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2009 CT NG Program Evaluation - ct2009ngprogramevaluation (Connecticut; Natural Gas State Program Evaluation)
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CT NG Program Evaluation, 2009, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2009 Natural Gas State Program Evaluation for Connecticut Department of Public Utility Control Document Legend PART: O -- Representative Date and Title Information A -- General Program Qualifications B -- Inspections and Compliance - Procedures/Records/Performance C -- Interstate Agent States D -- Incident Investigations E -- Damage Prevention Initiatives F -- Field Inspection G -- PHMSA Initiatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 957636095 2009 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 1#
CT NG Program Evaluation, 2009, page 22009 Natural Gas State Program Evaluation -- CY 2009 Natural Gas State Agency: Connecticut Rating: Agency Status: Date of Visit: 06/21/2010 - 06/25/2010 Agency Representative: Karl Baker PHMSA Representative: Dino N. Rathod, P.E. Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr Kevin M. DelGobbo, Chairman Agency: Connecticut Department of Public Utility Control Address: 10 Franklin Square City/State/Zip: New Britain, CT 06051 60105(a): Yes 60106(a): No Interstate Agent: Yes INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2009 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual certification/agreement attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART F): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART F, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A General Program Qualifications 26 26 B Inspections and Compliance - Procedures/Records/Performance 24.5 24.5 C Interstate Agent States 6 6 D Incident Investigations 5.5 5.5 E Damage Prevention Initiatives 9 9 F Field Inspection 12 12 G PHMSA Initiatives - Strategic Plan 10 10 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 105 105 State Rating................................................................................................................................................... 100.0 DUNS: 957636095 2009 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 2#
CT NG Program Evaluation, 2009, page 3PART A - General Program Qualifications Points(MAX) Score 1 Did the state submit complete and accurate information on the attachments to its most current 60105(a) Certification/60106 (a) Agreement? (NOTE: PHMSA Representative to verify certification/agreement attachments by reviewing appropriate state documentation. Score a deficiency in any one area as "needs improvement". Attachment numbers appear in parenthesis) Previous Question A.1, Items a-h worth 1 point each Yes = 8 No = 0 Needs Minor Improvement = 3-7 Needs Major Improvement = 2 a. State Jurisdiction and agent status over gas facilities (1) b. Total state inspection activity (2) c. Gas facilities subject to state safety jurisdiction (3) d. Gas pipeline incidents (4) e. State compliance actions (5) f. State record maintenance and reporting (6) g. State employees directly involved in the gas pipeline safety program (7) h. State compliance with Federal requirements (8) 8 8 SLR Notes: 2 Did the state have an adequate mechanism to receive operator reporting of incidents to ensure state compliance with 60105(a) Certification/60106(a) Agreement requirements (fatality, injury requiring hospitalization, property damage exceeding $50,000 - Mechanism should include receiving "after hours" reports)? (Chapter 6) Previous Question A.2 Yes = 1 No = 0 1 1 SLR Notes: Gas Pipeline Safety Unit (GPSU)- Adminstrative Procedures Rev 01/29/2010- Section 18 for Incident Reporting Mechanism 3 Has the state held a pipeline safety TQ seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar or if state requested seminar, but T&Q could not provide, indicate date of state request for seminar. Seminars must be held at least once every 3 calendar years.) (Chapter 8.5) Previous Question A.4 Yes = 2 No = 0 SLR Notes: CT GPSU attended and participated in a Joint T&Q- NEPSR seminar OCt 22-23, 2009 in Meridith, NH 2 2 4 Were pipeline safety program files well-organized and accessible?(NOTE: This also includes electronic files) (Chapter 5) Previous Question A.5 Yes = 1 No = 0 1 1 SLR Notes: GPSU files are kept in a secure bldg; well organized and accessible (hard copies, electronic files) 5 Did state records and discussions with the state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? (Chapter 4.1, Chapter 8.1) Previous Question A.6 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: Phil sher was Prog Mgr till June 2009. Karl Baker was named as Acting Prog Mgr for remaining 2009. Karl Baker became permanent Program Manager. He brings in wealth of Pipeline Safety Regulatory experience. He also has completed necessary T&Q training. He has worked with ER and PHMSA closely. 6 Did the state respond in writing within 60 days to the requested items in the Chairman's letter following the Region's last program evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8 Yes = 1 No = 0 1 1 SLR Notes: DUNS: 957636095 2009 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 3#
