Inspectionhistorical
PHMSA NH 2019 Gas Program Evaluation
2019 NH NG Program Evaluation - NH 2019 Gas Program Evaluation (New Hampshire; Natural Gas State Program Evaluation)
Current as of source date Government source
RegulusPipeline researchRegulusPipeline researchPHMSA NH 2019 Gas Program Evaluation
NH NG Program Evaluation, 2019, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2019 Gas State Program Evaluation for NEW HAMPSHIRE 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: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION, Page: 1#
NH NG Program Evaluation, 2019, page 22019 Gas State Program Evaluation -- CY 2019 Gas State Agency: New Hampshire Rating: Agency Status: Date of Visit: 11/17/2020 - 11/23/2020 Agency Representative: Randy Knepper, Director Safety Division PHMSA Representative: Rex Evans David Appelbaum - Part F Commission Chairman to whom follow up letter is to be sent: Name/Title: Ms. Dianne Martin, Chairwoman Agency: New Hampshire Public Utilities Commission Address: 21 South Fruit Street, Suite 10 City/State/Zip: Concord, NH 03301-2429 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 2019 (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 50 E Field Inspections 15 15 F Damage prevention and Annual report analysis 4 4 G Interstate Agent/Agreement States 0 0 TOTALS 94 94 State Rating................................................................................................................................................... 100.0 DUNS: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION, Page: 2#
NH NG Program Evaluation, 2019, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? 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: a. Jurisdictional information appears correct b. Inspection days, 108 days however 150 days were required. Staff turnover c-i. No issues with remaining data reported on progress report. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION, Page: 3#
NH NG Program Evaluation, 2019, 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: All types of inspections are covered in Section V of program procedures and activities are adequately covered. 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: Intervals are in Section IV of procedures, The risk process is covered in Section VI and remainder of considerations are covered adequately in their procedures document. All generally acceptable and no issues. 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: Generally covered in pages 16-20 of procedures. Acceptable 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: Procedures are in place, they have week staff call duty. Limited activity and limited history of incidents 3 3 DUNS: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION, Page: 4#
NH NG Program Evaluation, 2019, page 55 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION, Page: 5#
NH NG Program Evaluation, 2019, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines 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: Joe V and Randy have completed all courses and did the inspections in 2019. No issues 5 5 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: Randy has been program manager for many years, no issues 5 5 3 General Comments: Info Only = No Points Evaluator Notes: No issues Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION, Page: 6#
NH NG Program Evaluation, 2019, 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 5 Evaluator Notes: Summary sheets indicated all operators and types inspected in appropriate time frames. LNG visited annually at the three sites. Construction will be analyzed after current year is complete. 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 10 Evaluator Notes: It appears all code requirements are being covered. Increase in inspection staff has assisted in getting days caught up, the 2019 person days were below normal. All appear on track to be caught up. 3 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: OQ plan inspections appear caught up, more effort has been expended in CY2020 for Protocol 9 inspections. OQ programs appear up to date. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This 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? 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? 2 2 Evaluator Notes: DUNS: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION, Page: 7#
NH NG Program Evaluation, 2019, page 8As noted in previous evaluations, on 3 miles of transmission in NH with Liberty Utilities. No issues with IMP programs. DIMP programs appear up to date and sufficiently reviewed. Various issues are addressed in company DIMP plans. 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: All the items appear to be reviewed throughout inspection process, some in the DIMP plans. The new questions f. and g. were reviewed along with remainder. No issues at this time. 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 Evaluator Notes: No issues 1 1 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 DUNS: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION, Page: 8#
NH NG Program Evaluation, 2019, page 9Evaluator Notes: Reviewed compliance actions and no issues were found. All compliance activities are posted on commission web-site and appear to have very good follow-up and results. https://www.puc.nh.gov/Safety/Pipeline_Safety_Enforcement_Program.html 8 (Incident Investigations) Were all 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 CY2019, the program appears to have all processes in place to handle and respond to incidents and state investigates those not meeting federal threshold. No issues with and cooperation with AID and all activities appear acceptable. 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 in last letter. No issues. 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Info Only Info Only Years? Chapter 8.5 Info Only = No Points Evaluator Notes: No issues at this time, a New England combined seminar was last held in 2018, looking at virtual options due to Covid-19. No issues. 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: One Transmission with 3 miles, no issues. Info Only Info Only 12 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). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Excellent website, with public access to enforcements. No issues. 1 1 DUNS: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION, Page: 9#
