{"operation":"document","citation":"PI-22-0004","title":"On behalf of Philadelphia Gas Works Regulatory — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2022-05-12","effective_on":null,"summary":"PI-22-0004 response to On behalf of Philadelphia Gas Works Regulatory concerning 199.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-22-0004.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-22-0004.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-22-0004","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/76471/philadelphia-gas-works-pi-22-0004-5-12-2022-part1991.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMay 12, 2022\nJoel L. Greene\nAndrea I. Sarmentero Garzón\nJennings, Strouss & Salmon, PLC\n1300 I Street, Suite 1120\nWashington, D.C. 20005-3314\nDear Mr. Greene & Ms. Sarmentero Garzón:\nIn your February 1, 2022, letter to the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) you requested on behalf of Philadelphia Gas Works (PGW) an interpretation of the\nFederal pipeline safety regulations in 49 CFR Part 199 with respect to whether employees in the\nPlanning Utility Drafter I (PUD I) position at PGW are subject to PHMSA/DOT drug and\nalcohol (D&A) testing.\nPHMSA promulgated the first drug testing regulations in 1988 wherein PHMSA required\npipeline operators to have an “anti-drug program for employees who perform certain sensitive\nsafety-related functions covered by the pipeline safety regulations.”1 While the original drug\ntesting rule did not define covered employee or covered function, it was explained in the\npreamble that the drug testing regulations were limited to “those who perform regulated\noperation, maintenance, or emergency-response functions…on existing pipelines.” 2\nIn other words, from the onset of the drug testing regulations in 1988, PHMSA has specified that\nthe functions performed by employees subject to the regulations are operations, maintenance,\nand emergency-response functions subject to Parts 192, 193, and 195 that are performed on a\npipeline. Moreover, from the onset PHMSA specifically excluded the design function from\nDOT drug testing 3 and drafters are generally involved in design.\nWe reviewed the PUD I position description you submitted and did not identify any functions\nsubjecting a PGW PUD I to PHMSA/DOT D&A testing. While the position does perform some\nmaintenance functions, the functions described are not performed on the pipeline, which is the\ndiscriminator between maintenance functions that are D&A covered and maintenance functions\n1 53 FR 47084.\n2 53 FR 47089.\n3 53 FR 47088\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or\nobligations, and are provided to help the specific requestor understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\nthat are not D&A covered. Additionally, while the PUD I position description mentions\n“potential emergency situations,” it does not list any specific emergency-response functions\nregulated by Part 192 that are performed on a pipeline. As with operations and maintenance,\nonly those emergency-response functions performed on the pipeline are D&A covered functions,\nregardless of whether the functions are listed in § 192.615.\nWe noted, however, that you added comments regarding PGW’s Winter Emergency Plan in your\nletter explaining that the PUD I position is a source of personnel for the plan, but the duties\nstated in that plan are not included in the PUD I position description PGW provided.\nNonetheless, you explain that with regards to the Winter Emergency Plan,\n“PHMSA has clarified that persons who do a covered function even if infrequently or\nwho have a potential to do a covered function are subject to Part 199 drug testing.”\nTo support that statement, you referenced a guidance document published by PHMSA’s\npredecessor agency the Research and Special Programs Administration (RSPA) in March 1994.\nWe must point out that the definition of “covered function” did not appear in the drug testing\nsubpart of Part 199 until March 1998, four years after the guidance document you referenced.\n4\nFurthermore, the current definition of “covered function” and the only definition of “performs a\ncovered function” did not appear in Part 199 until Amendment 199-19 (effective September 11,\n2001)5, which was seven years after the RSPA guidance document. That RSPA guidance is no\nlonger available on PHMSA’s D&A website or through any other PHMSA source.\nTo clarify, Part 199 defines “performs a covered function” to include actually performing, ready\nto perform, or immediately available to perform a covered function. While PHMSA has not\npublished guidance on the meaning of “ready to perform, or immediately available to perform”\nthese terms are included in the definition to dispel the notion that an employee has to be actually\nperforming a covered function to be a covered employee. For example, some operators believed\nthat a welder on a coffee break or off-duty was not a covered employee because he/she was not\nactually welding at those times. The definitions of “performs a covered function” in § 199.3\nclarifies that the welder need not necessarily be welding at all times to be a covered employee.