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PHMSA oh-2017-gas-program-evaluation
2017 OH NG Program Evaluation - oh-2017-gas-program-evaluation (Ohio; Natural Gas State Program Evaluation)
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OH NG Program Evaluation, 2017, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2017 Gas State Program Evaluation for PUBLIC UTILITIES COMMISSION OF OHIO Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 1#
OH NG Program Evaluation, 2017, page 22017 Gas State Program Evaluation -- CY 2017 Gas State Agency: Ohio Rating: Agency Status: Date of Visit: 07/30/2018 - 08/17/2018 Agency Representative: August 16, 2018 Mr. Peter Chace Chief, Gas Pipeline Safety Section PHMSA Representative: Mr. Clint Stephens Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. Asim Z. Haque, Chairman Agency: The Public Utilities Commission of Ohio Address: 180 East Broad Street City/State/Zip: Columbus, Ohio 43215 60105(a): Yes 60106(a): No Interstate Agent: Yes INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2017 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 13 13 C Program Performance 49 49 D Compliance Activities 15 15 E Incident Investigations 11 11 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 7 7 I 60106 Agreement State (If Applicable) 0 0 TOTALS 125 125 State Rating................................................................................................................................................... 100.0 DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 2#
OH NG Program Evaluation, 2017, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Review of Attachment 1 of Progress Report seems data is accurate as reported. No issues. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: The PUCO has an electronic timesheet database for each employee to record time spent on different types of inspections. This information is stored to fill in data for Attachment 2 of Progress Report at end of calendar year. The information reviewed seems accurate as reported in Progress Report. No issues. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Review of Attachment 3 of Progress Report seems data is accurate as reported. No issues. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress 1 1 Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Attachment 4 ? All incident reports were included in the PDM. The PUCO stores incident reports in the t2000 (Gas Pipeline Safety Database). No issues. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Review of Attachment 5 of Progress Report seems data is accurate as reported. The oldest open compliance action dates to 10/2014. The PUCO is monitoring 10 items which date back to 2014 thru 2016 and looking to close these compliance actions by the end of 2018. No issues. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: All files are stored, accessible, and well organized on the GPS T2000 drive, and referenced through the GPS Database. No issues. 7 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Review of Attachment 7 of Progress Report seems employee training records are accurate and complete as reported. No issues. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 046289216 2017 Gas State Program Evaluation 1 1 Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 3#
OH NG Program Evaluation, 2017, page 4Review of Attachment 8 of Progress Report has been verified as reported. No issues. 9 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Attachment 10 ? Discuss Accelerated Main Replacement Program (AMRP). There are four operators that are under the AMRP program (Duke Energy, Columbia Gas, Dominion East Ohio, and Vectron). Duke Energy has completed their replacement of cast iron/bare steel; Columbia and Dominion are 10 years into a 25-year replacement program; and Vectron is 10 years into a 20-year replacement program. No issues. 10 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part A of the Program Evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 4#
OH NG Program Evaluation, 2017, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Standard inspection procedures are contained on page 11 of the PUCO Gas Pipeline Safety Plan. 2 2 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IMP and DIMP procedures are contained on page 11 of the PUCO Gas Pipeline Safety Plan. 1 1 3 OQ Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: OQ inspection procedures are contained on page 11 of the PUCO Gas Pipeline Safety Plan. 1 1 4 Damage Prevention Inspection procedures should give guidance to state inspectors that 1 1 insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Damage Prevention procedures are a part of the Standard inspection is contained on page 11 of the PUCO Gas Pipeline Safety Plan. 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: On-Site Operator Training procedures are contained on page 10 of the PUCO Gas Pipeline Safety Plan. 1 1 6 Construction Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Construction inspection procedures are contained on page 12 of the PUCO Gas Pipeline Safety Plan. 1 1 7 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 5#
OH NG Program Evaluation, 2017, page 6b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: PUCO inspection priorities are contained on page 7, and risk factors are in Attachment 2 of the Gas Pipeline Safety Plan. 8 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part B of the Program Evaluation. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 6#
OH NG Program Evaluation, 2017, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 1543.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 10.17 = 2236.67 Ratio: A / B 1543.00 / 2236.67 = 0.69 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Attachment 7 ? Ratio = A/B = 1543/220 x 10.17 = 1543/2237.4 = .68 >= .38. No issue. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 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? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: All inspectors, except two have completed OQ training; all but three completed DIMP; three inspectors qualified to perform IMP inspections; two inspectors have completed root cause training; and no outside training completed. 3 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 = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. The state pipeline safety program manager indicates adequate knowledge of PHMSA program and regulations. He has nine years' pipeline safety program management experience. 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. The Chairman's letter was sent on September 8, 2017, and the response was received on October 31, 2017. No issues. 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: Yes. The PUCO held its pipeline safety seminar on September 14-15, 2017. 1 1 6 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 Evaluator Notes: DUNS: 046289216 2017 Gas State Program Evaluation 5 5 Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 7#
