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2010 DC NG Program Evaluation - dc2010ngprogramevaluation (District of Columbia; Natural Gas State Program Evaluation)
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DC NG Program Evaluation, 2010, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2010 Natural Gas State Program Evaluation for Public Service Commission of the District of Columbia 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: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 1#
DC NG Program Evaluation, 2010, page 22010 Natural Gas State Program Evaluation -- CY 2010 Natural Gas State Agency: District of Columbia Agency Status: Date of Visit: 03/28/2011 - 05/18/2011 Agency Representative: Udeozo Ogbue PHMSA Representative: Dino N. Rathod, P.E. Commission Chairman to whom follow up letter is to be sent: Name/Title: Betty Ann Kane, Chairman Agency: Public Service Commision of District of Columbia Address: 1333 H Street City/State/Zip: Washington, DC 20005 Rating: 60105(a): Yes 60106(a): No Interstate Agent: No 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 2010 (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 25 B Inspections and Compliance - Procedures/Records/Performance 24.5 24 C Interstate Agent States 0 0 D Incident Investigations 3.5 3.5 E Damage Prevention Initiatives 9 9 F Field Inspection 11 11 G PHMSA Initiatives - Strategic Plan 9 9 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 95 93.5 State Rating................................................................................................................................................... 98.4 DUNS: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 2#
DC NG Program Evaluation, 2010, 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 SLR Notes: Incident reporting per 15 DCMR, Para. 2306 1 1 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: DC PSC staff participated in a Maryland PSC sponsored T&Q semianr May 2010 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 SLR Notes: PSC inspection files (hard copies + electronic database) are kept in a secure bldg. Files are well-organized and easily accessible. 1 1 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 1 SLR Notes: Udeozo Ogbue continues to take T&Q courses and training required. He completed 2 T&Q courses and scheduled to take 1 more. I discussed with him timeline to complete State Guideline Manual Ch 4.1 T&Q mandatory course requirements. 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 SLR Notes: DC PSC Chairman letter dated Feb 4, 2011 was received within 60 days. 1 1 7 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the 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 DUNS: 116190414 2010 Natural Gas State Program Evaluation 1 1 District of Columbia Public Service Commission of the District of Columbia, Page: 3#
DC NG Program Evaluation, 2010, page 4SLR Notes: DC PSC continues to help resolve issues raised by PHMSA evaluation last year. However, DCMR changes were not finalized at the time of 2011 annual evaluation. PSC met PHMSA legal staff. PSC intends to finalize in a timely manner and inform PHMSA when these proposed changes are published in the DC Register 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 SLR Notes: M Singh waitlisted for Public Awareness training-PL 3365 Sept 2011 A Bagayoko- scheduled to complete Public Awareness training-PL 3365 June 2011. U. Ogbue was scheduled to attend two T&Q courses- PL2258 and 1250 Aug 2011; wait listed for PL 1245 since Jul 2010 3 3 9 Brief Description of Non-TQ training Activities: Info Only = No Points For State Personnel: Info Only Info Only For Operators: For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: 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 1 1 SLR Notes: M Singh has completed OQ Training PL3OQ 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 SLR Notes: M Singh has completed IMP training course PL 1297. 1 1 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): 172.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 2.00 = 440.00 Ratio: A / B 172.00 / 440.00 = 0.39 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 SLR Notes: A.Total Inspection Person Days (Attachment 2)= 172 B.Total Inspection Person Days Charged to the program(220*Number of Inspection person years(Attachment 7)=440 Formula:- Ratio = A/B = 172/440 = 0.39 Rule:- (If Ratio >=.38 then points = 5 else Points = 0.) Thus Points = 5 5 5 DUNS: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 4#
DC NG Program Evaluation, 2010, page 513 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Info Only Info Only Question B.13 Info Only = No Points SLR Notes: 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 25 Total possible points for this section: 26 DUNS: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 5#
DC NG Program Evaluation, 2010, 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: 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: 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: 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: 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 Yes = 1 No = 0 1 1 SLR Notes: 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: No SRC in CY 2010 DUNS: 116190414 2010 Natural Gas State Program Evaluation .5 NA District of Columbia Public Service Commission of the District of Columbia, Page: 6#