\nIn summation, our review of the PUD I position description provided by PGW did not identify\nthe specific responsibilities necessary for this position to be subject to D&A testing under the\nPHMSA regulations in Part 199.\n4 63 FR 12998-13001\n5 66 FR 47114 - 47119\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or\nobligations, and are provided to help the specific requestor understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\nNotwithstanding the above, nothing in Part 199 prohibits an employer from D&A testing any of\nits employees using non-DOT procedures, including those employees already subject to D&A\ntesting under PHMSA regulations.\nIf we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\nJohn A. Gale\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or\nobligations, and are provided to help the specific requestor understand how to comply with the regulations.\n\n<<<PAGE 4>>>\n\nJoel L. Greene\nAndrea I. Sarmentero Garzón\nMembers, Energy\nP 202.371.9889 | F 202.292.4740\njgreene@jsslaw.com\nasarmentero@jsslaw.com\nJennings, Strouss & Salmon, P.L.C.\n1300 I Street, NW - Suite 1120\nWashington, D.C. 20005-3314\njsslaw.com\nFebruary 1, 2022\nJohn A. Gale\nDirector, Office of Standards and Rulemaking\nOffice of Pipeline Safety (PHP-30)\nPipeline and Hazardous Materials Safety Administration (PHMSA)\nUS Department of Transportation\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\nAttn: Interpretations\nRe: Request for Official Interpretation\nDear Mr. Gale:\nWe are writing on behalf of Philadelphia Gas Works (“PGW”) to request an official interpretation,\npursuant to 49 C.F.R. § 190.11, of the federal pipeline safety regulations in 49 CFR Part 199 with\nrespect to whether employees in the Planning Utility Drafter I position at PGW are subject to drug\nand alcohol (“D&A”) testing.\nI.\nBackground\nPGW is a natural gas local distribution company (“LDC”) in the city of Philadelphia serving over\n500,000 customers. It is also the operator of two (2) LNG facilities within Philadelphia. As an\noperator of pipeline facilities subject to parts 192, 193 and 195 of Title 49, it tests covered\nemployees pursuant to the requirements of 49 C.F.R §199.1.\nPHMSA’s D&A testing regulations, as codified in 49 C.F.R §199.1, provide in part:\n§ 199.1 Scope.\nThis part requires operators of pipeline facilities subject to part 192, 193, or 195 of this chapter to\ntest covered employees for the presence of prohibited drugs and alcohol.\nFurther, § 199.3 specifies the meaning of “covered employee” and “covered function.”\n§ 199.3 Definitions.\nAs used in this part –\nProgressive culture. Innovative vision.\n\n<<<PAGE 5>>>\n\nFebruary 1, 2022\nPage 2\n***\nCovered employee, employee, or individual to be tested means a person who performs a covered\nfunction, including persons employed by operators, contractors engaged by operators, and persons\nemployed by such contractors.\nCovered function means any operations, maintenance, or emergency-response function regulated\nby part 192, 193, or 195 of this chapter that is performed on a pipeline or on an LNG facility.\n***\nPerforms a covered function includes actually performing, ready to perform, or immediately\navailable to perform a covered function.\nThis request for interpretation asks whether the employee position of Planning Utility Drafter I\n(“PUD I”) at PGW is subject to coverage under Part 199. As demonstrated below, PGW believes\nthat the requirements of the PUD I position satisfy the operations, maintenance, or emergency-\nresponse criteria for a “covered function” under §199.\nII.\nJob Title and Description of Duties – Planning Utility Drafter I\nThe PUD I is a senior level position in the Distribution Planning section of PGW that requires\nskills to cover field drafting, estimating projects and senior drafting.1 The PUD I is responsible for\nplanning main extensions into new areas and new home developments, and the position may\ninvolve daily site visits to various locations in all weather and potential emergency situations on a\n24 hour, 7 day a week time frame depending upon the schedules of the field crews being covered.\nThis position involves field coverage where mains are being installed by construction crews, and\nthe PUD I makes pencil/future technology based field sketches showing make-up of mains in detail\nfor the purpose of updating all of the PGW detailed and general main pipeline maps. The PUD I’s\nfield sketch is the sole-source document, and the PUD I creates many of PGW’s operational\nrecords (e.g., drip cards, valve cards, test station cards) and is responsible for maintaining these\nfiles. The PUD I is responsible for creating PA One Call records of PGW’s pipelines associated\nwith construction projects. The PUD I can also act as backup to the Sr. Estimator and is required\nto perform the duties of a PUD II and PUD III as needed.