indiana utility regulatory commission pipeline safety division investigation... · 2018-08-31 ·...
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Indiana Utility Regulatory Commission
Pipeline Safety Division
Investigation Summary and Options
Regarding MetroNet’s Construction Activities As of September 12, 2017
At the request of the City of Fishers (“Fishers”), the City of Carmel (“Carmel”), and the City of
Westfield (“Westfield”), the Pipeline Safety Division (“PSD” or “Division”) of the Indiana Utility
Regulatory Commission (“IURC” or “Commission”) is providing this investigation summary and a
list of options to improve public safety regarding contractors working on behalf of CMN-RUS,
Inc., d/b/a MetroNet (“MetroNet”). All three communities have placed a halt on MetroNet
contractors excavating in public rights-of-way. The incident in Westfield that just occurred on
Friday, September 8, 2017, is under investigation at this time; therefore, only preliminary
information is being provided now, with a final investigation summary to be provided once that
investigation is completed.
This document contains the following:
A. Investigation Summary
1) Specific Case Information for Fishers
2) Specific Case Information for Carmel
3) Preliminary Information for Westfield
4) Failure to Register with Indiana Secretary of State
5) Additional Information Withheld by MetroNet
6) Safe Digging Best Practices
B. Options for Correction Action Regarding MetroNet’s Construction Activities
C. Attachments
1) Investigation Reports for each case
2) Letter from Chairman Atterholt to Indiana Attorney General regarding failure
to register with Indiana Secretary of State
3) Safe Digging Best Practices
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A. Investigation Summary:
This investigation summary includes a summary of the PSD findings regarding specific cases of
damaged gas lines in Fishers and Carmel and preliminary information regarding the recently
damaged gas line in Westfield, as well as other information discovered by PSD and Commission
staff during the course of the investigation. The Investigation Reports are attached and are in
order by case number.
Of the 20 cases investigated for Fishers and Carmel, the Division found that ten (10) cases were
violations by the excavators (i.e., MetroNet contractors), six (6) cases were violations by the gas
utility (i.e., Indiana Gas Company d/b/a Vectren), and four (4) cases involved no violations.
1) Specific Case Information for Fishers:
Of the 11 incidents of damage to gas lines in Fishers, six (6) were violations by the MetroNet
contractor (for using mechanized equipment within two feet of the marked gas lines and for
failure to plan when using hand tools); four (4) were violations by Indiana Gas Company d/b/a
Vectren, the operator of the gas lines (for failure to properly mark the lines); and one (1) was no
violation (as the excavator was using hand tools and there was no evidence of a failure to plan
the excavation);
Crosier Lane Consulting, Inc.
o Case #16484 – 6/19/2017 – excavator violation (used mechanized equipment
within 2 feet of marked line)
o Case #16524 – 6/20/2017 – excavator violation (used mechanized equipment
within 2 feet of marked line)
International, Inc.
o Case #16746 – 8/15/2017 – excavator violation (failure to plan in use of hand
tools)
o Case #16810 – 8/14/2017 – no violation (appropriate use of hand tools)
o Case #16811 – 8/17/2017 – excavator violation (failure to plan in use of hand
tools)
o Case #16812 – 8/24/2017 – excavator violation (used mechanized equipment
within 2 feet of marked line)
RC Underground, LLC
o Case #16008 – 4/25/2017 – operator violation (failure to properly mark)
o Case #16013 – 4/26/2017 – operator violation (failure to properly mark)
o Case #16521 – 6/29/2017 – operator violation (failure to properly mark)
o Case #16694 – 8/1/2017 – excavator violation (failure to plan in use of hand
tools)
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RLM Underground, LLC
o Case #16813 – 8/24/2017 – operator violation (failure to properly mark)
2) Specific Case Information for Carmel:
Of the nine (9) incidents of damage to gas lines in Carmel, four (4) were violations by the
MetroNet contractor (for using mechanized equipment within two feet of the marked gas lines
and for failure to plan when using hand tools); two (2) were violations by Indiana Gas Company
d/b/a Vectren, the operator of the gas lines (for failure to properly mark the lines); and three
(3) were no violation (as the excavator was using hand tools and there was no evidence of a
failure to plan the excavation);
International, Inc.
o Case #16726 – 8/9/2017 – operator violation (failure to properly mark)
Nexgen Directional, LLC
o Case #16392 – 5/30/2017 – excavator violation (used mechanized equipment
within 2 feet of marked line)
o Case #16480 – 6/16/2017 – no violation (appropriate use of hand tools)
o Case #16660 – 7/21/2017 – no violation (appropriate use of hand tools)
Radical Concepts, LLC (d/b/a Palindrome Construction)
o Case #16635 – 7/18/2017 – excavator violation (failed to call 811 to renew
marks)
o Case #16640 – 7/18/2017 – excavator violation (digging ticket expired)
o Case #16708 – 8/2/2017 – excavator violation (digging in area outside of ticket)
RLM Underground, LLC
o Case #16722 – no violation (appropriate use of hand tools)
o Case #16727 – operator violation (failure to properly mark)
3) Preliminary Information for Westfield:
According to some initial information provided by employees of Citizens Gas of Westfield
(“Citizens”), the information indicates that a gas line was damaged at 121 S. Walnut Street in
Westfield, Indiana, on Friday, September 8, 2017, by International Inc., a subcontractor for
MetroNet. The gas leaking from the damage migrated underground to the sewer system, the
Fire Department responded, homes in the vicinity were evacuated, and electricity was turned
off by Duke Energy Indiana, LLC, until the gas line was repaired.
