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PHMSA ma2011ngprogramevaluation
2011 MA NG Program Evaluation - ma2011ngprogramevaluation (Massachusetts; Natural Gas State Program Evaluation)
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MA NG Program Evaluation, 2011, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2011 Natural Gas State Program Evaluation for MA DEPT. OF PUBLIC UTILITIES 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: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 1#
MA NG Program Evaluation, 2011, page 22011 Natural Gas State Program Evaluation -- CY 2011 Natural Gas State Agency: Massachusetts Rating: Agency Status: Date of Visit: 11/26/2012 - 11/30/2012 Agency Representative: Jorge Santi PHMSA Representative: Dinubhai (Dino) N. Rathod Commission Chairman to whom follow up letter is to be sent: Name/Title: Ann G. Berwick, Chair Agency: Massachusetts Department of Public Utilities Address: One South Station City/State/Zip: Boston, MA 02110 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 2011 (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 9 7.5 B Program Inspection Procedures 15 9.5 C Program Performance 43 37 D Compliance Activities 14 14 E Incident Investigations 3 3 F Damage Prevention 8 8 G Field Inspections 11 11 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 103 90 State Rating................................................................................................................................................... 87.4 DUNS: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 2#
MA NG Program Evaluation, 2011, 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: MA provided accurate data for Jurisdictional Authority and Operator/Inspection Units. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 1 0.5 Evaluator Notes: MA DPU performed IMP and OQ inspections but did not indictate in Attachment 2. Discussed with DPU need to to revise and show corrected Inspection days devoted to IMP and OQ activities. DPU agreed to submit marked-up copy of these changes to Zach for his concurrence and implementation in FedStar ASAP. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress 1 1 Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Discused with DPU possible minor discrepency between Attachment 1 & 3 regarding Insepction Units. DPU to review and revise, if necessary. 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: No Reportable Incidents in CY 2011 1 NA 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DPU provided accurate Compliance Activities - 1 1 6 Were pipeline program files well-organized and accessible? - Progress Report 2 1 Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Discussed with DPU need for better organization and accessibility for all required supporting documents related to completed inspections forms/ check lsits and DPU activities. DPU indicated that the Commission intends to implement an enhanced capability for database allowing electronic records, sort and track etc. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 (A1g) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report 1 1 Attachment 8 (A1h) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DPU needs to finalize steps to Adopt federal amendments in a timely manner. DPU agreed to take care of this issue and adopt all necessary federal code amendments within time limit.DUNS: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 3#
MA NG Program Evaluation, 2011, 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 DPU hired an inspector in CY 2011. Inaddiotn, inspector has started taking T&Q courses. State lifted out-of -state travel ban so inspecots resumed sending inspectors to T&Q training courses. 1 1 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 7.5 Total possible points for this section: 9 DUNS: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 4#
MA NG Program Evaluation, 2011, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) Yes = 2 No = 0 Needs Improvement = 1 2 1 Evaluator Notes: Discussed with DPU need to review and provide pertinent details of Standard Inspection Procedure (see PHMSA Guideline manual Ch 5, Para 5.1.3(a) 2 IMP Inspections (including DIMP) (B1b) 1 0.5 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Discussed with DPU need to review and provide pertinent details of IMPInspection Procedure (see PHMSA Guideline manual Ch 5, Para 5.1.3(d & e) 3 OQ Inspections (B1c) 1 0.5 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Discussed with DPU need to review and provide pertinent details of Standard Inspection Procedure (see PHMSA Guideline manual Ch 5, Para 5.1.3(f) 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 5 On-Site Operator Training (B1e) 1 0.5 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Discussed with DPU need to review and provide pertinent details of On-Site Operator Training Inspection Procedure (see PHMSA Guideline manual Ch 5, Para 5.1.3(c) 6 Construction Inspections (B1f) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DPU Inspection Procedures- Section 7 8 Does inspection plan address inspection priorities of each operator, and if necessary each 6 3 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 DUNS: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 5#
MA NG Program Evaluation, 2011, 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: Yes No Needs Improvement Yes No Needs Improvement Discussed with DPU need to make modifications to Inspection Procedures and develop inspection plan with priorities of each operator. DPU must document these items and make readily available for use including PHMSA program annual evaluation. 9 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Discussed with DPU to make changes conveyed as part of PHMSA annual evaluation(s). DPU agreed to address pending review and modification to thier own Inspection Procedures Manual. Total points scored for this section: 9.5 Total possible points for this section: 15 DUNS: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 6#
MA NG Program Evaluation, 2011, 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): 841.17 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 6.83 = 1503.33 Ratio: A / B 841.17 / 1503.33 = 0.56 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Ratio> 0.38 5 points 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: For CY 2011- Verified that each DPU inspector and program manager fulfilled the T Q Training Requirements 3 Did state records and discussions with state pipeline safety program manager indicate 2 2 adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: For CY 2011 Chris Bourne was Program Manager/ Director. DPU made changes to Program Manager position effective Sept 2012 with selection of Jorge Santi. Both of them provide many years of pipeline safety regulatory experience. 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 2 2 Evaluator Notes: DPU attempted tor resolve the issue of Civil Penalties not substantially same as federal amounts. However it did not succceed. DPU indicated that it intends to bring this issue for legislative considerations. 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) 2 2 Yes = 2 No = 0 Evaluator Notes: MA DPU particiapted in NEPSR seminar in OCt 2012. This is hosted by sic New England states (CT. MA.ME. NH,RI and VT). 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 5 3 Evaluator Notes: Discussed with DPU need for a verifiable inspection plan to implement inspection activities in accordance with "time DUNS: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 7#