\nAdditionally, the PUD I performs other related duties as assigned. Most importantly, this includes\nthe PUD I’s performance of emergency response functions on PGW’s pipelines pursuant to PGW’s\nWinter Emergency Plan, discussed herein below.\n1 A complete copy of this job description (updated 10/2016 and including all essential functions), is attached hereto\nas Appendix A.\n\n<<<PAGE 6>>>\n\nFebruary 1, 2022\nPage 3\nIII.\nRequest for Interpretation\nSince the inception of mandatory drug testing in 1990, PGW, guided directly by the Office of\nPipeline Safety at the time, has determined that its PUD I position2 should be considered a safety\nsensitive position and covered under PGW’s drug testing program in accordance with the\nrequirements of 49 C.F.R. Part 199.\nThis designation is based, in part, on PGW’s determination, reinforced by a discussion with Mr.\nCesar DeLeon, then Assistant Director for Regulation, Office of Pipeline Safety in March, 1990,\nthat because employees in this position develop the original field drawing which is used to\nperpetuate the gas distribution mapping system, such draftsmen perform a covered operational\nfunction and are subject to PHMSA drug testing. The PUD I creates many of PGW’s operational\nrecords, including the field sketch, which is the sole-source document used for PGW’s general and\nmain maps. The PUD I also performs a maintenance function because he/she is responsible for\nmaintaining and updating, among other things, the critical infrastructure and pipeline maps in\nPGW databases, including but not limited to pipeline running through PGW’s LNG facilities.\nAccurate design and pipeline map maintenance is crucial in order to avoid issues such as over-\npressurization, which can lead to fatalities (e.g., the incident in Merrimack Valley).3 Furthermore,\nthe PUD I performs a covered maintenance function through the creation of PA One Call4 records\nof PGW’s pipelines, the accuracy of which is important in order to avoid damage to PGW’s active\npipelines during construction.\nPerhaps more critically, the PUD I position is a source of personnel in PGW’s Winter Emergency\nPlan, which is an emergency plan prepared in accordance with 49 C.F.R. § 192.615. The\nemployees holding the position of PUD I have risen through the craft and service ranks and are\nutilized to perform emergency-response functions on PGW’s pipelines and LNG facilities. During\nvarious phases of PGW’s Winter Emergency Plan, a PUD I may be assigned to a crew in the\nDistribution Department where the PUD I would be called upon to perform pipeline maintenance\nfunctions such as, inter alia, addressing gas/fire emergencies, winter leak survey patrol, performing\nnew leak investigations, addressing underground street issues, performing service restorations, and\nresponding to repair orders. Additionally, a PUD I may be assigned to the Field Services\n2 The PUD I position at PGW was formally known as the Senior Draftsman position at PGW.\n3 It is PGW’s understanding that on September 13, 2018, excessive pressure in natural gas lines owned by Columbia\nGas of Massachusetts caused a series of explosions and fires to occur in as many as 40 homes, with over 80 individual\nfires, in the towns of Lawrence, Andover, and North Andover, all within the Merrimack Valley, in Massachusetts.\nOne person was killed and 30,000 were forced to evacuate their homes immediately. It is PGW’s understanding that\nthe National Transportation Safety Board ultimately determined that the probable cause of the incident was weak\nengineering management that did not adequately plan, review, sequence, and oversee the construction project that led\nto the abandonment of a cast iron main without first relocating regulator sensing lines to the new polyethylene main.\n4 Pennsylvania One Call System is a non-profit corporation created to protect underground facilities before anyone\nbegins to disturb the earth. PA One Call receives requests from excavators, contractors, plumbers, builders, designers,\nand the general public to find out where underground lines are located. Pennsylvania One Call notifies member\nunderground facility owners of the intent to excavate. The facility owner then marks where their lines are located. Act\n50 of 2017 authorizes the Pennsylvania Public Utility Commission to enforce provisions of the state’s Underground\nUtility Line Protection Law, Act 287, also known as the “One Call Law.”\n\n<<<PAGE 7>>>\n\nFebruary 1, 2022\nPage 4\nDepartment where the PUD I may be called upon to conduct street leak relief, which includes\nusing a combustible gas instrument to constantly monitor gas readings on active pipelines and\nreport any change to the leak readings to Field Operations for disposition and/or reclassification.