Citizens promptly reported this incident to the Commission’s Pipeline Safety Division, and PSD
investigators were at the scene of the event immediately after being notified and they are
actively investigating the incident under Case #16872.
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Excavation damages to gas lines that result in the migration of natural gas underground
through sewer systems and into basements is extremely dangerous and often leads to
explosions, with injuries and loss of life.
4) Failure to Register with Indiana Secretary of State:
In order to assure accurate addresses for legal notices, the Commission’s Office of General
Counsel researched each of the contractors under investigation, reviewing information on the
website and on-line services of the Indiana Secretary of State. That review discovered that it
appears all six (6) contractors are out-of-state entities and all but one of the contractors has not
registered with the Indiana Secretary of State as required under Indiana law.
Specifically, it appears that the following MetroNet contractors have not registered as required
by Indiana law:
Crosier Lane Consulting, Inc. (Illinois business)
International, Inc. (Michigan business)
Nexgen Directional, LLC (Illinois business)
R C Underground, LLC (Florida business)
R L M Underground, LLC (Kansas business)
This failure to comply with Indiana law makes the Pipeline Safety Division’s important public
safety function more difficult. As a result, the IURC’s Chairman is referring this information to
the Indiana Office of Attorney General for review and possible fines of up to $10,000 per
company. Please see attached letter.
Note: Radical Concepts, LLC (d/b/a Palindrome Construction) is a New Jersey company and has
registered in Indiana.
5) Additional Information Withheld by MetroNet:
The Division requested that MetroNet provide a list of its contractors excavating in Indiana. To
date, the Division has not requested information on the company hiring an excavating
contractor because the “Call Before You Dig” law only allows enforcement against the person or
entity that caused the excavation damage, not the company who hired them. However, in
order to have a clearer understanding of what was happening with the damage cases involving
MetroNet’s contractors throughout the State of Indiana, the Division believed that having such
information may be helpful in determining trends or patterns of damages, which may then be
corrected. MetroNet’s counsel declined to provide the list, stating that it was “competitively
sensitive information.”
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In addition, economic or contract incentives to quickly complete a project involving excavation
can affect whether the appropriate safe digging practices are being followed. As a result, the
Division requested a copy of a sample contract between MetroNet and its contractors, with any
trade secret information appropriately redacted. Even though the Commission is required to
protect trade secret information under state law, MetroNet’s counsel declined to provide even
a redacted sample contract, stating that it was “competitively sensitive information.”
6) Safe Digging Best Practices:
The Division has attached a list of safe digging best practices from the Common Ground
Alliance, a national pipeline safety organization – see attached document. A complete book of
best practices is available at: http://commongroundalliance.com/best-practices-guide )
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B. Options for Corrective Action Regarding MetroNet’s Construction Activities:
The following are options that each City may want to consider in its determination regarding
the conditions under which MetroNet contractors may be allowed to resume the installation of
fiber optic cable in the City:
1) Documentation that MetroNet’s executive leadership, project managers, and supervisors
have taken training regarding safe digging practices and understand the requirements of
Indiana’s “Call Before You Dig” law (Indiana Code chapter 8-1-26), such as:
a) Attendance (with a passing score) at one of the Underground Plant Protection
Advisory Committee’s (“UPPAC’s”) mandatory training classes (designed for
those previously found in violation of Indiana’s “Call Before You Dig” law);
and/or
b) Completion of the IURC sponsored online excavation damage training at
https://www.safedigindiana.com/.
2) Documentation that all of MetroNet’s contractor crews are trained and qualified
regarding safe digging practices and understand the requirements of Indiana’s “Call
Before You Dig” law (Indiana Code chapter 8-1-26), such as:
a) Attendance (with a passing score) at one of the Underground Plant Protection
Advisory Committee’s (“UPPAC’s”) mandatory training classes (designed for
those previously found in violation of Indiana’s “Call Before You Dig” law);
and/or
b) Completion of the IURC sponsored on-line excavation damage training at
https://www.safedigindiana.com/.
3) Commitment that MetroNet’s contractor crews will follow the CGA Best Practices that
each City requires – see attached list of possible related best practices.
