The GPG Safety Declaration of Interdependence signed by all GPG pipeline 
operations staff is our promise to each other that safety on the job is first 
before all other concerns, that we will positively act to assure safe 
practices. This Safety Advisory Bulletin No. 6 is issued to reinforce the 
need for personal safety at all times and in all circumstances.

On April 12, a One-Call ticket was issued for the work being done adjacent to 
one of GPG,s pipelines. The ticket did not identify GPG as having facilities 
in the area so GPG was not notified. 

Sometime after April 12, a GPG employee observed a contractor working in the 
vicinity of an active pipeline. The employee located and marked the pipeline 
in the area where the contractor was working. On May 8, the contractor was 
excavating approximately 75 to 100 feet downstream of the marked pipeline, 
routing a water line, and uncovered a 12-inch pipeline that was assumed to be 
abandoned. The contractor was willing to incur the cost of removing a section 
of the abandoned pipeline if the facility owner would ensure it was 
abandoned. 

The contractor requested a One-Call ticket to mark all underground facilities 
in the area of the excavated 12-inch pipeline. GPG was notified, via fax, of 
the line locate request. The GPG employee who previously had located and 
marked the pipeline informed the contractor that he was unaware of any 
abandoned pipelines in the area, but that he would investigate further.  The 
employee checked his pipeline drawings and consulted with other team members 
and learned that there was an abandoned pipeline in the area. Team members 
also informed him that the accepted practice for checking abandoned pipelines 
was to drill into the pipe.  

On May 9, the GPG employee entered the contractor's excavation and drilled 
into what he assumed was the abandoned pipeline. The employee, believing the 
escaping medium was air, decided to let the pipe vent until the pressure 
relieved. After two hours of venting and no noticeable reduction in pressure, 
the employee re-entered the excavation to check cathodic protection readings. 
At this point the employee determined that the drilled pipeline was venting 
gas. Gas Control was informed of the situation and steps to shut-in, blow 
down and repair the pipeline were implemented.    

After a thorough inquiry by the GPG Incident Investigation Team, the Senior 
O&M Tech involved in the incident was disciplined as a result of his failure 
to follow the procedures listed below, and to reinforce the importance of 
safety interdependency. 

GPG Operating Procedures, 110.310, Gas Testing; 110.170 Confined Space Entry; 
110.260 Excavation; and 110.570 Work Permits :
No gas testing was done by the GPG employee to identify escaping medium.
No gas testing was done before the GPG employee entered the excavation 
considered to be a permit entry confined space.
No gas testing was done before an ignition source was introduced into a 
possibly hazardous atmosphere in the excavation.
No Confined Space Entry permit was issued when the employee re-entered the 
excavation to take cathodic protection readings.
The employee entered an excavation with inadequate means of egress.
No hot work permits were issued by the employee.

GPG Operating Procedure, Blowdown and Purging 80.409 :
The employee did not communicate, in a timely manner, the planned blowdown to 
residents of the adjacent neighborhood.

GPG Operating Procedure, Event Notification Sequence  10.101A :
Gas Control did not notify the GPG environmental specialist of the release of 
natural gas.

GPG Environmental Procedure, Spills and Releases 2.1.10  :
The release of natural gas was not reported to the GPG Division Environmental 
Specialist.

GPG Operating Procedure,  Damage Prevention 80.102 :   
The employee did not properly use maps when marking the pipeline.
The employee did not mark bends or other changes in the direction of the 
pipeline.

PLEASE NOTE THE PRACTICE OF DRILLING INTO A PIPELINE TO DETERMINE IF IT IS 
ABANDONED IS UNACCEPTABLE AND SHALL NOT BE UTILIZED.

Pre-existing abandoned pipe removal practice shall be as follows :

GPG employees shall contact local management when a pre-existing abandoned 
pipeline must be removed to allow routing of other facilities. Local 
management will contact the Engineering Department to evaluate the facility 
and provide guidance to the team on how to proceed with pipeline 
identification and the ensuing removal of the facility. 

Abandoned pipelines that will not be removed shall be treated as an active 
pipeline and marked in accordance with  GPG operating procedure 80.102

Moving Forward

The Pipeline Safety Department will review and revise GPG Operating Procedure 
80.102 to ensure that team members use all available resources to clearly 
identify an existing pipeline as active or abandoned.

The GPG Pipeline Safety Department is investigating why the GPG facility was 
not identified on the April 12 One-Call ticket. 


Near Misses

 There was potential for the contractor's backhoe operator to rupture and 
ignite an active pipeline.
 There was potential for  natural gas to ignite under traffic plates covering 
the excavation in the area of a public road prior to 
             the team diverting  traffic from the area.
 There was potential for a flash fire in the excavation site due to the hot 
work occurring in the area of the natural gas leak.