OH NG Program Evaluation, 2017, page 8Yes. The PUCO inspected all types of operators and inspection units in accordance with time intervals established in written procedures. No issues. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The inspection forms cover all applicable code requirements addressed on the PUCO inspection form. All applicable portions of inspection form were completed. No issues. 8 Did the state review operator procedures for determining if exposed cast iron pipe was 1 1 examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes. The question is included on page 9 in the PUCO Construction, Operations and Maintenance Plans and Procedures Review form (Headquarters Form). No issue. 9 Did the state review operator procedures for surveillance of cast iron pipelines, including 1 1 appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes. The question is included on page 13 in the PUCO Construction, Operations and Maintenance Plans and Procedures Review form (Headquarters Form). No issue. 10 Did the state review operator emergency response procedures for leaks caused by 1 1 excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes. The question is included on page 15 in the PUCO Construction, Operations and Maintenance Plans and Procedures Review form (Headquarters Form). No issue. 11 Did the state review operator records of previous accidents and failures including 1 1 reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes. The question is included on page 13 in the PUCO Construction, Operations and Maintenance Plans and Procedures Review form (Headquarters Form). No issue. 12 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 state has reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends. This data is in the form of graphs and data spreadsheets. No issues. 13 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 046289216 2017 Gas State Program Evaluation 1 1 Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 8#
OH NG Program Evaluation, 2017, page 9Yes. The question is included on page 2 in the PUCO Construction, Operations and Maintenance Plans and Procedures Review form (Headquarters Form). No issue. 14 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The question is included on page 25 in the PUCO Construction, Operations and Maintenance Plans and Procedures Review form (Headquarters Form). No issue. 15 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 determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. PUCO was utilizing PHMSA from 15 for OQ field inspections, and PHMSA form 14 for the OQ Headquarters inspections. No issue. 16 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually? Are replies to Operator IM notifications addressed? (formerly part of Question C-13)). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. PUCO utilized PHMSA form 16 (IA Equivalent) for the Gas IM inspections. Yes, the large operators, such as Duke Energy, Columbia Gas, Dominion, and Vectron all had IMP inspections performed in 2017. No issues. 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 2 This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. PUCO utilized PHMSA form 24 (IA Equivalent) for the DIMP inspections. Yes, the large operators, such as Columbia Gas and Vectron all had DIMP inspections performed in 2017. No issues. 18 Is state verifying operators Public Awareness programs are up to date and being 2 2 followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The PAP inspection is part of the Headquarters Inspection O&M form. The PUCO performed numerous PAP inspections as part of the Standard procedures inspections in 2017. No issues. 19 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. As part of the OGA annual technical meeting, PUCO makes a presentation on regulatory items that could affect operators within the State of Ohio. There is information on the PUCO website that gives the public access to enforcement cases. DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 9#
OH NG Program Evaluation, 2017, page 1020 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 SRCs for the State of Ohio. 1 1 21 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. The question is included on page 13 in the PUCO Construction, Operations and Maintenance Plans and Procedures Review form (Headquarters Form). No issue. 22 Did the state participate in/respond to surveys or information requests from NAPSR or 1 1 PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. The PUCO has participated in and responded to surveys or information requests from NAPSR and/or PHMSA. 23 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. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: 1 1 Yes. There was a waiver submitted by National Gas & CO-OP in 2017 and approved by the PUCO in 2018. 24 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes. PUCO attended the National NAPSR Board of Directors meeting in Columbus, OH in CY2017. 1 1 25 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: Discussed performance metrics with PUCO pertaining to decrease in 'Inspection Activity" ? Inspection Days per 1,000 miles of pipeline where they lost an inspector in 2017 which was not replaced. The PUCO was still able to meet inspection intervals. Pertaining to the decrease in inspection days for master meters/LPG units, PUCO feels master meters are of a safety risk, and are not inspected as often. Looking at inspecting larger operators more frequently. (considered greater safety risk) PUCO still able meet inspection intervals. Leak Management ? Gas distribution system leaks repaired/1,000 miles decreased from 2016 to 2017; hazardous leaks repaired/1,000 miles decreased from 2016 to 2017; and leaks outstanding/1,000 miles increased slightly from 2016 to 2017. Change in numbers could slight inaccuracies reporting data. PUCO needs to continue to monitor these trends for improvement. 26 Discussion with State on accuracy of inspection day information submitted into State 1 1 Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: Discussed the SICT tool with PUCO which indicates 1408 inspection person-days in CY2017, and Attachment 2 of CY2017 Progress Report has 1,543 inspection days completed. No issue.DUNS: 046289216 Ohio 2017 Gas State Program Evaluation PUBLIC UTILITIES COMMISSION OF OHIO, Page: 10#