\nPHMSA has clarified that persons who do a covered function even if infrequently or who have a\npotential to do a covered function are subject to Part 199 drug testing.5 Similarly, it is PGW’s\nunderstanding that persons whose positions require them to potentially perform a covered function,\nare subject to drug testing, even if the individual employee has not yet done a covered function.\nIndeed, PHMSA has clarified that:\nIf an operator determines that an employee, who performs design or construction\nfunctions, has other responsibilities which clearly relate to covered functions under\nPart 192, 193, or 195, then that employee may be subject to drug testing. The\ncovered functions (operation, maintenance, or emergency-response) must take\nplace on the pipeline or at any LNG facility and the functions must be performed\nby that individual in order to subject them to testing under Part 199.6\nThe example given by PHMSA is of a person an operator employs in a position responsible for an\nemergency-response function who may not have to do the function until sometime in the future;\nthat person is nevertheless subject to each type of drug testing to assure that prohibited drugs do\nnot impair the person’s capacity to do the function should an emergency occur.7 Because of their\ncritical role that may affect the safety of the public or pipeline personnel, PGW determined, after\na careful review of 49 C.F.R Part 192, that the PUD I position is covered. See, 49 C.F.R. §192.615\n(b).\nBased on these facts, PGW respectfully requests that PHMSA provide an official interpretation of\nits D&A testing regulations codified in 49 C.F.R Part 199, finding that PUD I employees working\nat PGW are a “covered employee” subject to D&A testing because they perform functions that\nare: (1) performed on a pipeline or LNG facility, (2) concerned with operations, maintenance or\nemergency-response activities, and (3) regulated by Part 192, 193, or 195.\n5 Guidelines for Implementing an Anti-Drug Program for Pipeline Personnel, Department of Transportation\nResearch and Special Programs Administration, at pp. 23-24 of Most Frequently Asked Drug Questions, issued\nMarch 4, 1994.\n6 Id. at pp. 17-18.\n7 Id. at pp. 23-24.\n\n<<<PAGE 8>>>\n\nFebruary 1, 2022\nPage 5\nShould you have any questions, or require any clarification, please contact the undersigned.\nVery truly yours,\nBy: /s/\nJoel L. Greene\nAndrea I. Sarmentero Garzón\nJennings, Strouss & Salmon, PLC\n1300 I Street, Suite 1120\nWashington, D.C. 20005-3314\n202-371-9889\n202-370-4128\njgreene@jsslaw.com\nasarmentero@jsslaw.com\nCounsel to Philadelphia Gas Works\nEnclosure\nCc: John Gale (John.Gale@dot.gov) and Tewabe Asebe (Tewabe.Asebe@dot.gov)\n\n<<<PAGE 9>>>\n\nAPPENDIX A\n\n<<<PAGE 10>>>\n\nA senior level position in the Distribution Planning section that requires skills to cover field drafting, estimating\nprojects and senior drafting. It could involve daily site visits to various locations in all weather and potential\nemergency situations on a 24 hour, 7 day a week timeframe depending upon the schedules of the field crews\nbeing covered. This position involves coverage where mains are being installed by construction crews and the\nPlanning Utility Drafter I makes pencil/future technology based field sketches showing make-up of mains in\ndetail for presentation to higher level employees for the purpose of entering and updating all of the PGW\ndetailed and general main maps.\nRequires the preparation of estimates and design for the installation of mains and services, including meters,\nregulators and related equipment for customers requesting gas service up to 20,000 CH through single\nservice. Can also act as backup to the Sr. Estimator if needed and if the work load permits. Develops a\npreviously selected main route; chooses the locations for proposed large mains, valves and pressure\nregulating stations within this route; and prepares the construction drawings for such installations. These\ncustomers may be in any classification including commercial, industrial major and residential. Estimates and\ndesigns these installations in an economical manner taking into consideration safety, efficient delivery of the\nproduct and the present and potential use of the installation. Estimates and Designs installation considering\nthe minimizing of future maintenance problems. These installations may be required to supply new\ncustomers, provide for the increased demands of existing customers, relocation of facilities of existing\ncustomers.\nSet up construction drawings for drafters, send and receive PA 1 Call tickets, handle file exchange from\nftp and other internet web sites, maintain various databases, maintain drawing archives, ensure updated\nmaps are current in Dispatch Area, provide printing and scanning, maintain printer/scanning equipment\nand software at multiple locations, and handle printing and scanning requests from various internal\ndepartments and outside agencies.