4) Documentation that all of MetroNet’s contractor crews are properly registered (as
needed) to do business in Indiana with 1) Indiana’s Secretary of State’s Office, 2) Hamilton
County, or 3) the Towns of Fishers or Carmel. If such contractor crews are exempt from
registration, MetroNet should provide proof to the City that their contractors are
adequately insured and/or bonded and that accurate contact information (including
mailing addresses and telephone numbers) has been provided to the Cities and the IURC
PSD.
5) A written plan by MetroNet describing how it will demand public safety over speed of
installation of its fiber optic lines by their MetroNet contractor crews, possibly including:
a) Regular reporting of MetroNet contractor crew performance;
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b) Contract incentives and penalties between MetroNet and its contractors
designed to avoid further incidents; and/or
c) MetroNet showing that it vets its contractor crews and they know they are
expected to focus on public safety, not simply footage.
6) A written plan by Indiana Gas Company (dba Vectren Energy Services) (“Vectren”)
describing how it will provide accurate and timely locates of Vectren’s underground
facilities, possibly including:
a) Regular reporting of Vectren’s contract locator performance to each City; and
b) Contract incentives and penalties between Vectren and its contract locators
designed to avoid further mis-locates.
7) Documentation that Vectren’s contract locators are trained and qualified.
8) Commitment that Vectren’s contract locating company, USIC, will assign more senior and
experienced locators to the jobs where MetroNet contractor crews are working.
9) Commitment that MetroNet contractor crews will request additional information from
the underground facility owners that they might need to help them in locating and
avoiding damage to underground facilities.
10) Commitment that MetroNet will have company inspectors on-site to monitor each
contractor crew to ensure safe digging practices are being followed; OR as an alternative,
MetroNet will reimburse the City for the associated costs of having a City inspector on
site.
11) Commitment that MetroNet will ensure its contractor crews are using hydro-excavation
rather than hand tools to expose gas facilities prior to boring or trenching operations.
With hard and dry soil conditions, it is very difficult to use hand tools to expose pipeline
facilities. Hydro-excavation essentially uses a combination of high pressure water and a
vacuum to remove soil, which is the preferred method to expose buried gas lines.
12) Commitment by MetroNet and Vectren to work together, and with other underground
facility owners, to ensure all parties know well in advance of where MetroNet contractor
crews will be working to ensure adequate locating resources are made available. This
should provide the underground facility owners and their contract locators (if applicable)
with sufficient time to adequately plan and staff for the number of notices of excavation
received and allow the coordination of resources accordingly.
13) A written plan by MetroNet to achieve improved proactive communications with all of its
stakeholders, including, but not limited to, the City, the City’s citizens, all underground
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facility owners (and their locators), and MetroNet’s own contract crews. This plan should
focus on improved coordination of efforts and collaboration to prevent and mitigate the
risks associated with any further excavation damages.
14) Commitment by MetroNet and its contractors to participate in the Indiana Damage
Prevention Council for the area(s) in which the City is located and where MetroNet
contractors are excavating. Information for the Indiana Damage Prevention Council
Central Chapter can be found at: https://indiana811.org/idpccc.
Pipeline Safety Division Investigation Report
Investigation regarding: Vectren Energy Delivery
Case Number: 16008
Report Date: 8/11/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 4/25/2017 12:00 AM Damage Address: 116th & Ringer Rd, Fishers
The Parties
Excavator: R C Underground
Address: 6421 Key Island Ave Apollo Beach, FL 33572
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Distribution
Type of Equipment: Boring Type of Work Performed: Cable TV Damage Impact
Product Release: Yes Service Interruption: No -
Repair Cost (if known): Facility Depth (inches): 20.0000 Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Yes Indiana 811 Ticket Number: 1704254341
Excavator Notify Operator: Yes Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: Yes Operator: Yes Findings: Excavator damaged a distribution main with a horizontal boring machine. They had a valid locate request at the time of the incident. The operator failed to mark the line correctly due to locator error.
Violation: IC 8-1-26-18(h) Operator failed to locate or provided incorrect locate markings.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: Vectren Energy Delivery
Case Number: 16013
Report Date: 8/11/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 4/26/2017 12:00 AM Damage Address: 13868 E 116th St, Fishers
The Parties
Excavator: R C Underground
Address: 6421 Key Island Ave Apollo Beach, FL 33572
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Distribution
Type of Equipment: Boring Type of Work Performed: Cable TV Damage Impact
Product Release: Yes Service Interruption: Yes - 1
Repair Cost (if known): Facility Depth (inches): Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Yes Indiana 811 Ticket Number: 1703211350
Excavator Notify Operator: Yes Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: Yes Operator: Yes Findings: Excavator damaged a distribution main with a horizontal boring machine. They had a valid locate request at the time of the incident. The operator failed to correctly mark the facility due to locator error.
