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PHMSA oh-2020-gas-program-evaluation
2020 OH NG Program Evaluation - oh-2020-gas-program-evaluation (Ohio; Natural Gas State Program Evaluation)
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OH NG Program Evaluation, 2020, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2020 Gas State Program Evaluation for PUBLIC UTILITIES COMMISSION OF OHIO 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: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 1#
OH NG Program Evaluation, 2020, page 22020 Gas State Program Evaluation -- CY 2020 Gas State Agency: Ohio Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: Yes Date of Visit: 06/01/2021 - 06/11/2021 Agency Representative: Joe Dragovich, Chief Gas Pipeline Safety Section Pete Chace, Chief Facility Operations & Field Division Thomas E. Stikeleather, Service Monitoring & Enforcement Department Joshua Knox, GPS Compliance Investigator PHMSA Representative: Glynn Blanton, State Evaluator Commission Chairman to whom follow up letter is to be sent: Name/Title: Jenifer French, Chair Agency: Public Utilities Commission of Ohio Address: 180 East Broad Street City/State/Zip: Columbia, OH 43215-3793 INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2020 (not the status of performance at the time of the evaluation). A deficiency in any one part of a multiple-part question should be scored as “Needs Improvement.” Determine the answer to the question then select the appropriate point value. If a state receives less than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their performance). This evaluation, together with selected factors reported in the state's annual progress report attachments, provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 49 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 99 State Rating................................................................................................................................................... 99.0 DUNS: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 2#
OH NG Program Evaluation, 2020, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress Info Only Info Only report) Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: a. Public Utilities Commission of Ohio (PUCO) is a 60105 & Interstate agency. Jurisdictional authority, number of operators and unit inspected were found correct and verified via PHMSA Portal. b. Number of inspection person days 1627.5 meet the minimum requirement. Construction days 130.1 does not meet the 270 required number. Total drug & alcohol was 26 person days. c. Verification of operator's names and ID numbers in PHMSA Portal match attachment 1 & 3. No issues. d. Eleven incidents were reported by PUCO on attachment 4 for CY2020. The incidents match the number in PHMSA Portal. The incident that occurred on 09/04/2020 Dominion Energy Ohio is listed as (IP) Investigation Pending. Need to determined if the investigation has been completed and results. e. Number of carry over violations have been reduced from 70 to 55. Fourteen compliance actions were taken and two civil penalties assessed and collected. Dollars collected in CY2020 was $1,025,000.00 f. A review of list of records appears to be correct. Unable to verify due to working remotely. g. A review of TQ Blackboard crystal report found 9 of the 10 inspectors are gas qualified. Four inspectors are category I, five category II and 1 category III. Two inspectors are Gas IM qualified. Four inspectors have completed the root cause course. PM has recently completed the failure investigation course and is an active gas inspector. h. PUCO has not adopted all federal regulations. Five regulations were not adopted in CY2020 and as a result a loss of 3 points occurred on Progress Report review. In Acting Chair Trombold letter to Zach Barrett, they indicated the adoption of the five amendments will occur in May, 2021. i. No issues good description was provided in each section. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 3#
OH NG Program Evaluation, 2020, page 4PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities 5 5 for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. TIMP and DIMP Inspections (reviewing largest operator(s) plans annually) c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) g. LNG Inspections Evaluator Notes: a. Yes, Standard Inspection is listed on page 10 of PUCO 2020 Gas Pipeline Safety Inspection Plan under the heading "Conducting Inspections". b. Yes, TIMP & DIM Inspection procedures are listed on page 10 of PUCO 2020 Gas Pipeline Safety Inspection Plan. c. Yes, OQ Inspection procedures are listed on page 10 of PUCO 2020 Gas Pipeline Safety Inspection Plan. d. Yes, Damage Prevention Inspection procedures are included in the Standard Inspection listed on page 10 of PUCO 2020 Gas Pipeline Safety Inspection Plan. e. Yes, Construction Inspection