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2013 CT NG Program Evaluation - ct2013ngprogramevaluation (Connecticut; Natural Gas State Program Evaluation)
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CT NG Program Evaluation, 2013, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2013 Natural Gas State Program Evaluation for CT Dept of Energy and Env Protection Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 108352811 2013 Natural Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 1#
CT NG Program Evaluation, 2013, page 22013 Natural Gas State Program Evaluation -- CY 2013 Natural Gas State Agency: Connecticut Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: Yes Date of Visit: 05/11/2014 - 05/16/2014 Agency Representative: Karl Baker PHMSA Representative: Patrick Gaume Commission Chairman to whom follow up letter is to be sent: Name/Title: Arthur House, Chairman Agency: Connecticut Department of Energy and Environmental Protection, Public Utilities Regulatory Authority Address: Ten Franklin Square City/State/Zip: New Britain, Connecticut 06051 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 2013 (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 progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): 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 G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 15 15 C Program Performance 42 42 D Compliance Activities 15 15 E Incident Investigations 9 9 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 7 7 I 60106 Agreement State (If Applicable) 0 0 TOTALS 118 118 State Rating................................................................................................................................................... 100.0 DUNS: 108352811 2013 Natural Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 2#
CT NG Program Evaluation, 2013, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 (A1a) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A1. Yes. All data reviewed was accurate and consistent with Attachments 3 & 8. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: A2. Yes, Inspection days were reported accurately and were in agreement with the Inspection Tracking spreadsheet & the Inspection Records database. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A3. Yes, is consistent with Attachment 1 and the Inspection Records database. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 (A1d) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A4. Yes, Two incidents (both intrastate) were reported and are consistent with Pipeline Data Mart. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A5. Yes. Information listed was accurate. 1 1 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A6. Yes. Files kept in pipeline safety section. Some kept electronicly and some kept in hard copy. Official files are now electronic with the paper files being kept in the office. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 (A1g) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A7. Yes, the TQ imported records are in agreement with the CT Training database. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 (A1h) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A8. Yes, CT pipeline safety rules automatically adopt federal regulations. 1 1 DUNS: 108352811 2013 Natural Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 3#
CT NG Program Evaluation, 2013, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 (H1-3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 A9. Yes. Planned Performance: -- Further accelerate cast-iron and bare steel replacement across all operators. Achieve 100% score on PHMSA evaluation of our state program. Reduce damages due to mismark and bad records. Expand Staff. Past Performance: -- Further accelerated the cast iron & bare steel replacement programs from 31 years to a 20 year plan. Implemented funding to facilitate the replacements. An uptick in 3rd party damages has resulted in increased scrutiny, more fines, and more on- site inspections. Was able to replace an inspector within 3 months. 10 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: A10. The Commission's support of Pipeline Safety is noted, specifically in authorizing two new streamlined fining procedures and expediting the hiring of replacement personnel. Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 108352811 2013 Natural Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 4#
CT NG Program Evaluation, 2013, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: B1. Yes. The Administrative Procedures define what a Standard Inspection consists of in Section 5 and the inspection interval times are listed in Section 8. 2 IMP Inspections (including DIMP) (B1b) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B2. Yes, CT performs TIMP assignments as assigned from the Eastern Region, and also performs DIMP inspections; See Administrative Procedures Section 5 & Section 8. 3 OQ Inspections (B1c) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B3. Yes; The Administrative Procedures define what an Operator Qualification Inspection consists of in Section 5 and the inspection interval times are listed in Section 8. 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B4. Yes, is part of the Standard Inspection, and is being re-checked during many 3rd party line hit inspections. 5 On-Site Operator Training (B1e) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B5. Yes. The Administrative Procedures define what a Training Inspection consists of in Section 5 and the inspection interval times are listed in Section 8. 6 Construction Inspections (B1f) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B6. Yes. The Administrative Procedures define what a Construction Inspection consists of in Section 5 and the inspection interval times are listed in Section 8. 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: B7. Yes. The Administrative Procedures define what an incident Inspection consists of in Section 5 & 18, and the inspection interval time is listed in Section 8. DUNS: 108352811 2013 Natural Gas State Program Evaluation 8 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? (B2a-d, G1,2,4) Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement Connecticut CT Dept of Energy and Env Protection, Page: 5#