Violation: IC 8-1-26-18(h) Operator failed to locate or provided incorrect locate markings.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: Nexgen Directional LLC
Case Number: 16392
Report Date: 8/29/2017 12:00 AM Investigator: Michael Neal
Damage Date: 5/30/2017 12:00 AM Damage Address: 13034 Abraham Run, Carmel
The Parties
Excavator: Nexgen Directional LLC
Address: 1712 S Whittle Ave. Olney, IL 62450
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Distribution
Type of Equipment: Boring Type of Work Performed: Cable TV Damage Impact
Product Release: Yes Service Interruption: Yes -5
Repair Cost (if known): Facility Depth (inches): 36.0000 Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Yes Indiana 811 Ticket Number: 1705182041
Excavator Notify Operator: Yes Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: Operator: Findings: Both the Operator and Excavator responded to a request for more information. The Excavator was boring within the tolerance zone when the gas line was damaged.
Violation: IC 8-1-26-20(a)(2) Failure to maintain two (2) feet clearance with mechanized equipment.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: Nexgen Directional LLC
Case Number: 16480
Report Date: 9/6/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 6/16/2017 12:00 AM Damage Address: 12788 Double Eagle Dr, Carmel
The Parties
Excavator: Nexgen Directional LLC
Address: 1712 S Whittle Ave. Olney, IL 62450
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function:
Type of Equipment: Hand Tools Type of Work Performed: Other Damage Impact
Product Release: Service Interruption: -
Repair Cost (if known): Facility Depth (inches): Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Indiana 811 Ticket Number:
Excavator Notify Operator: Excavator Notify 811: Excavator Notify 911: Severity Circumstances Submitted by Excavator/Operator: Excavator: Operator: Findings: Excavator requested a dig ticket and the operator accurately marked. Excavator used a shovel. Excavator notes that the ground was hard and there were tree roots in the area. However, neither party has pictures of the damaged line. Without that or some additional information, there is insufficient information to make a finding of IC 8-1-26-20(a)(1), failure to plan.
Violation: Insufficient evidence to find violation.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: Crosier Lane Consulting, Inc.
Case Number: 16484
Report Date: 8/31/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 6/19/2017 12:00 AM Damage Address: 9645 Claymore Dr, Fishers
The Parties
Excavator: Crosier Lane Consulting, Inc.
Address: 5325 N Lakewood Road Olney, IL 62450
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Service/Drop
Type of Equipment: Boring Type of Work Performed: Cable TV Damage Impact
Product Release: Yes Service Interruption: Yes -1
Repair Cost (if known): $560.78 Facility Depth (inches): 28.0000 Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Yes Indiana 811 Ticket Number: 1706070932
Excavator Notify Operator: Yes Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: Yes Findings: Excavator damaged an accurately marked service line with a horizontal boring machine. They had a valid request at the time of the incident, but failed to expose the line in the area of the excavation and therefore were using mechanized equipment inside the 2-foot tolerance zone.
Violation: IC 8-1-26-20(a)(2) Failure to maintain two (2) feet clearance with mechanized equipment.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: Vectren Energy Delivery
Case Number: 16521
Report Date: 8/31/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 6/29/2017 12:00 AM Damage Address: 9251 Crossing, Fishers
The Parties
Excavator: R C Underground
Address: 6421 Key Island Ave Apollo Beach, FL 33572
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Service/Drop
Type of Equipment: Boring Type of Work Performed: Cable TV Damage Impact
Product Release: Yes Service Interruption: Yes - 1
Repair Cost (if known): Facility Depth (inches): 36.0000 Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Yes Indiana 811 Ticket Number: 1706161192
Excavator Notify Operator: No Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: No Findings: Excavator damaged a service line with horizontal boring machine. They had a valid locate request at the time of the incident. The operator failed to mark the line due to locator error.
Violation: IC 8-1-26-18(h) Operator failed to locate or provided incorrect locate markings.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: Crosier Lane Consulting, Inc.
Case Number: 16524
Report Date: 8/31/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 6/30/2017 12:00 AM Damage Address: 12630 Longleaf Ln, Fishers
The Parties
Excavator: Crosier Lane Consulting, Inc.
Address: 5325 N Lakewood Road Olney, IL 62450
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Service/Drop
Type of Equipment: Boring Type of Work Performed: Cable TV Damage Impact
Product Release: Yes Service Interruption: Yes -1
Repair Cost (if known): $1,502.36 Facility Depth (inches): 21.0000 Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Yes Indiana 811 Ticket Number: 1706071418
Excavator Notify Operator: Yes Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: Yes Findings: Excavator damaged an accurately located service line with a horizontal boring machine. The excavator had a valid locate request at the time of the incident. The excavator made a pot hole and exposed a portion of the line. However, the diameter of the hole was not large enough, so when the bore came through, there was not sufficient time to stop the boring machine before it damaged the line.
