risk of glass fragments entering

a workers eyes in the event the windshield is struck by flying
debris.
Dark tinted lenses must not be worn in low-light conditions
(i.e. indoors, caissons, process buildings or at night).
Both safety glasses and a face shield must be worn when
operating a hand-held or stationary grinder.
Welders must not conduct arc welding when other workers
could be potentially be exposed to arc flash injury, unless all
workers are wearing suitable eye protection or are protected by
a welding screen or suitable device.
Workers who wear contact lenses shall inform their employer,
who in turn may advise them of potential job site hazards such
as dust, welding, chemicals, etc., and any alternatives to wearing
contact lenses. Use of contact lenses while wearing SCBA is
permitted.
Eye protection is required at all times, even in excluded areas, if
the work being performed presents a hazard.
Prescription safety eyewear having bifocal, trifocal, or
progressive glass lenses must not be used if there is danger
of impact unless it is worn behind equipment meeting the
requirements of subsection.
Protective Footwear
All workers and visitors accessing Niska process plants, property,

pipeline rights-of-way property, work sites, construction, and/or
maintenance projects are required to wear safety footwear which
meets or exceeds ANSI Standard 29 CFR 1910.136 Occupational
Footwear.
a) Workers and visitors must wear protective footwear that is
appropriate to the hazards associated with the work being
performed.
b) Safety footwear must have non-slip soles and should have
uppers that cover and support the ankle.
c) Safety footwear may be slip-on or lace-up styles.
d) Additional safety footwear requirements, as identified by a
workplace hazard assessment, shall take precedence over the
previously identified minimum standards.
e) Protective footwear must be maintained in good condition to
be effective for the intended purpose.
f) Exposed steel toes are not acceptable and shall not be allowed
on any Niska work site.
- 44 -
8.13
Head Protection
a) As a minimum, all workers and visitors accessing Niska process
b)
c)
d)
e)
f)
g)
h)
i)
j)
k)
plants, property, pipeline rights-of-way property, work sites,

construction, and/or maintenance projects are required to wear
approved hard hats, which meet or exceed ANSI Z89.1-1986,
Class E.
Metal hard hats, Fibremetal brand hard hats, normally worn
by welders and Class C hard hats are all electrically conductive
and are not permitted on Niska work sites.
Welders in the act of welding are permitted to wear a welding
face shield only. Upon completion of the welding, a hard hat
must be worn.
Hard hats shall not be painted, have holes drilled in them, or
otherwise be modified.
Its recommended that Niska field employees replace their hard
hats upon the expiry date and that contracted workers follow
the same practice. Hard hats are considered outdated 5 years
after the stamped date on the underside of the hat brim.
Hard hats that show signs of damage or have received a severe
blow must be replaced. Although a hard hat may not show any
signs of deterioration, UV rays subject the protective headwear
to damaging effects.
Hard hat suspension should be replaced on an annual basis or
when damaged.
Excessive numbers of stickers should not be applied to the
outer shell of a hard hat as they may hide defects.
As a guideline, hard hats are not specifically required in:
Offices
Break rooms
Enclosed cabs of motor vehicles
Control rooms
Parking lots
When required, only flame-resistant hard hat liners, that are
correctly installed, shall be used.
Hard hats are required at all times (even in excluded areas)
if the work being performed, or being done in the vicinity,
presents a Hazard.
8.14
Hearing Protection
a) Hearing protection must be worn by workers exposed to

noise levels in excess of 85 dBA Lex. Refer to Table 3 for
details.
b) Wherever noise hazards in excess of 82 dBA Lex exist and a
worker will be in the area for more than either (8) hours, the
worker must wear approved hearing protection.
- 45 -
c) Wherever work activities may generate noise levels in excess

of 85 dBA, signage for hearing protection requirements will be
posted.
d) A good Rule-of-thumb to determine whether or not you
need hearing protection or not is to stand at arms distance
away from a co-worker and talk to them in a normal voice. If
you have to raise your voice to be heard, you should probably
be wearing hearing protection while in that area or while
conducting that task.
8.14.1
Audiometric Testing
Niska field employees must undergo baseline and annual audiometric

testing. A contracted testing organization will perform audiometric
tests using qualified personnel meeting the requirements of 29 CFR
1910.95 (g) and (h) or 8 CCR 5097 (c) (3). Audiometric testing
equipment must meet the requirements of 29 CFR 1910.95, or 8
CCR 5097 Appendix B.
The audiogram will be repeated at least annually for employees
exposed at or above the action level. The results will be compared
to the baseline audiogram to determine validity and any shifts in
employee hearing acuity.
8.14.2
Training
8.14.3
Record Keeping
Hearing conservation training will be provided initially and at least

annually to personnel included in the Hearing Conservation Program
(HCP). This training will usually be conducted during a safety
meeting. Training must consist of at least the following:
The effects of noise on hearing
The purpose of hearing protectors
The advantages and disadvantages of various types of hearing
protection
Instructions for selecting, fitting, using, and caring for hearing
protection devices
The purpose of audiometric testing, and
An explanation of audiometric test procedures.
Niska will provide a copy of 29 CFR 1910.95 or and 8 CCR 50955100, Occupational Noise Exposure, to affected employees or their
representatives upon request and make it available at locations where
the action level (85 dBA) for noise is exceeded.
An accurate record of all audiometric testing in accordance with the
29 CFR 1910.95(m) or 8 CCR 5100 is maintained by the contract
testing organization. Records of noise exposure monitoring must be
- 46 -
maintained by each facility. Training records must be maintained by

the contract testing organization and each facility.
Sound Level dBA slow response
Duration/Day, Hours
90
8 Hrs
92
6 Hrs
95
4 Hrs
97
3 Hrs
100
2 Hrs
102
1.5 Hrs
105
1 Hrs
110
30 min.
115
15 minutes or less
Table 5 - OSHA Permissible Noise Exposures
8.15
Hair, Jewelry and Loose Fitting Clothing
a) All workers who may come into contact with moving parts or
machinery must confine or cut their head and/or facial hair

to prevent it from becoming snagged or caught in the work
process.
b) Where required to don respiratory protective equipment a
workers facial hair that could affect a respirator seal must be
clean-shaven. Clean-shaven means shaving within the past 24
hours.
Note:
Visitor exemptions will only be granted with supervisory
approval and direct supervision while in attendance at a Niska
work site
c) Where there is risk of a worker coming into contact with
moving parts of machinery or with electrically energized

equipment, or where the work process is such that a similar
hazard exists, the following shall apply:
Workers clothing shall fit closely about the body.
Dangling neckwear, bracelets, earrings, metal wristwatches
or watches with Velcro straps, rings, or other similar
articles are strictly prohibited.
- 47 -
8.16
Intoxicating Beverages and Medications
a) Possession of, or being under the influence of, illegal drugs or

alcoholic beverages is strictly prohibited on Niska work sites
and shall be cause for removal from the work site.
b) Workers shall ensure that legitimate use of over-the-counter
medications or prescription drugs does not impair their ability
to perform their job safely.
8.17
Smoking
a) All Niska work sites, including company vehicles are designated

smoke-free.
b) Niska management shall approve designated smoking areas.
c) Designated smoking areas will not be permitted within 75
feet/25 yards of wellheads, drilling or service rigs, process or
storage facilities or other hazardous areas.
d) Signs will be posted so that smoking and non-smoking areas
are clearly identified.
e) Additional breaks to allow smoking outside of an employees
normal work breaks will not be permitted.
f) The use of smokeless tobacco is prohibited at all times in all
offices, meeting room areas and lunchrooms.
g) Only safety matches (ignited on a box or folder) or lighters
with enclosed or covered mechanisms are permitted on
field location work sites. Strike-anywhere matches or openmechanism disposable lighters are prohibited.
8.18
Firearms
The possession and use of firearms on Niska work sites or company

vehicles is strictly prohibited unless approved in writing from Niska
management. If the possession and use of firearms is authorized
it will require the written approval of the Chief Operations
Officer and will take into consideration the anticipated risk, terms
of engagement, local laws and regulations, and qualifications of
individuals being given authorization.
8.19
Photographic Equipment
The use of photographic equipment on Niska property, without

permission from a Niska representative, is strictly prohibited.
8.20
Pets
Pets of any description are not allowed on Niska work sites.
- 48 -
8.21
Special Health Considerations
It is strongly recommended that workers or visitors with special

health considerations (e.g. epilepsy, diabetes or allergies to insect
bites) inform their supervisor, work site escort, other workers,
or first aid attendants of their condition and the specific first aid
requirements to deal with those issues.
8.22
Training Requirements
a) All workers must be orientated to the Niska EH&S Handbook

prior to commencing work on a Niska work site. EH&S
Handbook orientations are valid for approximately 1 year and
are not to exceed 15 months.
b) A valid wallet sized EH&S Handbook Orientation
Acknowledgement Cards must be carried while on Niska work
sites to indicate successful completion of the orientation.
Proof of orientation shall be provided upon request by a Niska
representative. If unable to produce an orientation card, a
time and date will be scheduled for orientation. In the interim,
access to Niska work sites will be limited and/or under the
direct supervision of an authorized Niska representative.
c) All workers, other than visitors and administrative staff, must
be trained in safe work practices and hold, as a minimum,
current safety training certificates common to the oil and gas
industry which includes:
Basic First Aid/CPR or an equivalent training course;
Department of Transportation (DOT) Operator
Qualification depending on which state the employee
is working in, (California requirements are considerably
different than Oklahoma); and
Hazard Material Identification System (HMIS)
d) Upon request, workers shall verify these training requirements
prior to starting the job by providing the original training
certificates to the Niska representative. Photocopies are not
accepted as proof of certification.
e) Additional required training may include firefighting, confined
space entry and rescue, defensive driving, ground disturbance
or spill management, as determined for a work activity or
project at the Pre-Project Safety Meeting.
f) Visitors may not be allowed on Niska work sites where hazards
exist that make specialized training mandatory for all persons.
g) Only those workers who are trained and authorized to operate
mobile, hand-held or shop equipment will be allowed to do so.
- 49 -
8.23
Working Alone
Work alone means working alone at a work site in circumstances

where assistance is not readily available in the event of an injury,
illness or emergency.
a) Working alone regulations apply to any worker working alone
on a Niska work site or field office where they are out of view
or have no direct contact with another worker.
b) Employees who typically work in an office environment must
also be in contact with another worker when traveling alone
on secondary roads. The worker must be informed of their
co-workers travel plans before the trip begins and must be
periodically contacted throughout the course of the travel
period.
c) The following is a list of Non-Routine tasks that must not be
conducted by an Employee Working Alone:
1. Level II or Level III confined space entry.
2. Working above 10 feet where fall protection is required;
3. Any work requiring the use of a self-contained breathing
apparatus (SCBA) or Supplied-Air Breathing Apparatus
(SABA);
4. Hot work;
5. Manual resetting of tripped high voltage (751 volts)
electrical breakers;
6. Conducting maintenance or repair on high voltage
equipment (751 volts);
7. Confronting intruders, dealing with irate landowners or any
situation that could present a violent confrontation; and
8. Driving from an office to a worksite during inclement
weather and conditions are considered hazardous (i.e.
visibility or road conditions are such that response times to
an employee, who is working alone and requires assistance,
is not readily available).
d) When traveling alone, communication of travel plans must be
conveyed where weather, road or other circumstances warrant.
e) Workers who will be working alone must have an effective
means of communication before proceeding to work alone (e.g.
cell phone, radio, call-in schedule).
f) Check-in intervals with a co-worker for workers working
alone depends on the hazards associated with the work,
location of the work, weather conditions and effectiveness
of the communication system between the two workers. As
a minimum, check-in intervals for low hazard tasks must be
conducted in the morning, at mid-day and at the end of the
day.
- 50 -
8.24
Visitor Guidelines
a) All persons, including Niska employees, visiting any Niska work
b)
c)
d)
e)
site must:
Provide a minimum 24-hour notification of their intended
visit to the Niska representative or facility office; and
Check-in with the Niska representative, field inspector or
facility office when they arrive on site to ensure that its safe
to enter the work site, and then when they leave the work
site to acknowledge their safe departure.
Visitors, including members of employees families, are not
allowed in/on Niska restricted operating areas or premises
except by special permission from authorized Niska personnel.
If theres a question about visitor status, a Niska representative
will determine whether a person or persons meets the visitor or
worker definition.
Visitors are expected to:
Follow the direction of their work site escort;
Remain in close proximity with their escort at all times and
not touch any equipment while on Niska property;
Wear the required Personal Protective Equipment (PPE);
and
Report to their escort any incident or hazard that comes to
their attention.
The work site escort is expected to:
Orientate the visitor to the work site;
Set the limits of visitor movement;
Supervise visitors in an emergency; and
Inform others of the visitors intended visit.
Note:
Due to the inherent hazards found on active construction
work sites, visitors without the training requirements stated
in Section 8.10 may not be permitted access.
- 51 -
- 52 -
- 53 -
9.0 WORK SITE SAFE WORK PRACTICES

9.1
Access and Egress
a) All entrances and exits to facilities and buildings at Niska work

sites and facilities must be kept free of ice and snow to prevent
worker injuries from slips, trips and falls, or vehicle accidents.
b) Aisles, stairways and walkways, and access to safety, firefighting
equipment and first aid equipment must be kept clear of
obstructions (i.e., equipment deliveries, office supplies, etc.)
and/or tripping hazards.
c) All fire lanes, access roads, and evacuation routes must be kept
clear of equipment, materials, and parked vehicles at all times.
9.1.1
Alarm Systems to Detect Explosive Gases,

and Fire
a) Alarm systems are installed at Niska facilities to detect

explosive gases and fire. Operations personnel at each Niska
facility must familiarize themselves with the detection and
alarm systems installed, and must be adequately trained in the
use of, and response to, plant alarms.
b) Monitor and alarm systems are inspected regularly. Alarm
systems will not be left in a bypass mode or be altered in
any way (even minor changes could introduce hazards). If
the detection system malfunctions, make arrangements for
immediate repairs by a qualified service technician.
c) Should an alarm (high LEL gas or fire) occur, notify all
personnel at the work site of the alarm condition, suspend
all hot work immediately, evacuate the area to a safe location
(especially when LEL readings exceed 10% ) and proceed with
emergency response and investigation of alarm conditions.
9.1.2
Building Entry
Workers entering well sites or facility process buildings must

ensure that it is safe to do so by understanding and exercising their
responsibilities to ensure that the activities can be carried out safely
and with minimal risk to people, the environment, public, private, or
company property. A hazard assessment and use of precautionary
measures must be considered as routine work practice when
entering well sites and facilities.
- 52 -
Typical hazards include:

Flammability, explosive, pressure;
Confined spaces, oxygen displacement, and toxic atmospheres;
Static electricity;
Chemicals such as methanol, biocide, demulsifiers, scavengers,
etc.
Typical precautionary measures include:
Hazard assessment,
Bonding and grounding practices before entry,
PPE appropriate to the nature of the hazard, and
Working alone practices and emergency preparedness.
9.2
Cathodic Protection (CP)
CP is used to reduce corrosion of tanks, pipelines, and other buried

structures. CP can involve the flow of a large amount of electrical
current in the soil and pipelines, which can lead to electrocution
or sparking hazards. All Niska pipelines, tanks and buried station
facilities are subject to CP. In order to prevent mechanical contact
with a CP system, contact the Niska Production Coordinator prior to
excavating on a Niska work site.
The following shall be considered when working on cathodic
protected facilities:
a) Prior to cold cutting or breaking a pipe flange connection,
ensure that the facility operations and electrical department has
been consulted to identify all CP rectifier locations required to
be turned off and locked out;
b) Any work such as cold cutting a line or breaking a flange
may cause an arc or spark creating a fire hazard. Electrical
continuity bonds (jumpers) must be used to maintain a safe
path for the flow of electrical current;
c) Upon completion of the work and reassembly of pipelines or
flanges, jumper cables shall be removed and rectifiers shall be
turned back on;
d) Only qualified Niska electricians are authorized to adjust CP
rectifier tap settings; and
e) Only qualified Niska electricians or qualified CP technicians
shall conduct service or maintenance on a CP rectifier.
9.3
Confined Space Entry
9.3.1
OSHA General Industry Standards
29CFR 1910.146 Permit-Required Confined Spaces for General

