Maintenance Procedure

Transcription

1 Maintenance Procedure Table Of Contents 1.0 Preparation for Excavation Trenching / Excavation Backfill and Compaction Site Restoration...14 Attachment A Duties and Responsibilities...15 Attachment B Safety and Precautions...19 Attachment C Job Hazard Analysis...22 Attachment D Site Specific Excavation and Backfill Plan...26 Purpose and Scope The purpose of this procedure is to provide direction to individuals involved in excavation and backfill activities at a Colonial worksite. This procedure describes the controls and methods used when performing excavation and backfill activities to support maintenance or inspection tasks on existing pipelines or facilities. This procedure does NOT cover excavations under the following conditions: Greater than twenty (20) feet in depth. (Requires the development of an excavation plan by a certified Professional Engineer. See Safety Awareness Manual Trenching and Excavation.) Under or adjacent to buildings, retaining walls, sidewalks or pavement. (Excavation MAY Not be Allowed by OSHA Standards OR May require the development of an excavation plan by a certified Professional Engineer of the appropriate discipline and background. See Sam Manual Trenching and Excavation, page 4, Safety Precautions Section.) Third-party activities that impacts Colonial right-of-way or facilities. (Refer to procedure NOP- ROW-005 Third Party Excavation and Backfill.) Installation of new lines or facilities (Refer to Engineering Standards, ES Trenches and Underground Lines.) Excavation that is too deep to locate the pipelines using two techniques including line finder, Probe rod, soft dig, and manual excavation tools. PAGE 1 OF 27

2 Duties and Responsibilities COLONIAL PIPELINE COMPANY CM Refer to Attachment A for Duties and Responsibilities Safety and Precautions 1. Refer to Attachment B for Safety and Precautions References CFR , OSHA Excavation Standard, 29 CFR COOQ (API Guidance Document Appendix D) 4. NOP-ROW-003, Line Locating and Marking 5. NOP-ROW-001, Exposed Piping 6. ES , Trenches and Underground Lines 7. Safety Awareness Manual 8. Environmental Compliance Manual 9. Contractor Safety Program 10. Alignment Sheets/Facility Drawings/Delivery Line Alignment Sheets 11. USGS Maps 12. Soil Erosion and Sediment Control best management practices for pipeline maintenance activities. 13. Conduct of Operations 14. Tool Run Data Feature List 3D profile Software Profiles from Tools equipped with Inertial Navigation Systems PAGE 2 OF 27

3 Special Equipment 1. Line locating device. 2. Atmospheric Monitor (If planned excavation will exceed 4 ft. in depth or there is a potential for encountering hazardous atmospheres). 3. Soft Dig Trucks, if necessary i.e. hydrovacs. 4. Temporary marking material (flags, marking paint, ribbon). Abnormal Operating Condition 1. The following situations may require entry into an Abnormal Operating Procedure (AOP) or Emergency Operation Procedure (EOP): Fire or explosion Hazardous liquid leaks Abnormal facility condition Component failure or component malfunction 2. IF an AOP or EOP entry condition is encountered while performing this procedure, ENSURE the appropriate individuals are notified. Prerequisites 1. Individuals performing activities covered by this procedure must have the appropriate Operator Qualifications. 2. Daily Work Permit and Safety Checklist have been completed with JSA. 3. Excavation Safety Form has been completed (if Option 1 is not selected). 4. The One-Call notification has been made in accordance with local laws and regulations. 5. Colonial s line has been located and marked in accordance with NOP-ROW-003, Line Locating and Marking. 6. There must be a Competent Person under OSHA s Excavation Standard, 29 CFR , or under local rules and regulations, if they are more stringent than the OSHA Standard, at the work site during excavation activities. It is preferred that the Excavating Contractor supplies the Competent Person for the excavation activities. 7. All Permits shall be obtained where required by state/local agencies, including roadways, DOT Right-of-ways, and counties that require excavation permits. 8. Attachment A Duties and Responsibilities has been reviewed by personnel filling the listed roles. 9. Attachment B Safety and Precautions has been reviewed by ALL personnel involved in the excavation activities. PAGE 3 OF 27