CT NG Program Evaluation, 2009, page 4CT DPUC sent response to PHMSA letter Feb 2, 2010. 7 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the 1 1 previous year? Did actions correct or address deficiencies from previous year's evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8/A.9 Yes = 1 No = 0 SLR Notes: CT DPUC selcted Karl Bkaer as a permanent replacment of Program Manager. GSPU also continues to work with LDCs for implementation of IMP. Personnel and Qualifications 8 Has each inspector fulfilled the 3 year TQ training requirement? If No, has the state been granted a waiver regarding TQ courses by the Associate Administrator for Pipeline Safety? (NOTE: If the State has new inspectors who have not attended all TQ courses, but are in a program which will achieve the completion of all applicable courses within 3 years of taking first course (5 years to sucessfully complete), or if a waiver has been granted by the applicable Region Director for the state, please answer yes.) (Chapter 4.4) Previous Question A.10 Yes = 3 No = 0 3 3 SLR Notes: 2011 CT DPUC maintains T&Q training requirements of pipeline inspection staff. New inpsectro John DePaolo has signed up for four (4) T&Q courses for FY 9 Brief Description of Non-TQ training Activities: Info Only = No Points For State Personnel: For Operators: For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: Info Only Info Only SLR Notes: 10 Did the lead inspectors complete all required T&Q OQ courses and Computer Based Training (CBT) before conducting OQ Inspections? (Chapter 4.4.1) Previous Question A.12 Yes = 1 No = 0 SLR Notes: Per CY 2010 Certificaiton, current GPSU staff members have completed required T&Q training for OQ 1 1 11 Did the lead inspectors complete all required TQ Integrity Management (IMP) Courses/Seminars and CBT before conducting IMP Inspections? (Chapter 4.4.1) Previous Question A.13 Yes = 1 No = 0 1 1 SLR Notes: in CY 2011 GPSU inspectors Karl, Bruce and Dan have completed IMP training. Another inspector Ed has signed up and expected to complete IMP training requirement 12 Was the ratio acceptable of Total inspection Person-days to Total Person-days charged to the program by state inspectors? (Region Director may modify points for just cause) (Chapter 4.3) Previous Question B.12 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 342.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 3.59 = 789.80 Ratio: A / B 342.00 / 789.80 = 0.43 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 SLR Notes: DUNS: 957636095 2009 Natural Gas State Program Evaluation 5 5 Connecticut Connecticut Department of Public Utility Control, Page: 4#
CT NG Program Evaluation, 2009, page 513 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Question B.13 Info Only = No Points Info Only Info Only SLR Notes: Phil Sher retired from DPUC in June 2009. Karl baker was named Acting Prog Mgr. GPSU also added a new Inspector John DePaolo in early June 2010. 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: State of Conecticut Gas Pipeline Safety Unit (GPSU) Admin Procedures- Rev 01/29/2010. I adcussed with GPSU minor changes of procedures. Total points scored for this section: 26 Total possible points for this section: 26 DUNS: 957636095 2009 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 5#
CT NG Program Evaluation, 2009, page 6PART B - Inspections and Compliance - Procedures/Records/ Performance Points(MAX) Score Inspection Procedures 1 Does the State have a written inspection plan to complete the following? (all types of operators including LNG) (Chapter 5.1) Previous Question B.1 + Chapter 5 Changes + Incorporate LNG Yes = 6.5 No = 0 Needs Improvement = 50% Deduction a Standard Inspections (Including LNG) (Max points = 2) b IMP Inspections (Including DIMP) (Max points = .5) c OQ Inspections (Max points = .5) d Damage Prevention (Max points = .5) e On-Site Operator Training (Max points = .5) f Construction Inspections (Max points = .5) g Incident/Accident Investigations (Max points = 1) h Compliance Follow-up (Max points = 1) SLR Notes: Gas Pipeline Safety Unit- GPSU Admin Procedure- Rev 01//29/2010 Section 5 6.5 6.5 Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement 2 Did the written Procedures for selecting operators adequately address key concerns? (Chapter 5.1) Previous 2 2 Question B.2, items a-d are worth .5 point each Yes = 2 No = 0 Needs Improvement = 50% Deduction a Length of time since last inspection Yes No Needs Improvement b History of Operator/unit and/or location (including leakage , incident and compliance history) Yes No Needs Improvement c Type of activity being undertaken by operator (construction etc) Yes No Needs Improvement d For large operators, rotation of locations inspected Yes No Needs Improvement SLR Notes: Gas Pipeline Safety Unit- GPSU Admin Procedure- Rev 01//29/2010 Section 8 Inspection Performance 3 Did the state inspect all types of operators and inspection units in accordance with time intervals established in its written procedures? (Chapter 5.1) Previous Question B.3 Yes = 2 No = 0 SLR Notes: Gas Pipeline Safety Unit- GPSU Admin Procedure- Rev 01//29/2010 Section 6 2 2 4 Did the state inspection form cover all applicable code requirements addressed on the Federal Inspection forms? (Chapter 5.1 (3)) Previous Question B.4 Yes = 1 No = 0 1 1 SLR Notes: Gas Pipeline Safety Unit- GPSU Admin Procedure- Rev 01//29/2010 DPUC reviews inspeciton forms and revises, as necessary. GPSU notes date of revision and Amemndment as part of Inspection Form footer 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 1 1 Yes = 1 No = 0 SLR Notes: I discussed ad suggested to GPSU to describe and provide short supplemental information in comments/ notes portion of inspeciton checklist /form. This should help capture necesary brief description in addtion to boxes being checked. (Short concise write-up should be sufficient, as necessary.) GPSU agrreed to start implemnting it going forward. 