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January 12, 2005

The Operator Qualification (OQ) rule has greatly impacted pipeline operations for all major pipeline system operators. For Panhandle Energy, the efforts to satisfy all segments of the rule have required a significant investment in money and manpower, with many changes to most aspects of field operations. Several key efforts are worthy of further explanation concerning the company’s approach to the rule. The first effort by the company dealt with writing a general OQ compliance procedure that outlined how the company would comply with all aspects of the OQ rule. Next was the task of establishing Panhandle’s interpretation of a “Covered Task List,” which is guided in the rule by the four part criteria listed in Subpart N 192.801 (b) (1), (2), (3) and (4). Since the rule also applies to contractors performing OQ tasks on the system, we determined that it would be best to use an “Industry Standard” task list numbering system (developed by Veriforce, an OQ contractor qualification firm, and multiple pipeline operating groups) to reduce confusion in the task identification for the field

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