\nResponsible to enter construction drawing information into GPIS, apply for Highway Openings, Lane Closures\nand ADA Ramp permits in GPIS, as well as apply for PennDOT permits. Responsible for the creation of AIMS\norders and preparing AIMS orders to be dispatched to Construction. Assists in requesting police and\ndocumenting the applications. Assist in documenting and processing invoices.\nThis position requires senior drafting skills and the ability to complete all drawings assigned as well as\nPlanner Utility Drafter I and Ill requirements, if and when needed.\nWorks in all inclement weather and construction hazard conditions.\nESSENTIAL FUNCTIONS\n• Must have a thorough knowledge of PGW policies in regard to main, service, regulator, meter, metering\nrelated equipment and other system installations as these matters must be discussed with the customer\nso that designs and subsequent installation are compliant with PGW, City, State and Federal\nregulations.\n• Must have the ability to complete all required PGW drafting needs.\n• Locates the main and its various fittings to reference points\n• Ability to make clear, free-hand sketches using approved symbols and lettering, and also ability to use\ningenuity and good judgment in the selection of reference points.\nPlanning Drafter I (Updated: 10/2016)\n\n<<<PAGE 11>>>\n\nsubstantiates and vermes as lald quantities or piping laid on tinal contract reports against the Field\nDraftsman, Planning Utility Drafters report and reviews the same with the Area Supervisor.\n• Interprets contour and survey maps in order to plan for main extensions into new areas. Must have an\nunderstanding of building plans in order to discuss details of service installation with architects,\nengineers or builders. Observes and considers surface conditions, such as, manholes, vent boxes,\nutility markings or pavement disturbance that could influence choice of locations for the proposed main\nor service.\n• Develops drawings for special supports for gas mains, brackets for mains crossing bridges, and\nretaining clamps for joints and drips.\n• Selection of route and location of mains, valves, pressure regulating stations and manholes.\n• Must have a working knowledge of street main instructions, contract instructions, work order\nauthorizations, job numbers, service and special job instructions and departmental account numbers.\n• Makes preliminary sketch and bills of material with specifications.\nEstimates and designs mains for new home developments as may be required from trunk mains\ndeveloped by Network Analysis group. Prepares sketches electronically so that it may be presented on\nexisting plans created by others or generated on detail main maps or general main maps. Creates\nMain and Service Estimates of cost of installations using PGW provided PC software.\nDesigns special shapes and structures for supporting or carrying gas mains.\n• Designs and draws\nmore complicated section of large main jobs, regulating and metering stations,\nvalves and manholes.\n• Checks the following Planning Utility Drafters reports and records for accuracy and completeness: final\nsketch records, daily progress report, daily progress report check sheet, valve records, drip records,\ncorrosion control records, bridge inspection records and miscellaneous records and submits to the\nSupervisor of Drafting to maintain monthly report.\n• Locates the main and its various fittings to reference points\n• Ability to make clear, free-hand sketches using approved symbols and lettering, and also ability to use\ningenuity and good judgment in the selection of reference points.\n• Draws permanent main records electronically from field sketches using various drawing programs.\n• Originates various reports covering assigned territories such as the main work daily progress report,\nand other record cards used in operation and maintenance of drips, valves, corrosion control\ninstallations, bridge mains and large (3\" and over) services.\n• Assembles and verifies field sketches made out of hours by Distribution street personnel.\n• Responsible to lay out special construction work in the field, as well as the normal duties of a\ndraftsman.\n• Directs, advises and trains Planning Utility Drafter I and III on construction drawings, maps, main\nrecords and estimates up to 8\" and smaller mains and services, including meters, regulators and\nrelated equipment for customers requesting gas service up to 20,000 CFH through single service\n• Checks final drawings and makes final bill of materials.\n• Directs the transfer work involved from field sketch to finished map\n• Revises and draws new maps as needed in the distribution system and keeps the records of their\ndistribution.\n• Meets contractors to settle construction problems, such as gas mains on bridges, highways and sewer\nPlanning Drafter I (Updated: 10/2016)\n\n<<<PAGE 12>>>\n\nDras and her Planning uny Drate paine real.\nand removals of mains and services, and updating the corrosion C.P. systems.