6 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.6 Yes = .5 No = 0 SLR Notes: DUNS: 957636095 2009 Natural Gas State Program Evaluation .5 NA Connecticut Connecticut Department of Public Utility Control, Page: 6#
CT NG Program Evaluation, 2009, page 7In CY 2009- No SRC 7 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence .5 .5 of graphitization and if necessary remedial action was taken? (NTSB) Previous Question B.7 Yes = .5 No = 0 SLR Notes: GPSU performed O&M inpection 02/23/2009 of CNG, Reviewed exposed cast iron pipe report (Part 192.459). Operator was cited for probable violation 8 Did the state review operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Previous Question B.8 Yes = .5 No = 0 SLR Notes: GPSU performed O&M inpection 02/23/2009 of CNG, Reviewed surveilance of cast iron pipe report (Part 192.755). .5 .5 9 Did the state review operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Previous Question B.9 Yes = .5 No = 0 SLR Notes: DPUC requires monthly Leak reports from LDCs (part 192.615) .5 .5 10 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 192.617? (NTSB) Previous Question 1 1 B.10 Yes = 1 No = 0 SLR Notes: Basis. GPSU performed O&M inpection , Reviewed revious incidnets, 3rd party damage report (Part 192.617). GRade 1 and 2 Leak Reports received ona Monthlt Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous Question B.14 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: 1 1 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a probable violation as specified in the "Guidelines for State Participating in the Pipeline Safety Program"? (Chapter 5.1) Previous Question D(1).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: GPSU Section 10-11 1 1 13 Does the state have written procedures to notify an operator when a noncompliance is identified as specified in the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(4)) Previous Question D (1).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: GPSU Section 10 1 1 14 Does the state have a written procedure for routinely reviewing the progress of compliance actions to prevent delays or breakdowns of the enforcement process, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(5)) Previous Question D(1).3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: GPSU Section 10 DUNS: 957636095 2009 Natural Gas State Program Evaluation 1 1 Connecticut Connecticut Department of Public Utility Control, Page: 7#
CT NG Program Evaluation, 2009, page 815 Has the State issued compliance actions for all probable violations discovered? (Note : PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation) Previous Question D(1).4 Yes = 1 No = 0 SLR Notes: Per 2010 Certification-A ttachmnet 5-- 27 were issued, 12 Compliance action taken 1 1 16 Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that prompt corrective actions were taken by operators, within the time frames established by the procedures and compliance correspondence, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? Previous Question D(1).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: GPSU Section 10 1 1 17 If compliance could not be established by other means, did state pipeline safety program staff request formal action, such as a "Show Cause Hearing" to correct pipeline safety violations? (check each states enforcement procedures) Previous Question D(1).6 No = 0 Yes = 1 SLR Notes: GPSU Section 10.1 1 1 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question D(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: GPSU follow-up actions are documented. 1 1 19 Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question D(1).8 Yes = .5 No = 0 SLR Notes: Procedures per GPSU Section 10 and Appendix "I" .5 .5 20 Did the compliance proceedings give reasonable due process to all parties? (check each states enforcement procedures) Previous Question D(1).9 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: GPSU Section 10.1 1 1 Compliance - 60106(a) States 21 Did the state use the current federal inspection form(s)? Previous Question D(2).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: 1 NA 22 SLR Notes: Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question D(2).2 Yes = 1 No = 0 Needs Improvement = .5 1 NA 23 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Previous Question D(2).3 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: DUNS: 957636095 2009 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 8#