Industry identifies a confined space that has one or more of the
following characteristics:
- 53 -
Is large enough and so configured that an employee can bodily

enter and perform assigned work; and
Has limited or restricted means for entry or exit (for example,
tanks, vessels, silos, storage bins, hoppers, vaults, and pits are
spaces that may have limited means of entry.); and
Is not designed for continuous employee occupancy.
Note:
Niska employees are not authorized to enter Permit-Required
Confined Spaces unless they have successfully completed a
Niska approved Confined Space Entry training course.
9.3.2
Basic Rules of Confined Space Entry:
a) Unusual or site-specific requirements for confined space entry

must be discussed with the Niska representative at the PreProject meeting or during the work as the need arises.
b) All supervisors, entrants and attendants working on a confined
space project will be able to verify successful completion of a
Niska-approved Confined Space Entry Training Course.
c) All entrants into any level of confined space must continuously
monitor the atmosphere by way of a 4-head electronic
gas detector and especially if there is a potential for the
atmosphere to change unpredictably after a worker enters the
confined space.
d) Workers working alone are permitted to enter a Level I
confined space (i.e. caisson) providing they:
i. Have contacted a co-worker who can be readily available to
respond to an emergency involving the entrant;
ii. Have established a call-in time with their co-worker;
iii. Have a two-way communication device on their person
while entering the Level I confined space; and
iv. Are equipped with a four-head electronic gas detector
capable of detecting an oxygen (O2) deficient or enriched
atmosphere, explosive gases and Carbon Monoxide (CO)
e) A worker who is working alone must not enter a level II or
Level III confined space for any reason.
9.3.3
Two Types of Confined Spaces
Permit-Required Confined Space Entry Requirements

An example of a permit-required confined space would be a 10%
LEL reading in a caisson or an atmospheric concentration of any
substance with an acutely toxic effect above the permissible exposure
limit (PEL) and any atmospheric condition that is immediately
dangerous to life or health (IDLH).
- 54 -
Niska employees and contingent staff must not enter permitrequired confined spaces unless they have been trained in
confined space entry procedures. Entry of such spaces may
only be performed by properly trained and qualified personnel
following the entry requirements Stated in 29 CFR 1910.146
Permit-Required Confined Spaces for General Industry.
Niska field supervision will inform the contractor/employee
of any permit-required confined spaces and ensure that a
pre-job hazard assessment is performed prior to entry. When
contracted to perform confined space entry, contractors are
required to utilize their own confined space entry permit
program for entry or contractually adopt Niskas program.
Niska will not write a confined space entry permit for a
contractor. A Niska representative should be on-site at any
permit-required entry by a contractor.
All permit-required confined spaces must be identified and
labeled as such. At a minimum, the label must contain the
following wording:
DANGER!
PERMIT-REQUIRED CONFINED SPACE.
ENTRY BY PERMIT ONLY.
Non-Permit Confined Spaces

Non-Permit confined spaces are confined spaces that do not actually
or potentially contain hazards that could cause death or serious
physical harm. Examples of non-permit confined spaces at Niska
gas storage facilities are:
Drop ceilings;
Mechanical equipment closets; and
Motor control cabinets
For further information on Confined Space Entry requirements
consult the Niska Gas Storage Confined Space Entry Standard
Important: When in doubt, treat as a Permit Required
Confined Space.
- 55 -
9.4
Drilling and Completions Rig Hazards and

Control
Unique hazards are present during drilling completion and well

work-over activities. Drilling and Completions and Well Work-over
contractors are expected to understand and mitigate these hazards to
ensure a safe work area. These unique hazards include, but are not
limited to:
Heavy equipment traffic
High pressure liquid and gas lines
Rotating Equipment
Steam lines and de-icing equipment
Overhead hazards
Boilers
Draw works
Mud and fluid handling systems
Pipe and casing handling
It is essential that any work being conducted concurrent with,
or adjacent to, active drilling and completions and well workover operations be coordinated with the drilling and completions
supervisor. Your supervisor will coordinate the communication
between construction operations and drilling and completions
operations. Hazards and control measures resulting from concurrent
or adjacent construction/drilling/completions will be communicated
to all employees and contractors during regular safety meetings.
Note:
Do not enter a well pad site where drilling and completion
and well work-over activities are ongoing without the
authorization of your supervisor.
9.5
Electrical Equipment
a) Only competent and certified journeyman electricians and/or
authorized electrical apprentices will perform maintenance on

electrical installations.
Exception:
The only exception is when site-specific minor electricalrelated activities (e.g., changing light bulbs, disconnecting
small motors, opening CP rectifiers) have been exempted
from this requirement by the provincial authority. However,
recognized courses must be taken, equipment-specific
electrical training is required, and workers must be authorized
by their employer.
b) Any maintenance or repairs shall conform to the requirements

of the National Electrical Code - NFPA 70.
- 56 -
c) Only authorized and qualified persons trained in high voltage

awareness are permitted to operate, lock out or reset tripped
high voltage equipment.
d) Resetting of tripped high voltage breakers will not be
conducted if working alone.
e) Only those workers who have been trained and authorized by
Niska shall conduct electrical system lockouts.
f) PPE requirements for non-routine electrical work must either
meet or exceed the requirements identified in NFPA 70E Electrical Safety in the Workplace.
9.6
General Electrical Safety Practices
When performing electrical work, always take appropriate precautions

against the hazards likely to be encountered when performing the
job. In particular:
Consider every circuit to be energized until otherwise proven.
Follow TEST BEFORE TOUCH procedures.
Turn off the electrical power before changing a light bulb.
When operating electrical equipment where there is a
possibility of an arc flash, always stand to one side to avoid
exposure to arc flash energy.
Do not overload electrical systems.
In an emergency when power lines are down, consider every
wire, including fences and guy wires, to be energized. Only
qualified personnel shall handle them.
Electrical equipment must be kept clear of all obstructions; do
not store materials inside, in front, behind, or on top of this
equipment.
All rooms, vaults, and other spaces containing electrical
equipment are to be kept clean with unobstructed walking and
working areas around them. Do not use these areas for storage
of any materials.
Report broken wire poles, guy lines, and any other equipment
requiring repair to your supervisor when discovered. Repairs
must be made promptly.
Use the proper stopping control for all motors. The motor
should only be disconnected by the main breaker in an
emergency.
All electrical equipment shall be provided with a local control
station within the sight of the controlled equipment.
All electrical maintenance tools must be in good condition and
approved and certified for the work being done.
Cleaning of electrical equipment must be done by a qualified
person. Only approved materials may be used.
- 57 -
Work must not be performed on pole lines, outdoor electrical

services, or associated equipment during electrical storms
except during an emergency.
Wet rags are never to be placed on electrical equipment either
to cool down the equipment or to dry the rags.
The use of water for washing down equipment in the vicinity
of electrical apparatus is not permitted.
Poles supporting electrical wires or any type of electrical
equipment are not to be used as a snub or dead man for winch
lines on trucks or pickups.
Any connected wire that is found on or near the ground shall
not be touched by anyone except qualified electrical personnel.
9.7
Elevating Platforms, Man Baskets and Man

Lifts
When working from an elevating platform (i.e. scissor lift) man

basket or man lift, workers must meet the following operating
requirements:
Only trained workers shall operate man lifts or elevating
platforms (i.e., scissor lifts).
Follow the manufacturers operating instructions and do not
exceed their rated load limits.
A complete fall protection system consisting of a full-body
harness and lanyard, equipped with a shock absorbing device,
must be worn by each person moving or operating a man
lift and their lanyard must be attached to the anchor point as
per the manufactures instructions or by that as designed by a
professional engineer as per 29 CFR 1910.
Never tie a safety lanyard to an adjacent structure.
Note:
When connected to the anchor point, the lanyard must be
short enough to prevent the workers from being ejected from
the equipment but also long enough to allow the worker to
perform their work.
9.8
Elevated Workspace
a) All scaffolding used on Niska work sites must comply with 29
CFR 1910. This regulation provides rules and requirements

for the design, fabrication, erection, inspection, testing,
maintenance and use of scaffolding equipment, materials and
equipment where scaffolds are erected to provide working
platforms for workers and materials during the construction,
alteration, repair or demolition of buildings and other
structures.
- 58 -
b) Tagging of scaffolding must be used at all phases of assembly

and disassembly and is required to let workers know that a
particular scaffold is safe for use, that a potential or unusual
hazard is present, or the scaffold is unsafe for use.
c) Tags must be placed at each point of entry to the scaffold.
d) The tagging of scaffolds following visual inspection is required
for the following types of scaffolds:
bracket scaffold;
double-pole scaffold;
needle-beam scaffold;
outrigger scaffold;
single-pole scaffold;
suspended scaffold; and
swing-stage scaffold
Color of inspection tag
Wording to appear on tag
Green
Safe for Use

or similar wording
Yellow
Caution: Potential or Unusual

Hazard
or similar wording
Red
Unsafe for Use

or similar wording
Table 6 - Summary of Scaffold Inspection Tag

Requirements
9.9
Energy Isolation & Lock-Out Tag Out
General
a) Only those workers who have been trained and authorized by
Niska are authorized to conduct electrical system lockouts.
b) Every affected worker is required to lock out equipment or
machinery and must work under the protection of their own
personal safety lock which is not keyed alike to any other
workers safety lock on site, and must keep the key to that lock
in their possession.
c) When performing repair or maintenance work on pneumatic,
- 59 -
d)
e)
f)
g)
h)
9.10
electrical, hydraulic or process equipment, all workers shall lock

out in accordance with the OSHA 29CFR 1910.147
Under normal conditions, the facility operator will de-energize
and apply the first lock if equipment is to be serviced,
repaired, tested or adjusted.
Work shall not be performed until that equipment has come to
a complete stop; and
The facility operator has locked and tagged the equipment, and
removed and rendered safe any hazardous conditions; or
Otherwise rendered the equipment inoperative in a manner
that prevents its accidental reactivation and provides equal or
greater protection than the protection afforded by the previous
clause; and
Each affected worker has applied their own personal safety lock
and tag to the lock out device, (e.g. lock out scissors or group
lock box).
Excavation and Trenching (Ground
Disturbance)
In general terms, ground disturbance is any work, operation or

activity that results in a disturbance of the earth, including without
limitation; surveying, excavating, digging, trenching, plowing, rig
anchor installation, drilling, funneling, auguring, back-filling, blasting,
topsoil stripping, land leveling, peat removing, quarrying, clearing,
grading, pounding a ground rod, fencing and hydrovacing for the
purpose of excavation.
It is not a ground disturbance if the ground penetration is less than
one foot deep and does not result in a reduction of the earth cover
over a pipeline to a depth less than the cover provided when the
pipeline was installed.
The definition of ground disturbance is if a work operation or
activity on or under the existing surface results in a disturbance or
displacement of the soil, but not if the disturbance or displacement
is a result only of:
(1) Routine, minor road maintenance,
(2) Agricultural cultivation to a depth of less than 18 inches below
the ground surface over a pipeline, or
(3) Hand-digging to a depth of no more than one (1) foot below
the ground surface, as long as it does not permanently remove
cover over a buried facility.
General Requirements
a) All excavations on Niska work sites shall comply with the
Niska Ground Disturbance Practice.
- 60 -
b) Ground disturbance procedures must be followed for

any ground disturbance work to protect workers, public,
property and the environment.
c) Perform atmospheric monitoring in excavations that are
greater than 4 feet deep and where a potential exists for
a hazardous atmosphere. Treat these excavations as a
confined space.
d) All underground facilities such as: water, sewage,
oil, natural gas lines, chemicals, cablevision services,
electric energy; or electric, telephonic and telegraphic
communications must be marked before any ground
disturbance is undertaken
e) Facility owners must be notified and have their facilities
marked on the surface prior to starting work.
f) A pre-job meeting must be held for all personnel and
contractors involved in the ground disturbance.
g) Spoil piles must be at least three (3) feet from the side of
the excavation and have a slope of 45o or less. Power line
poles, adjacent to excavations, must be protected from
cave-ins.
h) Proper barricades must be installed to warn people of
the dangers of an open trench and to protect co-workers,
the public, livestock, and wildlife from falling into the
excavation. In a trench or excavation of 12.5 in depth or
less, proper engineered shoring must be used.
i) Workers must know and understand the safe working
distances for heavy equipment from exposed underground
facilities in their jurisdiction.
j) Mechanical excavation must not take place within two (2)
feet of a buried pipeline unless the use of the equipment
is under the direct supervision of a representative of the
owner of the buried pipeline.
k) Only the facility owner representative can direct or permit
heavy equipment to operate within two (2) feet of an
exposed facility.
l) All buried facilities situated within the excavation and
within 16 feet of the work area must be hand exposed
prior to mechanical excavation.
m) Ensure that survey markers, line locates and/or paint
marks are not obscured by such things as materials,
vehicles, equipment or spoil piles;
n) In order to determine the stability of excavation walls,
the soil being excavated must be classified into one of the
three types in the following table by a competent person.
- 61 -
SOIL TYPE
Soil
characteristics
Consistency
Ability to
penetrate
Appearance
Type I
Type II
Type III
Hard and compact Likely to crack and Soft, sandy or loose

soil
soil
crumble soil
Hard, very dense
in compactive
condition
Stiff, compact
in compactive
condition
Firm to very soft,

loose to very loose
in compactive
condition
Only with
difficulty by a
small, sharp
object
With ease
With moderate
difficulty with a
small, sharp object
Dry
Damp after it is
excavated, has low
to medium natural
moisture content
Appears solid but

flows or becomes
unstable when
disturbed. Can be
dry, running easily
into a well-defined
conical pile, or wet
Ability to
excavate with
hand tools
Extremely difficult Moderately difficult With ease
Water seepage
Shows no sign of
water seepage
Shows signs of
localized water
seepage
Other
Does not include

previously
excavated soil
Shows signs of
surface cracking
Is granular soil
below the water
table, unless the
soil has been
dewatered
Exerts substantial
hydraulic pressure
when a support
system is used.
Table 7 - Soil Characteristics
- 62 -
9.10.1
Training Requirements
Workers representing Niska on a ground disturbance must possess

a valid Supervisor Level ground disturbance training certification
or jurisdiction specific equivalent certification and are familiar with
Niskas Ground Disturbance Practice.
All personnel involved in the planning, supervision and execution of
ground disturbances are required to understand and comply with the
Ground Disturbance Practice. It is your responsibility to identify,
to the best of your ability, what is in the ground you plan to dig
BEFORE the digging takes place.
Upon proposing to undertake a ground disturbance all reasonable
precautions must be taken to ascertain whether or not underground
facilities exist in the area of the proposed work prior to breaking
ground.
9.10.2
Soil Conservation
All excavation, earth moving, soil stripping and brush clearing

activities must be conducted in a manner that preserves the soil and
permits future land reclamation or restoration.
Competent personnel must identify soil horizons.
Topsoil and other soil horizons must be kept separate during
construction.
Measures to control soil wind and water erosion must be
implemented.
Erosion barriers (silt fences) and surface contouring should be
used as appropriate.
Construction and heavy traffic must be limited to times when
conditions are dry or frozen to the extent practical.
9.11
Fall Protection
All workers working 6 feet or higher above ground level

are required to use approved ladders, scaffolds, and/or fall
protection equipment.
Fall protection and fall arrest equipment must be certified for
its intended use.
9.11.1
Application
All workers working on a Niska work site must follow Fall Protection
regulations when conducting any one of the following tasks:
1. Working 6 feet or more above ground.
2. Working near a leading edge that is 6 feet or more above the
lower level.
- 63 -
3. Working on an aerial device, such as a scissor lift, boom lift or

vertical lift.
4. Working on an elevated work platform that has guardrails less
than 39 inches high.
5. Working from thrustouts or similar structures, such as, beams,
trusses, purlins or plates of 4 inches in horizontal width
or greater and 15 feet above ground and where temporary
guardrails are impracticable.
Note 1:
If it is unclear whether fall protection equipment is necessary,
ask your supervisor. The guideline is Whenever there is risk
of a fall, the fall protection system should be used.
Note 2:
When working near an excavation that is 6 feet or more deep
a guardrail system must be used.
9.11.2
General Information
Fall protection equipment must be used only for that purpose, not
for hoisting tools or equipment. Only workers trained in the proper
use of fall protection equipment shall use the equipment or work at
elevations where fall protection equipment is required.
9.11.3
Fall Protection Equipment
Body Harness
Lanyard
Anchoring Devices
Carabineer Used to hook retractable lifelines and vertical
drop lines to an overhead anchor point.
9.11.4
Component Compatibility
Fall protection equipment should be used as a complete system. That

is, the lanyard and body harness should always be used together and
they should be made by the same manufacturer. There should be no
component substitution unless approved by the supervisor.
9.11.5
Design and Performance Requirements and Test