MA NG Program Evaluation, 2011, page 8intervals" per Inspection Procedures. DPU was reminded of need for making available proper supporting inspection reports/ completed inspection forms/ check list documents 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 1 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: 1 Discussed with DPU need for revising all applicable check lists/ inspection forms and making sure that all applicable code requirements addressed on Federal Inspection form are covered. 2. DPU needs to maintain all completed check lists/ forms and making them easily available during PHMSA state program annual evaluation. DPU agreed and indicated that it intends to develop an enhance electronic database capability including appropriate inspedtion forms/ check lists beginning CY 2013. 8 Did the state review operator procedures for determining if exposed cast iron pipe was 1 1 examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 (B7) Yes = 1 No = 0 Evaluator Notes: CY 2011 DPU reviewed operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization. 9 Did the state review operator procedures for surveillance of cast iron pipelines, including 1 1 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: In CY 2011 DPU inspectors reviewed operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history etc. 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 1 1 Evaluator Notes: In CY 2011 DPU reviewed operator emergency response procedures for leaks caused by excavation damage near buildings. 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: In CY 2011 DPU inspectors reviewed operator records of previous accidents and failures including reported third party damage and leak responses 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: IN CY 2011DPU inspectors reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends. 13 Did state input all applicable OQ, IMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 (G10-12) DUNS: 084885826 2011 Natural Gas State Program Evaluation 2 1 Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 8#
MA NG Program Evaluation, 2011, page 9Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: IN CY 2011 DPU conducted IMP & OQ inspections (National Grid /KeySapn, MMEC & Baystate Gas). However, review of federal database (IMDB & OQDB) indicated lack of timely upload of completed inspection protocol forms. I emphasized need for timely upload and minimize unncessary delays. DPU agreed to adresss and resolve this issue. 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 1 1 Evaluator Notes: In CY 2011 DPU confirmed intrastate transmission operators have submitted information into NPMS database. 15 Is the state verifying operators are conducting drug and alcohol tests as required by 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: CY 2011 DPU verified that operators are conducting drug and alcohol tests as required by regulations. 2 2 16 Is state verifying operators OQ programs are up to date? This should include verification 2 1 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: IN CY 2011 DPU conducted OQ inspections but did not complete necessary OQ Protocol forms. I discussed and emphasized need for completed inspection forms (protocols) and be finalized in OQDB. DPU agreed to review and resolve this issue. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 1 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: CY 2011 DPU did not complete IMP inspection activities. I discussed and emphasized need for gas transmission IMP Plan reviews and be able to verify pertinent operator records. DPU agreed to review and resolve gas transmission IMP inspection issue. 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? Info Only Info Only 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 Info Only = No Points Evaluator Notes: DPU has indicated that inspectors will intiate review of DIMP Plans and pertinent records. This activities are expected to take substantial amount of inspection time in 2013/2014. 19 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) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: CY 2011 DPU received Public Awareness Plan(s) and continues to review. 2 2 DUNS: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 9#
MA NG Program Evaluation, 2011, page 1020 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). (G20-21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DPU has website and allows Access to Dockets. http://www.env.state.ma.us/dpu_fileroom/FRM docketlookup 1 1 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: CY 2011 NO SRC. 1 NA 22 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? (G13) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 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: CY 2011- DPU participated in/responded to surveys or information requests from NAPSR or PHMSA. 1 1 24 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Discussed with DPU need for major effort to resolve issues of Inspection Procedure Manual revisions, Inspection check lists/ forms to document necesary inspection activities and make commitment for timely uploads in various federal databases. DPU indicated that they intend to commit to enahnced database capability to allow electronic forms/ check lists , ability to track and sort various actions. DPU will keep PHMSA advised of progress to avoid breakdown. Total points scored for this section: 37 Total possible points for this section: 43 DUNS: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 10#
MA NG Program Evaluation, 2011, page 11PART 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: Dept of Public Utilities 220 MCR 69 "Procedures for Determination of Violations....." 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 Evaluator Notes: Dept of Public Utilities 220 MCR 69 "Procedures for Determination of Violations....." 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: CY 2011- DPU found 6 Probable Violations. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. (B17, B20) Yes = 2 No = 0 Evaluator Notes: Dept of Public Utilities 220 MCR 69 "Procedures for Determination of Violations....." 2 2 5 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) (B27) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes; Progam imposes civil penalties as a deterent. DPU assesed $81,000 civil penalties in CY 2011. 2 2 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety Info Only Info Only violations? (new question) Info Only = No Points Evaluator Notes: DPU assesed $81,000 civil penalties in CY 2011. 7 General Comments: Info Only = No Points Evaluator Notes: Dept of Public Utilities 220 MCR 69 "Procedures for Determination of Violations....." Info Only Info Only Total points scored for this section: 14 Total possible points for this section: 14 DUNS: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 11#