4 Procedure 1.0 Preparation for Excavation 1.1. VERIFY One-Call ticket has been processed VERIFY ALL foreign lines and company facilities, listed on the One-Call ticket, have been marked in the planned excavation area IF the planned excavation area changes, all activities shall cease, and this procedure shall be restarted. NOTE: Adequately marking the line should clearly identify the path of the buried line. However, if existing line markers adequately identify the path outside the work area, it is not necessary to install additional temporary markers further than the limits of the excavation, especially if additional hazards are involved (e.g., high traffic volume, stream crossings) that make the placement of additional markers impractical. This is an OQ covered task. NOTE: If excavation is within a company or shipper facility, refer to Section VERIFY company s pipeline has been adequately marked up to 100 feet in each direction from the planned excavation per NOP-ROW-003. In the event the pipelines are deep and cannot be located and this procedure cannot be followed, notification shall be made to the Project Manager and a written site specific excavation plan shall be developed and approved by the Project Manager before beginning any excavation activity. This plan may include using feature lists, surveyors with ILI profile, 3D graphics from ILI Data, extensive probing, etc. PAGE 4 OF 27

5 CAUTION Probe the area that is to be excavated even when sloping the ditch back or cleaning it out. DO NOT excavate outside the limits of the probed area COMPARE marked lines with Alignment Sheets. CAUTION Alignment sheets do not always reflect all pipe bends. Additional data should be used to identify all PIs, sag and over bends. Dig remediation list are excellent means of identifying pipeline features from past ILI Tool runs IF comparison reveals any of the following problems between Alignment Sheets and marked lines, RESOLVE problem before excavation activities begin IF discrepancy is due to inaccurate Alignment Sheets, COMPLETE a Change Diagram (Form C3331) Alignment sheets, Facility drawings and/or other available data such as feature lists, ILI Profiles, etc. MUST be reviewed prior to excavation for any appurtenances on the line(s) that may present a hazard during excavation IF planned excavation will impact property owners, ATTEMPT to contact owners, AND INFORM them of pending work. CAUTION Barbed wire must NOT be used for protection around excavations in highly populated areas unless livestock is present IMPLEMENT the following site security measures, as needed, based on the above walk down: Barbed wire (Minimum three strands) Warning barricades Safety fencing, strongly encouraged everywhere (Minimum height of three feet) Earth berms Flashing lights PAGE 5 OF 27

6 1.7. COMPLETE the following forms from the Safety Awareness Manual. Daily Work Permit and Safety Checklist Excavation Safety Form. It is not necessary to complete if type C soil is selected or excavation is less than 4 deep IMPLEMENT the following types of excavation protection, as needed, Shoring Sloping Trench boxes, with tabulated data Work Mats Soil moisture stabilization Water diversion (ditches, pumps, etc.) Leveled work areas for excavation equipment (in areas with significant cross slope) Entry and exit ramps or ladders (required if excavation will exceed 4 feet in depth) Reflective signs or flashing lights (potential traffic hazards) NOTE: Attachment D can be used as a guide to develop a Site-Specific Excavation and Backfill plan. However, the plan will need to be modified to address any maintenance or inspection work that will take place in the excavated area, as well as the excavation activities. NOTE: The Competent Person, whether Colonial or Contractor, is responsible for developing the Site-Specific Excavation and Backfill Plan. Input from the Excavation Operator and other team members should be obtained for the Site-Specific Excavation and Backfill Plan. (Review with Safety if Required by OSHA) 1.9. REVIEW AND APPROVE Site-Specific Excavation and Backfill Plan in Attachment D. PAGE 6 OF 27

7 1.10. IF excavation is in response to a known OR suspected leak, PERFORM the following actions: VERIFY the Line Controller (Control Center/Facility Operator) has completed the following procedures, as appropriate: Control Center AOP-CC-J01 Suspected Leak EOP-CC-K01 Leak Facility Operator AOP-CPC-J01 Suspected Leak EOP-CPC-K01 Leak ESTABLISH continuous Atmospheric Monitoring for oxygen and LEL levels. A plan shall be established for the monitoring of toxic chemicals ARRANGE for handling and disposal of contaminated soils OBTAIN Fire Extinguishers AND other safety equipment, as required ENSURE excavation equipment is in safe working order REMOVE OR STABILIZE any surface obstruction(s) that may create a hazard CONDUCT a Pre-Job Brief with ALL individuals involved in the excavation. PAGE 7 OF 27

