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PHMSA me-2020-gas-program-evaluation
2020 ME NG Program Evaluation - me-2020-gas-program-evaluation (Maine; Natural Gas State Program Evaluation)
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RegulusPipeline researchRegulusPipeline researchPHMSA me-2020-gas-program-evaluation
ME 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 MAINE PUBLIC UTILITIES 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: 002235294 2020 Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 1#
ME NG Program Evaluation, 2020, page 22020 Gas State Program Evaluation -- CY 2020 Gas State Agency: Maine Rating: Agency Status: Date of Visit: 07/13/2021 - 07/15/2021 Agency Representative: Mr. Gary Kenny Gas Safety Manager PHMSA Representative: Clint Stephens State Liaison Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. Philip L. Bartlett, Chairman Agency: Maine Public Utilities Commission Address: 26 Katherine Drive City/State/Zip: Hallowell, ME 04347 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 47 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 97 State Rating................................................................................................................................................... 97.0 DUNS: 002235294 2020 Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 2#
ME 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 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. Information in Attachment 1 of Progress Report seems accurate. 1b. Information in Attachment 2 of Progress Report seems accurate. 1c. Information in Attachment 3 of Progress Report seems accurate. 1d. Information in Attachment 4 of Progress Report seems accurate. No reportable incidents in CY 2020. 1e. Information in Attachment 5 of Progress Report seems accurate. 1f. Information in Attachment 6 of Progress Report seems accurate. 1g. Information 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. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 002235294 2020 Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 3#
ME 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 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: Yes. The procedures are in Appendix C, section C of the MPUC Standard Operating Procedures. 5 5 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? Evaluator Notes: The procedures are in Appendix C, section B of the MPUC Standard Operating Procedures. 4 4 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 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 are in Appendix D of the MPUC Standard Operating Procedures. 3 3 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. Evaluator Notes: The procedures are contained in Appendix E of the MPUC SOPs. 3 3 DUNS: 002235294 2020 Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 4#
ME NG Program Evaluation, 2020, page 55 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part B of the evaluation. DUNS: 002235294 2020 Gas State Program Evaluation Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 5#
ME 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: The MPUC has fulfilled all the training requirements, except for Sean Watson has not taken the LNG course. He is currently on the waitlist. 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 Evaluator Notes: Yes. The state program manager indicates adequate knowledge of PHMSA program and regulations. 5 5 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: 002235294 2020 Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 6#
ME 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 3 Evaluator Notes: Reviewed inspection intervals for Maine Natural Gas ? Standard O&M Records (11/24/20 & 5/18/17), PA (12/3/18), D&A (5/3/17), Construction (4/7/20), OQ (11/13/18), DIMP (11/18/2020 & 5/25/17); Bangor Natural Gas Co. Transmission ? Standard O&M Records (12/22/20 & 10/29/19), PA (2/28/18), D&A (3/16/18), Construction (N/A), TIMP (12/2/20 & 7/27/15), OQ (1/8/18); Northern Utilities LNG ? Standard O&M Records (2/14/21 & 6/30/19), PA (1/4/21 & 4/21/16), D&A (12/22/20 & 6/15/17), CRM (1/31/19), OQ (12/1/20 & 12/29/16); Highlands Fuel Delivery dba Irving Oil facility #1926 ? Standard (7/8/19), DIMP (6/9/14 past due 2019), OQ (not performed); M. W. Sewall Co. #460 (4/30/19 non-jurisdictional), DIMP (8/27/14, past due 2019), OQ (not performed); Eastern Propane #1905 ? Standard (5/12/20), DIMP (3/10/14 , past due 2019), OQ (not performed); Dead River Co. # 610 ? Standard (6/22/20 & 6/11/18), DIMP (1/6/15 past due 2020), OQ (not performed); Community Energy #1801 ? Standard (5/16/17), DIMP (7/24/14 past due 2019), OQ (not performed); Dodge Oil Company, Inc. #383 ? Standard (5/20/19), DIMP (8/20/14 past due 2019). 2 Did inspection form(s) cover all applicable code requirements addressed on Federal 10 10 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) Evaluator Notes: Reviewed inspection reports for Maine Natural Gas ? Standard O&M Records (11/24/20 - IA), Construction (4/7/20); DIMP (11/18/20); Bangor Natural Gas Co. Transmission ? Standard O&M Records (12/22/20), TIMP (12/2/20); Northern Utilities LNG D&A (12/22/20), OQ (12/1/20); Eastern Propane #1905 ? Standard (5/12/20); Dead River Co. # 610 ? Standard (6/22/20). 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 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: DUNS: 002235294 2020 Gas State Program Evaluation 2 1 Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 7#
ME NG Program Evaluation, 2020, page 8The MPUC has not performed OQ program inspection on its LPG operators. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This 2 2 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 inspection reports Maine Natural Gas ? DIMP (11/18/20) and Bangor Natural Gas Co. Transmission ? TIMP (12/2/20). All the operators are required to submit their plan to the MPUC by May 1st each calendar year. Plastic pipe fitting defects is a part of the Maine Gas Rule. Unitil is the only operator with low pressure system and it is a part of their DIMP. No issues. 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: The MPUC has included the NTSB recommendations in their findings when using the IA equivalent forms which includes them in the considerations. Unitil is the only operator with low pressure system and the MPUC has discussed the issue with the operator. Additionally, the MPUC sent emails to all the operators pertaining to inside meter sets. 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 1 Evaluator Notes: The MPUC has been emailing the operators information pertaining to advisory bulletins issued since last evaluation. DUNS: 002235294 2020 Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 8#
ME NG Program Evaluation, 2020, page 97 (Compliance Activities) Did the state follow compliance procedures (from discovery to 10 10 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) Evaluator Notes: Reviewed inspection reports for Maine Natural Gas ? Standard O&M Records (11/24/20 - IA), Construction (4/7/20); DIMP (11/18/20); Bangor Natural Gas Co. Transmission ? Standard O&M Records (12/22/20), TIMP (12/2/20); Northern Utilities LNG D&A (12/22/20), OQ (12/1/20); Eastern Propane #1905 ? Standard (5/12/20); Dead River Co. # 610 ? Standard (6/22/20). 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? Evaluator Notes: There were no reportable incidents in CY 2020. 10 10 9 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 Evaluator Notes: There was no response required from the MPUC for the CY 2019 program evaluation. 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Info Only Info Only DUNS: 002235294 2020 Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 9#