CT NG Program Evaluation, 2009, page 924 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(2).4 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 25 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(2).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 26 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Previous Question D(2).6 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 27 Part B: General Comments/Regional Observations Info Only = No Points Info Only NA SLR Notes: Written Inspeciton Procedures Manual- Titled: State of Connecticut- Gas Pipeline Safety Unit (GPSU) Administrative Procedure Rev 1/29/2010 Total points scored for this section: 24.5 Total possible points for this section: 24.5 DUNS: 957636095 2009 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 9#
CT NG Program Evaluation, 2009, page 10PART C - Interstate Agent States Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Previous Question D(3).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: DPUC utilized federal inspection forms (available from PHMSA website) 1 1 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Previous Question D(3).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: DPUC performed interstate inspection per PHMSA ER annual inspection plan (2009) 1 1 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Previous Question D(3).3 Yes = 1 No = 0 SLR Notes: DPUC worked closely with PHMSA ER Team Leaders 1 1 4 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Previous Question D(3).4 Yes = 1 No = 0 1 1 SLR Notes: 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(3).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: No safety hazard conditions found in 2009 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(3).6 Yes = 1 No = 0 SLR Notes: DPUC worked closely with PHMSA ER staff inspectors 1 1 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Previous Question D(3).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: 1 1 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: DPUC and PHMSA staff members work closely on intrerstate inspections Info Only Info Only Total points scored for this section: 6 Total possible points for this section: 6 DUNS: 957636095 2009 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 10#
CT NG Program Evaluation, 2009, page 11PART D - Incident Investigations Points(MAX) Score 1 Are state personnel following the procedures for Federal/State cooperation in case of an incident? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6.1) Previous Question E.1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: 1 1 2 Are state personnel familiar with the jurisdictional authority and Memorandum of Understanding between NTSB and PHMSA? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6 ? Appendix D) Previous Question E.2 Yes = .5 No = 0 SLR Notes: .5 .5 3 Did the state keep adequate records of incident notifications received? Previous Question E.3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: 4 If an onsite investigation of an incident was not made, did the state obtain sufficient information by other means to determine the facts and support the decision not to go on-site? Previous Question E.4 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? Previous Question E.5, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Observations and Document Review 2 2 b. Contributing Factors c. Recommendations to prevent recurrences where appropriate SLR Notes: Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement DPUC prepares detailed incident investigations. Dec 2009 investigation continues pending metallurgical lab analysis report. DPUC is expected to take appropriate actions as a result of review of this report. DPUC agreed to keep me informed of progress and closing of investigation and possible actions. 6 Did the state initiate enforcement action for violations found during any incident investigation(s)? Previous Question E.6 Variation Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: enforcement actions, if any. Dec 2009 investigation continues. DPUC is expected to conclude this investigation and keep me informed of progress including possible compliance/ 7 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate annual report data from operators concerning incidents/accidents and investigate discrepancies) (Chapter 6) Previous Question E.7/E.8 Yes = .5 No = 0 SLR Notes: .5 NA 8 Part D: General Comments/Regional Observations Info Only = No Points SLR Notes: GPSU is investigating Dec 2009 incident. GPSU expects to complete investigation report and resolve final actions in early 2010. DUNS: 957636095 2009 Natural Gas State Program Evaluation Info Only Info Only Connecticut Connecticut Department of Public Utility Control, Page: 11#
CT NG Program Evaluation, 2009, page 12Total points scored for this section: 5.5 Total possible points for this section: 5.5 DUNS: 957636095 2009 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 12#
