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PHMSA md-2020-gas-program-evaluation
2020 MD NG Program Evaluation - md-2020-gas-program-evaluation (Maryland; Natural Gas State Program Evaluation)
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MD NG Program Evaluation, 2020, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2020 Gas State Program Evaluation for MARYLAND PUBLIC SERVICE COMMISSION Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 1#
MD NG Program Evaluation, 2020, page 22020 Gas State Program Evaluation -- CY 2020 Gas State Agency: Maryland Rating: Agency Status: Date of Visit: 05/10/2021 - 06/23/2021 Agency Representative: Mr. John Clementson Assistant Chief Engineer PHMSA Representative: Clint Stephens State Liaison Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr Jason M. Stanek, Chairman Agency: Maryland Public Service Commission Address: 6 St. Paul Street, 16th Floor City/State/Zip: Baltimore, MD 21201 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2020 (not the status of performance at the time of the evaluation). 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 than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their 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. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 46 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 96 State Rating................................................................................................................................................... 96.0 DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 2#
MD NG Program Evaluation, 2020, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress Info Only Info Only report) Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: 1a. Data in Attachment 1 of Progress Report seems accurate. 1b. Data in Attachment 2 of Progress Report seems accurate based on information submitted to pipeline database. 1c. Data in Attachment 3 of Progress Report seems accurate. 1d. Data in Attachment 4 of Progress Report seems accurate based on information PDM. 1e. Data in Attachment 5 of Progress Report seems accurate. 1f. Information in Attachment 6 of Progress Report seems accurate. 1g. Data in Attachment 7 of Progress Report seems accurate. 1h. Information in Attachment 8 of Progress Report seems accurate. 1i. Information in Attachment 10 of Progress Report seems accurate. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 3#
MD NG Program Evaluation, 2020, page 4PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities 5 5 for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. TIMP and DIMP Inspections (reviewing largest operator(s) plans annually) c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) g. LNG Inspections Evaluator Notes: The pre-inspection procedures are included on page 10, Subpart V, Section B of the MDPSC Pipeline Safety Operation Procedures (SOP) which is required for all type of inspections. The inspection procedures are included on pages 10 thru 17, Subpart V of the MDPSC SOP. The post-inspection procedures are included on pages 17 thru 19, Subpart VI of the MDPSC SOP for all type of inspections. 2 Do written procedures address inspection priorities of each operator, and if necessary each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. 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? 4 4 Evaluator Notes: SOP. Inspection priority procedures are addressed on pages 8 thru 9, Subpart IV, Section B in the Inspection Priorities of the MD 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 3 3 taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: The procedures to identify steps to be taken from discovery to resolution of a probable violation is found on pages 17 thru 19, Subpart VI in the Post Inspection Activities/Enforcement of the MDPSC SOP. 4 (Incident/Accident Investigations) Does the state have written procedures to address state actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. 3 3 DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 4#
MD NG Program Evaluation, 2020, page 5Evaluator Notes: The procedures to address actions in the event of an incident/accident are found on pages 20 thru 24, Subpart VII in the Investigation of Incidents of the MDPSC SOP. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part B of the evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 5#
MD NG Program Evaluation, 2020, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines 5 5 Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead b. Completion of Required DIMP/IMP Training before conducting inspection as lead c. Completion of Required LNG Training before conducting inspection as lead d. Root Cause Training by at least one inspector/program manager e. Note any outside training completed f. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) Evaluator Notes: Acosta, Amroliwala, and Jaiyeola are qualified to perform IM inspections. Tesfaye is qualified to lead gas IM inspections as of March 2021. Samuel Tetteh is qualified to lead standard inspections as of January 2021. Acosta is qualified to perform the LNG inspections as lead. At least one inspector and the program manager have completed the Root Cause Training. There was no outside training completed in 2020. 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: State Pipeline Safety Program Manager displays adequate knowledge of PHMSA program and regulations. The Program Manager has been with the MDPSC for 16 years. 3 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part C of the evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 6#