\n• Responsible for researching and correcting all discrepancies found on all of the above maps, all\nchanges done out of hours or unreported through Field Drafting\n• Researches field sketches for previously installed main and service of any age, and abandoned\nstructures for Planning section, Distribution Department and outside contractors when conflicts occur.\n• Creates a pdf of all updated Detail Main maps twice a month; which are then forwarded to appropriate\npersonnel.\n• Must have thorough knowledge of the supporting records such as Service Records, Main Repair\nRecords, Broken Main Records, and Drip Records.\n• Must be completely familiar with the interpretation of survey and contour maps, and develop maps\nused in the operation of the distribution system, also known as 6X drawings.\n• Directs the operation of reproduction machines; has a working knowledge of the pipe locator and is\nproficient in the use if the transit and level.\n• Makes sketches and prepares cost estimates for such work, working from standard costs but allowing\nfor variations in underground structures, soil conditions, traffic, etc. Prepares these documents using\nCAD and other company supplied computer software programs. Designs services using PGW\napproved gas flow equations software, which may reside on various media including PC's to determine\nwhat size service pipe is needed. Required to input all job related data into an Excel based or AIMS\nprogram to electronically generate an estimate.\n• Plans mains for new home developments as may be required from trunk mains developed by Network\nAnalysis group. Prepares sketches electronically so that it may be presented on existing plans created\nby others or generated on detail\nEstimates of cost of installations using PGW provided PC software.\nators using PoW provided PC Sofivar maps. Creales Main and Service\n• Estimates and designs 8\" or smaller \"ahead of paving\" mains and assists in planning other 'ahead of\npaving\" mains. This at times requires contacts with PGW Sales personnel, engineers,\ndevelopers, builders and their agents, survey office personnel and others to develop information. Write\nstatement supporting need for the work. Attends pre-design, design and/or site meetings with\ndevelopers, builders, Marketing, FSD, Collections and other utility representatives to determine main\nand service locations, outdoor meter set locations and to solve issues associated with supplying gas to\none or several facilities up to 20,000 CFH through a single service.\n• Develops and prepares detailed, to scale sketches of mains and services using any and all PGW\nsupplied computer aided drafting (CAD) programs for new and existing facilities as required to complete\nfor the creation of construction work orders.\nResults of the flow computations must be included as\nrequired by PGW policy to enable decisions to be made on proposed designs.\n• Requires having sufficient knowledge and aptitude to associate conditions with possible corrosion\nproblems to enable corrosion protection precautions to be devised if necessary.\n• Assists Senior Estimators and other Planning Utility Drafters in the processing of estimates.\n• Studies and makes recommendations on mains proposed for abandonment.\n• Plans and carries out special assignments, some of which are non-repetitive in character.\n• If previously titled, or after being trained, performs Field Drafting duties as assigned. Demonstrate\nPlanning Drafter I (Updated: 10/2016)\n\n<<<PAGE 13>>>\n\n1 Call to other utilities and outside vendors as well as to update various title blocks in construction\ndrawings\n• Perform printing and scanning using the Oce 300, 600 and 2236: ScanPro 1000 and other various\nprinting equipment. This task includes maintaining and troubleshooting the equipment, ordering\nsupplies, (paper and ink) using Oracle, verifying printer usage monthly by checking meter reads,\nensuring backup paper copies of DMM and GMM are updated monthly with the latest changes\n(dispatch/planning areas) and Utilizing ScanPro 1000 for microfilm and aperture cards to scan and save\nas PDFs in associated job folders\n• Maintain FTP site and exchange files with vendors for various departments\n• Assist other departments with printing and archive retrieval of old drawings, work orders, job numbers,\nbill of materials, sketches and account numbers.