Determining tasks covered under the new Operator Qualification rule is a priority for most pipeline operator’s. Some tasks, such as valve maintenance and cathodic protection surveys definitely pass the 4 part test without much question from any operator. However, there are some tasks whose status as covered or not covered is not quite as clear. One such task is right-of-way flyovers. How does this task do in the four-part test:
- Is it performed on a pipeline facility?
The pipeline right-of-way is included in DOT’s definition of a pipeline facility. You are flying over the right-of way but looking for things on the right-of-way. Is this task performed on the right-of-way? - Is it an Operations and Maintenance task?
This is not even questionable. Right-of-way inspections are considered part of the routine maintenance of the pipeline system. - Is it performed as a requirement of 49 CFR Part 192 or 195?
This is also a given. 49 CFR Part 192.705 and 195.412 require routine inspections of the pipeline right-of-way. - Does it affect the operation or integrity of the pipeline?
This part of the test can also raise questions concerning this task. The results of this task can show that a pipeline is having integrity problems. However, does this have a direct effect on the operation and integrity of the pipeline?
What do you think about these questions? Please email your comments on these or other tasks that you would like to have included in future newsletters to tina@your-rcp.com.