CT NG Program Evaluation, 2013, page 6e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? Evaluator Notes: B8. Yes. It is well discussed in The Administrative Procedures in Section 8. Yes No Needs Improvement Yes No Needs Improvement 9 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: B9. The procedures were changed to specify that the first PAPEI inspections would be complete by Dec, 2013, and the first DIMP by Dec, 2013. Propane DIMP will be done by Dec, 2014. It is CT DEEP practice to inspect every Unit every year for some type of inspection. A major goal that started in 2010 was to identify jurisdictional LPG operators, and this effort will continue for many years. Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 108352811 2013 Natural Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 6#
CT NG Program Evaluation, 2013, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 (A12) Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 354.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 3.51 = 772.93 Ratio: A / B 354.00 / 772.93 = 0.46 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: C1. Yes, A=354 person-days, B=3.51person-years*220 pd/py, A/B=0.46, okay. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines for requirements) Chapter 4.4 (A8-A11, G19) Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement Evaluator Notes: C2. Yes. Each staff inspector with 3 or more years of service has completed all required core TQ training within the required timeframe. In addition most have received OQ, DIMP/IMP and Root Cause training. All new inspectors are scheduled for the TQ Classes or wait listed. They will be scheduled for additional courses as they become available. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C3. Yes. Karl Baker has been with the program for about 20 years and is very knowledgeable. 2 2 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 (A6-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C4. NA-No response was required (100 score) . 2 NA 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) 2 2 Yes = 2 No = 0 Evaluator Notes: C5. Yes, Oct 23-24, 2014 in Manchester, VT. Oct 10-11, 2012, Mystic, CT; Also Oct, 2011 & May, 2011(propane Seminar). 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 (B3) Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: C6. Yes. The records are in the Inspection Database. DUNS: 108352811 2013 Natural Gas State Program Evaluation 5 5 Connecticut CT Dept of Energy and Env Protection, Page: 7#
CT NG Program Evaluation, 2013, page 87 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 (B4-5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C7. Yes, CT uses their Forms that include the Current Fed Forms and are supplemented as needed to include NTSB requirements and State Regulations. The Revised Federal Forms are reviewed annually by the Program Manager & his staff and the inspections are updated as needed. . Inspections reviewed were 2013142, 2013066, 2013109, & 2013094; Standard, OQ, DIMP, & Incident; all had PV. 8 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 (B7) Yes = 1 No = 0 Evaluator Notes: C8. Yes. Question is on federal form, reviewed inspection reports and saw the question answered. 1 1 9 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) Chapter 5.1 (B8) Yes = 1 No = 0 Evaluator Notes: C9. Yes. Question is on federal form, reviewed inspection reports and saw the question answered. 1 1 10 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) Chapter 5.1 (B9) Yes = 1 No = 0 Evaluator Notes: C10. Yes. Question is on federal form, reviewed inspection reports and saw the question answered. 1 1 11 Did the state review operator records of previous accidents and failures including 1 1 reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 (B10,E5) Yes = 1 No = 0 Evaluator Notes: C11. Yes. Performed review during O&M audits. Last audits performed on 3 LDCs and Norwich Public Utilities in 2007, 2009, 2011 and 2013. This is also accomplished during normal review of one-call damages that are mandatorily reported to the GPSU. Dan Nivison reviews the data. 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for 2 2 accuracy and analyzed data for trends and operator issues? Data Initiative (G6-9,G16) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C12. Yes, CT reviews and analyzes Operator Annual Reports (see PIPEDATA.XLS located in S:\Gaspipe\Undergnd Facilities). As part of the investigation of incidents/accidents, CT reviews incident/accident data for accuracy and ensures that operators correctly file appropriate PHMSA incident forms. CT evaluates their program effectiveness and checks for operator issues and trends by using leak response time data, class 2 leak backlog data, third-party damage data and cast iron/bare steel replacement program data. DUNS: 108352811 2013 Natural Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 8#