\n• Archives drawings and sketches and researches previous archives (as needed)\n• Blue maps updates at Dispatching map table {bi-monthly)\n• GMM Books (as needed)\n• Inspector Area Maps (as needed)\n• Creates CD's for various bid contracts (as needed)\n• Train Personnel on setting up electronic folders and ERV (PWD Website)\n• Use ERV for Sewer Water Plans and Highway Plans\n• Maintain Engineering Key Library\n• Enter construction drawing information into GPIS - including application of Highway Opening, Lane\nClosures and ADA Ramp permits which includes creating new applications if there is no existing project\napplication in GPIS, entering GPIS application names, project information and estimated phase dates,\nadding and deleting street location/intersections, updating start and end dates for each phase, adding\nPA One Call Design number into each street location, referencing drawing details\nto add\nfootway/roadway locations, segments and offsets, requesting permit approval from other utilities and\nthe city of Philadelphia Streets Department and receiving and reviewing external GPIS clearance\nrequests, applications/plans, and entering comments\nas outlined in the Company policies and\nprocedures.\n• Applying for PennDOT permits which includes creating new application, adding attachments, adding\nwork summary and locations, completing application identification, adding fee information, reviewing\napplication summary, submitting applications, saving a copy of the application to the permit drawing\nfolder, updating the tracking spreadsheet, PennDOT notification and issuing of the permit\n• Responsible for the creation of AIMS orders and preparing AIMS orders to be dispatched to\nConstruction. Assists in requesting police and documenting the applications\n• Request police, document application and assist in billing.\n• Assist in documenting and processing various invoice types\n• Performs other related duties as assigned.\n• Must have regular and acceptable attendance\nEDUCATION & EXPERIENCE QUALIFICATIONS\n• HS Education\nPlanning Drafter I (Updated: 10/2016)\n\n<<<PAGE 14>>>\n\nPlanning Drafter I (Updated: 10/2016)\n\n<<<PAGE 15>>>\n\nSupervisor Drafting Services\nPlanning Utility Drafters I, II, II, Senior Estimators and\nSenior Field Drafters\nTHIS JOB\nPOSITIONS REPORTING TO THIS POSITION\nNone\nPlanning Drafter I (Updated: 10/2016)\n\n<<<PAGE 16>>>\n\n• Sedentary work - Exerting up to 10 pounds of force occasionally, and/or a negligible amount of force frequently or constantly to lift,\ncarry, push, pull or otherwise move objects, including the human body. Sedentary work involves sitting most of the time. Jobs are\nsedentary if walking and standing are required only occasionally, and all other sedentary criteria are met.\n• Light work - Exerting up to 20 pounds of force frequently, and/or a negligible amount of force constantly to move objects. If the use of\narm and/or leg control requires exertion of forces greater than that of sedentary work and if the worker sits most of the time, the job is\nconsidered light work.\nX Medium work - Exerting up to 50 pounds of force occasionally, and/or up to 20 pounds of force frequently, and/or up to 10 pounds of\nforce constantly to move objects.\n• Heavy work - Exerting up to 100 pounds of force occasionally, and/or up to 50 pounds or force frequently, and/or up to 20 pounds of\nforce constantly to move objects.\n• Very heavy work - Exerting in excess of 100 pounds of force occasionally, and/or in excess of 50 pounds of force constantly to move\nobjects.\nSPECIFIC WORK REQUIREMENTS:\nUtilizing the \"Key\" below, check appropriate boxes for each requirement category as it pertains to performing the essential\nfunctions of the attached position.\nKey:\nC = Constantly 75% or more of an average workday\nF = Frequently 50% to 75% of an average workday\nO = Occasionally 25% to 50% of an average workday\nR= Rarely less than 25% of an average workday\nF\nR\nWORKING ENVIRONMENT DESCRIPTIONS\nIndoor Work: Performs duties subject to inside environmental conditions protected from weather but not\nnecessarily from temperature changes.\nWeather Work: Performs duies subject to ulside environmental conditions with no effective protection from\nx\nExtreme Temperatures: Performs work activities at temperatures below 32 degrees or above 100 degrees for\nperiods of more than one hour, this includes such factors as the affects of wind and humidity\nx\nNoise: There is sufficient noise to cause the worker to shout in order to be heard above the noise level and/or\naffect hearing ability.\nx\nVibration: There is sufficient exposure to oscillating movements of the extremities or whole body.\nHazards: Exposed to one or more hazards such as moving mechanical parts, moving vehicles, electrical\ncurrent, high places, high heat, chemicals, etc.\nAtmospheric Conditions: Exposed to one or more conditions that affect the respiratory system such as fumes,\nodors, dusts, mists, gases, poor ventilation, etc\nPlanning Drafter I (Updated: 10/2016)\n\n<<<PAGE 17>>>\n\nX\nCrawling: Moving about on hands and knees or hands and feet.