DC NG Program Evaluation, 2010, page 77 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) Previous Question B.7 Yes = .5 No = 0 SLR Notes: Check List EN-17, Part 192.489 and WG Procedure 4084 cover this item .5 .5 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: Check List EN-17, 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: Check List EN-17, Part 192.605 (b), (c) and (d) cover it. .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 B.10 Yes = 1 No = 0 1 1 SLR Notes: 11 SLR Notes: Compliance - 60105(a) States Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous Question B.14 Yes = 1 No = 0 Needs Improvement = .5 1 1 12 SLR Notes: 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 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 1 1 SLR Notes: 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 1 1 SLR Notes: DUNS: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 7#
DC NG Program Evaluation, 2010, 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: PSC found possible non-compliance and issued one NOPV in 2010. 1 1 16 SLR Notes: 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 1 1 17 SLR Notes: 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 1 1 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question 1 .5 D(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Discussed with PSC need to maintain all supporting pertinent document in resolution of probable violations. These should include, as a minimum, what did inspector observe/ find possible non-compliance by operator, appropriate follow-up actions from PSC and responses from operator and details on resolution of each probable violation. PHMSA strongly encourages strong, fair and consistent enforcment of non-compliance issues encounterd as part of pipeline inspections, incident investigations etc. 19 SLR Notes: 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 .5 .5 20 SLR Notes: 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 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 DUNS: 116190414 2010 Natural Gas State Program Evaluation 1 NA District of Columbia Public Service Commission of the District of Columbia, Page: 8#
DC NG Program Evaluation, 2010, page 9SLR Notes: 24 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 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Info Only = No Points Info Only Info Only SLR Notes: 28 Part B: General Comments/Regional Observations Info Only = No Points Info Only NA SLR Notes: Total points scored for this section: 24 Total possible points for this section: 24.5 DUNS: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 9#
DC NG Program Evaluation, 2010, 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: DC PSC is not an Interstate Agent. 1 NA 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: DC PSC is not an Interstate Agent. 1 NA 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: DC PSC is not an Interstate Agent. 1 NA 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 NA 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: DC PSC is not an Interstate Agent. 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: DC PSC is not an Interstate Agent. 1 NA 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: DC PSC is not an Interstate Agent. 1 NA 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: DC PSC is not an Interstate Agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 10#
DC NG Program Evaluation, 2010, 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: Per DCMR 2306.5. In addiotn, the successful integration of DC PSC's telephone and e-mail system for the retrieval of WGL's Gas Leak, Odor, Incident Reports, and other utility safety program performance data was accomplished with a system called CISCO Unified Messaging Platform 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: PSC reviews incoming information and make appropriate determination. PSC may obtain additional information to help make a decision. 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 b. Contributing Factors c. Recommendations to prevent recurrences where appropriate SLR Notes: No Reportable Incidents in CY 2010 2 NA Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement 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 SLR Notes: No Reportable Incidents in CY 2010 1 NA 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: No Reportable Incidents in CY 2010 .5 NA 8 Part D: General Comments/Regional Observations Info Only = No Points SLR Notes: No Reportable Incidents in CY 2010 Info Only Info Only DUNS: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 11#
DC NG Program Evaluation, 2010, page 12Total points scored for this section: 3.5 Total possible points for this section: 3.5 DUNS: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 12#