CT NG Program Evaluation, 2013, page 913 Did state input all applicable OQ, IMP inspection results into federal database in a timely 2 2 manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 (G10-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C13. Yes, CT has uploaded all applicable OQ inspection results into the federal database in a timely manner. The one IMP Operator notification for calendar year 2013 was acted on. There are no intrastate transmission lines in Connecticut. For interstate operators, the PHMSA team leaders are responsible for uploading this data for team inspections and CT uploads data for inspections where they are lead. The GIMP interstate Field inspections performed by CT are uploaded by CT. 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? (G14) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C14. NA-no intrastate transmission in CT. 1 1 15 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 (I1-3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C15. Yes, annual field inspections are performed on all intrastate operators that are required to have the program (see inspection database for dates of inspections). In addition, an annual review of the Drug and Alcohol Testing MIS Data Collection forms is performed. Verification is made that any positive tests are responded to in accordance with the operator's program. 16 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N (I4-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C16. Yes. Both headquarters and Field, have been performed on all intrastate operators. In addition, on new construction, welding and joining OQ qualifications are being reviewed. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 NA up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart 0 (I8-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C17. NA - No intrastate transmission lines in Connecticut. CT has taken part in IMP inspections of interstate operators as part of their interstate annual inspection plan. 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart P DIMP ? First round of program inspections should be complete by December 2014 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: were started in 2013. C18. Yes, CT started DIMP inspections in 2012. All 3 LDCs and the 1 Municipal operators were done. The LPG operators DUNS: 108352811 2013 Natural Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 9#
CT NG Program Evaluation, 2013, page 1019 Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. 49 CFR 192.616 (I13-16) PAPEI Effectiveness Inspections should be complete by December 2013 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C19. Yes. Performed review during O&M audits. Last O&M audits performed in 2011 and 2013. In addition, PAPEI audits have been performed on all LDCs and Norwich Public Utilities in 2012. 20 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). (G20-21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C20. Yes. Communications occur with all operators on a regular basis. CT attends and communicates information at Call Before You Dig Board of Directors meetings and Public Awareness meetings. CT attends and provides training at operator training sessions with local officials including fire departments. CT participates in the Northeast Gas Association CT Advisory Group meetings as well. PURA maintains a website that has access to all docketed matters which include all pipeline safety and One-Call enforcement proceedings. Press releases issued to local media for more notable One-Call enforcement cases. As a member of NEPSR, the Safety Seminars are being done annually not only once every 3years as required. 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 (B6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C21. NA-no SRCR in 2013. Practice is to follow up quickly when they happen. 1 1 22 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? (G13) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C22. Yes, all data on class 1 and 2 leaks are required to be submitted to CT on a monthly basis. This data is reviewed to determine trends including any plastic pipe issues. Also, during O&M audits, this is reviewed under 192.617, and, starting in 2012, is being addressed during DIMP inspections. 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? (H4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C23. Yes, CT is very responsive to NAPSR, NEPSR & PHMSA. 1 1 24 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Info Only = No Points Evaluator Notes: Info Only Info Only C24. NA. CT has not issued any waivers or special permits in over 20 years. 25 General Comments: Info Only = No Points Evaluator Notes: DUNS: 108352811 2013 Natural Gas State Program Evaluation Info Only Info Only Connecticut CT Dept of Energy and Env Protection, Page: 10#
CT NG Program Evaluation, 2013, page 11C25. CT has been successful in hiring and holding engineers in its pipeline safety program. Credit goes to competitive salaries, a beautiful State, and a supportive Commission. Total points scored for this section: 42 Total possible points for this section: 42 DUNS: 108352811 2013 Natural Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 11#
CT NG Program Evaluation, 2013, page 12PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 (B12-14, B16, B1h) Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement Evaluator Notes: D1. Yes. They are in Sections 10-13 of CT DEEP GPSU's Administrative Procedures. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 (B11,B18,B19) Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Were probable violations documented? Yes No Needs Improvement c. Were probable violations resolved? Yes No Needs Improvement d. Was the progress of probable violations routinely reviewed? Yes No Needs Improvement Evaluator Notes: D2. Yes, Inspections reviewed were 2013142, 2013066, 2013109, & 2013094; Standard, OQ, DIMP, & Incident; all had PV. All were internally consistent, All followed procedures. 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: D3. Yes, 72 letters that addressed the 238 PV. See Attachment 5. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show 2 2 cause" hearing if necessary. (B17, B20) Yes = 2 No = 0 Evaluator Notes: D4. Yes, Due Process is explained in Admin Procedures Sections 10-12, and this information is included in noncompliance letters. 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) (B27) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: D5. Yes, Karl is staying within the penalty guidelines, but is using civil penalties more frequently than the previous Program Manager. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: D6. Yes. Of 72 letters, 24 included civil penalties for $307K. See Attachment 5. 1 1 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 108352811 2013 Natural Gas State Program Evaluation Info Only Info Only Connecticut CT Dept of Energy and Env Protection, Page: 12#