Methods
Fall protection equipment has many design and performance

requirements and test methods specified in the regulation (8 CCR
3299 Appendix A, B and C). A safety inspection must be conducted
prior to use.
- 64 -
9.11.6
Rescue Considerations
Every employer utilizing fall protection equipment on a Niska

work site must plan to have means available to promptly rescue
an employee should a fall occur, since the suspended employee
may not be able or incapable of reaching the work level
independently.
Fall protection equipment subjected to impact loading must be
immediately removed from service and must not be used again
until inspected or repaired by the manufacturer or authorized
personnel or replaced.
In California repaired or replaced components or component
parts must meet the performance and testing requirements of 8
CCR 3299 Appendix C.
9.11.7
Free Fall Considerations
Cal-OSHA requires that impact force in a fall not exceed 1,800

pound limit with an approved harness.
Fall Protection Equipment Checklist:
Before Use
Inspect body harness and lanyard for defects and compatibility.
If there are any problems, obtain or order another body
harness and lanyard.
Adjust body harness to fit your body snugly in the center of
the size range.
Have co-worker inspect harness for:
D-ring in the center of your back.
Snap hook is completely closed and locked.
Attach other end of lanyard to approved anchor point
(Structural beams and eyebolts are often used).
Anchor point must be directly above the worker and above the
harness D-ring.
Neither high enough so that worker can not fall more than 6
feet nor contact any lower level obstacle.
The equipment must support 5000 pounds per worker.
After Use
Wipe body harness and lanyard with clean, damp cloth.
Inspect for defects and tag defective if appropriate.
Lubricate connectors and snap hooks.
Return to storage area.
- 65 -
9.12
Fuel Gas as Instrument Gas
Before using fuel gas as instrumentation or power gas, ensure the fuel
gas is compatible with the equipment and materials. Potential hazards
include:
Asphyxiation
Fire and explosion
Pressure releases
Premature equipment failure
A hazard assessment must be completed as part of issuing the Safe
Work Permit. Review the MSDS of the pipe contents.
Safety Precautions
All instrumentation gas, power gas, and all gas from regulators
must be vented outside and away from any potential ignition
source. Prevailing wind direction must be considered.
Ensure all liquids present in the system can be safely trapped
and removed.
Vent lines should be sized and designed to eliminate back
pressure on instrumentation or line freezing.
Where sour fuel gas is used, the potential exposure
concentrations must be addressed.
Fuel gas must not be used as a substitute for air in portable
power tools (e.g., impact drivers, sprayers, pumps).
Establish and maintain a strict preventive maintenance schedule
to look for and correct all types of leaks (i.e., instrumentcontrolled gasket door leaks).
9.13
Gas and Liquid Sampling
All workers who are required to sample gas or liquids will undergo
on-the-job training and demonstrate their competence to the on-site
supervisor.
Hazards associated with gas and liquid samplings include:
Burns from hot fluids, gases, chemicals, and frost
Chemical exposure from inhaling toxic substances
Asphyxiation
Dermatitis or skin irritation
Fire and explosion from using improper sampling containers
Plugged sample lines and faulty valves
Static electricity
Based on the results of the hazard assessment and prior to
issuing a Safe Work Permit, a work-specific procedure must
be developed to eliminate or control the potential hazards
associated with gas and liquid sampling.
- 66 -
Additional PPE may include:

Goggles and face shields
Coveralls
Rubber gloves when working with caustic/acid samples
Personal monitor
Self-Contained Breathing Apparatus (SCBA)
For detailed information on Gas and Liquid Sampling, refer to sitespecific procedures.
9.14
Hazardous Waste Management and

Transportation
These guidelines were developed to provide information on the safe

handling, storage, labeling, and disposal of hazardous wastes based
of the regulations. Follow these guidelines for the protection of
yourself, your co-workers, and for the protection of the environment.
Hazardous Waste is defined as any waste substance that can
harm people, the environment or property.
For California, the legal definition can be found in the
California Health and Safety Code 25122.
9.14.1
List of Hazardous Wastes
Hazardous wastes generated at Niska gas storage facilities may

consist of:
Empty compressed gas cylinders i.e. oxygen or nitrogen
Empty Containers (smaller than 5 gallons) that held chemicals
Empty Containers (greater than 5 gallons) that held chemicals
Empty aerosol containers (non-RCRA Resource
Conservation and Recovery Act, the Federal hazardous waste
law)
Used Dehydrating Chemicals for example, ethylene glycol
and triethylene glycol
Waste (contaminated) Diesel
Waste (contaminated) Gasoline
Used Oils and Lubricants
Used Oil Filters
Used Oily Rags
Waste Solvents, degreasers or paints
9.14.2
Empty Container Disposal Guideline
Empty means that no hazardous material can be poured or drained

from the container when the container is held in any orientation,
or that, if the material is not pourable, no material remains in the
container that can be removed by scrapping or chipping.
- 67 -
9.14.3
Less than 5 gallon containers
For chemicals listed by RCRA (RCRA = Federal hazardous waste)

or is listed as an acutely hazardous waste, the containers must be
disposed of as hazardous waste.
When the container is empty, remove the label and dispose of
it in the trash. Nozzles from aerosol cans must be removed prior
to disposal in trash. In California this procedure only applies to
containers that held California listed hazardous wastes.
9.14.4
Greater than 5 gallon sized containers
When the container is emptied as much as possible, label empty

and dispose of as a hazardous waste.
9.14.5
Safe Handling of Hazardous Wastes
Safe handling procedures and Personal Protective Equipment

recommendations must be presented in the Material Safety Data
Sheet (MSDS) for each material. Access to msds for hazardous
materials and wastes are available through an internet based service
called msdsBinders found on the Niskanet.
9.14.6
Storage Areas for Hazardous Wastes
Hazardous wastes can be stored in two areas:

Satellite Accumulation Areas
Hazardous Waste Storage Area
The Satellite Accumulation Area is for storing up to 55
gallons of each waste type for up to 1 year. The Satellite
Accumulation Areas must be near where the waste is
generated. For example, a mechanic can dispose of waste oil
pads into a 55 gallon metal drum near where he works, as
long as he has direct control of the drum. When the drum
is 90% full or not more than 1 year has passed, the drum is
moved to the Hazardous Waste Storage Area.
The Hazardous Waste Storage Area is for storing all the
other hazardous wastes containers for up to 3 months.
There is no limit to the amount of hazardous waste stored
there.
- 68 -
9.14.7
Container and Disposal Procedures for Hazardous

Wastes
All hazardous wastes must be stored in a non-leaking, Department of

Transportation approved container for that specific waste as specified
in the following table:
Hazardous Wastes
Container
Disposal Procedures
Empty Compressed Gas

Not Applicable
Cylinders for example, oxygen,
acetylene, propane, hydrogen
(leak detector), nitrogen, and
calibration gases.
In general, empty cylinders must

be taken to the vendor and filled
the day they are emptied. If that
is not done, then, empty cylinders
must be labeled empty and
stored in the designated area. For
cylinders that are not refilled,
ensure they are empty, punch out
the valve and place in the trash.
Empty Containers (smaller than Not Applicable Ensure container is empty, remove
5 gallons and contained no
label, if possible, and place in
RCRA chemicals)
trash.
Empty Aerosol Containers
Not Applicable Ensure container is empty, and if
(contained no RCRA
possible remove label and nozzle,
chemicals)
place in trash.
Empty Containers (smaller
Metal 55 gallon Ensure container is empty, and
than 5 gallons and contained
drum
place in labeled, metal container in
RCRA chemicals) For
the Satellite Accumulation Area.
example, brake cleaner and
spray paints
Empty Containers (greater than Metal 55 gallon Ensure container is empty, and
5 gallons) that held chemicals
drum
place in labeled, metal container in
(RCRA or non-RCRA)
the Satellite Accumulation Area.
Used Dehydrating Chemicals
Underground Contact vendor to empty tank.
for example, triethylene glycol
storage tank
Used Glycol Filters
Metal 55 gallon Place in labeled, metal container
Drain filters as long as possible,
drum
in Satellite Accumulation Area or
at least 24 hours
Hazardous Waste Storage Area.
Used Oils and Lubricants
Underground Contact vendor to empty tank.
storage tank
Used Oil Filters
Drain filters as long as possible,
drum
at least 24 hours
Used Oily Rags and absorbent
Metal 55 gallon Place in labeled, metal container in
pads
drum
Satellite Accumulation Area.
Waste (contaminated) Diesel
drum
Waste (contaminated) Gasoline
drum
Waste Solvents
Metal 55 gallon Contact vendor to remove and
drum
recycle.
Table 8 - Hazardous Wastes - Container and Disposal

- 69 -
9.14.8
Container Labels of Hazardous Wastes
All containers in the Satellite Accumulation Areas and Hazardous

Waste Storage Area must be labeled. The requirements are:
9.14.9
Satellite Accumulation Area Label Requirements
Name of hazardous waste for example waste oily rags/pads.

Date waste was first placed in container.
9.14.10 Hazardous Waste Storage Area Label

Requirements
Detailed information required on a specific type of label.

Contact your supervisor for assistance.
9.14.11 Weekly Inspection of Hazardous Waste Storage

Area
Once a week the Hazardous Waste Storage Area must be inspected

and an inspection checklist completed.
9.14.12 Hazardous Waste Transporter and Manifests
The Niska Gas Storage facility supervisor will advise Niska

employees the certified hazardous waste transporter for your facility.
The transporter of the hazardous waste will complete the hazardous
waste manifest. The Niska supervisor should review all manifests to
ensure the information is correct. Hazardous waste manifests must
be kept forever. The generator of hazardous waste is responsible
for the product forever. The manifest documents details that may
become important in a Superfund (Federal law) cleanup situation.
9.14.13 Hazard Communication Program
The Hazard Communication Program provides information to

you so you can work safely with chemicals, understand the hazards
associated with the chemicals, and understand how to minimize
exposure to the chemicals.
9.14.14 Responsibilities
The supervisor is responsible for implementing and maintaining

the Hazard Communication Program. You are responsible for
understanding and following the Hazard Communication Program
and to always, perform job tasks in a safe manner. If it is unclear
whether the job is safe to do, ask your supervisor before beginning
the job.
All workers have a right to information about the chemicals they
work with. In addition to the Hazard Communication training,
- 70 -
employees may review the Hazard Communication Program, the

Hazard Communication regulation, and Material Safety Data Sheets
(MSDSs) at any time.
9.14.15 Requirements
The five requirements in the Hazard Communication Program

are:
1. Prepare a list of hazardous substances at the facility.
2. Collect and maintain MSDSs for those hazardous substances.
The chemical MSDSs must be available to all affected Niska
employees.
3. Train you on the hazards associated with the hazardous
substances and how to work safely and minimize exposure to
those hazardous substances and understand the products short
and long-term health effects;
4. Label all hazardous substance containers with the common
name and applicable hazards, such as, gasoline and flammable
substances.
5. Prepare a written Hazard Communication Program.
6. Labeling Chemical Containers
All chemical containers need two pieces of information
on the container:
Chemical or common name (for example, gasoline)
Appropriate hazard warning (for example, flammable)
If you cannot read the existing label, a legible label needs to
be put on the container.
9.14.16 Labeling of Pipes
The content of facility piping is indicated by a color coding system:

Outdoor piping is typically marked using a color banding at regular
intervals and indoor piping is typically marked using a solid color.
These colors are available at all field offices
9.14.17 Working with Unlabeled Pipes
Prior to working on an unlabeled pipe check with a Niska

representative. All workers are responsible for knowing the contents
of the pipe and the proper work procedures, safe work practices and
Personal Protective Equipment necessary for the job.
9.14.18 Non-Routine Tasks Using Chemicals
Prior to starting a non-routine task, affected workers are responsible

for reading the label and the MSDS for the chemicals used in the
non-routine task. Workers must understand the hazards related to
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the chemical and how to minimize those hazards. Workers that do

not understand the information on the label or MSDS must talk to
your supervisor prior to using the product.
9.14.19 Contractors and Visitors
Contractors and visitors must be informed of general chemical

hazards at the facility by the employee they are working for or
meeting with. Contractors must be required to provide an MSDS for
chemicals brought onto or used at a Niska facility.
a) Only chemicals permitted by the Niska EH&S department
shall be used on a Niska work site. Service providers must be
in possession of an MSDS for all of the controlled substances/
materials they intend to bring onto the site
d) Due to topical exposure to hydrocarbon liquids, when being
exposed to crude oil or condensate liquids Nitrile gloves
must be worn.
e) Regardless if a worker is wearing leather gloves, Nitrile gloves
must be worn underneath the leather gloves.
f) Do Not Use leather gloves that are saturated with either crude
oil or condensate.
g) All controlled products used, stored, handled or disposed of in
the workplace must be properly labeled, and a MSDS for that
product must be made available to all affected workers.
9.14.20 NFPA Warning Sign
National Fire Protection Association (NFPA) 704 Signs may be

required by the local Fire Marshall. The purpose of the sign is to
inform the emergency responders of the potential dangers at a
facility. The signs can also be read by other personnel to understand
the hazards at a facility. The signs must be a diamond shape with four
different colors in each corner of the diamond.
4
2
Table 9 - NFPA Warning Sign

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The signs must be typically located at the entrance to a facility

and/or on buildings and on above ground storage tanks that contain
chemicals. Below is an explanation of what the colors and numbers
on the colors communicate.
Blue Health Hazard (left diamond)
4 = Deadly hazardous
3 = Extreme danger
2 = Hazardous
1 = Slightly hazardous
0 = No health hazard
Red Fire Hazard (upper diamond)
4 = Extremely flammable
3 = Ignites at normal temperatures
2 = Ignites when heated
1 = Must be preheated to burn
0 = Will not burn
Yellow Reactivity Hazard (right
diamond)
4 = May detonate at normal temperatures

3 = Strong shock or heat may detonate
2 = Possible violent chemical change
1 = Unstable if heated
0 = Normally stable
White Special Hazard (lower diamond)
Cor = corrosive chemicals

OXY = oxidizing chemicals
W = reacts with water
9.15
Hot Work
Hot work is defined as work in which a flame is used or sparks or

other sources of ignition may be produced. This includes:
a) Cutting, welding, burning, air gouging, riveting, drilling,
grinding, and chipping;
b) Using electrical equipment not classified for use in a hazardous
location; and
c) Introducing a combustion engine to a work process.
Hot work will not be conducted on any Niska work site until:
a) A hot work permit is issued that indicates the:
(1) Nature of the hazard;
(2) Type and frequency of atmospheric testing required;
(3) Safe work procedures and precautionary measures to be
taken, and
(4) Protective equipment required,
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b) The hot work location is:

(1) Cleared of combustible materials, or
(2) Is suitably isolated from combustible materials,
c) Procedures are implemented to ensure continuous safe
performance of the hot work, and

d) Testing shows that the atmosphere does not contain:
(1) A flammable substance, in a mixture with air, in an amount
exceeding 20 percent of that substances lower explosive
limit for gas or vapors; or
(2) The minimum ignitable concentration for dust.
9.16
Ladders
Portable ladders must meet all regulatory requirements and shall, as a

minimum, meet the following:
a) Portable ladders used on Niska work sites must be equipped
with safety feet on hard surfaces or spike feet for soft surfaces.
b) Ladders must be free of weak or damaged steps.
c) Extension ladders must be tied off at the top with tag lines or
held by another worker, and extended at least 3 feet beyond the
top bearing point. The upper and lower sections of extension
ladders should overlap by at least three rungs.
d) Ladders must be non-conductive if used for electrical work.
e) The base of the ladder must be set at least one quarter of its
vertical length from the base of the wall or structure.
f) Work must not be conducted from either of the top two rungs
of a portable single or extension ladder.
g) Work must not be conducted from either of the top two rungs
of a stepladder, except where the stepladder is equipped with a
railed platform.
h) Workers must never climb or step onto piping, tubing or
electrical conduits.
i) Ladders placed near doors or in passageways shall be protected
against being struck by doors, traffic or personnel. The area
surrounding the ladder must be barricaded off to prevent
contact with the ladder.
j) Do not use ladders when working above 20 feet.
k) Check the ladder for broken rungs, split side rails, loose screws
or bolts, worn or broken non-slip feet, frayed or damaged
ropes. Tag it out of service and have it replaced.
l) Get help when handling heavy or long ladders.
m) Before climbing a ladder, clean your boots if they are muddy or
slippery. Avoid climbing with wet soles.
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9.17
Livestock Protection
Niska personnel will work closely with landowners to ensure all

livestock issues and concerns are addressed. Niska operations must
be managed to minimize impacts to livestock and the potential for
animal health issues. Gates and cattle guards must be in place, where
necessary, to protect Niska facilities from livestock and to prevent
entry of livestock onto leases or other Niska property.
Niska shall exercise due care:
In closing and opening gates and fences,
Ensuring cattle guards are maintained and in place,
Repairing or replacing fences,
Guarding open ditches and excavations with temporary fences
or barricades, and
Ensuring that crossings for livestock and vehicles are installed,
where necessary, to permit free access to watering places,
feeding areas, etc.
9.18
Manual Lifting
Niska recommends mechanical lifting of materials that exceed a

workers physical capability of manual lifting. When manually lifting
any object, proceed with the following steps:
1) Clear any obstructions in your path of movement before
lifting;
2) Plant your feet securely and set position of feet close to object.
This allows for better balance and keeps the center of gravity
above the feet and muscles in the legs;
3) Lower your body by bending at the knees; never bend from
the waist. Do not bend back when squatting try to keep the
natural curve of the back. Key is to not stoop or crouch over
the load;
4) Point your chin to the ceiling to keep your back straight,
forcing you to use your legs;
5) Firmly grip the object to be lifted, and lift with your leg
muscles while avoiding any twisting of your back;
6) When lifting jagged or sharp-edged objects, use gloves to
protect your hands; and
7) Ensure that a clear line of sight is maintained at all times
when lifting and moving items and never turn until the lift is
complete, only your feet should move.
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9.19
Pipeline Pigging & Pigging Valves
a) Regardless of how many workers are on site, when pigging, all

valves related to the procedure will be locked out and tagged by
each affected worker.
b) Open valves slowly to avoid sudden pressure changes in the
pipe which can produce enough force to blow a valve or gasket.
Valves should never be operated by a worker who has not been
properly trained to do so.
c) Always push a ball valve handle whenever opening the valve,
never pull the handle toward you. The pressure differential
across the surface of the ball valve could cause the valve and
attached handle to swing open with great force and has the
potential to severely injure a worker.
9.20
Pipeline Isolation
a) When long-term isolation is required to conduct repairs or

modifications to equipment, pipes or pipelines, all hazardous
substances must be removed from the equipment and pipes
being worked on, and a blind flange installed to provide
positive isolation.
b) When used, a double-block and bleed must be situated directly
upstream of the work area. This means that if flow in the pipe
can come from more than one direction, a double-block and
bleed setup is required on each upstream side. The valves of a
double-block and bleed system must be secured to ensure an
acceptable level of safety.
c) Securing of a double-block and bleed must be by a positive
mechanical means that is either:
(1) Lockable (operated by a key or similar device) and attached
to or integral with the securing device, or
(2) Not lockable but is strong enough to withstand
inadvertent/unauthorized opening without the use of
excessive force, unusual measures, or destructive techniques
e.g. metal-cutting tools.
d) Blind flanges must be of sufficient rating according to
engineering specifications to withstand the highest possible
pressure that may result should an isolation device such as a
block valve fail.
e) Any unit in which a blind flange has been installed must be
clearly marked as containing the device.
f) Before reactivating the piping, all blind flanges must be
removed and accounted for.
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9.21
Portable and Fixed Grinders
Grinders (portable and fixed) must be used, maintained, and

inspected regularly according to the manufacturers recommendations.
Workers who are grinding or buffing must wear full face shields
and safety glasses with side shields.
Prior to starting a grinder, inspect the abrasive wheels and discs
for defects (cracks and chips).
Check the position of the safety guards;
Do not use grinders without guards.
Do not use abrasive wheels and discs for side grinding unless
designed for that purpose.
A work or tool rest for a grinding wheel must have a maximum
clearance of inch from the abrasive wheel, must be
positioned at the center line of the abrasive wheel, and must
not be adjusted while the abrasive wheel is in motion
9.22
Overhead Work
a) When work is being conducted overhead of workers, rope off

or barricade the area below the work platform and post visible
signs reading Danger - Men Working Overhead.
b) For high traffic areas or if traffic conditions dictate, an
attendant may be required to warn of overhead hazards.
c) Take every precaution to ensure that tools workers may be
using do not fall on others working below.
d) Attach tools to a fixed point; if they are light in weight, attach
to the worker.
e) Use tag lines to guide overhead loads; do not use for the
manual handling of materials.
f) Do not use vessels or piping as support for any lifting or
moving operations.
g) Do not fasten cables or ropes to operating piping or vessels.
9.23
Overhead Power Lines
An overhead power line does not have to be hit to cause electric

contact; electricity can arc through the air between two conductors.
If an energized overhead power line is inadvertently struck,
occupants in a vehicle should remain in the vehicle and never step
from the cab to the ground. By contacting the ground and an
electrified vehicle, the circuit is completed and electrocution can
result. Wait for the power line to be de-energized before leaving the
vehicle.
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All workers shall adhere to the following practices wherever overhead

power line crossings may be encountered or when working in
proximity to power lines at Niska construction sites.
a) When performing operations in close proximity (23 feet or
less) to overhead power lines, there shall be a designated safety
standby or observer at the site or the line shall be de-energized
where possible.
b) Equipment shall always be kept away from overhead power
lines following the minimum requirements indicated in Table
5 - Safe Minimum Clearances When Working Near Overhead
Power Lines.
c) All equipment with movable booms must cross under power
lines with the boom in the lowered position.
d) In all cases, the height of power lines shall be established
before moving a high load underneath them.
e) If unsure of what the power line voltage is, and if the power
lines are not de-energized, operate equipment in the area
ONLY if a safe minimum clearance is maintained as follows:
At least 10 feet for lines rated 50 kilovolts or below;
At least 10 feet plus 0.4 inch for each kilovolt above 50
kilovolts; or maintain twice the length of the line insulator
(but never less than 10 feet)
f) Where it is difficult for equipment operators to maintain safe
clearance by visual means, designate a person to observe the
clearance and to give immediate warning when equipment
approaches the limits of safe clearance.
g) Do not use cage-type boom guards, insulating links, or
proximity warning devices as a substitute for de-energizing and
grounding lines or maintaining safe clearance.
h) Before beginning operations near electrical lines, notify the
owners of the lines or their authorized representatives and
provide them with all pertinent information: type of equipment
(including length of boom) and date, time, and type of work
involved. Request the cooperation of the owner to de-energize
and ground the lines or to help provide insulated barriers.
NIOSH encourages employers to consider de-energization
(where possible) as the primary means of preventing injury
from contact between cranes and power lines.
i) Danger Overhead Power Lines signage shall be installed
and maintained in pipeline rights-of-way during all operations
including clearing and equipment move-out. This signage will
be visible from both directions and printed in clear lettering in
a contrasting color to the background.
f) Warning poles with wire strung on both sides of a power line
may be used in lieu of a designated safety standby or observer
- 78 -
on pipeline rights-of-way, except where power line crossings

involve a busy roadway crossing (or construction sites as
above).
g) Work in the vicinity of power lines shall only be conducted
during daylight hours.
h) Do not store material or equipment directly under or adjacent
to an overhead power line.
i) Do not place earth or other material under or adjacent to
an overhead power line in such a manner that the minimum
ground clearance would be reduced.
9.24
Mechanical Contact with an Energized

Underground or Overhead Power Line
If mobile equipment contacts a power line:

Advise the operator to stay on the machine until the boom or
equipment is cleared or the current is shut off.
Dont let anyone approach within 30 feet of the machine.
(Electricity will take any path to the ground. Anyone touching
the machine would supply less resistance than the machine,
causing a touch potential.
If the machine that is in contact with an over head power line
is on fire and the operator has to leave a machine, the operator
must jump clear of the machine. The operator must NOT,
under any circumstances, step down and allow part of their
body to be in contact with the ground while any other part of
their body is touching the machine.
To avoid step potential when you jump, ensure you are not
touching the machine and the ground at the same time. Bunny
hop with feet together until you are at least 30 feet from the
equipment.
All contacts with sources of electrical energy must be
immediately reported to a Niska representative and OSHA.
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Power Line Voltage

Phase to Phase
Minimum Safe
Clearance (feet)
50 or below
10
Above 50 to 200
15
Above 220 to 350
20
Above 350 to 500
25
Above 500 to 750
35
Above 750 to 1,000
45
Table 10 Safe Minimum Clearances When Working

Near Overhead Power Lines
9.25
Safe Welding Practices
Welding on a Niska work site and especially within a process plant

area is an activity which requires extreme caution and proper
procedures. Welding and other hot work are not considered to be
routine operations. Great care and consideration must be taken
before welding onto or cutting into any production lines.
Adequate controls must be in place to offset the hazards
associated with welding or cutting on any work site.
a) A Safe Work Permit is required for welding on Niska work
sites. In areas where sparks could pose a fire hazard, blankets
or tarps shall be used to isolate the work area. This applies to
work such as welding, grinding and oxy/acetylene cutting.
- 80 -
b) Areas for structural steel and pipe fabrication require welding

screens to protect nearby workers from welding flash injuries.
c) The amount of general structural fabrication within the area
subject to flammable hazards must be kept to a minimum.
General fabrication shall be done outside of the area subject to
the permit, wherever possible.
d) Contractors shall use only competent certified welders to
operate cutting and welding equipment.
e) When welding on anything other than mild, uncoated steel,
respiratory protection is required.
f) Hot tapping and stress relieving require; detailed procedures,
pre-job discussions between the Niska Representative and the
contractor and a Safe Work Permit prior to starting the work.
g) Each hose of an oxygen-fuel system e.g. oxy/acetylene torch
system that uses the gases acetylene and oxygen, must have a:
i. Flashback device installed at either the torch end or the
regulator end; and
ii. A back-flow prevention device installed at either the torch
end or regulator end.
h) Gas cylinders must have a valve-cover cap in place when the
cylinders are not in use.
i) Always ensure that the gas cylinder(s) is turned off at the
tank(s), and that the nozzle or torch head and the hose(s) are
drained of its contents to prevent uncontrolled gas release
should the hose be damaged.
j) When welding, fire extinguishers must be easily accessible to
the welder.
k) The welding ground return shall be placed on the material
being welded and as close to the arc as possible, unless an
alternative method is approved.
l) Welding electrodes must be removed from an electric welding
machine left running and unattended.
m) Welding machines shall be turned off at the end of each days
work or when left unattended.
n) Ensure adequate ventilation is present in the welding or cutting
area.
o) Ensure the compressed gas cylinders are regularly checked for
signs of defects, deep rusting or leakage.
p) Ensure cylinders, cylinder valves, couplings, regulators, hoses,
and apparatus is kept free of oily or greasy substances.
- 81 -
9.26
Safe Work Permit (SWP)
Safe Work Permits perform many functions. They are an agreement
between the issuer and the receiver used for controlling and
coordinating work to establish and maintain safe working conditions.
They also ensure that all foreseeable hazards have been considered
and that the appropriate precautions are identified and carried out in
the correct sequential order.
A SWP is also a written record that authorizes specific work at
specific work location for a specific period of time.
Every attempt must be made to issue SWP in person so that
the issuing and receiving parties can discuss the job particulars,
face to face.
Qualified individuals authorized to fill out a SWP must be fully
knowledgeable about all aspects of the form and the hazards
associated with the work to be conducted. Questions raised
during the filling out process shall be cleared with a Niska
representative before the permit is signed.
The issuer and receiver must carry out all safety checks before
work begins.
A SWP cannot be altered in any way or transferred from one
individual to another.
SWP are required for all jobs conducted by contracted workers.
A SWP must be issued by a Niska representative when work
is being performed by an Niska employee, outside agency,
contractor or employer for any non-routine work on a Niska
work site.
Note:
All SWPs are immediately considered rescinced and/or
suspended should an emergency, unexpected gas detector
alarm, incident, reportable spill, reportable incident or site
alarm occur.
9.27
Walkways and Steps
Stairways and walkways must be kept free of debris and

tripping hazards as well as snow and ice as well as free-standing
water and mud.
Use anti-slip material if required.
Handrails are to be kept clean.
Steps or walkways with handrails must be installed over
firewalls.
Avoid carrying tools or materials in a way which would prevent free
use of hands while going up or down stairways; use the handrails.
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10.0
10.1
CHEMICALS AND MATERIALS

Work Site Housekeeping Behavior
All workers shall ensure that good housekeeping practices are

continuously observed at Niska work sites. Such practices include,
but are not limited to, the following:
a) Keep all exits and emergency equipment clear of obstructions;
b) Leave work sites in an orderly fashion at the end of each
workday and at the end of the job;
c) Keep all building entrances and exits free of snow and ice;
d) Store combustibles and flammable materials in covered
receptacles and identify with appropriate warning signs;
e) Collect all rubbish or excess building materials and place in
the appropriately marked bins or barrels. Take to an approved
disposal site or area designated by a Niska Representative.
Never let waste blow off of the right-of-way or lease onto the
landowners property or into ditches;
f) Properly dispose of hazardous wastes or controlled products
and according to waste control;
g) Do not burn trash at Niska work sites without the permission
of the Niska representative;
h) Ensure material storage is on level ground and that materials,
which may be blown about by the wind, are secured or covered
by tarps; and
i) Perform site safety and environmental inspections periodically,
and document and correct all findings in a timely manner.
10.2
Respiratory Protection
a) Approved respiratory protective equipment must be worn

when sandblasting or applying paints, coatings or polyurethane
insulating materials.
b) All exposed workers shall wear respiratory protection when
conditions dictate.
c) Personal Niska-supplied air-purifying respiratory protective
equipment is for Niska employees use only and will not be
shared with contracted or subcontracted workers.
d) Consult the relevant material safety data sheet (msds) prior to
working with a controlled product to determine what, if any,
respiratory protective equipment is required.
- 84 -
10.3
Compressed Gas Cylinders
Compressed gas cylinders used of stored on a Niska work site shall:

a. Have an identification and product label as to its contents and
hazards;
b. Be secured in an upright position;
c. Be kept away from heat, fire, or electric power lines; and
d. Be stored away from general traffic paths and not adjacent to
vehicle paths.
e. Storage areas should be divided and marked as areas for Full
and Empty.
f. Appropriate measures must be taken to separate cylinders
containing substances that could produce an explosive
atmosphere if mixed (i.e. oxygen and acetylene).
g. Protective caps shall be placed over cylinder valves when not in
use or during transport.
h. An approved gas cylinder carrier shall be used whenever lifting
gas cylinders by mobile crane.
i. Unused cylinders shall be returned to the storage area and
should never be left about the work site.
j. Flammable (i.e. acetylene and propane) gas cylinders must
never be used or stored in a horizontal position.
Note:
Acetylene is very unstable. Acetylene cylinders are packed
with porous material that is saturated in acetone in which the
acetylene is dissolved. If the cylinder is laid on its side, the
acetone will separate from the porous material and can be
drawn out of the cylinder when put into use thereby causing
an unstable mixture and potential explosion.
k) Always ensure that gas cylinders are turned off at the tank and
that the nozzle or torch-head and the hose are drained of its
contents and pressure, to prevent uncontrolled gas release in
the event the hose becomes damaged.
l) Hoses, gauges and regulators shall be inspected before
equipment is used and, if defective, must be repaired
immediately. Only approved equipment shall be used for
replacement.
m) Oxy/Acetylene units must be fitted with suitable flashback
arrestors.
n) Compressed gas cylinders shall be removed from all confined
spaces at the end of each job or when the confined space is left
unattended overnight.
- 85 -
10.4
10.5
Compressors and Compressed Air
Air compressors must be equipped with pressure relief valves