DC NG Program Evaluation, 2010, 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: DC PSC has reviewed WG procedures for Directional Drilling ( Washington Gas Engineering & Operating Stds, Section 7930 Trenchless Installation) 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: PSC Inspection Form/ Check list for Plastic Pipe and Steel Pipe- Inspector notes Miss Utility Ticket# , verifies validity, locate accuracy etc. 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: Before You Dig message. PSC actively supports damage Prevention activities and promotes CGA. April 2010 was observed as National Safe Digging month and emphasized Call 811 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 1 1 SLR Notes: DC collects and reviews damage data for trends. 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: PSC reviews operator records including incident/ failure of pipelines. In addition, PSC performed One Call Grant project in 2010. PSC inspected underground facility markings and verified accuracy and timeliness of responses 6 Part E: 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: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 13#
DC NG Program Evaluation, 2010, 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: Washingtn Gas Name of State Inspector(s) Observed: Manmohan Singh Location of Inspection: Nicholsn St, NE Washington, DC, Date of Inspection: 03/28/2011, 03/29/2011; 04/12/2011 Name of PHMSA Representative: Dino N.Rathod, P.E. SLR Notes: Multiple day inspection activities. March 28 Construction- replacement of low pressure gas service with newplastic gas service; March 29- valve maintenance for distribution transmission pipeline (300 psi max) 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: 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: 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: Construction- repalcement of low pressure steel service to a residience; valve maintenance on 300 psi trnasmission pipeline. 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 SLR Notes: DUNS: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 14#
DC NG Program Evaluation, 2010, page 15DIMP- Implementation considerations 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 2 2 SLR Notes: 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 1 1 SLR Notes: 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous Question F.11 Yes = 1 No = 0 SLR Notes: No issues were found during multiple days of field activities 1 NA 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Info Only = No Points SLR Notes: Construction, valve maintenance on 300 psi distribution transmission pipe and DIMP implementation status review. Info Only Info Only 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 p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings DUNS: 116190414 2010 Natural Gas State Program Evaluation Info Only Info Only District of Columbia Public Service Commission of the District of Columbia, Page: 15#
DC NG Program Evaluation, 2010, page 16u. 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: DIMP implementation status review 14 Part F: General Comments/Regional Observations Info Only = No Points SLR Notes: DUNS: 116190414 2010 Natural Gas State Program Evaluation Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 District of Columbia Public Service Commission of the District of Columbia, Page: 16#
DC NG Program Evaluation, 2010, 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 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: PSc pays close attention to issues such as : Dead Ends and Service pipe Replacement, coupling encaptulation. 1.5 1.5 2 Are inspection units broken down appropriately? (see definitions in Guidelines) Yes = .5 No = 0 SLR Notes: Washington Gas isthe only LDC in DC area. .5 0.5 3 Consideration of operators DIMP Plan? (if available and pending rulemaking) Info Only = No Points Info Only Info Only SLR Notes: 4 Does state inspection process target high risk areas? Yes = .5 No = 0 SLR Notes: PSC pays close atentionto cast iron and bare steel pipe repalcement and construction activities, .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) Yes = .5 No = 0 SLR Notes: PSC receives and analyzes Washington Gas data for effectiveness for damage prevention. .5 0.5 6 Has state reviewed data on Operator Annual reports for accuracy? Yes = .5 No = 0 SLR Notes: PSC has reviewed CY 2010 Operator Annual Reports for accuracy. .5 0.5 7 Has state analyzed annual report data for trends and operator issues? Yes = .5 No = 0 SLR Notes: PSC reviews annual data for operator issues etc. PSC also recieves quarterly damage data. .5 NA 8 Has state reviewed data on Incident/Accident reports for accuracy? Yes = .5 No = 0 SLR Notes: No Reportable Incidents in CY 2010. However, PSC reviews WG reports and records for accuracy. .5 0.5 DUNS: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 17#