CT NG Program Evaluation, 2013, page 13D7. 2013 was the second year for more frequent civil penalties. An area of emphasis is Excavation Damages. Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 108352811 2013 Natural Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 13#
CT NG Program Evaluation, 2013, page 14PART E - Incident Investigations Points(MAX) Score 1 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 (A2,D1-3) Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: E1. Yes. CT has 2-3 inspectors on call each week. Operators call Karl Baker's cell phone and he contacts on-call inspectors for dispatching them to an incident. 2 If onsite investigation was not made, did state obtain sufficient information from the 1 1 operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 (D4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: E2. YES, In 20 years, EVERY reportable incident has been investigated on-site. In addition many leaks are investigated on- site. 3 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? (D5) Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: E3. Yes, the two (both intrastate) incidents were thoroughly documented and reported. 4 Did the state initiate compliance action for violations found during any incident/accident investigation? (D6) Yes = 1 No = 0 Evaluator Notes: E4. Yes. One incident had 4 Violations and a $150k fine assessed & collected. 1 1 5 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 report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 (D7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: E5. Yes. CT responds and investigates ALL reportable incidents. 1 1 6 Does state share lessons learned from incidents/accidents? (sharing information, such as: 1 1 at NAPSR Region meetings, state seminars, etc) (G15) Yes = 1 No = 0 Evaluator Notes: E6. Yes, CT incidents/accidents have been presented at NAPSR meetings and pipeline safety seminars. 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. 7 General Comments: DUNS: 108352811 2013 Natural Gas State Program Evaluation Info Only Info Only Connecticut CT Dept of Energy and Env Protection, Page: 14#
CT NG Program Evaluation, 2013, page 15Info Only = No Points Evaluator Notes: E7. Two reportable incidents is an abnormal high count for CT. Safety is an area of emphasis, and it is expected that the incident will drop back to the more normal 0 or 1 reportable incident per year. Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 108352811 2013 Natural Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 15#
CT NG Program Evaluation, 2013, page 16PART F - Damage Prevention 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? NTSB (E1) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: F1. Yes. It is covered in Standard Inspections and is a CT State Law. 2 2 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? (E2) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 F2. Yes, performed review during O&M audits. Last audits performed on 3 LDCs and Norwich in 2007, 2009, 2011 and 2013. This is also accomplished during normal review of One-Call damages that are reported to the CT DEEP GPSU. 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) (E3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: F3. Yes. The GPSU has performed a review of the CGA Best Practices document and determined that all pertinent best practices are included in the state regulations. CT is currently working on revising their underground damage prevention laws and are reviewing the CGA Best Practices to see if they can strengthen their program. The state program has adopted the 9 elements. 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? (This can include DIRT and other data shared and reviewed by the pipeline safety program) (E4,G5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: F4. Yes, the GPSU collects and evaluates this data. Ticket ratio per 1000 ticket request 2006 4.39 total 2007 4.26 total 2008 4.10 total 2009 3.21 total 2010 3.53 total; 1.73 gas operators only 2011 2.84 total; 1.46 gas operators only 2012 3.0 total; 1.7 gas operators only 2013 3.1 total; 1.8 gas operators only 2 2 5 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: F5. The uptick in damages per thousand has caused an effort to streamline the issuing and collection of civil penalties. CT is focused on having all parties obey all aspects of the One Call Law. Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 108352811 2013 Natural Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 16#
CT NG Program Evaluation, 2013, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: Superior Energy Name of State Inspector(s) Observed: Bruce Benson, Inspector Location of Inspection: 299 Boston Turnpike, Bolton, CT 06040 Date of Inspection: 5/13/14 Name of PHMSA Representative: Patrick Gaume Evaluator Notes: G1. Jurisdictional propane system Field Inspection. Superior Energy. 299 Boston Turnpike, Bolton, CT 06040. Bruce Benson, Inspector. 5/13/14. Patrick Gaume Construction, installing 4" PE 60# main. CNG opid 2700. John DePaolo, Inspector. 5/13/14 Patrick Gaume 2 Was the operator or operator's representative notified and/or given the opportunity to be 1 1 present during inspection? (F2) Yes = 1 No = 0 Evaluator Notes: G2. Yes, The propane system was selected from a list vetted with the operator, and the Construction was a visit to an ongoing project. 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) (F3) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: G3. Yes, the Propane System State Form & the State Construction Form which has the detail of the Federal Form. 