CT NG Program Evaluation, 2009, page 13PART E - Damage Prevention Initiatives Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? Previous Question B.11 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: DPUC Performed review during O&M audits. $ LDCs udits performed in 2009. Also state regulations, 16-345-4(a)(5), states "?If the excavator is utilizing trenchless excavation, the excavator shall, if such excavation is expected to cross or encroach within the approximate location of underground facilities either horizontally or vertically, prior to the crossing or encroaching, determine the precise location of such underground facilities expected to be so crossed or encroached 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? New 2008 Yes = 2 No = 0 2 2 SLR Notes: the DPUC. Performed review during O&M audits. Audits of 4 LDCs 2009. This is also accomplished during normal review of one-call damages that are reported to 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to 2 2 its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.7 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: DPUC has performed a review of the CGA Best Practices document and determined that all pertinent best practices are included in the state regulations. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? New 2008 Yes = 1 No = 0 SLR Notes: 2006 ? 4.39 2007 ? 4.26 2008 ? 4.10 2009 ? 3.21 DPUC collects and evaluates this data(Damages per 1000 locate requestes). 1 1 5 Did the state review operators' records of accidents and failures due to excavation damage to ensure causes of failure are addressed to minimize the possibility of recurrence as required by 192.617? Yes = 2 No = 0 2 2 SLR Notes: that are reported to the GPSU DPUC Performed review during O&M audits. Audits of 4 LDCs performed in 2009. This is also accomplished during normal review of one-call damages 6 Part E: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Owners of Public Utilities are required by state regulations to file damage reports. DPUC is reviewing possiblity of excavator formally reporting to DPUC/ CBYG. This issue may be taken up in late 2010 Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 957636095 2009 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 13#
CT NG Program Evaluation, 2009, page 14PART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Info Only Info Only Name of Operator Inspected: Norwich Public Utilites Name of State Inspector(s) Observed: Ed F Location of Inspection: Norwich Date of Inspection: 06/22/2010 Name of PHMSA Representative: Dino N. Rathod, P.E. SLR Notes: Observed GPSU inspectors Ed and Bruce perfom plastic pipe instllation and Critical Valve maintenance including Operator Qualification (OQ #9) Field Verification Inspection of various covered tasks 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? New 2008 Yes = 1 No = 0 SLR Notes: Norwich DPU Asst Gen Mgr Chris LaRose was present duirng field activities and records review at Norwich DPU office. 1 1 3 Did the inspector use an acceptable inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Previous Question F.2 Yes = 2 No = 0 2 2 SLR Notes: by e-mail GPSU inspectors used inspection check list hard copy initially and susequently transferred into electronic forms. I also received necessary completed copies 4 Did the inspector thoroughly document results of the inspection? Previous Question F.3 Yes = 2 No = 0 2 2 SLR Notes: 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps, pyrometer, soap spray, CGI, etc.) New 2008 Yes = 1 No = 0 1 1 SLR Notes: 6 What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) New 2008 Info Only = No Points SLR Notes: Plastic pipe installation and Valve Maintenance in Norwich. Info Only Info Only 7 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) New 2008, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities/Facilities d. Other (Please Comment) 2 2 DUNS: 957636095 2009 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 14#
CT NG Program Evaluation, 2009, page 15SLR Notes: Also observed OQ#9 Field verification 8 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Liaison will document reasons if unacceptable) Previous Question F.8 Yes = 2 No = 0 SLR Notes: GPSU inspectors are experience and completed necessary T&Q courses. Inspeciton activites wer performed well. 2 2 9 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) Previous Question F.10 Yes = 1 No = 0 SLR Notes: GPSU inspectors conducted brief exit interviews 1 1 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous 1 1 Question F.11 Yes = 1 No = 0 SLR Notes: No major issues were found. Discused concern with quality of backfill above top of padded sand cover. GPSU will review to assure that LDC procedures adequatey address this concern. Concern was with size of rock, asphalt chunks from street paved surface. 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector Info Only Info Only performed) Info Only = No Points SLR Notes: Norwich DPU- GPSU inspector Ed Fabricki perofrmed inspection of 6 and 8-inch HDPE plastic pipe installation- Driscoe Pipe 8100 PE 3408- approx 800 ft of new pipe. He checked Dig Safe ticket validity and line locate mark outs of various utilities. He performed field verificatin of OQ#9 of covered employees. Norwich crew used tracer wire (12THHN-solid copper), yellow warning tape and 6-inch clean sand all arounf pipe. Ed also observed pipe fusion of butt joints with use of McElroy. He also verified heating iorn surface temp at various points of heating iron. Crew used Digital infrared thermometer (Westward). On site storage on grassy surface- ok. He also verified trench depth. Quality of back-fill procedures- GPSU to follow-up in O&M. Crtical Valves- Emergency Valves GPSU inspector Bruce Benson used inspection check list and checked procedures and selected records. Norwich performs annual maintenace of these valves. We also observed field mainteance at Fifth Street in Norwich. Bruce aslo performed OQ#9 field verification. No issues wee found. Bruce 12 SLR Notes: Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only = No Points Info Only Info Only 13 Field Observation Areas Observed (check all that apply) Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys DUNS: 957636095 2009 Natural Gas State Program Evaluation Info Only Info Only Connecticut Connecticut Department of Public Utility Control, Page: 15#