Violation: IC 8-1-26-20(a)(2) Failure to maintain two (2) feet clearance with mechanized equipment.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: Radical Concepts d/b/a Palindrome Construction
Case Number: 16635
Report Date: 9/11/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 7/18/2017 12:00 AM Damage Address: 13580 Brentwood Ln, Carmel
The Parties
Excavator: Radical Concepts d/b/a Palindrome Construction
Address: 6623 W 13th St Indianapolis, IN 46214
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Service/Drop
Type of Equipment: Boring Type of Work Performed: Cable TV Damage Impact
Product Release: Yes Service Interruption: Yes -1
Repair Cost (if known): Facility Depth (inches): 30.0000 Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Yes Indiana 811 Ticket Number: 1707064305
Excavator Notify Operator: Yes Excavator Notify 811: Excavator Notify 911: Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: Yes Findings: Only the Operator responded to the request for information. Excavator damaged a service line with a horizontal boring machine. Operator properly marked the area to be excavated. The homeowner removed the flags and excavator dug without calling 811 to renew the marks. The damaged line was on the property line between 13580 and 13596. It was damaged closer to 13580 but was the line for 13596.
Violation: IC 8-1-26-20(a)(3)(b) Failure to notify IN811 when locate markings have become illegible
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: Radical Concepts d/b/a Palindrome Construction
Case Number: 16640
Report Date: 9/11/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 7/18/2017 12:00 AM Damage Address: 1204 Smokey Row Ln, Carmel
The Parties
Excavator: Radical Concepts d/b/a Palindrome Construction
Address: 6623 W 13th St Indianapolis, IN 46214
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Distribution
Type of Equipment: Boring Type of Work Performed: Cable TV Damage Impact
Product Release: Yes Service Interruption: Yes -5
Repair Cost (if known): Facility Depth (inches): 30.0000 Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Yes Indiana 811 Ticket Number: 1706273510
Excavator Notify Operator: Yes Excavator Notify 811: Excavator Notify 911: Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: Yes Findings: Only the Operator responded to the request for information. Excavator damaged a distribution main with a horizontal boring machine. They allowed their prior ticket to expire and were therefore digging without a valid request.
Violation: IC 8-1-26-16(h)(expire) Failure to provide notice of excavation - expired ticket.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: Nexgen Directional LLC
Case Number: 16660
Report Date: 9/1/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 7/21/2017 12:00 AM Damage Address: 14370 Jeremy Dr, Carmel
The Parties
Excavator: Nexgen Directional LLC
Address: 1712 S Whittle Ave. Olney, IL 62450
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Service/Drop
Type of Equipment: Hand Tools Type of Work Performed: Cable TV Damage Impact
Product Release: Service Interruption: -
Repair Cost (if known): Facility Depth (inches): Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Indiana 811 Ticket Number:
Excavator Notify Operator: Excavator Notify 811: Excavator Notify 911: Severity Circumstances Submitted by Excavator/Operator: Excavator: Operator: Findings: Excavator requested a dig ticket and the operator accurately marked. Excavator used a shovel. No additional information was provided by either party that would indicate a violation of IC 8-1-26-20(a)(1).
Violation: Insufficient evidence to find violation.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: R C Underground
Case Number: 16694
Report Date: 9/5/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 8/1/2017 12:00 AM Damage Address: 9660 Overcrest Dr, Fishers
The Parties
Excavator: R C Underground
Address: 6421 Key Island Ave Apollo Beach, FL 33572
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Service/Drop
Type of Equipment: Probing Type of Work Performed: Cable TV Damage Impact
Product Release: Yes Service Interruption: Yes -1
Repair Cost (if known): Facility Depth (inches): 25.0000 Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Yes Indiana 811 Ticket Number: 1707263022
Excavator Notify Operator: Yes Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: Yes Operator: Yes Findings: Excavator damaged an accurately marked service line with a probe rod. They were attempting to expose the line by potholing with hydro excavation, but used the probe rod when the line was not visible. The line does not appear to be brittle or otherwise have a loss of integrity. Therefore, the excavator would have used the probe rod with force to drive it into the line. Using a probe rod in this manner fails to avoid damage.
Violation: IC 8-1-26-20(a)(1) Failure to plan excavation to avoid damage or interference with underground facilities.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: Radical Concepts d/b/a Palindrome Construction
Case Number: 16708
Report Date: 9/11/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 8/2/2017 12:00 AM Damage Address: 490 Tulip Poplar Crest, Carmel
The Parties
Excavator: Radical Concepts d/b/a Palindrome Construction
Address: 6623 W 13th St Indianapolis, IN 46214
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Service/Drop
Type of Equipment: Hand Tools Type of Work Performed: Other Damage Impact
Product Release: No Service Interruption: Yes -1
Repair Cost (if known): Facility Depth (inches): 21.0000 Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Yes Indiana 811 Ticket Number: 1707183912
Excavator Notify Operator: Yes Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: Yes Findings: Only the Operator responded to the request for information. Excavator damaged a service line with a shovel while attempting to expose the line. The area of the damage was outside the requested scope of their ticket, therefore they were digging without a valid request in the area of the incident.