8 2.0 Trenching / Excavation NOTE: Do not jack hammer concrete unless all sides of the concrete are exposed and the possibility of a power cable and/or piping running through the concrete can be eliminated. Red or Dyed concrete indicate high voltage, but the concrete may not look dyed, especially in red clay soils CONFIRM depth AND horizontal location of pipeline and adjacent underground structures in at least two places in the planned excavation work area using two of the following methods: Line locator Hand Excavation Probe Rod Soft Dig Technology (i.e. Hydrovac) 2.2. VISUALLY CONFIRM the location of the pipeline using Hand Excavation or Soft Dig Technology until the pipeline is exposed. IF THE PIPELINE IS NOT LOCATED AND VISUALLY CONFIRMED using these techniques, no mechanical excavation shall begin until a written site specific excavation plan, which may include a combination of mechanical excavation and soft excavation techniques, is approved by the Project Manager 2.3. In Permitted areas (i.e. Wetlands), ENSURE excavation remains in the permitted footprint. CAUTION The primary function of the Spotter is to spot for the Excavation Operator. The Spotter must NOT be distracted with other tasks while mechanical excavation is actually underway WHEN the location of the pipeline has been visually confirmed, ENSURE mechanical excavation is done parallel to pipeline, use caution around PI s and appurtenances (TOR, etc.) ENSURE excavation equipment is maintained a safe distance from the pipeline and to where the equipment operator can maintain eye contact with the swamper. Any and all equipment not involved in the excavation shall be maintained downhill and a minimum of 3 feet from the excavation. PAGE 8 OF 27

9 When digging a PI (bend), the outside of the bend should be dug first. If it is not feasible to do so, a site specific excavation plan is required. For multiple parallel PI s a Site Specific Excavation plan is required IF excavation affects an agricultural or residential area where topsoil must be protected, REMOVE top six inches of soil or until color change indicates subsoil reached, AND PLACE on a separate pile from the excavation spoil pile ENSURE spoil pile is maintained a MINIMUM of two feet from edge of excavation AND angle of repose is LESS THAN 45º from horizontal IF excavation involves soil contaminated with product, ENSURE spoil handling and disposal is conducted as directed by the District Environmental Team 2.7. REQUIRE hand excavation under any of the following conditions: Excavation closer than 2 feet from top or bottom of pipeline until pipeline has been exposed. Excavation closer than 2 feet from sides of pipeline until pipeline has been exposed Excavation closer than 1 foot from top or sides after pipeline has been exposed. This means that after the pipe has been exposed, no mechanical excavation is permitted within 1 foot around the pipe. Complex excavation involving tight quarters WHEN the pipeline(s) are in marshes, lakes, in shallow water, REQUIRE water lifting or jetting and under any of the following conditions: Excavation is closer than 3 feet from the top of the pipe. Excavation is closer than 2 feet from the side of the pipeline IF a line hit occurs OR an anomaly containing visible cracks is observed, TERMINATE all excavation activities, AND NOTIFY Line Controller (Control Center or Facility Operator) of condition IF excavation exceeds 4 feet in depth, ENSURE the following is implemented before allowing entry into excavation. Atmospheric Monitoring Entry and exit equipment Adequate and OSHA-compliant sloping or shoring PAGE 9 OF 27

10 2.11. TERMINATE all excavation activities if any of the following are encountered. Hazardous atmosphere Potential cave-ins Indications of failures of protective systems (sloping, shoring, etc.) Colonial s Representative (who, as defined in Attachment A is the person who has responsibility for performing inspection activities according to this Procedure (e.g., Project Inspector, Technician, etc. i ) and may be either a Colonial employee or a contractor)leaves the excavation site. Hazardous material is discovered in the ditch including blasting material, chemicals, potentially pressured vessels, medical waste, etc. Proceed only after consulting with Project Manager and/or safety personnel. Upon the initial discovery of excavation being located in a possible landfill or landfill material in excavation site, work must be stopped, update or develop a JHA before proceeding. Company representative must notify the District Environmental Team and HSS to identify possible materials that could be dangerous to life and health that has been discovered. It may be determined that an Industrial Hygienist may need to on site for the duration of the project. Identify the nearest hospitals and have GPS coordinates for the jobsite for easy location for medical personnel if needed IF excavation activities will be stopped for an extended period of time OR left unattended overnight, PERFORM the following actions NOTIFY Line Controller (Control Center or Facility Operator) ENSURE site security measures are in place Water control measures have been taken if necessary. NOTE: Do not pinch out from under the pipeline with the track-hoe arm extended over the pipeline WHEN excavating UNDER pipeline, EXCAVATE from NEAR SIDE of pipeline IF length of unsupported pipeline reaches twenty feet, INSTALL appropriate supports to prevent undue stress on line, OR OBTAIN Engineering evaluation that identifies MAXIMUM safe span. PAGE 10 OF 27

11 2.14. IF rock is being excavated, INSTALL mechanical shielding for the pipeline using oak planks, blasting mats, oversized pipe or sleeve, or similar whenever the pipe is exposed even if there is only a small portion of the pipe that is exposed IF rocks larger than the hoe bucket must be removed, PRIOR to removal, FRACTURE the rocks to a size that the hoe bucket can carry. Be sure to shield pipe as stated above before fracturing rock. PAGE 11 OF 27