MA NG Program Evaluation, 2011, page 12PART 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: 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: DPU obtained sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site. 3 Were all incidents investigated, thoroughly documented, and with conclusions and 3 NA 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: CY 2011- No Reportable gas incidents (in CY 2011 Progress Reprot Attachment 4) 4 Did the state initiate compliance action for violations found during any incident/accident investigation? (D6) Yes = 1 No = 0 Evaluator Notes: CY 2011- No Reportable gas incidents. 1 NA 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: CY 2011- No Reportable gas incidents. 1 NA 6 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) (G15) Yes = 1 No = 0 Evaluator Notes: CY 2011- No Reportable gas incidents. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 084885826 2011 Natural Gas State Program Evaluation Info Only Info Only Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 12#
MA NG Program Evaluation, 2011, page 13CY 2011- No Reportable gas incidents. Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 13#
MA NG Program Evaluation, 2011, page 14PART 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: In CY 2011- DPU reviewed directional drilling/boring procedures 2 2 2 Did the state inspector check to assure the pipeline operator is following its written 2 2 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: In CY 2011- DPU state inspector checked 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 Dig Safe system. 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: In CY 2011 DPU encouraged and promoted practices for reducing damages to all underground facilities to its regulated companies? (promoting/adopting the Common Ground Alliance (CGA) Best Practices encouraging adoption of the 9 Elements. 4 Has the agency or another organization within the state collected data and evaluated 2 2 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: In CY 2011 DPU 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. 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only CY 2011- reviewed Dig Safe data including types of damages, trends, amount of fines levied and collected. Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 14#
MA NG Program Evaluation, 2011, page 15PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Columbia Gas of MA and N-Statr Name of State Inspector(s) Observed: Glen LaChance/ Richard Wllace and Jorge Santi Location of Inspection: Brockton and Marlboro Date of Inspection: 11/28/2012 Name of PHMSA Representative: Dinubhai (Dino) N. Rtahod Evaluator Notes: Info Only Info Only DIMP implementation -status review of Columbia Gas of MA and N-Statr "Take Station" review in Marlboro. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? (F2) Yes = 1 No = 0 Evaluator Notes: Company representatives were notified and were present for these field activities 1 1 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 Evaluator Notes: DPU inspector used inspection check lists 2 2 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Both DPU inspectors thoroughly document results of the inspection activities 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.) (F5) Yes = 1 No = 0 Evaluator Notes: 1 1 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 b. Records c. Field Activities d. Other (please comment) Evaluator Notes: Columbia Gas of MA- DIMP Plan Status review N-Star Take Station- maintenance / reiew 2 2 DUNS: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 15#
MA NG Program Evaluation, 2011, page 167 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 Both inspector have many years of pipline safety experience . They also have taken necessary T&Q training courses. 8 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) (F9) Yes = 1 No = 0 Evaluator Notes: Both inspectors conducted exit interviews. 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) (F10) Yes = 1 No = 0 Evaluator Notes: No probable vioataions were found during these field activities. 1 NA 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 A. Repairs B. Signs C. Tapping D. Valve Maintenance E. Vault Maintenance DUNS: 084885826 2011 Natural Gas State Program Evaluation Info Only Info Only Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 16#
MA NG Program Evaluation, 2011, page 17F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: 1 Columbia Gas of MA- Review DIMP Implementation status; 2 N-Star Take Station maintenance in Marlboro. N-Star employees performed maintenance activities. In addition odorization of incoming gas and pipe coating showing sign of mild corrosion/ peeling off in few places. N-Star to adress these minor concerns. Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 17#
MA NG Program Evaluation, 2011, page 18PART 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: MA DPU is only 60105(a) Certification state. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? (C2) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: MA DPU is only 60105(a) Certification state 1 NA 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: 1 NA 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: 1 NA 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: 1 NA 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: 1 NA 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: 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: MA DPU is only 60105(a) Certification state intrastate natural gas Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 18#
MA NG Program Evaluation, 2011, page 19PART 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: MA DPU is only 60105(a) Certification state intrastate natural gas 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: MA DPU is only 60105(a) Certification state intrastate natural gas 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: MA DPU is only 60105(a) Certification state intrastate natural gas 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: MA DPU is only 60105(a) Certification state intrastate natural gas 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: MA DPU is only 60105(a) Certification state intrastate natural gas 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: MA DPU is only 60105(a) Certification state intrastate natural gas 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: MA DPU is only 60105(a) Certification state intrastate natural gas Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 084885826 2011 Natural Gas State Program Evaluation Massachusetts MA DEPT. OF PUBLIC UTILITIES, Page: 19#
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