Violation: IC 8-1-26-16(h)(out) Failure to provide notice of excavation - damage occurred outside requested locate area.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: R L M Underground
Case Number: 16722
Report Date: 9/8/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 8/8/2017 12:00 AM Damage Address: 513 Chauncy Dr, Carmel
The Parties
Excavator: R L M Underground
Address: 4902 W 57th Street Roeland Park, KS 66205
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function:
Type of Equipment: Hand Tools Type of Work Performed: Cable TV Damage Impact
Product Release: Service Interruption: -
Repair Cost (if known): Facility Depth (inches): Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Indiana 811 Ticket Number:
Excavator Notify Operator: Excavator Notify 811: Excavator Notify 911: Severity Circumstances Submitted by Excavator/Operator: Excavator: Yes Operator: Yes Findings: Excavator requested a dig ticket and the operator accurately marked. Excavator used a shovel. No additional information was provided by either party that would indicate a violation of IC 8-1-26-20(a)(1).
Violation: Insufficient evidence to find violation.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: Vectren Energy Delivery
Case Number: 16726
Report Date: 9/1/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 8/9/2017 12:00 AM Damage Address: 3965 Chadwick, Carmel
The Parties
Excavator: International, Inc.
Address: 9971 Woodbend Dr. Saline, MI 48176
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Service/Drop
Type of Equipment: Boring Type of Work Performed: Cable TV Damage Impact
Product Release: Yes Service Interruption: Yes - 1
Repair Cost (if known): Facility Depth (inches): 24.0000 Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Yes Indiana 811 Ticket Number: 1707204420
Excavator Notify Operator: No Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: No Findings: Excavator damaged a service line with a horizontal boring machine. They had a valid request at the time of the incident. The operator failed to mark the line due to locator error.
Violation: IC 8-1-26-18(h) Operator failed to locate or provided incorrect locate markings.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: Vectren Energy Delivery
Case Number: 16727
Report Date: 9/1/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 8/9/2017 12:00 AM Damage Address: 515 Chauncy Street, Carmel
The Parties
Excavator: R L M Underground
Address: 4902 W 57th Street Roeland Park, KS 66205
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Service/Drop
Type of Equipment: Boring Type of Work Performed: Cable TV Damage Impact
Product Release: Yes Service Interruption: Yes - 1
Repair Cost (if known): Facility Depth (inches): 28.0000 Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Yes Indiana 811 Ticket Number: 1707313932
Excavator Notify Operator: No Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: No Findings: Excavator damaged a service line with a horizontal boring machine. They had a valid locate request at the time of the incident. The operator failed to mark the line due to operator's incorrect maps/records.
Violation: IC 8-1-26-18(h) Operator failed to locate or provided incorrect locate markings.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: International, Inc.
Case Number: 16746
Report Date: 9/1/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 8/15/2017 12:00 AM Damage Address: 10328 Woods Edge Dr, Fishers
The Parties
Excavator: International, Inc.
Address: 9971 Woodbend Dr. Saline, MI 48176
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Service/Drop
Type of Equipment: Hand Tools Type of Work Performed: Cable TV Damage Impact
Product Release: Yes Service Interruption: Yes -1
Repair Cost (if known): Facility Depth (inches): 30.0000 Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Yes Indiana 811 Ticket Number: 1708090723
Excavator Notify Operator: Yes Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: Yes Operator: Yes Findings: Excavator damaged an accurately marked 1-inch service line with a shovel. Rather than using the shovel in a standard fashion, the excavator used the shovel to drive through the ground, puncturing the line. Excavator failed to take care and precaution to avoid damage.
Violation: IC 8-1-26-20(a)(1) Failure to plan excavation to avoid damage or interference with underground facilities.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: International Inc.
Case Number: 16810
Report Date: 9/1/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 8/14/2017 12:00 AM Damage Address: 10430 Woodsedge Drive, Fishers
The Parties
Excavator: International Inc.
Address: 5395 Cogswell St Wayne, MI 48184
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function:
Type of Equipment: Hand Tools Type of Work Performed: Cable TV Damage Impact
Product Release: Service Interruption: -
Repair Cost (if known): Facility Depth (inches): Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Indiana 811 Ticket Number:
Excavator Notify Operator: Excavator Notify 811: Excavator Notify 911: Severity Circumstances Submitted by Excavator/Operator: Excavator: Operator: Findings: Excavator requested a dig ticket and the operator accurately marked. Excavator used a shovel. Excavator notes that the ground was hard and there were tree roots in the area. However, neither party has pictures of the damaged line. Without that or some additional information, there is insufficient information to make a finding of IC 8-1-26-20(a)(1), failure to plan.
Violation: Insufficient evidence to find violation.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: International Inc.
Case Number: 16811
Report Date: 9/1/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 8/17/2017 12:00 AM Damage Address: 10168 Parkway Drive, Fishers
The Parties
Excavator: International Inc.