CT NG Program Evaluation, 2009, page 16p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other SLR Notes: 14 Part F: General Comments/Regional Observations Info Only = No Points SLR Notes: DUNS: 957636095 2009 Natural Gas State Program Evaluation Info Only Info Only Total points scored for this section: 12 Total possible points for this section: 12 Connecticut Connecticut Department of Public Utility Control, Page: 16#
CT NG Program Evaluation, 2009, page 17PART G - PHMSA Initiatives - Strategic Plan Points(MAX) Score Risk base Inspections - Targeting High Risk Areas 1 Does state have process to identify high risk inspection units? Yes = 1.5 No = 0 1.5 1.5 Risk Factors (criteria) to consider may include: Miles of HCA's, Geographic area, Population Density Length of time since last inspection History of Individual Operator units (leakage, incident and compliance history, etc.) Threats - (Excavation Damage, Corrosion, Natural Forces, Other Outside Forces, Material or Welds, Equipment, Operations, Other) SLR Notes: DPUC Section 8 of Administrative Procedures states "Inspections are ordinarily conducted pursuant to one of the following criteria. (a) Routine scheduling (b) A complaint received from a member of the public (c) Information obtained from a previous inspection (d) Pipeline accident or incident (e) Whenever deemed appropriate by the DPUC Every operator and every inspection unit is typically inspected in accordance with 6c above, with priority given to inspecting systems with greater risk potential. In determining the potential risk of a facility, the following factors may be considered. (a) The length of time since the last inspection. (b) The history of the inspection unit (leak history, unaccounted-for gas, prior non-compliances, accident/incident history, etc.). (c) Types of activities being undertaken by the inspection unit (construction, recent changes in personnel and procedures, etc.). (d) For multi-unit operators, rotation of inspection units to be inspected. (e) The nature of the facility (pipeline, LNG plant, propane plant) (f) Pressure classification (low, elevated-low, high) (g) Material involved (cast iron, steel, plastic) (h) History of the type of facility (i) Population density (j) Threats to the facilities (Excavation damage, corrosion, natural forces, other outside forces, material or welds, equipment, operations 2 Are inspection units broken down appropriately? (see definitions in Guidelines) Yes = .5 No = 0 .5 0.5 SLR Notes: 3 Consideration of operators DIMP Plan? (if available and pending rulemaking) Info Only = No Points SLR Notes: DPUC is working closely with implementation of IMP and Plan ddevelopment. Info Only Info Only 4 Does state inspection process target high risk areas? Yes = .5 No = 0 SLR Notes: Also details as noted in Part Q 1 .5 0.5 Use of Data to Help Drive Program Priority and Inspections 5 Does state use data to analyze effectiveness of damage prevention efforts in the state? (DIRT or other data, etc) .5 0.5 Yes = .5 No = 0 SLR Notes: Approximately twice per year the damage prevention data is reviewed by DPUC to determine trends. These trends are reviewed to determine where emphasis is to be placed. These trends are also reviewed with the Call Before You Dig (CBYD)Public Awareness Committee and where appropriate, the public awareness campaigns are modified. 6 Has state reviewed data on Operator Annual reports for accuracy? DUNS: 957636095 2009 Natural Gas State Program Evaluation .5 0.5 Connecticut Connecticut Department of Public Utility Control, Page: 17#
CT NG Program Evaluation, 2009, page 18Yes = .5 No = 0 SLR Notes: DPUC reviews LDC annual reports- in 2008 Southern Connecticut Gas report was ok however in 2009 error was found and DPUC had SCG revise and resubmit annual report to PHMSA. SCG submitted to PHMSA dated 6-10-2010 7 Has state analyzed annual report data for trends and operator issues? Yes = .5 No = 0 SLR Notes: DPUC maintains reports and reviews for trends etc. See PIPEDATA.XLS located in L:\Gaspipe\Undergnd Facilities .5 0.5 8 Has state reviewed data on Incident/Accident reports for accuracy? Yes = .5 No = 0 SLR Notes: DPUC reviewed Dec 2009 gas incident=4-inch cast iron cracked. DPUC ordered Lab Analysis. .5 0.5 9 Does state do evaluation of effectiveness of program based on data? (i.e. performance measures, trends, etc.) .5 0.5 Yes = .5 No = 0 SLR Notes: DPUC evaluates program using leak response time data, class 2 leak backlog data, third-party damage data and cast iron/bare steel replacement program data 10 Did the State input