How do operators assess and control risk caused by third-parties over which they have no direct control?
As part of a comprehensive risk analysis required by 192.917 (c), OPS expects operators to determine the risk associated with third party damage to pipeline segments that could affect an HCA. Operators must follow section 5 of ASME/ANSI B31.8S, which contains guidance on risk assessments. OPS will not prescribe specific risk analysis methods that the operator must use. OPS also understands that outside force damage prevention is challenging because it involves factors outside of the operator s control. Nonetheless, there are a number of actions operators can take to reduce the likelihood of third party damage. If a pipeline segment is in an HCA, and third party damage is determined to be a significant risk (e.g., as might be expected in a high population area, with new construction near the line), the operator must implement the comprehensive additional preventive measures in 192.935.
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