procedures are listed on page 11 of PUCO 2020 Gas Pipeline Safety Inspection Plan. f. Yes, this is listed on page 10 of PUCO 2020 Gas Pipeline Safety Inspection Plan. g. N/A. PUCO has jurisdictional authority but no LNG in the State of Ohio. 2 Do written procedures address inspection priorities of each operator, and if necessary 4 4 each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? Evaluator Notes: Yes, items a to e are listed page 4 of 2020 PUCO Pipeline Safety Inspection Plan that states: Ohio uses a process for prioritizing inspections that considers the following: ? Operator size (data analysis shows larger operators tend to have a higher relative incident risk). ? Prior compliance performance of operators, including both the number and severity of past non-compliances and the number, nature and age of outstanding issues that remain open. ? Prior history of reportable incidents. ? Data from annual reports including pipe mileage and HCA mileage, pipe age and type, leak history, and dig-ins per 1,000 locates. ? Amount of time since a previous inspection. ? Pipeline system expansion (new construction, acquisition, etc.) f. Yes, this item is listed on page 2 and a review of operators show the inspection units are correctly broken down. 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 3 3 DUNS: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 4#
OH NG Program Evaluation, 2020, page 5b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: a. Yes, written procedures to identify notification of noncompliance are located on page 17 of 2020 PUCIO Pipeline Safety Inspection Plan under subtitle, "Enforcement Procedures". b. Yes, written procedures to routinely review progress of compliance action is listed on page 17 of 2020 PUCIO Pipeline Safety Inspection Plan under subtitle, "Enforcement Procedures". c. Yes, written procedures to routinely review progress of compliance action is listed on page 17 of 2020 PUCIO Pipeline Safety Inspection Plan under subtitle, "Enforcement Procedures". 4 (Incident/Accident Investigations) Does the state have written procedures to address state 3 3 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: a. Yes, mechanism to receive and respond to incidents reported by the operator are located on page 12 of 2020 PUCO Pipeline Safety Plan under subtitle "Incident Investigation". b. Yes, this item is described on page 12 under the subtitle, Assigning Incident and Outage Investigations, of 2020 PUCO Pipeline Safety Plan. 5 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 5#
OH NG Program Evaluation, 2020, 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) 5 5 Evaluator Notes: A review of TQ Blackboard crystal report found 9 of the 10 inspectors are gas qualified. Four inspectors are category I, five category II and 1 category III. Two inspectors (Michael Purcell & Victor Omameh) are Gas IM qualified. Four inspectors have completed the root cause course. PM has recently completed the failure investigation course and is an active gas inspector. 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Yes, Mr. Dragovich has completed all required training at TQ and familiar with the responsibilities of the Program Manager position. He was previously with Ohio Environmental Protection Agency and PUCO as Gas Pipeline Safety Compliance Investigator. 3 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 6#
OH NG Program Evaluation, 2020, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 4 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) Evaluator Notes: Random generated operators to be checked for this evaluation period consisted of 9 distribution, 7 transmission & 3 gas gathering operators. A review of data provided by Program Manager on inspections performed on each operator found the time intervals were met in accordance to PUCO procedures to at least once every 2 calendar years. PUCO performed 1627.5 inspection Person-Days for CY2020. The required number of construction inspection Person-Days for CY2020 was established as 270. The actual number of construction inspections performed was 130.1. The actual number was 10% of total required construction inspection Person-Days. PUCO did not achieve the 20% level requirement for the evaluation period under review. Due to COVID-19 restrictions established by Governor Mike DeWine, a loss of only one point instead of two points occurred. 