Mr. Ken Vanover with ExxonMobil shared his opinion with us concerning last month's Covered Task item. He feels that placing and maintaining pipeline markers IS a covered task, because if the markers were not in place and someone accidentally dug into the line, it WOULD affect the integrity of the line. Certainly, these markers are very important safety devices, and their placement and maintenance should be considered a covered task. Do you agree?
And now for this month's item: Is installing pipe in a ditch a covered task?
- Is it performed on a pipeline facility? This is definitely performed in the pipeline right-of-way.
- Is it an Operations and Maintenance task? The answer to this question depends on when the pipe is being installed. If it is a new line that is being constructed, then the task would be construction and not maintenance. However, since repairs fall under maintenance activities and this task could very well represent a segment of pipe being replaced, it could very well be a covered task.
- Is it performed as a requirement of 49 CFR Part 192 or 195? This task is performed to comply with 49 CFR Parts 192.319 and 195.246
- Does it affect the operation or integrity of the pipeline? How the pipe is handled and covered when being installed in a ditch affects the pipeline integrity. The integrity is affected by the possibility of undue stress on the pipe from cover or hits from equipment.
What do you think about these questions? Please email your comments on this or other tasks that you would like to have included in future newsletters to tina@your-rcp.com.
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