Address: 5395 Cogswell St Wayne, MI 48184
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function:
Type of Equipment: Hand Tools Type of Work Performed: Cable TV Damage Impact
Product Release: Service Interruption: -
Repair Cost (if known): Facility Depth (inches): Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Indiana 811 Ticket Number:
Excavator Notify Operator: Excavator Notify 811: Excavator Notify 911: Severity Circumstances Submitted by Excavator/Operator: Excavator: Operator: Findings: Excavator damaged an accurately marked 1-inch service line with a shovel. Rather than using the shovel in a standard fashion, the excavator used the shovel to drive through the ground, puncturing the line. Excavator failed to take care and precaution to avoid damage.
Violation: IC 8-1-26-20(a)(1) Failure to plan excavation to avoid damage or interference with underground facilities.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: International Inc.
Case Number: 16812
Report Date: 9/5/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 8/24/2017 12:00 AM Damage Address: 10260 Night Hawk Dr, Fishers
The Parties
Excavator: International Inc.
Address: 5395 Cogswell St Wayne, MI 48184
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Distribution
Type of Equipment: Boring Type of Work Performed: Cable TV Damage Impact
Product Release: Yes Service Interruption: Yes -3
Repair Cost (if known): Facility Depth (inches): 32.0000 Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Yes Indiana 811 Ticket Number: 1708092473
Excavator Notify Operator: Yes Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: Yes Operator: Yes Findings: Excavator damaged a distribution main with a horizontal boring machine. They had a valid request at the time of the incident. They damaged the line attempting a second pass with the bore head underneath the exposed facility.
Violation: IC 8-1-26-20(a)(2) Failure to maintain two (2) feet clearance with mechanized equipment.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Pipeline Safety Division Investigation Report
Investigation regarding: Vectren Energy Delivery
Case Number: 16813
Report Date: 9/1/2017 12:00 AM Investigator: Aaron Holeman
Damage Date: 8/24/2017 12:00 AM Damage Address: 10235 Bent Creek Ct, Fishers
The Parties
Excavator: R L M Underground
Address: 4902 W 57th Street Roeland Park, KS 66205
Facility Owner: Vectren Energy Delivery
Pipeline Facility
Facility Type: Natural Gas Facility Function: Service/Drop
Type of Equipment: Boring Type of Work Performed: Cable TV Damage Impact
Product Release: Yes Service Interruption: No -
Repair Cost (if known): Facility Depth (inches): 36.0000 Excavator Activities/Cause of Damage Information:
Excavator Request Locates: Yes Indiana 811 Ticket Number: 1708093627
Excavator Notify Operator: Excavator Notify 811: Excavator Notify 911: Yes Severity Circumstances Submitted by Excavator/Operator: Excavator: No Operator: No Findings: Excavator damaged a service line with a horizontal boring machine. They had a valid locate request at the time of the incident. The operator failed to mark the line due to incorrect maps/records.
Violation: IC 8-1-26-18(h) Operator failed to locate or provided incorrect locate markings.
STATE oy INDIANA
INDIANA UTILITY REGULATORY COMMISSION
101 WEST WASHINGTON STREET, SUITE 1500 EAST
INDIANAPOLIS, INDIANA 46204‐3419
www.in.gov/iurc
Office: (317) 232‐2701
Facsimile: (317) 232‐6758
Page 1 of 4
Common Ground Alliance Best Practice Recommendations
5.10 Locate Verification
Practice Statement: Prior to excavation, excavators verify that they are at the correct location, verify locate markings and, to the best of their ability, check for unmarked facilities. Practice Description: Upon arrival at the excavation site and prior to beginning the excavation, an excavator does the following:
Verifies that the dig site matches the one call request and is timely Verifies that all facilities have been marked and reviews color codes if in doubt Verifies all service feeds from buildings and homes Checks for any visible signs of underground facilities, such as pedestals, risers, meters, and
new trench lines Checks for any facilities that are not members of the one call center and contact someone to
get them located. Use of a pre-excavation checklist is recommended by insurers and practiced by responsible excavating contractors.
5.12 Work Site Review with Company Personnel
Practice Statement: Prior to starting work, the excavator reviews the location of underground facilities with site personnel. Practice Description: Sharing information and safety issues during an on-site meeting between the excavator and the excavating crews helps avoid confusion and needless damage to underground facilities.
5.13 One Call Reference at Site
Practice Statement: Except in case of an emergency, the excavator at each job site has available a complete description of the dig site, a list of the facility owner members impacted at that dig site as identified by the one call center, and the one call center ticket number. Practice Description: The availability of locate request details on site is useful because excavators can easily access information about the location and extent of work, the valid start time, and the list of operators notified. The documentation also provides an excavator with appropriate information for daily tailgate meetings for crews; provides quick references for
Page 2 of 4
excavation equipment operators; and facilitates communications between the excavator and the one call center with respect to that particular locate request, should it become necessary. When multiple crews are working on the same project at separate locations or when different employers have crews working at the same location, each crew has the information.