DC NG Program Evaluation, 2010, page 189 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: PSC reviews WG damage reports(quarterly), leak repair status and annual reports. PSC also reviews and monitors construction activities to repalce CI and bare steel mains and new pipe installations. 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: PSC performed 18 OQ inspections (field verification) in CY 2010. .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: PSC indicated that there wee no operatro notifications in IMDB. .5 NA 12 Have the IMP Federal Protocol forms been uploaded to the IMDB? Previous Question B.17 Yes = .5 No = 0 SLR Notes: PSC uploaded IMP inspections in IMDB ( in 2009) .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 SLR Notes: PSC has asked WG for plastic pipe issues, if any. None were found. .5 0.5 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: PSC indiated that WG completed submission into NPMS in CY 2009. .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: PSC presented and shared at ER NAPSR meeting .5 0.5 16 Does the State support data gathering efforts concerning accidents? (Frequency/Consequence/etc) .5 0.5 Yes = .5 No = 0 SLR Notes: PSC receives incident data from WGL. However PSC is unable to require data from others. 17 SLR Notes: Does state have incident/accident criteria for conducting root cause analysis? Info Only = No Points Info Only Info Only 18 Does state conduct root cause analysis on incidents/accidents in state? Info Only = No Points DUNS: 116190414 2010 Natural Gas State Program Evaluation Info Only Info Only District of Columbia Public Service Commission of the District of Columbia, Page: 18#
DC NG Program Evaluation, 2010, page 19SLR Notes: 19 Has state participated on root cause analysis training? (can also be on wait list) Yes = .5 No = 0 .5 0.5 SLR Notes: Udeozo Ogbue completed Root Cause Analysis Training in Feb 2010. 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 .5 0.5 SLR Notes: DC PSC observed April 2011 as National Safe Digging Month and encourage Call 811 Before Start Digging Activities. 21 Does state share enforcement data with public? (Website, newsletters, docket access, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: DC PSC website: http://www.dcpsc.org/pipelinesafety.asp. PSC also provides links to e-docket system 22 Part G: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 19#
DC NG Program Evaluation, 2010, 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. DC continues to monitor replacement of cast iron and bare steel pipe including vintage coupling with encapsulation method. 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: DC initiated steps to resolve issues identified in 2010 annual evaluation. At this time no final outcome yet. DC indicated that the Proposed changes are expected to be released upon final review by DC PSC Chairman and send to DC Register. 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 DC monitors CI and Bare Steel repalcement activities. 2. DC PSC receives and reviews quarterly Damage Data from WGL. 4 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 1 1 SLR Notes: PSC responded to Staffing level request. 5 Sharing Best Practices with Other States - (General Program) Yes = .5 No = 0 .5 0.5 SLR Notes: DC PSC shared at ER NASPR meeting at Essex Junction, VT. 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: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 20#
DC NG Program Evaluation, 2010, 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 SLR Notes: DC conducted comprehensive D&A insepction Form EN-10 of WG in 2009 1 1 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: DC conducted comprehensive D&A insepction Form EN-10 of WG in 2009; Page 3 Post Incident and Random Test (Part 199.105) .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: DC conducted comprehensive D&A insepction Form EN-10 of WG in 2009; Positive Test per Part 199.103 .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: PSC has completed 2 OQ Plan Reviews in 2009 and 18 OQ inspections in 2010. 1 1 5 Has the state reviewed operator qualification programs for compliance with PHMSA rules and protocols? Yes = .5 No = 0 .5 0.5 SLR Notes: 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 SLR Notes: .5 0.5 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: 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: PSC performed Gas transmission IMP inspection in Nov/Dec 2009. DC used federal IMP protocols A thru N. 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: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 21#
DC NG Program Evaluation, 2010, page 2210 Has the state reviewed operator IMPs for compliance with Subpart O? (In accordance with State Inspection plan) Yes = .5 No = 0 SLR Notes: .5 0.5 11 SLR Notes: 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 12 SLR Notes: Is the state verifying that operators are periodically examining their transmission line routes for the appearance of new HCAs? Yes = .5 No = 0 .5 0.5 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: Public Awareness (PA) inspection in Dec 2006 (Clearinghouse participation) aPSC performed PA inspection in 2009 .5 0.5 14 SLR Notes: 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 .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: 116190414 2010 Natural Gas State Program Evaluation District of Columbia Public Service Commission of the District of Columbia, Page: 22#
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