and pressure gauges.
Air compressor intakes must be installed and equipped to
ensure only clean air enters the compressor.
Air filters must be installed on the compressor intake.
Safety devices on the compressed air system must be checked
frequently.
Signs must be posted to warn of automatic starting feature of
the compressors.
The belt drive system is totally enclosed to provide protection
for the front, back, top, and sides.
You are prohibited from using highly compressed air for
cleaning purposes.
You are prohibited from directing compressed air towards a
person.
You are prohibited to use compressed air to clean up or move
combustible dust.
Before repair work is done on the pressure system of the
compressor, the pressure is bled off and the system is locked
out.
Safety chains or other suitable safety devices must be used
at couplings of high pressure hose lines where a connection
failure would create a hazard.
Before compressed air is used to empty containers of liquid,
the safe working pressure of a container is checked.
When compressed air is used with abrasive blast cleaning
equipment, the operating valve must be manually held open.
Compressed Air Receivers
A current operating permit, from the local jurisdiction must be

maintained if required
Every receiver is equipped with a pressure gauge and with one
or more automatic spring-loaded safety valves.
The total relieving capacity of the safety valve is capable
of preventing pressure in the receiver from exceeding the
maximum allowable working pressure of the receiver by more
than 10 percent.
Every air receiver is provided a drain pipe and valve at the
lowest point for the removal of accumulated oil and water.
The compressed air receivers must be periodically drained of
moisture and oil.
All safety valves must be tested frequently and at regular
intervals to determine whether they are in good operating
condition.
- 86 -
10.6
The inlet of the air receivers and piping system must be kept
free of accumulated oil and carbonaceous materials.
Static Electrical Charge in Hydrocarbons
Static electrical charges can be generated whenever hydrocarbons are

pumped through piping or hose into pails, containers, storage tanks
or vessels.
The following should also be noted about static electricity:
a. If static electricity builds up sufficiently, it can cause a spark
resulting in an explosion or fire;
b. Although grounding prevents a static electrical charge between
the tank or container and the earth, this does not prevent a
spark from occurring inside the tank or container, between the
liquid and the tank or container;
c. Highly polar liquids such as acetone or isopropanol are
electrical conductors; consequently grounding equipment is
necessary to reduce the danger from static electrical charge
causing a spark;
d. Less conductive liquids can generate static electrical charge
build up at the start of pumping when equipment first goes
back into service after being idle;
e. Loading a tank or container by top-filling will cause a static
electrical charge to build up on the surface of the liquid and
can also form a mist in the tank, which, like a flammable dust,
is explosive; and
f. Use a dip-type fill pipe that transfers liquid as close as possible
to the bottom of the tank.
g. Workers must discharge potential static buildup in their
clothing by grounding themselves prior to undertaking these
activities.
h. Wellheads or wellbores are not deemed to be a sufficient
grounding system. Scale and deposits may form to insulate the
steel from the surrounding earth.
i. Do not use plastic pails for flammable or combustible liquids
due to the generation and conduit characteristics to support
static electricity;
j. When loading and unloading product or chemicals, ensure all
trucks (contracted or other) are bonded;
The usual precaution to avoid static electricity sparking is proper
bonding or grounding. Proper bonding and grounding is required to
prevent ignition due to static electricity sparks when:
Drawing samples into containers;
Transferring flammable liquids between containers,;
- 87 -
Unloading or loading tank trucks;

Using portable electrical equipment and tools; and
Entering or working in a confined space.
Note:
The terms bonding and grounding should not be used
interchangeably, because the two processes have distinctly
different functions. Bonding eliminates a difference in
potential between objects, while Grounding eliminates the
difference in potential between objects and the ground.
Bonding and grounding are only effective when applied to
conductive bodies.
10.7
Bonding Requirements for Decanting of

Liquids
Table 11 - Bonding Requirements for Decanting of Liquids
- 88 -
10.8
Handling and Storage of Line Pipe
a) Pipe racks shall be set on a level foundation designed to

support the load placed on them and to prevent accidental
rolling off of any tubular goods. It is good practice to use
spacers between the layers of pipe on a rack.
b) No worker shall be on top of a load or between the load and
the racks during pipe handling operations.
c) The unloading area must have adequate access and egress and
be free of debris that could impede unloading activities.
d) Load tie-downs shall not be removed until lifting slings and the
hoist line have been attached to the material and slack taken up.
e) Trailers used as pipe racks shall have guards the full length of
both sides of the trailer.
f) All workers involved in loading or unloading of pipe from pipe
racks or trucks must be competent.
g) Load tie-downs shall not be removed until lifting slings and the
hoist line have been attached to the material and the slack taken
up.
h) When unloading the pipe, position the truck so that the pipe
can roll directly off the truck onto the pipe rack.
i) If a picker truck is used to load or unload pipe, use tag lines so
workers can work from the ends of the pipe well away from
the swing radius of the boom.
j) Refuse to unload unstable/unsafe loads.
k) No personnel should be permitted in the area parallel to the
truck trailer once the load tie downs have been removed.
l) During unloading the driver should return to the cab of the
truck or wait at a safe location clear of unloading operations.
m) If for any reason a line pipe load arrives on site that upon
visual inspection does not look safe and stable all work on
that load must be stopped and the unsafe situation corrected.
Under no circumstances should unloading commence until it is
safe to do so.
10.9
Equipment, Tools and Materials
All workers shall meet the following requirements:

a) No worker shall use any tool or piece of equipment without
proper training in its correct usage, unless directly supervised
by a worker competent in the use of that specific tool or
equipment;
b) Power tools shall be operated in accordance with
manufacturers specifications;
c) Shut off power to tools any time they are left unattended;
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d) All equipment and tools required to complete a task must be in

good working order and condition;
e) Tools damaged or in need of repair shall be tagged out of
service and must not be used until repaired or replaced;
f) All portable lamps, extension cords, and electrical tools shall
have proper grounding and shall be certified for the electrical
classification of the work area in which they are to be used;
g) Before leaving pneumatic tools unattended, bleed air pressure
from the airline; and
h) When using electrical tools in a wet area, use ground fault
interrupter (GFI) circuit breakers on the power line or check
that equipment insulation is sound. Use an insulating platform
and wear rubber gloves to minimize shock hazard.
Note:
All non-classed; portable electronic devices, tools, PDA, laptop

computers etc., require a hazard assessment prior to usage in a
hazardous location and must be documented on a Niska Safe
Work Permit.
Only intrinsically safe portable electronic devices may only be
used within 75 feet of production facilities or other sources of
hydrocarbons.
10.10
Fire prevention
Explosive Limits
a) Explosive limits give the concentration range (usually expressed
in percent by volume) at which a flammable vapor or gas in air
will ignite or explode, once the ignition temperature is reached.
The lowest percentage at which this will occur is the Lower
Explosive Limit (LEL) and the highest percentage is the Upper
Explosive Limit (UEL). This range varies from substance to
substance.
b) No work shall take place on a Niska work site where the
atmosphere exceeds 10% of the LEL.
c) Properly calibrated combustible gas indicators will check
the presence of such a condition at both LEL and UEL
concentrations.
Note:
LEL gas detectors will not operate correctly by themselves
and must be used in conjunction with an oxygen detector, in
the presence of 19.5% - 23% oxygen.
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d) Any work capable of giving rise to an ignition source (Hot

Work) shall not take place in the presence of a flammable
atmosphere > 10% of the Lower Explosive Limit (LEL).
Any question as to the possibility of an explosive or flammable
atmosphere shall be referred to the Niska representative
or contractor representative, who has the responsibility for
making such determinations as to the presence of explosive or
flammable substances.
e) Personal communication devices including cellular phones,
pagers, and radios are not normally intrinsically safe. These
devices should not be on work sites where flammable
atmospheres could exist unless a worker is equipped with a
4-head electronic gas detector and the atmosphere has been
determined to be safe. It is recommended that these devices
remain in your vehicle.
f) Internal combustion engines shall not be located in a Zone
0 hazardous location as defined in the latest version of the
NFPA 70 E Standard for Electrical Safety in the Workplace or
in a part of a Division 1 hazardous location as defined in the
NFPA 70 E Standard for Electrical Safety in the Workplace
that meets the description of a Zone 0 location.
10.11
Fired Equipment
All workers who are required to light fired equipment (boilers, line
heaters or re-heaters) must be properly trained, must follow the
manufacturers instructions, and must have demonstrated their
competency to their immediate supervisor. Improper lighting of
fired equipment is a common source of injury and fire.
Safety guidelines for lighting fired equipment include:
A wand designed for lighting fired equipment should be
used;
Never use a torch made of rags and flammable liquids to
ignite fired equipment;
Never light fired equipment manually, if it is equipped
with an automatic ignition system. Obtain the services of
an instrument technician to determine why the unit is not
lighting;
Prior to any adjustments or repairs to a burner, check the
wind direction and ensure all vents and hatches are closed;
When fired equipment has been down for maintenance,
for an extended period of time, or during freezing weather,
a worker should remain at the location (along with a fire
extinguisher), during the firing-up operation, until it is
determined through checks that the equipment is operating
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properly; and
When fired equipment is open for cleaning, inspection
or repairs, extreme caution should be exercised to avoid
explosions due to open fires, matches, or sparks around the
open vessel and that fuel gas is isolated and locked out by all
affected workers.
10.12
Fire Safety Guidelines
All workers and visitors at Niska work sites shall adhere to the
following fire safety guidelines:
a) Understand the work site evacuation procedure;
b) Follow pertinent safe work procedures;
c) Take a proactive approach in fire prevention measures. The
major causes of fire include:
Electrical overloads or malfunctions,
Poor housekeeping,
Smoking,
Improper welding procedures, and
Poor equipment maintenance.
d) Inform your immediate supervisor and co-workers of potential
fire hazards; and
e) Perform all tasks relating to the inspection and maintenance of
fire extinguisher equipment.
f) Vacuuming or using water to wash work areas is done
whenever possible rather than blowing or sweeping
combustible dust.
g) Flammable and combustible material spills must be cleaned up
promptly.
h) The transfer/withdrawal of flammable and combustible liquids
is performed by trained personnel.
i) Storage procedures must be followed to minimize the risks of
fire or spontaneous combustion.
j) Oily rags and other combustible waste materials must be
placed in covered, metal, fire-resistant containers and stored in
designated areas.
k) Flammable and combustible liquids must be stored in approved
containers and tanks.
l) Connections on drums and combustible liquid piping must be
vapor and liquid tight.
m) Flammable and combustible liquids must be kept in closed
containers when not in use (for example, solvent drum).
n) Bulk drums of flammable liquids must be grounded and
bonded to containers during dispensing.
o) Storage rooms for flammable and combustible liquids have
intrinsically safe lighting and mechanical or gravity ventilation.
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p) Spare propane tanks used for forklifts etc. or otherwise, must

be stored in accordance with regulations.
q) Storage tanks must be adequately vented to prevent excessive
vacuum or pressure as a result of filling, emptying, or
atmosphere temperature changes.
r) Storage tanks must be equipped with emergency venting that
will relieve excessive internal pressure caused by fire exposure.
10.13
Fire Prevention and Protection Equipment
The following fire prevention and protection equipment

requirements shall be met:
a) Store all flammable or combustible liquids in approved fireresistant containers. All such containers will be grounded
or bonded when pouring flammable substances (See Static
Electrical Charge in Hydrocarbons for further information);
b) Never allow combustible or flamable materials (e.g., used
adsorbent materials, soaked rags, waste and packaging) to
accumulate;
c) Contractors shall supply and maintain their own fire
extinguishers and ensure that all workers under their direction
are proficient in the proper use, maintenance, and inspection
of fire extinguishers;
d) Ensure all fire extinguishers are suitable to the hazard. Niska
vehicles must be equipped with, as a minimum, a 20 lb dry
chemical (Purple K or other ABC type) extinguisher with the
appropriate DOT and HMIS labels;
e) Inspect, maintain and locate all fire extinguishers in accordance
with NFPA 10 Standard for Portable Fire Extinguishers by
conducting the following:
10.14
Monthly Portable Fire Extinguisher

Inspections
Facility Operations personnel will conduct monthly inspections

of portable fire extinguishers by ensuring the following;
The fire extinguisher is in its designated place;
The tamper proof seal is in place and it has not been broken;
The canister gauge reads full or the pressure indicator is not
sticking up;
There is no visible damage to the canister or hose, (dents,
rust, frayed or plugged hose). If there is any damage, the
extinguisher must be sent to an authorized maintenance
company for repairs.
There must be no obstructions that will prevent quick access to
the fire extinguisher.
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After the monthly inspection is completed of all fire

extinguishers, the inspector of the fire extinguisher will
complete the Fire Extinguisher Record Form.
10.15
Annual Inspections
A Certified Company specializing in the maintenance of fire

extinguishers will do the Annual Inspections.
Ensure all workers are familiar with the location and use of
firefighting equipment at the work site;
A worker must not attempt to extinguish a fire if:
The fire is quickly spreading beyond its point of origin;
The fire could block your safe egress; or
That worker is unsure how to use a fire extinguisher.
When using a portable fire extinguisher:
Never place the fire between yourself and a safe exit;
Never turn your back on any fire;
Always keep your back to the exit; and
Remember the PASS method when using a portable
handheld fire extinguisher;
P - Pull the tamper proof pin.
A -Aim the extinguisher nozzle at the base of the fire while
standing back 8 12 feet away from the fire.
S - Squeeze the handle expelling the extinguishing agent
onto the fire.
S - Sweep the nozzle of the fire extinguisher side-to-side
while aimed at the fire extending 12 inches on either side
of the fire.
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10.16
Fire Classifications
The universal fire types may be divided into four basic categories:
Class A, B, C and D. The classification depends largely on the
methods of extinguishment and on the combustible materials
involved in the fire.
Class A
Class B
Class C
Class D
Ordinary combustible materials such as paper,

wood or cloth.
Letter A in Green Triangle identifies
extinguishing equipment for this type of fire.
Class A fires require the cooling effect of water
or water solutions, or the coating effect of certain
dry chemicals that retard combustion.
Vapour combustion over surface of flammable/
combustible liquid such as grease, oil, or
gasoline.
Letter B in Red Square identifies extinguishing
equipment for this type of fire.
The most effective means of extinguishment calls
for the exclusion of air from the fire inhibiting
the release of combustible vapours.
Electrical fires. Circuit may be live so nonconducting extinguishing agents shall be used.
Letter C in Blue Circle identifies extinguishing
The safe response to an electrical fire calls for
de-energization of the electrical equipment,
the applying a Class A or Class B method of
extinguishment.
Highly reactive flammable liquids or combustible
metals or powders like magnesium, titanium or
sodium.
Letter D in Yellow Star identifies extinguishing
A Class D fire requires a heat-absorbing
extinguisher that is not reactive with the burning
product.
Table 12 - Fire Classification
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11.0
11.1
OTHER SAFETY PRACTICES

Defensive Driving/Motor Vehicle Operation
1. Driving Safety
a) Niska vehicles must be operated in a defensive manner.