5.15 Facility Avoidance
Practice Statement: The excavator uses reasonable care to avoid damaging underground facilities. The excavator plans the excavation so as to avoid damage or to minimize interference with the underground facilities in or near the work area. Practice Description: Foremost on any construction project is safety. Excavators using caution around underground facilities significantly contribute to safe excavation of existing facilities.
5.17 Marking Preservation
Practice Statement: The excavator protects and preserves the staking, marking, or other designation of underground facilities until no longer required for proper and safe excavation. The excavator stops excavating and notifies the one call center for re-marks if any facility mark is removed or is no longer visible. Practice Description: During long, complex projects, the marks for underground facilities may need to be in place far longer than the locating method is durable. Painting, staking, and other marking techniques last only as long as the weather and other variables allow. When a mark is no longer visible, but work continues around the facility, the excavator requests a re-mark to ensure the protection of the facility.
5.18 Excavation Observer Practice Statement: The excavator has an observer to assist the equipment operator when operating excavation equipment around known underground facilities. Practice Description: The excavator designates a worker (an observer) who watches the excavation activity and warns the equipment operator while excavating around a utility to prevent damaging that buried facility.
Page 3 of 4
5.20 Excavation within Tolerance Zone
Practice Statement: When excavation is to take place within the specified tolerance zone, the excavator exercises such reasonable care as may be necessary for the protection of any underground facility in or near the excavation area. Methods to consider, based on certain climate or geographical conditions, include hand digging when practical (pot holing), soft digging, vacuum excavation methods, pneumatic hand tools, other mechanical methods with the approval of the facility owner/operator, or other technical methods that may be developed. Hand digging and non-invasive methods are not required for pavement removal. Practice Description: Safe, prudent, non-invasive methods that require the excavator to manually determine the actual location of a facility are considered “safe excavation practices” in a majority of state/provincial laws (38 states). A majority of states outline safe excavation practices to include hand digging or pot holing (16 states). Some states specifically allow for the use of power excavating equipment for the removal of pavement. Each state/province must take differing geologic conditions and weather related factors into consideration when recommending types of excavation within the tolerance zone.
5.29 Trenchless Excavation
Practice Statement: All stakeholders comply with all best practices and the following general guidelines prior to, during, and after any trenchless excavation (as applicable). Practice Description:
The excavator requests the location of underground facilities at the entrance pit, trenchless excavation path, and the exit pit by notifying the facility owner/operator through the one call center.
The trenchless equipment operator performs a site inspection, walking the trenchless excavation path prior to commencing work, and has a good understanding of the job.
The trenchless excavation operator confirms and maintains the path and minimum clearances established by the project owner and design engineer by tracking and recording the path of the trenchless excavation until complete. Means of tracking trenchless excavations include electronic locating/guidance devices, pipe lasers, water levels, visual inspection, etc.
When existing facilities are known to be present but cannot be potholed as a result of local conditions, the facility owner and the excavator meet to discuss how to safely proceed with the excavation.
The excavator stops the trenchless excavation operations if an abnormal condition, unknown substructure, or other hidden hazard is encountered. The excavator proceeds safely only
Page 4 of 4
after making positive identification. (Refer to Practice Statements 2–13 and 4–19 for additional information.)
5.32 Vacuum Excavation
Practice Statement: Vacuum excavation, when used appropriately, is an efficient, safe, and effective alternative to hand digging within the designated underground facility tolerance zone. Use of equipment also follows state/provincial laws and/or local ordinances. Practice Description: The safe exposure of underground facilities within the tolerance zone is essential to damage prevention. Site conditions may make the use of hand tools to expose underground facilities difficult or even impractical. Vacuum excavation is often an appropriate alternative. Locates must be obtained prior to the commencement of work (see Practice Statement 5–1). Many underground facility owners/operators have specific criteria for safe excavation/exposure practices around their facilities. Some underground facility owners/operators accept vacuum excavation as equivalent to hand excavation for exposing their facilities, and others have restrictions on its use. Vacuum excavation is an appropriate method of excavating safely around underground facilities provided that the equipment: has been specifically designed and built for this purpose; is operated by a worker trained and experienced in its operation; is operated in accordance with practices that provide appropriate levels of worker and public
safety and prevent damage to buried facilities; and is used in compliance with state/provincial laws and/or local ordinances
5.33 Facility Owner Provides a Monitor During Excavation
Practice Statement: If a facility owner/operator considers it necessary to be on site during excavation activities to work with the excavator in protecting their existing facilities, the facility owner/operator makes arrangements with the excavator to be present during those excavation activities within the time specified by state/provincial law. Practice Description: The facility owner/operator may determine it necessary to be on site during excavation activities taking place near their facilities to help protect them. A facility owner/operator has access to information and resources that may not be available to the excavator. This practice should be considered in conjunction with Practice Statement 2–4: Utility Coordination.