MD NG Program Evaluation, 2020, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction (did state achieve 20% of total inspection person-days?) g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) 5 4 Evaluator Notes: Standard: Baltimore Gas & Electric (Records 2/25/20 ? Stay of Enforcement 3/31/20 & 10/29/18, Regulator 12/11/20 & 9/17/20, Field leak 9/30/20 & 7/30/20); Petroleum Equipment TA (Records 6/15/20 & 9/27/18) ? 2 months past due; Columbia Gas of Maryland (Records 2/4/20 & 7/9/18, Corrosion 5/15/20 & 5/23/19, Leak Repair 1/29/20 & 3/18/19); Cato Gas Oil (Records 8/27/20 & 2/8/19); Crisfield H/A (Records 2/6/20 & 7/19/18); Deep Creek Mountain Utilities, LLC. (O&M 4/6/20 & 3/9/17); Douglas Pipeline (new operator as of 2020); Baltimore Gas & Electric LNG (Gas Plant 3/31/2021 & 12/20/18) ? 3 months past due; Bonnie Ridge Apts. (Records 10/14/20 & 3/20/19); Briarwood Apts. 2 (Records 9/11/20 & 3/7/19); Burnt Mills Condos (Records 9/9/20 & 1/7/19) ? 2 months past due; Hagerstown H/A (Records 9/25/20 & 3/15/19); Seneca Village (Records 10/30/20 & 5/31/19); The Forest Apts. (Records 3/3/21 & 7/31/19); Verona at Landover Hills (Records 5/15/20 & 10/5/18) ? 1 month past due. Public Awareness: Petroleum Equipment TA (Records 6/15/20 & 9/27/18) ? 2 months past due; Cato Gas Oil (Records 8/27/20 & 2/8/19); Crisfield H/A (Records 2/6/20 & 7/19/18); Deep Creek Mountain Utilities, LLC. (Records 4/22/21 & 10/3/19); Bonnie Ridge Apts. (Records 10/14/20 & 3/20/19); Briarwood Apts. 2 (Records 9/11/20 & 3/7/19); Burnt Mills Condos (Records 9/9/20 & 1/7/19) ? 2 months past due; Hagerstown H/A (Records 9/25/20 & 3/15/19); Seneca Village (Records 10/30/20 & 5/31/19); The Forest Apts. (Records 3/3/21 & 7/31/19); Verona at Landover Hills (Records 5/15/20 & 10/5/18) ? 1 month past due. D & A: Columbia Gas of Maryland (6/1/20 & 5/3/17). Control Room: Baltimore Gas & Electric (10/2/19 & 8/9/16). LNG: Baltimore Gas & Electric LNG (Gas Plant 3/31/2021 & 12/20/18) ? 3 months past due. Construction: Baltimore Gas & Electric (7/2/20), Columbia Gas of Maryland (7/30/20). OQ: Petroleum Equipment TA (4/13/21 & 2/16/18) ? 2 months past due; Cato Gas Oil (8/18/20 & 7/20/17); Crisfield H/A (1/16/20 & 12/21/16); Seneca Village (10/16/20 & 11/17/17). IMP/DIMP: Columbia Gas of Maryland (5/28/20 ? Stay of Enforcement 4/10/20 & 5/2/17); Cato Gas Oil (Scheduled 5/13/21 & 4/13/18); Verona at Landover Hills (5/15/20 ? still open & 10/18/16) ? Past due. 2 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) 10 9 Evaluator Notes: Reviewed inspection reports: Baltimore Gas & Electric (Regulator 12/11/20) form was not filled out completely; Petroleum Equipment TA (Records 6/15/20); Columbia Gas of Maryland (Records 2/4/20); Cato Gas Oil (Records 8/27/20); Crisfield H/A (Records 2/6/20); Deep Creek Mountain Utilities, LLC. (O&M 4/6/20); Bonnie Ridge Apts. (Records 10/14/20); Seneca Village (Records 10/30/20); Petroleum Equipment TA (Public Awareness 6/15/20); Cato Gas Oil (Public Awareness 8/27/20); Crisfield H/A (Public Awareness 2/6/20); Deep Creek Mountain Utilities, LLC. (Public Awareness 4/22/21); Bonnie Ridge Apts. (Public Awareness 10/14/20); Briarwood Apts. 2 (Public Awareness 9/11/20); Burnt Mills Condos DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 7#
MD NG Program Evaluation, 2020, page 8(Public Awareness 9/9/20); Hagerstown H/A (Public Awareness 9/25/20); Seneca Village (Public Awareness 10/30/20); The Forest Apts. (Public Awareness 3/3/21); Verona at Landover Hills (Public Awareness 5/15/20); Columbia Gas of Maryland (D & A 6/1/20); Baltimore Gas & Electric LNG (Gas Plant 3/31/2021) ? needs to better explain N/A when checked; Baltimore Gas & Electric (Construction 7/2/20); Columbia Gas of Maryland (Construction 7/30/20); Petroleum Equipment TA (OQ 4/13/21); Cato Gas Oil (OQ 8/18/20); Crisfield H/A (OQ 1/16/20); Seneca Village (OQ 10/16/20) ? no correspondence with operator on issue found; Columbia Gas of Maryland (DIMP 5/28/20); Verona at Landover Hills (DIMP 5/15/20 ? still open). 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 2 2 should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Reviewed inspection reports Petroleum Equipment TA (OQ 4/13/21); Cato Gas Oil (OQ 8/18/20); Crisfield H/A (OQ 1/16/20); Seneca Village (OQ 10/16/20). No issues identified. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This 2 1 should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 a. Are the state's largest operator(s) plans being reviewed annually to ensure they are completing the full cycle of the DIMP/IMP process? b. Are states verifying with operators any plastic pipe and components that have shown a record of defects/leaks and mitigating those through DIMP plan? c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? Evaluator Notes: Reviewed DIMP inspections for Columbia Gas of Maryland (5/28/20) and Verona at Landover Hills (5/15/20) which have not been completed. The MDPSC has plan to communicate with its two largest operators pertaining to changes to IMP plan in 2021. The records inspection checklist now includes questions for plastic pipe components and low distribution systems threat analysis. 5 Did the state review the following (these items are NTSB recommendations to PHMSA that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. 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); c. 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; d. 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; e. 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; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? 2 2 Evaluator Notes: DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 8#
