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PHMSA oh-2018-gas-program-evaluation
2018 OH NG Program Evaluation - oh-2018-gas-program-evaluation (Ohio; Natural Gas State Program Evaluation)
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OH NG Program Evaluation, 2018, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2018 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 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 1#
OH NG Program Evaluation, 2018, page 22018 Gas State Program Evaluation -- CY 2018 Gas State Agency: Ohio Rating: Agency Status: Date of Visit: 08/20/2019 - 08/22/2019 Agency Representative: August 27, 2019 Pete Chace Chief, Gas Pipeline Safety Section PHMSA Representative: Clint Stephens Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. Sam Randazzo, 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 2018 (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. 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 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 2#
OH NG Program Evaluation, 2018, 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 information stored in the PUCO electronic timesheet database is used 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 Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Review of Attachment 4 of Progress Report and all incident reports were included in the PDM. No issues. 1 1 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. 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. The PUCO is using the Inspection Assistance (IA) for interstate, DIMP and IM inspections. 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: Review of Attachment 8 of Progress Report has been verified as reported. No issues. 1 1 DUNS: 046289216 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 3#
OH NG Program Evaluation, 2018, page 49 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: Action item with PUCO continuing its accelerated main replacement program with four of its operators, Duke Energy, Columbia Gas, Dominion East Ohio, and Vectron. No issues. 10 General Comments: Info Only = No Points Evaluator Notes: There were no issues 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 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 4#
OH NG Program Evaluation, 2018, 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 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: As part of the Standard Inspections, the Damage Prevention inspection procedures are 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 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 5#
OH NG Program Evaluation, 2018, 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. Recommend revise wording in Attachment 2 of Plan to eliminate reference to "for 2016". 8 General Comments: Info Only = No Points Evaluator Notes: There were no issues in Part B of Program Evaluation. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 046289216 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 6#
OH NG Program Evaluation, 2018, 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): 1490.40 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 9.75 = 2145.00 Ratio: A / B 1490.40 / 2145.00 = 0.69 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Ratio = A/B = 1490.4/220 x 11 = 1490.4 x 2420 = .61 >= .38 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: Training has been reviewed in Blackboard. Those inspectors that have conducted inspections as lead have completed the required training. The inspectors attended the Ohio Gas Association Technical seminar in 2018. No issues. 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 indicated adequate knowledge of PHMSA program and regulations. 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 Evaluator Notes: There was no response required from the 2017 Chairman's letter. 2 2 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 previous 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 5 5 Evaluator Notes: DUNS: 046289216 2018 Gas State Program Evaluation Reviewed standard records inspections for Lancaster Municipal Gas and Consolidated Gas Coop.; reviewed DIMP inspection Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 7#
OH NG Program Evaluation, 2018, page 8for Glenwood Energy and The Swickard Gas Co.; reviewed IM inspection for Vectren Energy Delivery of Ohio, Dominion Energy Ohio, and Duke Energy; reviewed OQ Plan inspection for Arlington Natural Gas, Ohio Gas Co.; and reviewed control room inspection for Dominion Energy Ohio. There were 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 covered all applicable requirements addressed on Federal Inspection forms. PUCO utilizes IA equivalent for DIMP and IM inspections. All applicable portions of inspection forms were filled out. There were 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 10 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 15 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 17 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 15 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 PUCO has prepared spreadsheet for each data item in the annual reports and analyzing that data for trends and operator issues. This data is also broken down into graphs and pie charts. There were no issues. 13 DUNS: 046289216 2018 Gas State Program Evaluation 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 1 1 Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 8#
OH NG Program Evaluation, 2018, page 9Evaluator Notes: Yes. 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 27 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 IA question inspection set for the OQ HQ, and for the field OQ inspections they use the PUCO Gas Distribution Inspection Report and Gas Transmission/Gathering Inspection Report forms. 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 the PHMSA Protocol Form for Gas IM inspections. Yes, the large operators, such as Duke Energy, Columbia Gas, Dominion, and Vectron all had IMP inspections performed in 2018. 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 the Inspection Assistant for DIMP inspections in 2018. There were 13 DIMP inspections performed on 2018. There were 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 23 PAP inspections as part of the Standard procedures inspections in 2018. There were no issues 19 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: 1 1 Yes. Stakeholders are communicated with as part of the (Ohio Gas Association) OGA annual technical meeting, PUCO DUNS: 046289216 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 9#
OH NG Program Evaluation, 2018, page 10makes a presentation on regulatory items that could affect operators within the State of Ohio. The public has access to pipeline safety dockets, pipeline safety rules, and damage prevention information on the PUCO website. 20 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: PUCO had no open SRCRs in 2018. 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 16 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 PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. PUCO is responding to information request from NAPSR and PHMSA. 1 1 23 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. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes. There was a waiver submitted by National Gas & CO-OP in 2017 and approved by the PUCO in 2018. Project will start September 2019. 24 Did the state attend the NAPSR National Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 1 1 Evaluator Notes: Yes. The a PUCO representative attended the NAPSR National Meeting in CY 2018 held in Santa Fe, NM. 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: Damage Prevention Program ? excavation damages per 1,000 tickets has decreased steadily from 2014 to 2018. ? Inspection Activity ? Inspection Days per 1,000 mile of gas pipeline has decreased from 2016 to 2018 (negative trend). Inspection days for master meters/LPG units has increased from 2017 to 2018. ? Inspector Qualification - % Core Training has increased from 2017 to 2018; % Additional Training has remained consistent from 2015 to 2018; and % 5-Year Retention decreased from 2017 to 2018. ? Leak Management - Total leaks eliminated/repaired has decreased from 2016 to 2018; hazardous leaks eliminated/ repaired has remained constant from 2011 to 2018; and leaks scheduled for repair at end of year has increased from 2016 to 2018. 26 DUNS: 046289216 2018 Gas State Program Evaluation Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 1 1 Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 10#