b) Drivers must examine their vehicles daily before operating
them. If unsafe conditions are found, the vehicle must not be
used. These conditions or defects shall be reported to their
immediate supervisor for immediate correction.
c) In winter, allow for extra stopping distances, especially on
bridges or intersections prone to icing. Drivers should become
familiar with skid control procedures for the vehicle type they
are driving (front-, rear- or four-wheel drive).
d) During slippery or icy conditions it is highly recommended that
cruise control is not used.
e) Ensure your vehicle is in good running order and is equipped
with basic emergency equipment such as a cellular phone or
radio phone, explosion-proof flashlight, jack, spare tire, flares,
triangular road reflectors or three road flares, shovel, tow
rope, booster cables, first aid kit, fire extinguisher (ABC dry
chemical), extra clothing and blankets for inclement weather,
and a survival kit.
f) Niska vehicles that breakdown shall be parked with all
wheels off the main road and one reflector shall be placed
approximately 100 feet to the rear of the disabled vehicle.
g) No vehicle shall approach or park within 25 feet of any
wellhead, piping, process vessel, or tank containing combustible
fluids unless a Safe Work Permit for maintenance/vehicle entry
has been issued.
h) Flammable or explosive materials shall not be transported in
the cab of any vehicle on a Niska work site.
2. Vehicle Operation Guidelines
Each worker operating a motor vehicle on a Niska work site shall
ensure that they:
a) Are the holder of a valid operators license for the vehicle that
they plan to operate;
b) Report to their employer the loss of driving privileges due to
suspension or restriction as soon as possible;
c) Drive vehicles in accordance with all local, state and federal
laws and company requirements;
d) Report to their employer any traffic tickets received while
operating a company vehicle or engaged in work for the
company;
e) Do not operate a vehicle if driving conditions or the condition
of the vehicle is believed to be unsafe;
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f) Report all accidents to the authorities and a Niska

representative, (i.e. your immediate supervisor;
g) Wear seatbelts when riding or driving in a Niska vehicle or on
Niska property; and
h) Ensure vehicles are parked safely and are secured when left
unattended.
3. Recommended Safe Driving Practices
a) Keep maintenance schedules for vehicles.
b) Drive with headlights and marker lights on.
c) During daylight with good, dry roads and low traffic volume,
you can ensure youre a safe distance from the car ahead of you
by following the three-second rule.
d) In heavy traffic, at night, or when weather conditions are not
ideal (eg. light rain, light fog, light snow), double the three
second rule to six seconds, for added safety.
e) If the weather conditions are very poor, eg. heavy rain, heavy
fog, or heavy snow, start by tripling the three second rule to
nine seconds to determine a safe following distance
f) Back-in parking is recommended at all Niska facilities.
g) Secure tools and loads inside and outside the vehicle. Loose
items shall be placed or secured to ensure they do not pose a
hazard to occupants or other vehicle operations.
4. Electronic Communication Device (ECD) Usage While
Operating a Motor Vehicle
Recommended practices to follow while operating a motor vehicle
and using an ECD (cell phone, Blackberry etc):
a) When behind the wheel minimize distraction and ensure
driving is always your first priority;
b) Using an ECD while driving a Niska owned, leased or rented
motor vehicle is not permitted;
c) If your ECD rings while you are driving let the call go to a
voice message. If you must answer the call, pull over to the
side of the road and park in a safe location before you answer.
11.2
Vehicle Rescue Practices
1. Extrication of a Vehicle
a) It is recommended that a tow truck service capable of safely
extricating or towing the unit be used.
b) Only nylon tow ropes, nylon-webbed tow straps or load-related
chains are to be utilized when rescuing. The tow rope or strap
shall be in good repair, load rated and of sufficient strength to
safely carry out the rescue operation.
c) Chains and cables must not be jerked during the rescue
procedure.
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d) If a clevis is used, it must be the threaded pin type and have

the load-rated capacity and sufficient strength to safely carry
out the rescue operation.
e) Under no circumstances will ropes or straps equipped with
metal eyelet hook and chain tail ends or any other type of
clevis, other than the type stated, be permitted.
f) If winching a vehicle is required:
Workers should never be between the winching vehicle and
the load being winched;
Always wear leather gloves when handling cable to avoid
injury from pieces of wire protruding from the cable; and
Use hand over hand action; the winch line should not be
allowed to slip through the hands.
11.3
Vehicles and Heavy Equipment
The following vehicle and heavy equipment requirements shall be

met:
a) All vehicles must be parked in a safe area away from work
being conducted and in a location that allows for safe exit in
the case of an emergency;
b) All diesel engines vehicles or equipment on Niska work sites
must be equipped with an automatic positive-air shut-off
system; or
i. Engines not equipped with an automatic positive-air
shut-off system must be equipped with a manual positiveair shut-off system and the operator of the unit must be
stationed in such a way that they can immediately activate
the emergency shutdown device, i.e. in the cab; or
ii. The unit must be shut off if the vehicle or piece of
equipment is to be left unattended.
c) Do a walk around check of the equipment before and after
operating it. Check the fluid levels, hydraulic system, lights, tire
pressure, and check for loose parts.
d) Any vehicle with restricted vision is not to be moved in the
vicinity of other workers or equipment except under the
direction of a designated guide; this person must be in a
position to see if the path to be traveled is all clear.
e) All vehicles and heavy equipment shall meet and be operated
in accordance to manufacturers instructions and state and/or
federal regulations while on Niska work sites;
f) Refueling a motorized vehicle or piece of equipment while the
engine is running is not allowed;
g) All contractor vehicles will have an acceptable exhaust system,
including mufflers;
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h) Operators must have valid operating licenses;

i) Authorization to allow Off-Highway Vehicles (OHV), such as
quads, to be used on Niska worksites must be gained by the
Deviation Process described in Section 1;
j) Vehicles shall contain only as many passengers as there are
seats and seat belts;
k) Only Authorized Persons (i.e. the operator) are permitted to
ride on mobile equipment;
l) All cargo loads shall be contained, immobilized or secured so
that they cannot:
i. Leak, spill, blow off, fall from, fall through or otherwise be
dislodged from the vehicle, or
ii. Shift upon or within the vehicle to such an extent that the
vehicles stability or maneuverability is adversely affected
m) Trucks handling loose materials shall have a tailgate and tarp
covering the load. If any materials fall off in transit, drivers are
expected to stop and safely remove these from the roadway;
n) Individuals transporting dangerous products shall comply
with DOT Regulations, including the requirements for worker
certifications, manifests and placards;
o) If vehicles or heavy equipment are left unattended on
Niska property overnight, the operator shall notify a Niska
representative to ensure that all security measures have been
taken to deter unauthorized entry or movement of the vehicle
(e.g. removing the key and locking the cab door);
p) Cranes, rat-hole diggers or auguring machines that have swingtype arms shall have barricades or flags to prevent workers
from entering the swing radius;
q) Movement of mobile cranes or boom equipment on a Niska
work site requires the use of a signal man or boom walker; and
r) Permission from a Niska representative is required to operate
crane booms or mechanical equipment over or under a pipe or
conduit rack.
11.4
Cranes, Hoists and Lifting Devices
11.4.1
Annual Testing and Inspection
Only certified contracted maintenance personnel will perform annual

test and inspection of cranes, hoists and lifting devices. Annual
testing and inspection must meet the OSHA requirements of 29 CFR
1910.179 (J) (3) and (K) (1). The Preventive Maintenance Program
includes annual testing, detailed inspections, visual inspections, and
following the manufacturers maintenance instructions.
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11.4.2
Pre-Use and Operational Inspections
A pre-use inspection will be done prior to operating any lifting

device. This is a visual inspection ensuring key components are intact
and operational. Operational inspections will be conducted on a daily
basis if the lifting device is being used for more than one day.
Cranes, hoists, and lifting devices must be operated only by
competent/qualified personnel. Prior to using any equipment,
the area must be inspected to determine if any hazards exist such
as overhead power lines, ditches, soft spots on the ground, or
underground facilities (e.g., pipelines, drains, gas mains, etc.).
1. Requirements
A traffic vest is required for signal person.
Operators must refuse to lift any load that exceeds the cranes
rated capacity. All cranes, excluding manually operated hoists,
with a lifting capacity of 2,000 kilograms or more are required
to have logbooks (i.e., repairs, maintenance, certifications,
examinations, checks or tests, lifts 50% or greater of rated
capacity).
Tag lines must be used.
Never work or cross under any suspended load.
Never ride the load or hook.
All areas of a specific swing path for a suspended load shall be
identified and protected (using barricades or rope with warning
signs) against inadvertent personnel traffic during the lift.
Operators and workers must be made aware of a safe location
to position themselves for all lifts, should the crane fail.
The signal person must always be in clear view of the operator.
The operator is to agree on a signaling system with the signaler
prior to operating the equipment. Only one person shall give
hand signals to the operator.
Only commercially manufactured and certified lifting devices
will be used on a Niska work site.
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Table 13 - Hand Signals for Directing Vehicles
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11.5
Truck Mounted Cranes
All operators of hoisting, lifting and mobile equipment must

be competent, and possess required regulatory certifications.
Equipment operators must conduct a visual hazard assessment
and inspection of the work site and their equipment prior to
commencement of work. All equipment must be operated within the
manufacturers specifications.
All lifting equipment including rigging below the hook must display
valid certifications and rated capacities.
11.6
Truck Loading and Unloading of Hazardous

Materials
1. General Safety Requirements

a) Wheel chocks must be used at all times to prevent movement
of the vehicle.
b) Bonding cables must be connected before attaching product
unloading hose to riser and disconnected after removing hose
from riser to prevent static electricity.
c) Cam-lock fittings shall be properly secured to prevent
accidental uncoupling.
d) Drivers shall not exceed posted speed limits and shall drive
according to the weather and road conditions.
e) Trucks must be driven to the loading area slowly, making sure
the path is clear of loading hoses or cables, etc.
f) No loading/unloading is permitted during an electrical storm.
11.7
Industrial Trucks
While not an inclusive list of proper operating practices, Industrial

trucks (lift truck) shall be operated in a safe manner in accordance
with the following operating rules:
1. Only drivers authorized by Niska and trained in the safe
operations of industrial trucks are be authorized to operate
such vehicles.
2. Stunt driving and horseplay are strictly prohibited.
3. Only the operator is permitted on industrial trucks while in
operation.
4. Employees shall not ride on the forks of lift trucks.
5. Employees shall not place any part of their bodies outside the
running lines of an industrial truck or between mast uprights
or other parts of the truck where shear or crushing hazards
exist.
6. Employees are not allowed to stand, pass, or work under the
elevated portion of any industrial truck, loaded or empty,
unless it is effectively blocked to prevent it from falling.
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7. The lift truck operator must check the vehicle at the beginning
of each shift, and if it is found to be unsafe, the matter shall
be reported immediately to their immediate supervisor and
the vehicle will kept out of service until it has been made safe.
Attention shall be given to the proper functioning of tires,
horn, lights, battery, controller, brakes, steering mechanism,
cooling system, and the lift system for fork lifts (forks, chains,
cable, and limit switches).
8. No truck shall be operated with a leak in the fuel system.
9. Trucks shall not be loaded in excess of their rated capacity.
10. A loaded vehicle shall not be moved until the load is safe and
secure.
11. Operators shall look in the direction of travel and shall not
move a vehicle until certain that all persons are in the clear.
12. The forks shall always be carried as low as possible, consistent
with safe operations.
13. When leaving a vehicle unattended (the operator is over 25 feet
from or out of sight of the industrial truck), the brakes are set,
the mast is brought to the vertical position, and forks are left in
the down position, either:
The power shall be shut off and, when left on an incline,
the wheels shall be blocked; or
The power may remain on provided the wheels are blocked,
front and rear.
14. When the operator of an industrial truck is dismounted and
within 25 feet (7.6 meters) of the truck which remains in the
operators view, the load engaging means shall be fully lowered,
controls placed in neutral, and the brakes set to prevent
movement.
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12.0
Definitions
Accident: An undesired event that results in physical harm to a

person or damage to property.
ACM (Asbestos Containing Material): The generic term for a
group of naturally occurring fibrous minerals with high tensile
strength, flexibility and resistance to thermal, chemical and
electrical conditions.
ANSI: American National Standards Institute.
Authorized Person: A person who is designated by an
appropriate authority as having the responsibility and authority
to conduct certain activities.
Bump or Function Test: The required method to ensure that an
electronic gas detector is fully functional. The test is conducted
at the start of each shift or before the gas detector is used, by
subjecting it to a known concentration of calibration or bump
gas.
Cold Work: A work procedure that does not generate heat and
does not cause sparks or an open flame, which could result in
an explosion or flash fire.
Competent Person: A person who:
a) Is qualified because of their knowledge, training and
experience to organize the work and its performance;
b) Is familiar with the provisions of the Federal, State and
local laws, Acts and Regulations and all applicable Niska
Standards and Procedures that apply to the work; and
c) Has knowledge and the capability to identify any potential
or actual hazardous conditions to health and safety at the
work site and has the authority to take prompt corrective
measures to eliminate or mitigate those hazards.
Confined Space:
a) An enclosed or partially enclosed space not designed
or intended for continuous human occupancy that may
become hazardous to a Worker entering it due to the
following:
Its design, construction, location, work activities or
atmosphere.
The material or substances in it.
Any hazards relating to it.
- 104 -
b) An enclosed or partially enclosed space not designed or

intended for continuous human occupancy that has limited
or restricted means of entry or exit and that may complicate
the provision of first aid, evacuation, rescue or other
emergency response service.
Contractor: A person, partnership, or group of persons who,
through a contract, agreement or ownership, directs the
activities of one or more employers involved in work at a work
site.
Dangerous Goods: A product, substance or organism included
by its nature or by the regulations and any of the classes listed
in the Transportation of Dangerous Goods (TDG) Regulations
and the United States Department of Transportation.
dBA Lex: The level of a Workers total exposure to noise in dBA
(decibels) averaged over the entire workday and adjusted to an
equivalent 8-hour exposure.
Emergency: An unplanned event that calls for immediate action
to counteract a threat to life or significant loss of property or
environmental damage.
Employee: A person who is employed for wages or salary.
Employer: A person who:
a) Is self employed in an occupation;
b) Employs one or more workers;
c) Is designated by an employer as his representative; or
d) Is a director or officer of a corporation who oversees the
occupational health and safety of the workers employed by
the corporation.
ERP (Emergency Response Plan): A response action plan to help
address Emergency situations on Niska facilities or properties.
FR (Flame-Resistant Fabric): The characteristic of a fabric that
causes it not to burn in air. Flame resistant is often confused
with flame retardant, which is a term used to describe a
chemical substance that imparts flame resistance in a fabric.
Ground Disturbance: Any work, operation or activity that
results in the disturbance of the earth, including, without
limitation, excavating, digging, trenching, plowing, drilling,
tunneling, auguring, pile driving, backfilling, topsoil stripping,
- 105 -
land leveling, clearing, grading and fencing above or near any

pipeline, power line, cable or utility, but does not include:
a) A disturbance of the earth to a depth of less than 1 foot
that does not result in a reduction of the earth cover over
the pipeline to a depth that is less than the cover provided
when the pipeline was installed;
b) Cultivation to a depth of less than 1.5 feet below the
surface of the ground; or
c) Any work, operation or activity that is specified in the
Regulations not to be a Ground Disturbance.
Hazard: Any circumstances or conditions that pose the risk of an
incident.
Hazard Assessment: A thorough examination of an operation
or activity at a work site, shop, etc. to identify what actual and
potential hazards exist.
Hazardous Substance (Cal OSHA): Any substance which is a
health hazard or a physical hazard or is included in the List of
Hazardous Substances prepared by the Director pursuant to
Labor Code section 6382.
Health Hazard (Cal OSHA): A substance for which there is
statistically significant evidence based on at least one study
conducted in accordance with established scientific principles
that acute or chronic health effects may occur in exposed
employees. Refer to Appendix C in the regulation for a more
detailed definition of health hazard.
Health Hazard (Federal OSHA): A chemical for which there
is statistically significant evidence based on at least one study
conducted in accordance with established scientific principles
that acute or chronic effects may occur in exposed employees.
The term health hazard includes chemicals which are
carcinogens, toxic or highly toxic agents, reproductive toxins,
irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins,
neurotoxins, agents which act on the hematopoietic system
and agents which damage the lungs, skin, eyes or mucous
membranes. Appendix A provides further definitions and
explanations of the scope of health hazards covered in this
section, and Appendix B describes the criteria to be used
to determine whether or not a chemical is to be considered
hazardous for the purpose of this standard.
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Hot Work: Any work involving flames, sparks or high enough