ME NG Program Evaluation, 2020, page 10Evaluator Notes: The last seminar was held April 27 -29, 2021 virtually for all the New England states. 11 Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only = No Points Evaluator Notes: Info Only Info Only Yes. The MPUC has confirmed transmission operators have submitted information into the NPMS database. 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: Yes. The MPUC has enforcement cases available for the public through their State website if the case is contested. Most inspection documents are available for the public upon request. 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 are no open SRCRs for the MPUC. 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: The MPUC has responded to requests from NAPSR and/or PHMSA. Additionally, they have responded to PHMSA WMS tasks, such as operator ID request. 15 If the State has issued any waivers/special permits for any operator, has the state verified 1 1 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: There is open waiver with Unitil which was amended as of May 8, 2014 pertaining to MAOP retest due to not knowing all the pipeline system. Unitil is required to submit annual updates to the MPUC. 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes. We were able to review files electronically from their pipeline database. Info Only Info Only 17 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 Evaluator Notes: Yes. The MPUC has updated their SICT data and submitted that information for the CY 2021. 3 3 18 Discussion on State Program Performance Metrics found on Stakeholder Communication site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Info Only Info Only DUNS: 002235294 2020 Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 10#
ME NG Program Evaluation, 2020, page 11Discussed the State Program Performance Metrics with the MPUC and found no negative trends that warranted correction. 19 Did the state encourage and promote operator implementation of Pipeline Safety 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 Info Only Info Only Evaluator Notes: There was a presentation on PSM during the 2021 pipeline safety seminar. Unitil is implementing a PSM within its organization. Also, the MPUC presented information on PSM in the 2018 NECPUC Symposium. 20 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: There were two issues identified during the program evaluation: (1) The MPUC did not inspect all types of operators and inspection units in accordance with time intervals established in written procedures; and (2) the MPUC verify with its LPG operators that their OQ programs are updated and that persons performing covered tasks are properly qualified. Total points scored for this section: 47 Total possible points for this section: 50 DUNS: 002235294 2020 Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 11#
ME 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: Maine Natural Gas Inspector(s): Nathan Dore, Sean Watson, Gary Kenny Location: Virtual Date: July15, 2021 PHMSA Rep.: Clint Stephens The MPUC performed an O&M records inspection utilizing IA. Info Only Info Only 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist 2 2 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 Inspection Assistant which was used as a guide for the inspection. 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 Maine Natural Gas' O&M manual. 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 2 2 Evaluator Notes: From my observation, the inspectors showed adequate knowledge of the pipeline safety program and regulations. 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: The inspection was not completed at the time of the field observation, so an exit interview was not conducted at this time. 6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points Info Only Info Only DUNS: 002235294 2020 Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 12#
ME NG Program Evaluation, 2020, page 13a. 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 Evaluator Notes: The inspection was performed in a safe, positive, and constructive manner. 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: 002235294 2020 Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 13#
ME 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: Yes. The MPUC summarizes information from the annual reports and analyzes data for trends and operator issues. 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: Yes. The MPUC has discussed with the operators of potential excavators that repeatedly violated one-call laws and damaged their facilities. Main Natural Gas has included an excavator in their DIMP plan as a potential threat to damaging their pipeline by excavation. The MPUC has analyzed excavation damages for the purpose of root cause, such as one-call, locating, excavation, and other. 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: Yes. Reviewed data from the damage prevention team which works closely with the pipeline safety office when communicating information pertaining to damages caused locator mismarks, locating within time requirements, mapping errors, and correcting mapping errors. The state in conjunction with damage prevention team has evaluated the causes for damages under "One-Call Notification Practices Not Sufficient" and "Locating Practices Not Sufficient". The damage prevention team provides training to operators, excavators, and locators on an annual basis. 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: 002235294 2020 Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 14#
ME 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: Yes. The stakeholder group causing the highest number of damages is being collected by the damage prevention team. Based on data for 2020, data has been broken down into excavators (contractors, operator, public) and operators, with excavators having caused the most damages to pipelines. Data is being recorded in the excavation damage investigation form. The data from this form is stored in the damage incident investigation tracker spreadsheet. Managing Underground Safety Training is being utilized for the training of excavators in the State of Maine. 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: 002235294 2020 Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 15#
ME 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 MPUC 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 MPUC 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 MPUC 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 MPUC 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 MPUC is not an interstate agent. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: The MPUC is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 002235294 2020 Gas State Program Evaluation Maine MAINE PUBLIC UTILITIES COMMISSION, Page: 16#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.