OH NG Program Evaluation, 2017, page 1127 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 1 1 Evaluator Notes: Yes. The question is included on page 3, subpart A, in the PUCO Construction, Operations and Maintenance Plans and Procedures Review form (Headquarters Form). 28 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: There is one recommendation to revise "Gas Intrastate Inspection Report" form by changing the Y and N to S and U. This will clarify the ambiguity for inspectors when deciding if an issue found during the inspection is "Satisfactory" or "Unsatisfactory". Discussed performance metrics with PUCO pertaining to decrease in 'Inspection Activity" ? Inspection Days per 1,000 miles of pipeline where they lost an inspector in 2017 which was not replaced. The PUCO was still able to meet inspection intervals. Pertaining to the decrease in inspection days for master meters/LPG units, PUCO feels master meters are of a safety risk, and are not inspected as often. Looking at inspecting larger operators more frequently. (considered greater safety risk) PUCO still able meet inspection intervals. Leak Management ? Gas distribution system leaks repaired/1,000 miles decreased from 2016 to 2017; hazardous leaks repaired/1,000 miles decreased from 2016 to 2017; and leaks outstanding/1,000 miles increased slightly from 2016 to 2017. Change in numbers could slight inaccuracies reporting data. PUCO needs to continue to monitor these trends for improvement. Total points scored for this section: 49 Total possible points for this section: 49 DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 11#
OH NG Program Evaluation, 2017, page 12PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: Yes. The written procedures are contained in the PUCO Gas Pipeline Safety Plan, page 16. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: Yes. The state followed compliance procedures (from discovery to resolution) and adequately documented all probable violations, up until resolution. Recommend PUCO amend Gas Pipeline Safety Plan to include 30 day, post inspection briefing with owner or operator; and 90 day, provide owner or operator with preliminary findings of the inspection. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. PUCO issued compliance actions for all probable violations discovered during their inspections. No issues. 4 Did compliance actions give reasonable due process to all parties? Including "show 2 2 cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes. Compliance actions were given reasonable due process to all parties. However, Ohio Rural Natural Gas was labeled a hazardous facility in 2017, and the operator was shut down in 2018 based on unsatisfactory operations and maintenance practices. No issues. 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Program manager is familiar with the PUCO civil penalty process. Civil penalties were not considered for repeat violations or violations resulting in incidents/accidents in 2017. No issues. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 12#
OH NG Program Evaluation, 2017, page 13Evaluator Notes: Yes. The State is demonstrating its enforcement authority by issuing corrective action orders (CAOs); however, there were no fines assessed in 2017, but there was a total of $400,000 of fines assessed in 2016, and $200.000 collected form operators. No issues. 7 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Recommend PUCO amend Gas Pipeline Safety Plan to include 30 day, post inspection briefing with owner or operator; and 90 day, provide owner or operator with preliminary findings of the inspection. Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 13#
OH NG Program Evaluation, 2017, page 14PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The procedures are in page 9, 13 and 14 of the Gas Pipeline Safety Plan. 2 2 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: Yes. The all operators have been sent a letter with a 24-hour hotline number to report all incidents. PUCO keeps a record on their database of all Telephonic Notices of incidents. No issues. 3 If onsite investigation was not made, did state obtain sufficient information from the 1 1 operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. If the PUCO does not decide to go on-site to investigate an incident, information determining the facts not to go are obtained from the operator and is documented on the "Telephonic Notice of Incidents and Service Failures" form and stored in the PUCO database. No issues. 4 Were all incidents investigated, thoroughly documented, and with conclusions and recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review 3 3 Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: Yes. There were six incidents that occurred in 2017. They were thoroughly investigated and documented with conclusions and recommendations. No issues. 5 Did the state initiate compliance action for violations found during any incident/accident 1 1 investigation? Yes = 1 No = 0 Evaluator Notes: Yes. PUCO initiated Corrective Action Order (CAO) for violations found during two incident/accident investigations in 2017. No issues. 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking 1 1 appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. PUCO has assisted AID by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy, and final report has been received by PHMSA. No issues. DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 14#
OH NG Program Evaluation, 2017, page 157 Does state share lessons learned from incidents/accidents? (sharing information, such as: 1 1 at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: Yes. PUCO shares lessons learned from incidents/accidents during the State of State address at the National and Regional NAPSR meetings. 8 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part E of the Program Evaluation. Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 15#