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: Yes, PUCO inspection forms cover all federal and state code requirements. A review of inspection reports for this evaluation period consisted of the following and found to be complete with all applicable portions of the inspection form: Distribution OHIO CUMBERLAND GAS CO 11/13/2020 Records 8/13/2020 Headquarters Distribution COMMUNITY ENERGY RESOURCE COOPERATIVE 8/28/2020 Records 11/5/2019 Records Distribution FORAKER GAS CO 12/21/2020 Records 10/30/2020 Headquarters Distribution VERONA GAS DEPT, VILLAGE OF 5/6/2019 Records 8/17/2018 Records Distribution CONSUMERS GAS COOPERATIVE 10/27/2020 Headquarters 4/24/2019 Records Distribution BRIGHT ENERGY 8/4/2020 Headquarters 6/24/2019 Records Distribution GRANGER ENERGY OF LAKE COUNTY, LLC 10/2/2020 Records 8/6/2019 Records Distribution CONSOLIDATED GAS COOPERATIVE, INC. 6/24/2019 Records 3/8/2019 DIMP Distribution ARLINGTON NATURAL GAS CO 5/2/2019 Records 12/5/2018 DIMP Transmission SUMMIT MIDSTREAM PARTNERS, LLC 6/28/2019 Records 5/30/2018 Records Transmission ETHOS POWER PLANT SERVICES, LLC 12/6/2018 Records 1/2/2018 Headquarters Transmission ASPIRE ENERGY OF OHIO LLC 3/18/2019 Records 1/23/2019 Records Transmission UTICA EAST OHIO MIDSTREAM LLC 1/10/2019 Headquarters 1/9/2019 Records Transmission TRIAD HUNTER 11/25/2020 Records 3/23/2017 Records Transmission AK STEEL CORP 3/19/2021 Records 7/26/2019 Records Transmission NATIONAL GAS & OIL CORP 2/19/2019 Records 6/14/2018 Records DUNS: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 7#
OH NG Program Evaluation, 2020, page 8Gathering COBRA PIPELINE COMPANY, LTD. 12/4/2020 Records 10/30/2019 Records Gathering ASPIRE ENERGY OF OHIO LLC 3/18/2019 Records 1/23/2019 Records Gathering SUMMIT MIDSTREAM PARTNERS, LLC 6/28/2019 Records 5/30/2018 Records 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 2 2 should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, a review of database confirm PUCO uses the questions in IA to monitor the operator's OQ program. Additionally, they use their Headquarter Inspection and Gas Distribution & Transmission Inspection report forms to check the operator's OQ plan. 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 to ensure they are completing the full cycle of the DIMP/IMP process? b. Are states verifying with operators any plastic pipe and components that have shown a record of defects/leaks and mitigating those through DIMP plan? c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? 2 2 Evaluator Notes: 2020. a. Yes, PUCO continues to use Inspection Assistant for DIMP inspections. The largest operator(s) plans were reviewed in b. Yes, This is listed on the Headquarters' Inspection under failure investigation procedures of the form. c. Yes, PUCO continues to use the Low Pressure Gas System Survey Form to monitor the operator's threat analysis. 5 Did the state review the following (these items are NTSB recommendations to PHMSA that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. Operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance); c. Operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21; d. Operator records of previous accidents and failures including reported third- party damage and leak response to ensure appropriate operator response as required by 192.617; e. Directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? 2 2 Evaluator Notes: a. Yes, operator procedures for determining if exposed cast iron was examined for graphitization is in PUCO Headquarter form on page 12. Section question 192.459. b. Yes, surveillance of cast iron pipelines is found PUCO Headquarter form page DUNS: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 8#
OH NG Program Evaluation, 2020, page 918, question 192.613 c. Yes, operator emergency response procedures is check and found in PUCO Headquarter form on page 28 question (192.615) d. Yes, this item is located in PUCO Headquarter form on page 18 question (192.617) e. Yes, located in PUCO Headquarter form on page 27 question (192.614) f. Yes, located in the LP system survey document. g. Yes, this is found in the PUCO Headquarters' inspection form. 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes, PUCO provided information to the operators on the advisory bulletin document at the PUCO 2020 Virtual Pipeline Operator Training Seminar held on October 29 & 30, 2020. 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to 10 10 resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) Evaluator Notes: a. Yes. A review of 2020 PUCO Progress Report found 14 compliance actions taken, 2 civil penalties assessed and collected $1.025 Million. Violations cited 67 and number corrected including carryover was 82. Conducted a review of the compliance letter to verify letters were sent to company officers. The following letters were reviewed: Columbia Gas of Ohio dated, July 21, 2020; Dominion Energy dated May 20, 2020; Dominion Energy Ohio dated October 23, 2020; Dominion Energy Ohio dated June 3, 2020; Dominion Energy Ohio dated September 15, 2020; All America Energy dated January 31, 2020; Columbia Gas of Ohio dated February 6, 2020; Dominion Energy Ohio dated January 22, 2020; Dominion Energy Ohio dated January 21, 2020; Millennia Housing Management dated January 29, 2020; Sheldon Gas Company dated February 3, 2020; Duke Energy Ohio dated October 23, 2020. Additionally review Commission Case number 