temperatures to ignite flammable materials, or release materials.
Ignition Sources: Heat, flame, sparks and static electricity that
are capable of causing a fuel mixture to burn.
Incident: Any unplanned or unwanted event that results in
damage or injury, or an event that could have resulted in
damage or injury (including Near Misses).
Informal Hazard Assessment: An evaluation of potential
or existing hazards at a work site that is conducted prior to
entering the facility.
Niska: Niska Gas Storage.
Niska Representative: A Niska Employee that has decision
rights over a specific area or process.
Intrinsically Safe: Any spark or thermal effect that may occur
in normal use, or under any conditions of fault likely to occur
in practice, and is incapable of causing an ignition of the
prescribed flammable gas, vapor or dust.
LEL (Lower Explosive Limit): Lower limit of flammability
or explosiveness of a gas or vapor at ordinary ambient
temperatures expressed as a percentage of gas or vapor in air
by volume.
Near Miss: An incident that, under slightly different
circumstances, could have resulted in personal harm, Property
Damage or loss.
Owner: A person who:
a) Is in legal possession of the work site, or
b) Has an ownership interest in the work site and who
requests that the work be done, even if the person in legal
possession does not request the work.
Physical Hazard (Cal OSHA): A substance for which there is
scientifically valid evidence that it is in a combustible liquid, a
compressed gas, explosive, flammable, an organic peroxide, an
oxidizer, pyrophoric, unstable (reactive) or water-reactive.
Physical Hazard (Federal OSHA): A chemical for which there
is a scientifically valid evidence that it is a combustible liquid, a
compressed gas, explosive, flammable, an organic peroxide, an
oxidizer, pyrophoric, unstable (reactive) or water-reactive.
- 107 -
PPE (Personal Protective Equipment): PPE includes, but is

not limited to, safety boots, hard hats, safety glasses with side
shields, flame-resistant clothing, respirators and/or breathing
air systems, chemical protective clothing, face shields, gloves,
aprons and hearing protection. Personal gas monitoring
equipment can also be included in this category.
Project Coordinator: A Niska representative who is responsible
for managing the execution of a project, which may include,
but is not limited to, the work timing, project execution and
scope of the project activity.
Note:
The Project Coordinator could be any Niska Employee (e.g.
a Niska representative, Production Coordinator or Project
Engineer).
Property damage: Any incident that causes damage to property

or equipment regardless of severity.
SWP (Safe Work Permit): A method of authorizing specific
work to be done at a work site or location. All hazards are
noted and the required precautions are assigned to individuals.
The permit is normally valid only for a specific time period
before re-testing and/or reissuing is required. All Safe Work
Permits are automatically cancelled in the event of an Accident,
incident or Emergency.
Tailgate Safety Meetings: Meetings that are held before work
activity commences on a work site between the foreman
and/or supervisors with their employees to review safety
requirements, job procedures, and Employee questions or
concerns. Tailgate Safety Meetings must be documented.
TDG (Transportation of Dangerous Goods): Refers to the
current Act and Regulations.
UEL (Upper Explosive Limit):
a) Maximum proportion of vapor or gas in the air above
which propagation of flame does not occur.
b) Upper limit of the flammable or explosive range.
Visitor: Anyone invited by Niska, or where Niska is aware of
their presence, who enters a Niska work site or property for
purposes other than performing actual services.
- 108 -
Worker: A Niska Employee, Contracted employer or Employee,

Contractor or Consultant who is engaged in an occupation for
Niska or who works at a Niska work site.
Work site: Any Niska field property, right-of-way, field
construction or maintenance project location or area, including
vehicle or mobile equipment, occupied by a Worker in the
course of or in connection with the work.
- 109 -
USER COMMENTS
If you have comments for Handbook improvements, we would
appreciate hearing them. Please feel free to fax, phone or mail
them to the Niska EH&S Department or contact your Niska
Representative.
Send to:
Niska Gas Storage
Environment, Health, Safety and Security
Coordinator
400, 607 8th Ave Street S.W.
Calgary, Alberta
T2P 0A7
Phone:
(403) 513-8663
Fax to:
1-866-871-6417
- 110 -
Safety First
The information in this booklet is, to the authors and publishers

knowledge, correct and accurate to the time of printing. It is not
intended as a substitute for your employers health and safety policies.
The publisher or distributor cannot be held responsible for action
taken pursuant to the advice given within the booklet.
2008 Niska Gas Storage
Printed in Canada for Niska Gas Storage by:
Quick Books Publishing Ltd.
1-800-308-6658 www.quickbookspublishing.com
- 111 -
PublicAwarenessProgram

NiskaGasStorage

WildGooseStorageLLCFacility

TableofContents
1.0
PURPOSEandSCOPE....................................................................................................................... 4
2.0
MANAGEMENTSUPPORT...............................................................................................................4
2.1 Commitment............................................................................................................................... .....5
2.2 EmergencyManagementPrinciples.................................................................................................5
2.3 PipelineIntegrityManagementPlan...............................................................................................5
3.0
RESPONSIBILITYFORIMPLEMENTATION.......................................................................................6
3.1 RolesandResponsibilitiesforPublicAwarenessProgram...............................................................6
4.0
PRIMARYAUDIENCEFORPUBLICAWARENESSPROGRAM...........................................................7
4.1 EducatingthePublic......................................................................................................................... 8
5.0
PUBLICAWARENESSPROGRAMOBJECTIVES.................................................................................9
5.1 EmergencyResponse........................................................................................................................ 9
5.1.1 CharacteristicsofNaturalGas.........................................................................................................9
5.1.2 Signsofaproblem.......................................................................................................................... 10
5.1.3 PotentialEmergencies....................................................................................................................10
5.1.4 Whatshouldaresidentorlandownerdoiftheysuspectaproblem?...........................................10
5.1.5 WhatwillWGS,LLCdoifthereisanemergency?..........................................................................10
5.1.6 StayInShelterProcedures.............................................................................................................11
5.2 EvacuationProcedures...................................................................................................................11
5.3 PublicAwarenessofPipelines........................................................................................................13
5.4 PipelineMarkerSigns.....................................................................................................................13
5.4.1 AbovegroundPipelineMarkerSigns.....................................................................................13
5.5 UndergroundServiceAlert(USA)NorthOneCallCenter.............................................................14
5.6 CompanyWebsites......................................................................................................................... 14
5.7 NationalPipelineMappingSystem................................................................................................14
5.8 PreventionandResponse...............................................................................................................15
5.9 ManagementofPublicAwarenessPrograms................................................................................16
6.0
TARGETEDAUDIENCES,I.E.STAKEHOLDERAUDIENCES...........................................................16
7.0
MESSAGECONTENTFORKEYSTAKEHOLDERAUDIENCES...........................................................16
7.1 MessageContent........................................................................................................................... 16
7.2 PipelineMaintenanceActivities.....................................................................................................17
8.0
DELIVERYMETHOD,MEDIA,ANDFREQUENCY............................................................................17
8.1 PrintMaterials............................................................................................................................... 17
8.1.1 TargetedMailings,Brochures,Flyers,Pamphlets,Leaflets...................................................17
8.1.2 Letters............................................................................................................................... ....18
8.2 PersonalContactGeneral............................................................................................................18
8.2.1 DoortoDoorContactalongPipelineRightofWay..............................................................18
8.2.2 TelephoneCalls...................................................................................................................... 19
8.2.3 GroupMeetings.....................................................................................................................19
8.2.4 OpenHouse........................................................................................................................... 20
8.2.5 CommunityEvents.................................................................................................................20
8.2.6 CharitableContributions.......................................................................................................20
8.3 ElectronicCommunicationsMethods.............................................................................................21
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PrintDate:28/06/2012

Papercopiesareuncontrolled.Thiscopyonlyvalidattimeofprinting.
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NiskaGasStorage,2012
8.3.1 VideosandCDs.....................................................................................................................21
8.3.2 ElectronicMail(Email).........................................................................................................21
8.4 MassMediaCommunications........................................................................................................21
8.4.1 PublicServiceAnnouncements(PSAs)..................................................................................21
8.4.2 NewspapersandMagazines..................................................................................................21
8.4.3 PaidAdvertising.....................................................................................................................22
8.4.4 CommunityandNeighborhoodNewsletters.........................................................................22
8.4.5 SpecialtyAdvertisingMaterials.............................................................................................22
8.4.6 InformationalorEducationalItems.......................................................................................22
9.0
EXPANDABILITYOFPUBLICAWARENESSPROGRAM...................................................................23
9.1 ExpandabilityofthePublicAwarenessProgram...........................................................................23
9.2 ConsiderationforProgramExpansion...........................................................................................23
9.3 ConsiderationofExternalFactors..................................................................................................23
9.3.1 TheAffectedPublic................................................................................................................24
9.3.2 PublicOfficials....................................................................................................................... 25
9.3.3 EmergencyOfficials...............................................................................................................25
9.3.4 Excavators/ContractorsandOneCallCenters......................................................................26
10.0 PROGRAMEVALUATIONANDEFFECTIVENESS............................................................................26
10.1 EvaluationObjectives.....................................................................................................................26
10.2 EvaluationTechniques...................................................................................................................27
10.2.1 SelfAssessmentTechniques..................................................................................................27
10.2.2 FeedbackorReplyMessages.................................................................................................27
10.2.3 FocusGroupsorInterviewPanels.........................................................................................27
10.2.4 FeedbackInstruments...........................................................................................................28
10.2.5 AudienceCounts....................................................................................................................28
10.2.6 SurveysofAffectedAudience................................................................................................28
10.2.7 SelfAssessment.....................................................................................................................28
10.2.8 PreTestEffectivenessofMaterials.......................................................................................29
10.2.9 MeasuringPublicAwarenessActivities.................................................................................30
10.2.10MeasuringtheOutcomesorImpactsofthePublicAwarenessProgram...............................30
10.2.11AssessKnowledgeduringPersonalEncounterswiththeAffectedPublic...............................30
10.2.12SurveyMeasuringImpactofPublicAwarenessProgram.......................................................31
10.3 MinimumComponentsofPublicAwarenessEvaluation................................................................31
11.0 MEASURINGIMPACTONREDUCINGTHIRDPARTYDAMAGEANDSUPPLIMENTALACTIVITIES31
11.1 MeasuringImpactonReducingThirdPartyDamage....................................................................31
11.2 SupplementalActivities..................................................................................................................31
12.0 RECORDS............................................................................................................................... .........33
13.0 REFERENCE............................................................................................................................... ......33
ExhibitACompanyCommitment&SupportStatement...................................................................34
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PUBLICAWARENESSPROGRAM
1.0
PURPOSEandSCOPE
ThepurposeoftheWildGooseStorageLLC(theCompany,WildGooseorWGS,LLC)Public
Awareness Program is to outline the public educational requirements as defined within the
American Petroleum Institute (API) Public Awareness Programs for Pipeline Operators
RecommendedPractice(RP)1162.Thisprogramwillprovidecustomers,thepublic,appropriate
governmentorganizations,personsengagedinexcavation,public/privateutilitycompanies,and
related activities with information on how to identify the location of underground pipelines
ownedandoperatedbytheWildGooseandhowtorecognizeandreportanaturalgaspipeline
emergency.WGS,LLCwillfollowthegeneralprogramrecommendationsofAPIRP1162andwill
assesstheuniqueattributesandcharacteristicsofourpipelinefacilities.
2.0
MANAGEMENTSUPPORT
Impacttotheenvironment,protectionagainstharmtothepublicoritsworkers,preventionof
damage to company materials and property are core business values of Niska Gas Storage
Partners LLC (Niska), parent company of Wild Goose Storage LLC. Niska is dedicated to
continuingourcommitmentofoperatingourfacilitiestothehigheststandardofhealth,safety
andenvironmentalcomplianceintheareasandcommunitiesinwhichweoperate.
AtNiskawetakesafetytothepublicandouremployeesseriously.OurWGS,LLCfacility,located
in northern California, was constructed and put into production in 1998 and has successfully
stored natural gas without incident. During this timeframe, while delivering the clean and
efficientnaturalgasourcustomersrelyondailyfortheircomfortandlivelihood,wehaveearned
anenviablerecordforsafety,reliabilityandenvironmentalexcellence.
The WGS, LLC facility has a total of 30 miles of transportation pipelines and is part of a 1.5
millionmile national underground pipeline network. Many people of the public sector are
unawareofthisvitaltransportationsystemthatdeliverstheenergythatdrivesoureconomy.
WGS, LLC operations is overseen and regulated by the United States Department of
Transportation's(DOT)OfficeofPipelineSafety(OPS)anditsstatepartners.TheDOTimposes
minimum standards and the Company along with other pipeline companies, invest millions of
dollars each year in training and new technology that is designed to monitor and continually
improve the safety and integrity of their pipelines. These pipeline companies conduct public
outreachprogramstoincreaseawarenessaboutpipelinesafety,aswellaspotentialhazardsand
how to avoid them through proven damageprevention practices. Government statistics
indicate that pipelines are the safest transportation system in the nation today. WGS, LLC is
committedtomaintainingandstrengtheningthisreputationforsafetyandpipelineintegrityand
fullysupportsthisinitiative.WildGoosewillstrivetokeepthoseinhabitantslivingwithintheir
pipelinerightofway(R.O.W.),thegeneralpublicandlocalexcavatorsabreastofitsoperations
andemergencyresponseprocedures.
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2.1
Commitment
WGS,LLCwillcomplywithallapplicablehealth,safetyandenvironmentallawsandregulations.
We will strive to maintain and continuously improve our operating practices, preventative
maintenance procedures and emergency response activities at our facilities and will respond
promptlyandeffectivelytoincidentsoremergencies.WildGoosewillprovideitsemployeesand
contractor personnel with the guidance and resources necessary to handle these types of
situations. For evidence of Niskas commitment review Exhibit A Company Commitment &
SupportStatement.
2.2
EmergencyManagementPrinciples
WildGoosesemergencymanagementprinciplesareto:
x
Protectlives(personnel,emergencyresponders,public)
Effectivelyrescueandtreatcasualties
Minimizeenvironmentalimpacts
Minimizedamagetocompany,publicandprivateproperty
Effectively use the combined resources of the Company, mutual aid partners, the
governmentand/ortheiragenciesandotherexternalservices
Providefactualinformationtonewsmediaandotherstakeholdersonatimelybasis,and
Preserverecordsandevidenceforuseinpostincidentinvestigations.
The Company recognizes the importance of emergency response and prevention, and has
implementedcontrolsandprocedurestominimizetheoccurrenceofanincidentandmanagethis
processaseffectivelyaspossibleintheeventthatonedoesoccur.
2.3
PipelineIntegrityManagementPlan
WGS, LLC has developed a Pipeline Integrity Management Plan which contains the following
procedures/programs:
1.
Surveillanceofitsfacilitiestoidentify:
x
Changesoranomalieswithoperationsasaresultofnewdevelopments(i.e.upgradeto
cathodicprotectionsystems)
Changeinoperatingconditionsorpractices(i.e.pressure,temperature,flow)
Integrityofthesystem(i.e.failures,leakage,corrosion),and
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Incorporationofmaintenanceandmonitoringpractices.
2. A onecall system in place to ensure that underground facilities (i.e. pipelines, power lines,
etc.)havebeenaccuratelylocatedandidentified.
3. A preventive damage program to minimize the risk of contact by mechanical means to an
undergroundfacilityasaresultofgrounddisturbanceactivities(i.e.excavationsordrilling),
and
4. Aprogramthatinformsandeducatesthepublicofthehazardsassociatedwithpipelineand
facilityoperation.
It is the Companys mandate to adhere to these guidelines while operating our facilities in a
mannerthatreflectsprofessionalismandconcernforourneighborsthatsurroundus.
3.0 RESPONSIBILITYFORIMPLEMENTATION
Wild Goose Storage LLC is owned and operated by its parent company, Niska Gas Storage
Partners LLC, located at 400, 607 8th Ave SW in Calgary, Alberta, Canada. It is the primary
responsibilityofthePresidentofNiskatoactasthePipelineManagerofWGS,LLCforensuring
theimplementationandperformanceofthisPublicAwarenessProgramtothepartiesidentified
withinthisdocument.ThePresidentwillensurethatallrolesandresponsibilities,asidentified
inTable1RolesandResponsibilities,areadheredto.
3.1
RolesandResponsibilitiesforPublicAwarenessProgram
3.1.1
WGS, LLC will follow the general program recommendations, including baseline and
supplemental requirements of API RP 1162, unless the Company provides justification in its
program or procedural manual as to why compliance with all or certain provisions of the
recommendedpracticeisnotpracticableandnotnecessaryforsafety.
3.1.2
TheManagerofEngineeringandOperations,alsolocatedattheNiskaGasStorageheadofficein
CalgaryAlbertaCanada,isresponsibleformonitoringtheeffectivenessofeducationalprograms
andadvisingthePresidentifchangesarenecessary,orcouldbemade,toimproveeffectiveness.
3.1.3
TheCompanywillselectthemostappropriatemixoftargetaudiences,messagetypes,delivery
methodsandfrequenciesforeachpipelineorpipelinesegmentdependingontheneedsofthe
communities. The practices set forth establish the Company baseline for public awareness
programsanddescribeconsiderationsforprogramexpansionthatcanfurtherenhancespecific
publicawarenessoutreach.
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Description
Section#
President
Manager
E&O
Plant
Manager
Operator
EHSCo.
1.
Developwrittendamage
preventionprocedures
5.8
X
2.
Reviewandupdatedamage
preventionproceduresas
required.
5.8
X
X
3.
Definetargetaudience
6.0
X
X
X
4.
Developmessagecontent
7.1
X
X
X
5
Sendmailing,brochures,etc.to
targetaudience,or
8.1.1
X
6
Conductpersonalcontactto
targetaudience
8.2.1
X
X
7
Conductmasscomm.totarget
audience
8.2.3
X
X
8
Conductelectroniccomm.to
targetaudience
8.3
X
X
9
Sendspecialtyadvertising
materialstotargetaudience
8.4.5
X
10
Expandprogramasappropriate
fordefinedsegments/systems
9.0
X
X
X
X
11
Performprogramevaluation
10.0
X
X
X
X
12
Performexcavationactivities
accordingtoprocedures
9.3.4
X
13
Maintainprogramrecords
12.0
X
Table1RolesandResponsibilities