MD NG Program Evaluation, 2020, page 9MDPSC has added the NTSB recommendations to its gas records inspection checklist in 2021. 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 1 0 Evaluator Notes: MDPSC needs to take appropriate action regarding advisory bulleting by providing link to operators and/or including question in inspection form. 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) 10 10 Evaluator Notes: Reviewed inspection reports for Columbia Gas of Maryland (Records 2/4/20) and Crisfield H/A (OQ 1/16/20). The letter was sent to a company officer, probable violations were well documented with each being resolved, and compliance actions for all violations discovered. Records indicated post briefings were performed within 30 to 90 days. There were no issues. 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? i. Does state share any lessons learned from incidents/accidents? 10 10 Evaluator Notes: There were no reportable incidents in 2020. However, there were a number of events investigated, but were found non- jurisdictional or non-reportable. DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 9#
MD NG Program Evaluation, 2020, page 109 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 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes. Chairman letter sent on November 9, 2020, and response received on January 5, 2021. 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Evaluator Notes: MDPSC participated in pipeline safety seminar in 2019. Info Only Info Only 11 Has state confirmed transmission operators have submitted information into NPMS Info Only Info Only database along with changes made after original submission? Info Only = No Points Evaluator Notes: The MDPSC sends the operator a specific information request which includes the NPMS submission by the operator on an annual basis. 12 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). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Quarterly the MDPSC has a Gas Operators Advisory Committee (GOAC) meeting to discuss pipeline safety issues with all the jurisdictional operators. Also, there is information about the Pipeline Safety Program on the State website. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no open SRCRs. 1 1 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? 1 1 Evaluator Notes: Yes. The State was responsive to information request from NAPSR or PHMSA and completed WMS tasks on time. 15 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. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: MDPSC has no waivers/special permits. 1 1 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes. We were able to gain access of files remotely. Info Only Info Only DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 10#
MD NG Program Evaluation, 2020, page 1117 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 3 3 Evaluator Notes: number for CY2020. Discussed SICT numbers with MDPSC, and determined the information submitted was accurate. The State had updated the 18 Discussion on State Program Performance Metrics found on Stakeholder Communication Info Only Info Only site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Discussed State Program Performance Metrics with MDPSC and found Inspection Activity ? Inspection days per MMO/LPG Units has decreased dramatically from 2019 to 2020; Inspector Qualification - % Core Training has decreased for HL staff from 2019 to 2020; and Leak Management ? Gas distribution system leaks such as total leaks eliminated/repaired, hazardous leaks eliminated/repaired, and scheduled leaks for repair have decreased from 2019 to 2020. All negative trends were explained by Program Manager and no issues were identified. 19 Did the state encourage and promote operator implementation of Pipeline Safety Info Only Info Only Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Evaluator Notes: The MDPSC discussed the PSMS with operators at the Gas Operations Advisory Committee (GOAC) meeting in September 2020. These meetings are held on a quarterly basis. 20 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: The following issues were identified in Part D of the evaluation: (1) The state did not inspect the operators in accordance to time intervals, Petroleum Equipment TA (Records 6/15/20 & 9/27/18) ? 2 months past due; Burnt Mills Condos (Records 9/9/20 & 1/7/19) ? 2 months past due; Petroleum Equipment TA (Public Awareness 6/15/20 & 9/27/18) ? 2 months past due; and Verona at Landover Hills (5/15/20 ? still open & 10/18/16) ? Past due; (2) The state did not fill out inspection forms completely for Baltimore Gas & Electric (Regulator 12/11/20) form was not filled out completely and Baltimore Gas & Electric LNG (Gas Plant 3/31/2021) ? needs to better explain N/A when checked; (3) The state did not complete DIMP inspection for Verona at Landover Hills (5/15/20 ? still open & 10/18/16) ? Past due.; (4) The state did not take appropriate action regarding advisory bulletins issued since last evaluation. Total points scored for this section: 46 Total possible points for this section: 50 DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 11#