\nLight Carrying/Lifting: Physically transporting items weighing less than 15 pounds from one location to\nanother\nModerate Carrying/Lifting: Items weighing 15 to 44 pounds\nHeavy Carrying/Lifting: Items weighing 45 pounds and over\nFingering: Picking, pinching, typing, or otherwise working primarily with fingers rather than with the whole hand\nor arm\nGrasping: Applying pressure to an object with fingers (including thumb) and palm\nKneeling: Bending legs at knees to come to rest on one or both knees\nX\nLight Lifting: Raising objects under 15 pounds from a lower to a higher position or moving objects horizontally\nfrom one position to another\nModerate Lifting: Objects 15 - 44 pounds\nX\nHeavy Lifting: Objects 45 pounds and over\nPulling Hand over Hand: Using upper extremities to exert force in order to draw, drag, haul, or tug objects in a\nsustained motion\nX\nPushing: Using upper extremities to press against something with steady force in order to thrust forward,\ndownward, or upward\nReaching above shoulder: Extending hand(s) and arms) in any direction\nRepetitive motion: Substantial movements of the wrists, hands, and/or fingers for sustained periods of time\nSitting: Particularly for sustained periods of time\nStanding: Particularly for sustained periods of time\nx\nWalking: Moving about on foot, particularly for long distances.\nHearing: Utilizes hearing to perform one or more of the following: use communication equipment, detect\nspecific noises, proper equipment operation, understand what clients are saying in normal conversation\nPlanning Drafter I (Updated: 10/2016)\n\n<<<PAGE 18>>>\n\nassignment or general observations of facilities/structures (i.e. custodial, inspection, security guard, laborer)\nC\nF\nR\nCOMPREHENSION\nAbility to understand, remember, and apply oral and/or written instructions or other information\nAbility to understand, remember, and communicate routine, factual information\nAbility to understand complex problems and to collaborate and explore alternative solutions\nAbility to understand opposing viewpoints highly complex issues and to negotiate/integrate different viewpoints\nC\nF\nR\nORGANIZATION\nX\nAbility to organize thoughts and ideas into understandable terminology\nAbility to organize and prioritize own work schedule on short-term basis (longer than one month)\nAbility to organize and prioritize work schedules of others on short-term basis\nX\nAbility to organize and prioritize work schedules of others on long-term basis\nC\nF\nR\nREASONING and DECISION MAKING\nX\nAbility to apply common sense in performing job\nx\nAbility to make decisions which have moderate impact on immediate work unit\nAbility to make decisions of significant impact on the immediate work unit & moderate impact outside work unit\nAbility to make decisions which have significant impact on the department's credibility, operations, and services\nC\nF\nR\nCOMMUNICATION\nAbility to understand and follow basic instructions and guidelines\nAbility to complete routine forms, use existing form letters and/or conduct routine oral communication\nAbility to compose letters, outlines, memos, basic reports and/or to orally communicate technical information\nx\nAbility to communicate with individuals utilizing a telephone; requires ability to hear & speak effectively on phone\nx\nAbility to express or exchange ideas by means of the spoken word, communicating orally with others accurately,\nloudly, and quickly\nx\nAbility to make informal presentations speaking before groups inside and/or outside the organization\nx\nAbility to compose materials such as detailed reports, work-related manuals, publications of limited scope or\nimpact, etc., and/or to make presentations outside the immediate work area\nx\nAbility to formulate complex and comprehensive materials such as legal documents, authoritative reports, official\npublications of major scope and impact, etc., and/or to make formal presentations\nPlanning Drafter I (Updated: 10/2016)\n\n<<<PAGE 19>>>\n\nC F 0 R MATHEMATICS\nX No mathematical ability is required\nX Ability to count accurately\nX Ability to add, subtract, multiply, divide and to record, balance, and check results for accuracy\nX Ability to compute, analyze, and interpret numerical data for reporting purposes\nX Ability to compute, analyze, and interpret complex statistical data and/or to develop forecasts and computer\nmodels\nEQUIPMENT/ DEVICE OPERATION: Check All that Apply\nCOMPUTER SOFTWARE VEHICLES □ Microsoft Office 0 Bicycle X Outlook X Standard Passenger Vehicle (Coupe, □ ADP Sedan, Light SUV, Minivan, etc.) □ Oracle 0 TrucksNans (Pick-up, CDL, Cargo Van, □ Visio etc.) □ SCCS 0 Skilled Trade Vehicles (Excavator, Front X AIMS End Loader, Crane, Towed Compressor, □ Forklift, etc.) Goldmine 0 Other, (describe below) □ Other, (describe below) Gas Calc AutoCAD\nGoogle Earth\nAdobe PRO\nHEAVY EQUIPMENT/TOOLS\n□ Construction Equipment (Jackhammers,\nexcavation hand tools, shovels, bars,\nrakes, levels, etc.)\n□ Welding Tools (AC/DC welders, Arc\nwelders, Welding machines\nX Drafting Tools (CAD, drafting machines,\nhand compass, dividers, protractors, etc.)\n□ Natural Gas Equipment (compressors,\nscrubbers, evaporators, refrigeration\nequipment, etc.)\n□ Other, (describe below)\nAPPROVALS:\nUnion Representative Printed Name & Title\nUnion Representative's Signature Date\n","truncated":true,"body_characters":40166}