4.0
PRIMARYAUDIENCEFORPUBLICAWARENESSPROGRAM
TheprimaryaudienceofthePublicAwarenessProgramconsistsof:
x The affected public i.e., landowners, residents, and places of congregation (businesses,
schools,hospitals,etc.)alongthepipelineandtheassociatedrightofway
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x Local and state emergency response and planning agencies, i.e., Local Emergency Planning
Committees(LEPCs)
x Localpublicofficialsandgoverningcouncils
x PrivateandpublicutilitycompaniesneartheR.O.W.,and
x Excavators
4.1
EducatingthePublic
1.
The Company's program specifically includes provisions to educate the public, appropriate
governmentorganizations,andpersonsengagedinexcavationrelatedactivitieson:
a.
UseoftheonecallnotificationsystemtoUSA(UndergroundServiceAlert)Northprior
toexcavationandotherdamagepreventionactivities
b.
Possiblehazardsassociatedwithunintendedreleasesfromagaspipelinefacility
c.
Physicalindicationsthatsuchareleasemayhaveoccurred
d.
Stepsthatshouldbetakenforpublicsafetyintheeventofagaspipelinerelease,and
e.
Proceduresforreportingsuchanevent.
2. This program and the type of media used to train the public must be as comprehensive as
necessarytoreachallareasinwhichtheWildGossetransportsgasviaundergroundpipeline.
3. Training on the program will be conducted in English and in Spanish or in other languages
commonlyunderstoodbyasignificantnumberandconcentrationofthenonEnglishspeaking
populationwithintheCompanysareaofoperation.
4. Upon request, the Company will submit their completed programs to the Pipeline and
HazardousMaterialsSafetyAdministration(PHMSA).
5. TheWGS,LLCPublicAwarenessProgramandevaluationresultsmustbeavailableforperiodic
reviewbyappropriateregulatoryagencies.
6. The following elements of the Public Awareness Program are defined in more detail in the
followingsections;
x
ResponsibilityforImplementation(Section1.0)
PublicAwarenessProgramObjectives(Section5.0)
Targetedaudiences(Section6.0)
MessageContentforKeyStakeholderAudiences(Section7.0)
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5.0
DeliveryMethod,Media,andFrequency(Section8.0)
ExpandabilityofPublicAwarenessProgram(Section9.0)
ProgramEvaluationandEffectiveness(Section10.0)
PUBLICAWARENESSPROGRAMOBJECTIVES
Theobjectiveofthisprogramistoenhancepublicsafetyandenvironmentalprotectionthrough
increased public awareness and knowledge. There are five elements of the program to
accomplishthisgoal.Theseelementsare:
1. EmergencyResponse
2. PublicAwarenessofPipelines
3. PreventionandResponse
4. ManagementofthePublicAwarenessProgram
5. ExpandabilityandContinuousImprovement
5.1
EmergencyResponse
WGS,LLCisusingindustrystandardtechnologyandsupervisorypracticestoensurethatthereare
no production upsets that could create a release of methane gas or other emergencies. Plant
operatorsarehighlyskilledandtrainedtooperatetheplant.
Intheeventofanemergency,theWGS,LLCEmergencyResponsePlan(ERP)willbeinitiatedand
theentireCompanysresourceswillbedirectedtowardeffortsthatwillensurethesafetyofthe
workers,publicandtheenvironment.
5.1.1 CharacteristicsofNaturalGas
Naturalgas(methane)isanodourless,colorless,nonpoisonous,flammablegas,whichislighter
than air and burns with a pale, faintly luminous flame. Methane has an explosive range of
approximately5%15%whenmixedwithair.Methanehasarelativeweightof.55comparedto
airwhichhasarelativeweightof1.0.Ittendstoriseandaccumulatenearthehigher,stagnant
partsofenclosedbuildingsandtightlyclosedstoragepits.Itismostlikelytoaccumulateduring
hot,humidweather.
Marketed or sales natural gas is odorized with mercaptan which gives it a pungent noticeable
odour, however gas inside Wild Goose Storage pipelines are not odorized and may not be
detectedbysmell.
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5.1.2 Signsofaproblem
WGS, LLC facilities have a variety of automatic shutdown and alarm systems to protect worker
and public safety. However, smaller problems may first be noticed by our operators or by a
neighbor.
Somesignsofproblemsmayinclude:
x
Unusualsmells
Uncommonorunusualsounds
Cloudsofvapor
Liquidsprayingfromaleak
Apoolofwater
Anexplosionorafire
5.1.3 PotentialEmergencies
Potentialemergenciescouldresultfromanuncontrollednaturalgasreleasecausedbyastorage
vesselleak,breakorfailureofgasprocessingequipment.
Itisimportanttonote,thattheprobabilityofasignificantincidentoraccidentoccurringduring
WGS, LLC operations, which could affect anyones safety, is extremely remote. Uncontrolled
releasesfromvesselsandprocessingfacilitiestypicallydonotoccursuddenlyorwithoutwarning.
WGS, LLC field operations personnel must follow oilfield safety and operating practices which
include daily checks and regular planned safety inspections of the processing equipment and
pipelinesystems.
5.1.4 Whatshouldaresidentorlandownerdoiftheysuspectaproblem?
If a resident believes there is a problem with any of the facilities they should not hesitate to
contactWGS,LLCpersonnelatthe24houremergencynumberat18669407351
Membersofthepublicmustbeencouragedtoneverattempttoinvestigateapotentialproblem.
Emergencyresponseisforprofessionalsonlyandmembersofthepublicmuststayawayfromthe
area. If a resident is unsure about how safe they are, a Wild Goose representative will advise
themtoremainshelteredinsidetheirresidenceuntilaCompanyrepresentativegivesthemthe
okaytoleave.ReviewSection5.1.6StayInShelterProcedures.
5.1.5 WhatwillWGS,LLCdoifthereisanemergency?
IfaresidentresidingalongtheWildGoosepipelineROWcallsthe24houremergencynumberat
18669407351,aCompanyrepresentativewilltraveltotheareatoinvestigatetheconcern.
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In extreme situations, or if a problem is serious, a Company representative will talk with other
neighbors and consider evacuating the public until the situation has been investigated and the
problemaddressed.
5.1.6 StayInShelterProcedures
Ifanoption,stayinshelterisaneffectiveandviablemeansofpublicsafetywhen:
x
Thereisnotenoughtime,oradvancedwarning,toinitiateevacuationsafely;
Residentsarewaitingforevacuationassistance;
Thelocationofareleasehasnotbeenidentified;
Thereleaseisoflimitedvolumeorshortduration(severalminutestohalfanhour);and/or
Itisdeemedthatthepublicwouldbeatagreaterriskbecauseevacuationmaypotentially
exposeindividualstohazardousortoxicsubstancesduetoaslowdeparturefromthearea
orproximityofresidencetoincidentsite(i.e.residenceislocatedimmediatelydownwind).
If residents are advised to stayinshelter, Company personnel must advise them to not leave
their residence, and to follow the instructions listed below. Remaining sheltered indoors will
protect the public from possible explosion and/or reduce the possibility of igniting the vapor
cloudviaaninternalcombustionmotorvehicle.
TheCompanyrepresentativewilladviseeachstayinshelterresidentto:
5.2
Gathereveryoneinsidetheirresidenceand,ifpossible,gotoaninsideroomandstayaway
fromoutsidewindowsanddoors,andotherplaceswheregasesmayleakin.
Pleasedonotleaveyourresidence.
Shut off the main electrical breaker and extinguish all potential sources of ignition and
strongly encourage them NOT TO SMOKE and NOT TO USE YOUR TELEPHONE. A
Companyrepresentativewillcontacteachresidentwithfurtherinstructionswhenthearea
issafe.
EvacuationProcedures
Intheunlikelyeventwhereevacuationofaresidenceisrequired,aCompanyrepresentativewill
contact the resident and recommend immediate evacuation from the area. Although the
residentmaynotappeartobeinanyimmediatedanger,ashiftinwinddirectionoranincrease
intheconcentrationofthegascouldchangethesituation.TheCompanyrepresentativemust
ask if transportation or assistance to leave the area is required. WGS, LLC personnel will
immediatelydispatchtothoseresidentsrequiringassistance.
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If a resident is required to immediately evacuate their residence the Company representative
will advise them to proceed immediately to a designated Evacuation Centre as specified by a
WGS,LLC.
Company representatives must advise affected residents not to remain in the area any longer
thannecessaryandnottoattempttopackpersonalitemsorbelongings,orreturntoretrieve
pets.Ifnecessary,WildGoosepersonnelwillmakearrangementstofeedandwateranimalsat
the residence premises and arrange to have veterinarians available to monitor the health of
animals.
Prompt arrival at the Evacuation Centre by each affected resident will assist Company
representativesinidentifyingandaccountingforevacuatedpersons,aswellasthosewhocould
still be in the Emergency Planning Zone (EPZ) area. At the Evacuation Centre, informational
updateswillbeprovidedandCompanyrepresentativeswillbeavailabletoaddressquestionsor
concerns.
Residents choosing not to go to the Evacuation Centre must beaskedtoinformtheCompany
representativewheretheywillbegoingandhowtheycanbecontactedsothatWildGoosemay
confirmtheirsafetyandkeeptheminformedofemergencyevacuationupdates.
Evacuation,unlessunderextremecircumstances,shouldonlyberequiredforashortperiodof
timeuntiltheproblemcanbecontrolledandcorrected.WGS,LLCwillreimburseareauserswho
have been requested to evacuate the area due to an emergency resulting from Company
operations for any reasonable outofpocket expenses, such as; accommodations, meals, and
transportation.
Forfurtherinformationemergencyresponseorgeneralinquiriestelephonecallscanbemadeto
Wild Goose Gas Storage operations. Refer to Table 2 Wild Goose Storage Operations Phone
Numbers.
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WhotoCall
PhoneNumber
WildGooseControlRoombetween7:30a.m.5:00p.m.
15308467351
OnCallOperator
18003528771
24HourEmergencyContactNumber
18669407351
Table2WildGooseStorageOperationsPhoneNumbers
5.3
PublicAwarenessofPipelines
The WGS, LLC Public Awareness Program will assist in raising the awareness of the affected
public and key stakeholders of the presence of pipelines in their community, and help them
understand their role in transporting energy. WGS, LLC believes a more informedpublicalong
pipelinerouteswillsupplementtheCompanyspipelinesafetymeasuresandwillcontributeto
reducingthelikelihoodofemergenciesand/orreleases.
Onewayofinformingthepublicofthelocationofundergroundpipelinesandotherfacilitiesis
byusageofpipelinemarkersalongthepipelinerightofway.
5.4
PipelineMarkerSigns
In order that the public and residents living within a WGS, LLC pipeline ROW are aware of
pipelinesintheirvicinity,theCompanywillinstallpipelinewarningsignsthatincludethewords
Warning, Caution or Danger followed by the words Gas Pipeline along with the
Company name Wild Goose StorageLLC and telephone numbers identified in Table 2 Wild
GooseStorageOperationsPhoneNumberswhereaCompanypipelineoperatorcanbereached
atalltimes.
5.4.1 AbovegroundPipelineMarkerSigns
Theprimarypurposesofabovegroundpipelinemarkersignsareto:
x
Marktheapproximatelocationofapipeline,
Providepublicawarenessthataburiedpipelineorfacilityexistsnearby,
Provideawarningmessagetoexcavatorsaboutthepresenceofapipelineorpipelines,
Providepipelinecompanycontactinformationintheeventofapipelineemergency,and
Facilitate aerial or ground surveillance of the pipeline rightofway by providing
abovegroundreferencepoints.
Abovegroundpipelinemarkerswillbeinstalled:
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At each side of the crossing where a pipeline crosses a highway, road, railway or
watercourse;
Within the land acquired for the pipeline and facing the highway, road, railway or
watercourse,
If the pipeline right of way adjoins the right of way of a highway, road or railway, on the
commonboundaryoftherightsofwaybutnotwithintherightofwayofthehighway,road
orrailway,and
Ifthepipelineis:
o Locatedinaditchorunpavedareaintherightofwayofahighwayorroad;or
o Conveying HVP product in an urban area, at intervals that will clearly and continuously
markthelocationofthepipeline.
5.5
UndergroundServiceAlert(USA)NorthOneCallCenter
The Underground Service Alert, known as "USA", provides a high quality Underground Facility
Damage Prevention service to Central / Northern California and Nevada. USA's purpose is to
receive planned excavation reports from public and private excavators and to transmit those
planned excavation reports to all participating members of USA who may have underground
facilities at the location of excavation. Wild Goose is an active member of USA North. USA
members will either, mark or stake their facility, provide information or give clearance to dig.
USANorthcanbecontactedathttp://www.usanorth.org/orbycalling811or18002272600.
CaliforniaLawRequirementsToJoinUSA

Everyoperator,includingWildGooseStorage,ofasubsurfaceinstallation,exceptthe
DepartmentofTransportation,shallbecomeamemberof,participatein,andshareinthecosts
of,aregionalnotificationcenter,(USA).
5.6
CompanyWebsites
WGS, LLC may at some point of operation decide to enhance communications to the public
throughtheuseofaCompanywebsiteontheInternet.Sinceacorporatewebsitewillconsistof
various business needs (e.g. investor relations, marketing, affiliate needs etc.) the guidance in
thissectionstrivestocommunicatetheminimumfeaturesoftheCompanydamageprevention
program. A Company website will supplement, not replace, the other various direct outreach
delivery tools discussed in this program. The WGS, LLC website is
http://www.niskapartners.com/.
5.7
NationalPipelineMappingSystem
TheNationalPipelineMappingSystem(NPMS)isageographicinformationsystem(GIS)created
by the U.S. Department of Transportation, Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety (OPS) in cooperation with other federal and
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Operations and Maintenance Procedures Manual

Source: AGA Purging Principle and Practice 1975.Table 8-2.

Operations and Maintenance Procedures Manual

2.17 Safety Related Condition Report

Operations and Maintenance Procedures Manual

On a pipeline that operates at hoop stress of 20% or more of its Specified

Unintended movement or abnormal loading by environmental causes, such as

Any material defect or physical damage that impairs the serviceability of a

Any malfunction or operating error that causes the pressure of a pipeline

A leak in a pipeline that is characterized by the need for immediate corrective

Reduction in pressure as a precaution to avoid an unsafe condition for the

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

2.18 Security of Facilities

Operations and Maintenance Procedures Manual

2.19 Tapping Pipelines under Pressure

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Weld the ends of the split tee to the parent pipe.

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

SECTION 3.0 PIPELINE MAINTENANCE

Operations and Maintenance Procedures Manual

SECTION 3.0 PIPELINE MAINTENANCE

Abandonment or Inactivation of Facilities

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Clearing Pipeline Freezes and Ice Blocks

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

INTERNAL AND EXTERNAL EXAMINATION OF BURIED PIPELINES

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual

EVALUATION OF BARE, BURIED OR SUBMERGED UNPROTECTED

Operations and Maintenance Procedures Manual

Operations and Maintenance Procedures Manual