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: G4. Yes. The Propane was completed as a Field Inspection, & the Construction Inspection was completed as a Daily Construction Inspection. 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) (F5) Yes = 1 No = 0 Evaluator Notes: G5. Yes. The Construction site had trucks, backhoe, front loader, fill sand, road process, asphalt cutter, PE pipe welding equipment, contact thermometer, hand tools, safety equipment, traffic control markers, etc. No special equipment was needed for the Field Propane System inspection. 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) (F7) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures 2 2 b. Records c. Field Activities d. Other (please comment) Evaluator Notes: DUNS: 108352811 2013 Natural Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 17#
CT NG Program Evaluation, 2013, page 18G6. Yes. Both inspections were Field only. 7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) (F8) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 G7. Yes. Both Bruce and John expressed and demonstrated professional knowledge of their inspection duties. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) (F9) Yes = 1 No = 0 Evaluator Notes: G8. Yes. John observed a clean, well-organized, & well provisioned work site with no PV; Bruce noted the need for additional vehicle barriers, some atmospheric corrosion, and a regulator was too close to a recently re-positioned electrical box. 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) (F10) Yes = 1 No = 0 Evaluator Notes: G9. Yes. John observed a clean, well-organized, & well provisioned work site with no PV; Bruce noted the need for additional vehicle barriers, some atmospheric corrosion, and a regulator was too close to a recently re-positioned electrical box. 10 General Comments: What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Other. 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 p. 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 DUNS: 108352811 2013 Natural Gas State Program Evaluation Info Only Info Only Connecticut CT Dept of Energy and Env Protection, Page: 18#
CT NG Program Evaluation, 2013, page 19A. 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 Evaluator Notes: G10. Propane System - Barriers, atmospheric corrosion, venting, fill points, gauges, covers, caps, piping, connections, regulators, meters, vent screens, insect & animal evidence, clearances and spacings, Propane tank, relief valve. Construction Site- site cleanliness, traffic control, backhoe operations, pipe joining, pipe welding, pipe welding procedures, site safety, PPE, back fill procedures, back fill activity, verification of neighbor contact, moving pipe, pipe storage, pipe inspection, pipe handling. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 108352811 2013 Natural Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 19#
CT NG Program Evaluation, 2013, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (C1) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: H1. Yes. 1 1 2 Are results documented demonstrating inspection units were reviewed in accordance with 1 1 "PHMSA directed inspection plan"? (C2) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: H2. Yes. Reviewed the PHMSA-ER State Tracking spreadsheet which shows CT to be in compliance with its IA obligations. 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? (C3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: H3. Yes. Spreadsheet dates are within timeframe. 1 1 4 Were 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.) (C4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: H4. NA-there were none in 2013. 1 1 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? (C5) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: H5. NA-there were none in 2013. 1 1 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? (C6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: H6. NA-there were none in 2013. 1 1 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? (C7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: H7. NA-there were none in 2013. 1 1 8 General Comments: Info Only = No Points Evaluator Notes: regulations. Info Only Info Only H8. CT sees value in being an IA. The interstate Operators in CT were found to be in compliance with the inspected for DUNS: 108352811 2013 Natural Gas State Program Evaluation Total points scored for this section: 7 Total possible points for this section: 7 Connecticut CT Dept of Energy and Env Protection, Page: 20#
CT NG Program Evaluation, 2013, page 21PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (B21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: I1-7. NA-CT is not a 60106 Agreement State. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? (B22) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: I1-7. NA-CT is not a 60106 Agreement State. 1 NA 3 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.) (B23) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: I1-7. NA-CT is not a 60106 Agreement State. 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? (B24) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: I1-7. NA-CT is not a 60106 Agreement State. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? (B25) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: I1-7. NA-CT is not a 60106 Agreement State. 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? (B26) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: I1-7. NA-CT is not a 60106 Agreement State. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: I1-7. NA-CT is not a 60106 Agreement State. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 108352811 2013 Natural Gas State Program Evaluation Connecticut CT Dept of Energy and Env Protection, Page: 21#
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