12 3.0 Backfill and Compaction 3.1. ENSURE ALL inspection activities AND post-maintenance testing are complete ENSURE the excavation and backfill is free of any metal objects (cans, hand tools, clamps, scrap metal) and non-soil materials ENSURE that any material excavated from a landfill or identified as landfill type material shall not be placed back into the excavation. Clean backfill shall be used to support and pad the pipe ENSURE the pipe has been padded where necessary BEFORE beginning backfill operations, ENSURE that the Excavation Operator and Spotter have reviewed the Site Specific Excavation and Backfill Plan. CAUTION Backfill must be placed, NOT pushed. For example, the first 2-feet of backfill around and over the top of the pipe can be accomplished with a backhoe but NOT a bulldozer WHEN equipment is backfilling within 2-feet of any Colonial asset, ENSURE that the Colonial Representative, as defined above and in Attachment A, is in the work area. NOTE: Best compaction is attained when moisture content of the soil is at or near 10%. In some cases, adding lime to the backfill mixture or in severe conditions bringing in select back fill may be necessary to obtain proper compaction of the backfill. In some cases Fly Ash or Lime can be added to reduce the moisture content of the soil. Locations where compaction test are required a proctor will be required once the added material has been mixed with the soil IF compaction of backfill is necessary due to conditions at the location (e.g., steep slope or cross-slope, proximity to road or railroad crossings, or potential for heavy equipment traffic), ENSURE the following compaction guidelines are followed. Backfill is placed in MAXIMUM of 6-inch lifts AND compacted between lifts. WHEN backfilling under the pipeline, USE hydraulic, Pneumatic, and/or Mechanical compacting equipment for compaction until backfill comes up to pipe. PAGE 12 OF 27

13 CAUTION For long excavations such as recoating or casing removal, special monitoring of pipe settlement is required. Pipe support compaction plan will be required ENSURE that ONLY clean, soft backfill is placed into the excavation UNTIL 2-feet of good backfill material surrounds the pipe ENSURE backfill is placed equally along both sides of pipe and properly compacted, UNTIL pipe is covered ENSURE backfill is crowned, where appropriate, to compensate for settling CREATE diversion berms and cross ditches as cross-slope requires, preventing pooling along trench line. (Refer to ES for guidance.) ENSURE temporary erosion control methods are monitored once they have been installed and removed when the excavation and backfill activities are no longer a threat to the environment. PAGE 13 OF 27

14 4.0 Site Restoration 4.1. REPLACE any soil moved to provide level foundation for equipment REPLACE topsoil over spoil crown, AND RESEED with appropriate ground cover REMOVE all construction debris and other trash from work site INSTALL OR REPAIR Line markers as necessary END PAGE 14 OF 27

15 Attachment A Duties and Responsibilities The following list of duties and responsibilities represents the normal course of events. In some instances, the same individual may serve in the positions of Project Inspector and Competent Person. Additionally, some listed tasks may be performed by individuals other than those named below. However, the individual identified below remains responsible for ensuring that the tasks are properly performed. 1. Colonial Representative is the person who has the responsibility for performing inspection activities according to this Procedure (e.g., Project Inspector, Technician, etc.): Ensures the alignment sheets, ILI data or other material that identifies pipeline features have been reviewed and are available for reference. Ensures that he or she is at the work site anytime excavation activities are in progress. Ensures work activities are stopped if there is a concern for injury, pipeline integrity, public safety, or damage to Colonial facilities. Ensures proper one-calls have been made. Ensures compliance with all state one call laws. Ensures all necessary environmental permits are obtained or the proper notification is made to the agencies having jurisdiction. Ensures State/local permits have been obtained for excavations, if required. Ensures landowners have been notified. Ensures that the Site-Specific Excavation and Backfill Plan, if, required, has been reviewed and is followed Ensures that the following are completed before work begins: 1) Daily Work Permit and Safety Checklist. 2) Job Safety Analysis. 3) Excavation Safety Form, if required Conducts tailgate safety meetings. Ensures individuals who are performing Covered Tasks, as identified in the Operator Qualification manual, have appropriate OQ documentation. Coordinates commencement of work with Line Controller (Control Center and Facility Operator of nearest staffed facility). Ensures communications with Line Controller (Control Center and/or Facility Operator at nearest staffed facility) is available. PAGE 15 OF 27