MD NG Program Evaluation, 2020, page 12PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Evaluator Notes: Operator: Douglas Pipeline Co. Inspector: John Clementson Location: Virtual Date: June 10, 2020 PHMSA Rep.: Clint Stephens Info Only Info Only MDPSC performed an initial Standard Comprehensive records inspection on the CPV St. Charles pipeline. The operator representative (Andi Shacklett) was present during the inspection. 2 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) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The inspector used the IA equivalent form as a guide for the inspection. 2 2 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: Yes. The inspector adequately reviewed records pertaining to design and construction, emergency preparedness, maintenance and operations, public awareness, reporting, cathodic protection, and training and qualification. The inspection was of adequate length to properly perform the inspection. 4 From your observation did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The inspector showed adequate knowledge of the pipeline safety program and regulations. 2 2 5 Did the inspector conduct an exit interview, including identifying probable violations? (If 1 1 inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. The inspector did conduct an exit interview, indicating records that need to be sent to the state and outlining those issues that were of a concern. DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 12#
MD NG Program Evaluation, 2020, page 136 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Info Only Info Only Evaluator Notes: The inspection was performed in a positive and constructive manner. The state and operator discussed those items that were outlined in the inspection form. 7 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part E of the evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 13#
MD NG Program Evaluation, 2020, page 14PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues. Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: The MDPSC has taken the operator annual report data and analyzed it for trends and operator issues. Reviewed a spreadsheet with annual report for all the operators, showing pipe material, excavation per 1,000 tickets, and number of services. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The MDPSC has a spreadsheet ? "Operators 2020 Damage Prevention Sheet" which gathers data to determine root cause of excavation damages and identifies excavators who repeatedly violate one-call laws and damages their facilities. 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation 4 4 Damage? Yes = 4 No = 0 Needs Improvement = 1-3 a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: The MDPSC has a spreadsheet ? "Operators 2020 Damage Prevention Sheet" which gathers data from Part D ? Excavation Damage of the annual report. They have gathered the data such as, "One Call Notification Practices Not Sufficient", "Locating Practices Not Sufficient, and "Excavation Practices Not Sufficient". This information is accurate with root causes. These items will be discussed with operator in CY2021. 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? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? 2 2 DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 14#
MD NG Program Evaluation, 2020, page 15c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? Evaluator Notes: The MDPSC has a spreadsheet ? "Operators 2020 Damage Prevention Sheet" which gathers data to determine root cause of excavation damages and identifies excavators who repeatedly violate one-call laws and damages their facilities. Once the numbers are analyzed, then focus will be made appropriately to damage prevention education and training to address the causes of excavation damage. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part F of the evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 15#
MD NG Program Evaluation, 2020, page 16PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections? Info Only = No Points Evaluator Notes: The MDPSC is not an interstate agent. Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days? Info Only = No Points Evaluator Notes: The MDPSC is not an interstate agent. 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: The MDPSC is not an interstate agent. Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: The MDPSC is not an interstate agent. Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: The MDPSC is not an interstate agent. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: The MDPSC is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 839662079 2020 Gas State Program Evaluation Maryland MARYLAND PUBLIC SERVICE COMMISSION, Page: 16#
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