OH NG Program Evaluation, 2018, page 11Evaluator Notes: No issues. The SICT calculation for CY2018 is 1401. From Attachment 2 of Progress Report PUCO had 1490 inspection person days. 27 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 = No Points Evaluator Notes: There were no issues found in Part C of the Program Evaluation. Info Only Info Only Total points scored for this section: 49 Total possible points for this section: 49 DUNS: 046289216 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 11#
OH NG Program Evaluation, 2018, 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, pages 15 - 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? (Incident Investigations do not need to meet 30/90 day requirement) 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: Reviewed inspection reports for Bright Energy, Duke Energy, Brainard Gas Corp., and Foraker Gas, for which PUCO followed compliance procedures (from discovery to resolution) and adequately documented all probable violations, including resolution to gain compliance. 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 did issue compliance actions for all probable violation discovered. If issue found did not rise to the level of an compliance action, a Warning Letter was issued to the operator. 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. PUCO gave due process to all parties for compliance actions. In the case of Rustic Hills Outdoor Inc. both parties came to mutual agreement that operator would cease gas operations and went to all electric utilities. 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 2018. No issues. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? DUNS: 046289216 2018 Gas State Program Evaluation 1 1 Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 12#
OH NG Program Evaluation, 2018, page 13Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PUCO previous record of civil penalty was CY 2016; however, there is civil penalty pending for CY 2019. 7 General Comments: Info Only = No Points Evaluator Notes: There were no issues in Part D of Program Evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 046289216 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 13#
OH NG Program Evaluation, 2018, 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/ 2 2 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. Incident Investigation Checklist is in included in Attachment 4 of Safety Plan 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. 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 3 3 recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: Reviewed incident reports for Columbia Gas Transmission (interstate) ? New Straitsville, OH and Dominion Energy Ohio ? Mayfield Heights, OH which were investigated, thoroughly documented, with conclusions and recommendations. 5 Did the state initiate compliance action for violations found during any incident/accident 1 1 investigation? Yes = 1 No = 0 Evaluator Notes: Reviewed incident reports for Columbia Gas Transmission (interstate) ? New Straitsville, OH with information being forwarded to the PHMSA Eastern Region. There has been no status update from PHMSA on the non-compliance issues found by PUCO during the accident investigation. 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. Reviewed correspondence between PUCO and AID and found then taking appropriate follow-up actions related to the operator incident reports to ensure accuracy. There were no issues. DUNS: 046289216 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 14#
OH NG Program Evaluation, 2018, 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 in CY 2018. 8 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Reviewed incident reports for Columbia Gas Transmission (interstate) ? New Straitsville, OH with information being forwarded to the PHMSA Eastern Region. There has been no status update from PHMSA on the non-compliance issues found by PUCO during the accident investigation. Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 046289216 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 15#
OH NG Program Evaluation, 2018, 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), along with the Ohio Damage Prevention Law. 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? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes. PUCO is collecting data and evaluating trends on the number of pipeline damages per 1,000 locates based on information included in the operator annual report. There has been a decline in damages from 2014 thru 2018. No issues. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues in F of the Program Evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 046289216 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 16#
OH NG Program Evaluation, 2018, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: NGO Transmission Inc. Name of State Inspector(s) Observed: Victor Omameh (Lead) and Mike Purcell Location of Inspection: 120 O'Neil Drive, Hebron, OH 43025 Date of Inspection: July 30 - August 1, 2019 Name of PHMSA Representative: Clint Stephens Evaluator Notes: Observed the inspectors perform an IMP inspection on NGO Transmission Inc. 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 Evaluator Notes: Yes. The operator's representative was notified and was present during the inspection. 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The inspector used IA equivalent form and it was used as a guide for the inspection. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The inspectors thoroughly documented results of the inspection. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: Yes. The inspector reviewed data in GIS mapping. 1 1 2 2 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 b. Records c. Field Activities d. Other (please comment) Evaluator Notes: records on HCAs. Yes. The inspectors reviewed operator's IM Plan, CY2018 Annual Report, HCA Assessment Summary, and Pressure test DUNS: 046289216 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 17#
OH NG Program Evaluation, 2018, page 187 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: 2 2 Yes. The inspectors have adequate knowledge of the pipeline safety program and regulations during the inspection. 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: Yes. The inspector did a brief-out each day to discuss possible issues found during the review of procedures and records. An exit interview was performed on the last day 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: Yes. The inspectors identified probable violations during the inspection and they were communicated to the operator during the exit interview. 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 x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping Info Only Info Only DUNS: 046289216 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 18#
OH NG Program Evaluation, 2018, page 19D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: The inspectors did a good job of reviewing procedures and records during the inspection. There was no field activity. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 046289216 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 19#
OH NG Program Evaluation, 2018, 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 PHMSA 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 PHMSA Eastern Region. 1 1 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Results were documented in IA and completed at time of inspection. 1 1 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: PUCO identified probable violations, which resulted in a case being issued. 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 Evaluator Notes: There were no immediate safety hazard concerns. 1 1 6 Did the state give written notice to PHMSA within 60 days of all probable violations 1 1 found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 PUCO identified probable violation by submitting inspection records through (IA) and PIM within 60 days. 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: PUCO submitted necessary inspection records for identified probable violations. 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 Total points scored for this section: 7 Total possible points for this section: 7 DUNS: 046289216 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 20#
OH NG Program Evaluation, 2018, 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 2018 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 21#
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