16 Ensures that all excavation and backfill activities are performed in accordance with this Procedure and all applicable pipeline safety regulations. Remains in the work area and continuously monitors all excavation and backfill activities. Ensures permanent pipe support and backfill material are satisfactory and meet Colonial specifications. Conducts inspections of excavations daily, before starting work, as needed throughout the workday, and after rainstorms or other change in conditions that may impact the excavation. Inspects excavations for potential cave-ins, indications of failures of protective systems (sloping, shoring, etc.), and hazardous atmospheres or other hazardous conditions. If hazardous conditions are encountered, ensure exposed individuals are removed from the hazardous area until necessary safety precautions have been taken. Ensures spoil material is safely stored at least 2-feet from the edge of excavation. Ensures mechanical equipment not directly involved with the work at the excavation site does not operate closer than 3-feet from the edge of the excavation and is securely parked when not in use. Monitors excavation activities, equipment and water removal, as necessary. Ensures that soil classifications are performed and the need for shoring or similar protective systems is evaluated. Records data, as required. Determines the effects of operating equipment, traffic, etc. around the excavation. Ensures excavations are clearly marked and properly barricaded, if left open. 2. Competent Person Is capable of identifying existing and predictable hazards in the surroundings, or working conditions that are unsanitary, hazardous, or dangerous to employees and has authorization to take prompt corrective measures to eliminate them. Develops the Site-Specific Excavation and Backfill Plan with input from the Excavation Operator and Spotter (Swamper). Ensures spoil material is safely stored at least 2-feet from the edge of excavation. Ensures mechanical equipment not directly involved with the work at the excavation site does not operate closer than 3-feet from the edge of the excavation and is securely parked when not in use. Monitors excavation activities, equipment and water removal, as necessary. Determines soil classifications and the need for shoring or similar protective systems. PAGE 16 OF 27

17 3. Line Controller (Control Center/Facility Operator) Takes measures, if appropriate, to mitigate the consequences should an accident occur (isolate line, reduce line pressure, etc.). 4. Excavation Operator The Excavation Operator is the contractor employee operating the excavation equipment. Is responsible for an accident free workplace. Shall perform a Job Hazard Analysis to identify and mitigate hazards in the area of excavation. Ensures work activities are stopped if there is a concern for injury, pipeline integrity, public safety, or damage to Colonial facilities. Confirms the location of the pipeline using a line locator, probe rod, hand excavation or soft dig techniques prior to mechanically excavating the planned excavation area. Seeks guidance from the Spotter to prevent pipeline damage. Safely stores spoil material at least 2-feet from the edge of excavation. Provides significant assistance and input in the development of Site-specific Excavation and Backfill Plan. Reviews and understands this procedure. 5. Spotter (Swamper) The Spotter is the person spotting the Excavation Operator. The Spotter shall NOT perform other duties if they interfere with the ability to perform the duties listed below. Is responsible for an accident free workplace. Shall be Operator Qualified to perform all covered tasks associated with excavation and backfilling or shall be immediately supervised by a Qualified Individual. Ensures work activities are stopped if there is a concern for injury, pipeline integrity, public safety, or damage to Colonial facilities. Using two methods, confirms the location of the pipeline using a line locator, probe rod, hand excavation or soft dig techniques prior to allowing any mechanically excavating in the planned excavation area. The Spotter s most important responsibility is to direct the Excavation Operator to prevent pipeline damage. He/She is responsible for maintaining top and side clearances. Remains vigilant as to the potential for hazardous conditions and damage to the line. Observes excavation progress and remains vigilant to potential hazards. During excavation uses a line locator and a probe rod to verify pipe location. PAGE 17 OF 27

18 Reviews and understands this procedure. Shall be responsible for guiding and directing backhoe while mobilizing and demobilizing to prevent hitting power lines or other obstructions. This is especially necessary when working in congested areas, around power lines and when moving track hoes and cranes around the worksite. PAGE 18 OF 27