all operator qualification inspection results into web based database provided by PHMSA in a timely manner upon completion of OQ inspections? Previous Question B.15 Yes = .5 No = 0 SLR Notes: in 2009 DPUC uploaded 43 OQ#9 field verification nspections and 4 OQ Plan reviews .5 0.5 11 Did the State submit their replies into the Integrity Management Database (IMDB) in response to the Operators notifications for their integrity management program? Previous Question B.16 Yes = .5 No = 0 SLR Notes: DPUC does not have any intrastate IMP facilities. DPUC works closely with ER for interstate IMP inspections. .5 0.5 12 Have the IMP Federal Protocol forms been uploaded to the IMDB? Previous Question B.17 Yes = .5 No = 0 SLR Notes: DPUC works with ER Team Leader and PHMSA ER/ Cycla enters data in IMDB. .5 0.5 13 Did the State ask Operators to identify any plastic pipe and components that has shown a record of defects/leaks and what those operators are doing to mitigate the safety concerns? Previous Question B.18 Yes = .5 No = 0 .5 0.5 SLR Notes: All data on class 1 and 2 leaks are required to be submitted to the DPUC on a monthly basis. This data is reviewed to determine trends including any plastic pipe issues. Also, during the O&M audits, this is reviewed under 192.617 14 Has state confirmed transmission operators have submitted information into National Pipeline Mapping System (NPMS) database along with any changes made after original submission? Yes = .5 No = 0 SLR Notes: No intrastate IMP pipeline facilities; DPUC works closely with PHSMA ER for Interstate facilities .5 0.5 Accident/Incident Investigation Learning and Sharing Lessons Learned 15 Has state shared lessons learned from incidents/accidents? (i.e. NAPSR meetings and communications) Yes = .5 No = 0 SLR Notes: DUNS: 957636095 2009 Natural Gas State Program Evaluation .5 0.5 Connecticut Connecticut Department of Public Utility Control, Page: 18#
CT NG Program Evaluation, 2009, page 19DPUC presented at NAPSR meetings. In addition, all incident/accident reports are sent to all applicable operators in the state for their review and response to any applicable recommendations included in the report. 16 Does the State support data gathering efforts concerning accidents? (Frequency/Consequence/etc) .5 0.5 Yes = .5 No = 0 SLR Notes: DPUC ensures that operators correctly file appropriate PHMSA incident forms. 17 SLR Notes: Does state have incident/accident criteria for conducting root cause analysis? Info Only = No Points Info Only Info Only 18 SLR Notes: Does state conduct root cause analysis on incidents/accidents in state? Info Only = No Points Info Only Info Only 19 Has state participated on root cause analysis training? (can also be on wait list) Yes = .5 No = 0 SLR Notes: 3 DPUC inspectorscompleted Root Cause Analysis training in Feb 2010; 1 in March 2010. .5 0.5 Transparency - Communication with Stakeholders 20 Other than pipeline safety seminar does State communicate with stakeholders? (Communicate program data, pub awareness, etc.) Yes = .5 No = 0 SLR Notes: DPUC web page has CBYD enforcment data docketyed and available to public .5 0.5 21 Does state share enforcement data with public? (Website, newsletters, docket access, etc.) Yes = .5 No = 0 SLR Notes: DPUC has weblink www.ct.gov/dpuc .5 0.5 22 Part G: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 957636095 2009 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 19#
CT NG Program Evaluation, 2009, page 20PART H - Miscellaneous Points(MAX) Score 1 What were the major accomplishments for the year being evaluated? (Describe the accomplishments, NAPSR Activities and Participation, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: 1 DPUC selected Karl Baker as a Program Manager in 2010. he was Acting Program Manager since departure of Phil Sher in June 2009. 2 DPUC was able to hire a new Pipeline Safety Engineer in June 2010. 3. Karl worked closely with investigation of Keen Energy, Middletown Power Plant exlosion investigation- PHMSA and Chemical Safety Board 2 What legislative or program initiatives are taking place/planned in the state, past, present, and future? (Describe initiatives (i.e. damage prevention, jurisdiction/authority, compliance/administrative, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: 1. DPUC actively working to resolve SCG related incident issues- damage prevention related issues. DPUC intends to pursue it furhter in consideration on possible compliance actions upon completion of metallurgical analysis and final report. 2. DPUC works actively to promote CBYD. GPSU also reviews CBYD data for repeat violations, trends and means to resolve this issue. 3 Any Risk Reduction Accomplishments/Projects? (i.e. Cast iron replacement projects,bare steel,third-party damage reductions, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: 1. CT DPUC has cast iron and bare steel replacement program. 27 miles of mains and 2972 services replaced. 2 Call Before You Dig (CBYD)- 377 possible violation notices wer issued in 2009 and $68, 750 civil penalty amount was asssessed. 4 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 1 1 SLR Notes: DPUC participated in Jul30, 2009 in CGA/DIRT; Aug 11, 2009 NPRM Periodic Updates. 5 Sharing Best Practices with Other States - (General Program) Yes = .5 No = 0 .5 0.5 SLR Notes: DPUC shares with NAPSR and NEPSR stakeholders. 6 Part H: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 957636095 2009 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 20#