OH NG Program Evaluation, 2017, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The question is included on page 14 in the PUCO Construction, Operations and Maintenance Plans and Procedures Review form (Headquarters Form). 2 Did the state inspector verify pipeline operators are following their written procedures 2 2 pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The question is included on page 14 in the PUCO Construction, Operations and Maintenance Plans and Procedures Review form (Headquarters Form). 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The question is included on page 13 in the PUCO Construction, Operations and Maintenance Plans and Procedures Review form (Headquarters Form). 4 Has the agency or another organization within the state collected data and evaluated 2 2 trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. PUCO is collecting data and evaluating trends on the number of pipeline damages per 1,000 locates. There has been a decline in damages from 2014 thru 2017. No issues. 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only The PUCO now has enforcement authority for excavation damage as of 2016. PUCO resolved 37 investigations in 2017, and fines and penalties were issued in 26 instances. There were no issues identified in Part F of the Program Evaluation. Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 16#
OH NG Program Evaluation, 2017, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: City of Hamilton Name of State Inspector(s) Observed: Scott Landon and Joshua Knox Location of Inspection: Hamilton, OH Date of Inspection: July 31 thru August 2, 2018 Name of PHMSA Representative: Clint Stephens Evaluator Notes: The PUCO performed a standard records inspection during the evaluation. Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 1 1 Evaluator Notes: Yes. The operator's representatives were notified and given the opportunity to be present during the inspection. 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: guide for the inspection. Yes. The inspector used the PUCO, "Gas Distribution System Inspection Report" inspection form. The form was used as a 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The inspector thoroughly documented the results of the inspection. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: There was no field inspection performed during this week of the evaluation; however, the operator's computer GIS mapping system was used to review leak surveys, pipeline data, and corrosion records. 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures 2 2 b. Records c. Field Activities d. Other (please comment) Evaluator Notes: The inspector adequately reviewed the following procedures and records: DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 17#
OH NG Program Evaluation, 2017, page 18Procedures ? welding, joining, customer meter installation, pressure test requirements, emergency response manual Records ? welding/welder qualifications, joining (fusion) qualifications, corrosion control, exposed mains, regulator station inspections, atmospheric corrosion, continuing surveillance, leak surveys, public awareness, odorization, and MAOP. 7 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 has adequate knowledge of the pipeline safety program and regulations. 2 2 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: No. The inspection was not completed during the evaluation, so the exit interview will be conducted upon completion of the inspection. 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: The inspection was not completed during the evaluation, so the exit interview will be conducted upon completion of the inspection. 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation Info Only Info Only DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 18#
OH NG Program Evaluation, 2017, page 19x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: The inspection encompassed only records and procedure records for review. There was no field inspection performed during the evaluation. The inspector was thorough with the review of records, and documenting information on the inspection form. The inspector asked the operator pertinent questions to resolve possible issues, and clarify items that seemed ambiguous based on information provided by the operator. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 19#
OH NG Program Evaluation, 2017, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PUCO utilized IA and PIMs as directed by the Eastern Region. 1 1 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Results were documented in IA as directed by the Eastern Region. 1 1 3 Did the state submit documentation of the inspections within 60 days as stated in its latest 1 1 Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Results were documented in IA and completed at time of inspection. There were no concerns, therefore a PIM was not necessary. 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no probable violations identified. 1 1 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: There were no immediate safety hazard concerns. PUCO reported Operator's Plan to not odorize transmission line and the potential concerns of the downstream installation of wick odorizers on farm taps. 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no probable violations identified. 1 1 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no probable violations identified. 1 1 8 General Comments: Info Only = No Points Evaluator Notes: PUCO provided thorough IA inspections and brought concerns to PHMSA's attention. Info Only Info Only DUNS: 046289216 2017 Gas State Program Evaluation Total points scored for this section: 7 Total possible points for this section: 7 Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 20#
OH NG Program Evaluation, 2017, page 21PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The PUCO does not have a 60106 agreement. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The PUCO does not have a 60106 agreement. 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The PUCO does not have a 60106 agreement. 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The PUCO does not have a 60106 agreement. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The PUCO does not have a 60106 agreement. 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The PUCO does not have a 60106 agreement. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: The PUCO does not have a 60106 agreement. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 046289216 2017 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 21#
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