19 Attachment B Safety and Precautions Refer to the Operations Section of the Safety Awareness Manual, under Trenching and Excavation, for additional information regarding safety concerns. Colonial personnel must maintain a high level of concern for the safety of contractors and subcontractors performing work for Colonial. Contractors must comply with the Colonial Contractor s Safety Plan. 1. Individuals must wear appropriate safety equipment (hard hat, safety shoes, etc.). 2. Individuals who are exposed to public vehicular traffic must wear warning vests or other suitable garments marked with or made of reflective or high-visibility material. 3. Individuals should NOT operate equipment without first being properly trained to handle it and being fully alerted to its potential hazards. 4. Fire extinguishers must be in place (hand held). 5. The Line Controller (Control Center/ Facility Operator) must be informed of all actions performed that may potentially affect pipeline operations. 6. Support systems, (e.g., shoring, bracing, or underpinning) must be used to ensure the stability of adjacent structures such as buildings, walls, sidewalks, or pavements (OSHA requirement). 7. Excavation below the level of the base or footing of any foundation or retaining wall is prohibited unless one of the following conditions is met (OSHA requirement): A support system or underpinning is provided. The excavation is in stable rock. A registered professional engineer determines that the structure is sufficiently removed from the excavation and that the excavation will not pose a hazard to employees. 8. Excavations under sidewalks or pavement are prohibited unless an appropriately designed support system is provided or other effective method is used (OSHA requirement). 9. Before a person enters excavations greater than 4-feet in depth or excavations where an oxygen deficient atmosphere exists or could possibly be expected to exist, a Competent Person must test the atmosphere using an oxygen/lel monitor extended down in the excavation (OSHA requirement). 10. If any controls are used to reduce atmospheric contaminants to acceptable levels, the excavation shall be tested continuously for deficiencies in oxygen, toxic vapors, and an explosive atmosphere (OSHA requirement). 11. Unknown or unidentifiable materials work will cease until notifications have been made to the District Environmental Manager and HSSE. This will require developing a new Site Specific Excavation and Backfill Plan along with all of the Safety paperwork. PAGE 19 OF 27

20 12. Access and Egress (OSHA requirement) COLONIAL PIPELINE COMPANY CM-102 Where individuals are required to be in excavations greater than 4-feet deep, adequate means of egress, such as ramps (maximum 20% grade for ramp), ladders, steps, or other safe means, must be provided within 25-feet of lateral travel. If structural ramps are used as a means of access or egress, they must be designed by a competent person. Structural members used to form ramps must be of uniform thickness and joined in a manner to prevent tripping or displacement. 13. Sloping (OSHA requirement) Sloping of the walls of the excavation should be performed in accordance with OSHA guidelines depending on the class of soil and soil conditions, such as: 1) Water 2) Silty materials 3) Loose boulders 4) Evidence of erosion, deep frost action, or slide planes Another option is to use what is called OPTION 1, which means you do not classify the soil, but slope or shore to the most stringent requirements. 14. Shoring (OSHA requirement) When an excavation requires shoring, refer to the guidance provided in ES Trenching and Underground Lines on the materials and methods that should be used. 15. Falls and Equipment Material or equipment that might fall or roll into an excavation must be kept at least 2- feet from the edge of the excavation, or provide retaining barriers, or both. Where necessary, scaling must be provided to remove loose rock or install protective barricades to protect individuals against falling rock, soil, or other materials. Work on faces of sloped or benched excavations at levels above other individuals is prohibited unless individuals at lower levels are adequately protected from the hazard of falling, rolling, or sliding material or equipment. Individuals are NOT allowed under loads that are handled by lifting or digging equipment. Individuals working around equipment should be aware of equipment movements (swinging, lifting, bucket movements, etc.) Spotter(s) watch equipment as it moves around job site. PAGE 20 OF 27

21 16. Water Accumulation COLONIAL PIPELINE COMPANY CM-102 Individuals are prohibited from working in excavations where water has accumulated unless adequate protective measures have been taken. Where necessary, diversion ditches, dikes, or other suitable methods will be used to prevent surface water from entering the excavation and to provide adequate drainage of the area adjacent to the excavation. 17. Factors Affecting Soil Stability. CAUTION must be exercised under the following conditions, where soil stability may be significantly degraded: Soil expansion due to freezing or thawing decreases its stability and may result in shoring or support systems not performing adequately. Large excavations that are left open for extended periods are particularly subject to wall collapse due to changes in weather producing either an increase or a decrease in soil moisture content. Structures in the vicinity of excavations increase the forces at the excavation walls, particularly if close to the excavation. Examples of such structures are heavy equipment, vehicles, and materials (pipes, timber, or spoil piles). Passing vehicles, blasting, and operation of excavation equipment or certain tools can loosen soil and increase the possibility of cave-ins. Soils subjected to prior excavation and backfilling may take years to regain the cohesive nature of undisturbed soil. PAGE 21 OF 27