CT NG Program Evaluation, 2009, page 21PART I - Program Initiatives Points(MAX) Score Drug and Alcohol Testing (49 CFR Part 199) 1 Has the state verified that operators have drug and alcohol testing programs? Yes = 1 No = 0 1 1 SLR Notes: these inspections. In 2009 DPUC performed Drug & Alcohol inspections of LDCS (CNG, SCG, Norwich DPU and YAnkee Gas). DPUC used federal inspection form #13 for 2 Is the state verifying that operators are conducting the drug and alcohol tests required by the operators program (random, post-incident, etc.) Yes = .5 No = 0 SLR Notes: Using Form #13 DPUC verified interview questions (Part 199.3) .5 0.5 3 Is the state verifying that any positive tests are responded to in accordance with the operator's program? Yes = .5 No = 0 SLR Notes: DPUC verified positive tests are responded to in accordance with the operator's program. .5 0.5 Qualification of Pipeline Personnel (49 CFR Part 192 Subpart N) 4 Has the state verified that operators have a written qualification program? Yes = 1 No = 0 SLR Notes: In 2009 DPUC performed 43 OQ field verification and 4 OQ Plan inspections 1 1 5 Has the state reviewed operator qualification programs for compliance with PHMSA rules and protocols? Yes = .5 No = 0 SLR Notes: in 2009 DPUC reviewed 4 OQ Plans and used OQ Protocols .5 0.5 6 Is the state verifying that persons who perform covered tasks for the operator are qualified in accordance with the operator's program? Yes = .5 No = 0 .5 0.5 SLR Notes: program. In 2009 DPUC used OQ protocols and verified that persons who perform covered tasks for the operator are qualified in accordance with the operator's 7 Is the state verifying that persons who perform covered task for the operator are requalified at the intervals specified in the operator's program? Yes = .5 No = 0 .5 0.5 SLR Notes: In 2009 DPUC verified that persons who perform covered task for the operator are requalified at the intervals specified in the operator's program Gas Transmission Pipeline Integrity Management (49 CFR Part 192 Subpart O) 8 Has the state verified that all operators with transmission pipelines have either adopted an integrity management program (IMP), or have properly determined that one is not required? Yes = 1 No = 0 1 1 SLR Notes: No intrastate pipelines in CT; DPUC works closely with PHMSA ER for Interstate Gas Transmission pipelines. DPUC used IMP Protocols. 9 Has the state verified that in determining whether a plan is required, the operator correctly calculated the potential impact radii and properly applied the definition of a high consequence area? Yes = .5 No = 0 .5 0.5 SLR Notes: DUNS: 957636095 2009 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 21#
CT NG Program Evaluation, 2009, page 22No intrastate pipelines in CT; DPUC works closely with PHMSA ER for Interstate Gas Transmission pipelines. DPUC used IMP Protocols 10 Has the state reviewed operator IMPs for compliance with Subpart O? (In accordance with State Inspection .5 0.5 plan) Yes = .5 No = 0 SLR Notes: No intrastate pipelines in CT; DPUC works closely with PHMSA ER for Interstate Gas Transmission pipelines. DPUC used IMP Protocols 11 Is the state monitoring operator progress on the inspections, tests and remedial actions required by the operator's IMP, including that they are being done in the manner and schedule called for in its IMP? Yes = .5 No = 0 .5 0.5 SLR Notes: No intrastate pipelines in CT; DPUC works closely with PHMSA ER for Interstate Gas Transmission pipelines. DPUC used IMP Protocols. Algonquin Sept 2009; Tennessee Gas Oct 2009 12 Is the state verifying that operators are periodically examining their transmission line routes for the appearance .5 0.5 of new HCAs? Yes = .5 No = 0 SLR Notes: No intrastate pipelines in CT; DPUC works closely with PHMSA ER for Interstate Gas Transmission pipelines. DPUC used IMP Protocols Public Awareness (49 CFR Section 192.616) 13 Has the state verified that each operator has developed a continuing public awareness program? (due date was 6/20/06 for most operators, 6/20/07 for certain very small operators,6/13/08 for master meters) Yes = .5 No = 0 SLR Notes: DPUC reviewed LDCs and propane operators for Public Awareness Programs .5 0.5 14 Has the state reviewed the content of these programs for compliance with 192.616 (by participating in the Clearinghouse or by other means)? Yes = .5 No = 0 SLR Notes: DPUC performed reviews in 2009 as a part of Standard inspection process. .5 0.5 15 SLR Notes: Is the state verifying that operators are conducting the public awareness activities called for in its program? Yes = .5 No = 0 .5 0.5 16 SLR Notes: Is the state verifying that operators have evaluated their Public Awareness programs for effectiveness as described in RP1162? Info Only = No Points Info Only Info Only 17 Part I: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 957636095 2009 Natural Gas State Program Evaluation Connecticut Connecticut Department of Public Utility Control, Page: 22#
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