NH NG Program Evaluation, 2019, page 1013 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 SRC's, no issues. 1 1 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; b. Operator IM notifications; and c. PHMSA Work Management system tasks? Evaluator Notes: No issues with responsiveness and participation. 1 1 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: No issues and there are no waivers pending or in place. 1 1 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: No issues- this evaluation was completed via virtual exchange of information. 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 3 3 Evaluator Notes: We discussed SICT information, will be sending out 2021 number of 143 soon, 150 days will be required for 2020 which indicated should be achieved. No issues at this time. 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: Viewed metrics together and all trends were with explainable or positive. No issues. Info Only Info Only 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 Evaluator Notes: Brief discussion, no issues Info Only Info Only 20 General Comments: Info Only = No Points Evaluator Notes: performance. Info Only Info Only Evaluation was conducted via MS Teams meeting and electronic exchange of information. No issues with program DUNS: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION, Page: 10#
NH NG Program Evaluation, 2019, page 11Total points scored for this section: 50 Total possible points for this section: 50 DUNS: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION, Page: 11#
NH NG Program Evaluation, 2019, page 12PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the Info Only Info Only 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: This was a virtual control room management inspection, growth and size of operator have made this necessary and not before. Leo Cody and others from Liberty were present, this was first day of inspection and multi-states will be participating next week. 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: No issues with forms/checklists being used. 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: The CRM is primarily a procedure review process, Liberty had not previously had control room inspection but due to company growth, particularly in New Hampshire they now have enough customer to fall into CRM regulations. This was an advance audit before a multi-state audit was to take place, although the company has majority of system in New Hampshire. They had purchased some assets of ATMOS in other states. No issues with time spent to adequately review their CRM plans 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: Joe Vercellotti was lead and Randy Knepper also participated. No issue with knowledge and specific CRM 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: I only participated in Day 1 of multi-day virtual inspection, although no issues with progress and coverage of issues. 6 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 Info Only Info Only DUNS: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION, Page: 12#
NH NG Program Evaluation, 2019, page 13b. 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: No issues with audit 7 General Comments: Info Only = No Points Evaluator Notes: As mentioned above this was one-day of multi-day inspection. No issues. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION, Page: 13#
NH NG Program Evaluation, 2019, 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: Program demonstrated a comprehensive review and understanding of Operator annual reports, and the data contained within them. Program did make an assertion that, with regard to annual reports, that "operators are encouraged but not mandated (through enforcement mechanisms) to submit accurate data." PHMSA informed the PM that this may be a specious claim and that the burden of accuracy is implicit in any regulation requiring data submission. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 NA 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. Program clearly burdened their operators to understand excavation damages for the purpose of preventing further incidents and enhancing the State's excavation damage prevention program. 3 Has the state reviewed the operator's annual report pertaining to Part D ? Excavation 4 NA 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: Program demonstrated a comprehensive review and understanding of Operator annual reports specific to Part D, and the data contained within them. PHMSA suggested the Program consider assessing mismarks against the number of damages (versus notifications) since this will provide a more usable year over year assessment of locator performance. 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? c. 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. 2 2 DUNS: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION, Page: 14#
NH NG Program Evaluation, 2019, page 15d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? Evaluator Notes: Program collects, maintains, and makes available comprehensive excavation damage data. New Hampshire is a benchmark state for the data analysis on this topic. 5 General Comments: Info Only = No Points Evaluator Notes: Evaluation. Info Only Info Only New Hampshire is a benchmark state with regard to the completing the intended requirements for Part F of this Program Total points scored for this section: 4 Total possible points for this section: 4 DUNS: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION, Page: 15#
NH NG Program Evaluation, 2019, 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: N/A 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: N/A 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: N/A 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: N/A 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: N/A Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: Section not applicable Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 049445518 2019 Gas State Program Evaluation New Hampshire NEW HAMPSHIRE 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.