22 Attachment C Job Hazard Analysis Attachment C can be used as a guide to develop a Job Hazard Analysis. This is not the JHA. However, the JHA will also need to identify any hazards associated with the maintenance or inspection work that will take place in the excavated area. EXCAVATION HAZARDS Proper communication / notification Unknown utilities Traffic Soil conditions ACTIONS / CONSIDERATIONS Make one-call, notify landowners, and proper authorities (Colonial or non-colonial) Proper working equipment (radio, cell phone, satellite phone, etc. Identify Hospitals and medical facilities prior to beginning work. Check strip map Check surrounding area for markers Additional probing Check community for location of gas, electric, and water lines Make the proper one-calls Road at work/injection site to be closed and barricaded only authorized personnel posted Traffic control personnel (someone to watch for vehicles entering and leaving work site) Limit access of vehicles to work site Designated parking area Construction signs and flashers installed at entrances to work sites Proper sloping, shoring or trench boxes, if needed Fill out proper excavation safety form (Colonial form C7020) Refer to Colonial Excavation and Backfill Standard Excavation and handling of soil Store per Colonial environmental standard Groundwater Adjacent pipelines Equipment close to excavation Mud at roadsides at work site entrances Terrain conditions Egress and Ingress Have pumps available and pump water to area according to Colonial Pipeline Co. Environmental Specifications Diversion (Flumes, Coffer damns, etc.) Locate, mark and ensure proper cover and protection for other pipelines Limit amount of activity over pipelines Have Spotter observe equipment, as it is moving Have safety personnel monitor equipment movement Have Excavation Operator follow Colonial Excavation and Backfill Standard Monitor road condition, and handle as necessary All personnel are responsible for keeping road clean Make sure there is good footing in ditches for worker to move around Use caution on hillsides, creek banks, etc. Incorporate protective measures in excavation and backfill plan Mark and define escape routes Keep egress routes free of obstructions Backfilling Refer to Colonial Excavation and Backfill Standard PAGE 22 OF 27

23 Rev. 4 01/03/2012 EXCAVATION HAZARDS Possible atmospheric contamination Site security Fenced areas vs. non-fenced areas ACTIONS / CONSIDERATIONS Sniffing atmospheric check Monitor oxygen and LEL during N2 injection, cut out sites, and bleed off sites If LEL is above 3% at work sites a sphere will be installed or controls will be put in place to reduce LEL below 3% before work can progress in the excavation. This is due to the toxicity level of hydrocarbons. Refer to Colonial Excavation and Backfill Standard Erosion control Install proper erosion control as needed for weather conditions Weather conditions Be aware of weather conditions and prepare as necessary Pipe supports Support every 20-feet unless special conditions exist Removal and disposal of coating Critter/Wildlife factor Water hazards Tripping hazard Improperly marked pipe size / lamination Product Spill Overhead Power Lines Waste or Hazardous Material Wear proper PPE when removing coating Dispose of coating per colonial environmental specifications Pay attention to surroundings Have first aid kit available Life jackets required near water bodies Refer to Accident Prevention Manual Be aware of potential tripping hazards (welding leads and extension cords) Maintain proper house keeping Ultrasound location to be welded Mag- particle after welding X-Ray after tie-ins During Blowdown, open valves slowly to check for product. Before starting cold cut, check for product in the line (dipstick), have vacuum truck on site Caution operators against contacting overhead power lines Identify on excavation and backfill plan Set up barriers if practical Spotter to watch for them with equipment is moving Shutdown and consult with safety personnel to determine specific needs including monitoring, PPE, etc. Work must be stopped, update or develop a JHA before proceeding. Company representative must notify the District Environmental Manager and HSSE to identify possible materials that could be dangerous to life and health that has been discovered. It may be determined that an Industrial Hygienist may need to on site for the duration of the project. Identify the nearest hospitals and have GPS coordinates for the jobsite for easy location for medical personnel if needed. PAGE 23 OF 27

24 Rev. 4 01/03/2012 OTHER TASKS WITH ADDITIONAL HAZARDS: WELDING / TAPPING Flying debris Ignition source Burns Cutting and Grinding Electrical hazard Tapping failure Drill steel binds Laminated pipe ABRASIVE CLEANING Flying debris LIFTING / RIGGING AND PILING / SHORING Overhead Hazard Pinch points CASING REMOVAL / ARCH GOUGE ADDITIONAL HAZARDS ACTIONS / CONSIDERATIONS Proper eye protection Face shields and goggles Lower Explosive Limit (LEL) / Oxygen monitoring Manned fire extinguishers Proper procedures and PPE First Aid Kit available See flying debris See ignition source Proper PPE Proper Grinding Disc for Grinder Guards on Grinder Inspect cords and equipment Proper grounding Notify Controller Follow Emergency Response Plan Inspect drill steel for wear Use proper tapping procedures Ultrasound area where cutting or welding for proper pipe thickness Mag- particle area after welding for cracks Proper eye protection Face shields and goggles PAGE 24 OF 27 ACTIONS / CONSIDERATIONS ACTIONS / CONSIDERATIONS Be aware of overhead obstructions Ensure tag lines are in place Be aware of possible pinch point locations such as sleeve material, line-up clamps, etc. Stay away from moving equipment and only move in to rig once the operator has stopped operating the equipment and is ready to hook up. Use tag lines to clear yourself from objects being moved. ACTIONS / CONSIDERATIONS Pipeline not properly shielded Install shield between pipeline and casing Flying debris Ignition source Proper eye protection Face shields and goggles Lower Explosive Limit (LEL) / Oxygen monitoring Manned fire extinguishers

