Last Word – Key Strategies to Reduce Excavation Damages

Andrew Lu

For American Gas Association (AGA) member utilities, the mission is to deliver natural gas safely and reliably to the 74 million customers in our country who rely on this critical energy. In order to achieve pipeline safety, any pipeline operator must also strive toward building an effective and robust damage prevention program. Historical incident data shows that approximately 60 percent of the gas distribution industry’s serious accidents are caused by excavation damage.

In January 2023, AGA’s Excavation Damage Prevention Executive Task Force published a document “Working with Other Stakeholders to Advance Pipeline Safety in Damage Prevention.”

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The publication defines the 12 core characteristics of an effective state damage prevention law and the states that have these characteristics in their legislation. The report also identifies the states with the lowest rate of excavation damages to natural gas pipelines. Finally, the publication highlights existing state legislative language related to the twelve core characteristics of an effective state excavation damage prevention law.

Below are the 12 core components that the Excavation Damage Executive Task Force believes serve as the foundation for an effective state excavation damage prevention law:

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  1. Size or scope of One Call Ticket is limited for a standard locate request (may be process exceptions for special large project tickets)
  2. Longevity of One Call Ticket is restricted for a standard locate request (may be process exceptions for special large project tickets)
  3. Specific tolerance (hand-dig only) zone dimensions
  4. Specific tolerance zone requirements
  5. Specific emergency excavation notification requirements
  6. Identifies the responsibilities of an excavator (including the reporting of a damage)
  7. Defines who is an “excavator” or what is considered “excavation.”
  8. Requires the use of white-lining.
  9. Requires a positive response – i.e., utility placing the marks positively responds to the notification center and excavator checks for a positive response before beginning excavation.
  10. Requires that newly installed underground facilities be locatable with commercially available technology.
  11. Requires the marking of sewer lines.
  12. Specifies the qualifications/requirements for those excavators performing trenchless excavation activities that are not subject to pipeline construction requirements under 49 CFR 192/195

In order to reduce excavation damages, AGA and its Excavation Damage Prevention Executive Task Force believes there must be balanced and active enforcement that holds individuals accountable to following federal, state and local ordinances. Therefore, the paper also provides insights on how utilities can work with other stakeholders to get new legislation passed at the state level.

The publication is accessible to the public and can be found at: the information provided in the publication, I would like to offer some additional thoughts on strategies to reduce excavation damages:

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  1. All stakeholders should work together to set aside their own self-interest and find ways to improve the efficacy of the One Call System. This means finding solutions to over-notification where 811 tickets are initiated for work that never materializes or where tickets are initiated for a specified area that is far larger than necessary.
  2. There is an added level of risk that is inherent when excavation is done by horizontal directional drilling (or other forms of trenchless technologies) over open cut. When trenchless technologies are utilized, it is imperative that best practices are followed and that personnel are knowledgeable and qualified to use trenchless technologies as a methodology for installing any underground utility. Many organizations have authored their version of best practices when using trenchless technologies, including AGA.
  3. The severity of damage caused by a 1st or 2nd party can be the same as that caused by a 3rd party excavator. Natural gas pipelines will behave the same way when struck by a shovel, backhoe, bore rod, or probe bar – regardless of the name of the company on the excavator’s truck. Facility owners/operators are encouraged to evaluate tactics that can help prevent damage from all excavators, including 1st and 2nd party.
  4. The Common Ground Alliance continues to be the ideal forum for all stakeholders to share perspectives, exchange ideas and work on solutions. It is important to actively participate in the process that is afforded by CGA.

Andrew Lu is the vice president of operations and engineering for the American Gas Association.

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