25 Rev. 4 01/03/2012 ADDITIONAL HAZARDS WELDING / TAPPING Burns Cutting and Grinding Electrical hazard DIGGING ON WORK MATS Slide off mats onto pipeline Drop mats on pipeline when moving them ACTIONS / CONSIDERATIONS Proper procedures and PPE First Aid Kit available See flying debris See ignition source Proper PPE Inspect cords and equipment Proper grounding ACTIONS / CONSIDERATIONS Ensure mats are level and secure to dig on Ensure area for mats will support equipment Ensure mat hook is secure Ensure mat cables are in good condition CONSEQUENCES OF HAZARDS: Environmental Damage Personal injury Pipeline damage Property damage Equipment damage PAGE 25 OF 27

26 CM-102 Rev. 4 01/03/2012 Attachment D Site Specific Excavation and Backfill Plan Attachment D can be used as a guide to develop a Site-Specific Excavation and Backfill plan. However, the plan will need to be modified to address any maintenance or inspection work that will take place in the excavated area, as well as the excavation activities. The Competent Person, whether Colonial or Contractor, is responsible for developing the Site- Specific Excavation and Backfill Plan. Input from the Excavation Operator and other team members should be obtained for the Site-Specific Excavation and Backfill Plan. Upon the discovery of landfill material a new Site-Specific Excavation and Backfill Plan will be developed or conditions warrant procedure not valid for the excavation. Date: Line: Location: Reason for Excavation: Size, Depth, Drawing All excavations meeting any of the following conditions must be planned and designed by a registered professional engineer trained in an appropriate discipline: Excavations in excess of 20 feet in depth. Excavations adjacent to structures/improvements. One Call Ticket # Locate Methods used: Excavation Equipment Used Make: Model: EXCAVATION PLAN Method of excavation: Method of ingress and egress: Method of pipe support: Protective measures applied to excavation walls: Type of pipe shield used: Placement of spoil: COMMENTS (or N/A if appropriate) SITE SPECIFIC CONSIDERATIONS Traffic Adjacent structures & their condition Overhead & underground utilities Soil type Livestock / wildlife Surface/ground water Weather Topography (slopes, working area, etc.) Residential area children Adequate room for spoil piles Work mats COMMENTS (or N/A if appropriate) PAGE 26 OF 27

27 CM-102 Rev. 4 01/03/2012 Description of area (rural, city, farm, livestock, etc.) Barriers or signs used Abnormal events PI s Other: INSPECTOR: EXCAVATION OPERATOR SPOTTER: OQ PERSONNEL PERFORMING TASK: Location No. State Map No. One Call Ticket No. Task Before excavation begins the Colonial Pipeline Company and the contractor and contractor s workers will review the Colonial Pipeline Company Excavation and Backfill Standard and check equipment for good working order. Excavations will be made on Colonial s The excavation will be approximately ft. deep with sloping or appropriate shoring as needed. The bottom of the ditch will be approximately ft. wide. The amount of pipe to be uncovered will be determined by a Colonial Pipeline Company representative. The spoil will be stored adjacent to the excavation at a distance to provide safe walking around the edge of the excavation and according to Colonial Pipeline Company Excavation and Backfill Standard. Ingress and egress of the trench will be ladders and other means of exit every 25 ft. and on both sides of the excavation. Pipe supports will be dirt plugs or other mechanical means of support. Clean soft backfill material will be placed, not pushed in the excavation until 2 ft. of good backfill material surrounds the pipe. Backfill will be performed with the use of a backhoe, or track hoe. i Nothing in this Procedure or any of its attachments is intended to create any type of employment or agency relationship between Colonial and any individual or entity that provides services to Colonial as an independent contractor, including any contractor who fulfills the role of the Colonial Representative, as that term is defined in Exhibit A and used throughout this Procedure. PAGE 27 OF 27