20-0681. b. Yes, each letter listed the probable violation correctly with a description of items found or noted. c. Yes, probable violations were resolved with an order or plan of action. d. Yes, all probable violations are reviewed in the database program. Each month a reminder is provided to each inspector requesting the status of the violation(s). The response is entered into the database. e. Yes, compliance action was taken on the fourteen items of non-compliance. f. Yes, Commission case number 19-2140 resulted in an assessment and collection of $1 Million. Also, Commission case number 20-0681 resulted in a fine amount of $25,000. g. Yes, Program Manager routinely reviews and approves all compliance letters. h. Yes, due process is provided to all operators in accordance to PUCO rules and regulations. i. Yes, a review of inspection reports clearly demonstrated an exit interview was conducted at the end of the inspection audit. j. Yes, a review of inspection reports and compliance letters demonstrated written findings were provided to the operator within 90 days from the inspection date. DUNS: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 9#
OH NG Program Evaluation, 2020, page 108 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly 10 10 documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? i. Does state share any lessons learned from incidents/accidents? Evaluator Notes: a. Yes, PUCO 2020 Gas Pipeline Safety Inspection Plan pages 9, 12 & 14 list the mechanism to receive and respond to incidents from operators. b. Yes, a review of PUCO database on Telephonic Notice of Incident & Service Failure confirm adequate records are maintained. c. Yes, a decision to not go on-site to investigate an incident is documented in the "Telephonic Notice of Incidents and Service Failures" form. This information is stored in their PUCO database. d. e., & f. Eleven incidents listed on 2020 PUCO Progress Report attachment 4. Incident reports were reviewed. Reviewed Dominion Energy Ohio incident dated 09-04-2020 and found the report was detailed and excellent description was provided. No issue. g. Yes. Compliance action was taken against Dominion Energy Ohio and Columbia Gas of Ohio on incidents that occurred in CY2020. h. Email sent to PHMSA AID on June 7, 2021, confirmed PUCO responded and provided follow-up information on all incidents that occurred in OH. i. Yes, information on incidents will be shared at the NAPSR Eastern Region next week June 14, 2021 during the virtual meeting. 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 1 1 Evaluator Notes: No response was required due to a perfect state program score. However, Acting Chair Trombold letter dated December 28, 2020 reflected action taken by PUCO in the adoption of the pipeline safety regulations. 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Evaluator Notes: Yes, PUCO 2020 Virtual Pipeline Operator Training Seminar was held on October 29 & 30, 2020. Info Only Info Only 11 Has state confirmed transmission operators have submitted information into NPMS Info Only Info Only database along with changes made after original submission? Info Only = No Points Evaluator Notes: Yes, this item is reviewed with the operator during their inspection and found on page 2 of PUCO Headquarters Inspection Form. DUNS: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 10#
OH NG Program Evaluation, 2020, page 1112 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: This is accomplished via PUCO website and meetings with operators. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes. One safety related condition report was submitted on October 26, 2020. The report was submitted by Enbridge pertaining to exceedance of maximum allowable operating pressure. An investigation was conducted and report submitted on October 21, 2020. The information is located in PUCO Safety Related Condition Follow Up Report. 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? 1 1 Evaluator Notes: Yes. Email sent to Robert Clarillos. His response was, "We had 18 NAPSR surveys in 2020. Ohio participated in 8 of them. All of those 8 responses were timely. Some may not have applied to them, but that is a decision the PMs makes at the time." 15 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Waiver submitted by National Gas & CO-OP in 2017 and approved by the PUCO in 2018 is still open. 1 1 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes. 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: Program manager understands the SICT on the scoring of inspection days. For current year 2021, the number of inspection days is 1190 and construction days will be 238. 18 Discussion on State Program Performance Metrics found on Stakeholder Communication Info Only Info Only site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: A review of performance metrics showed Total leaks repaired in 2020 was down to 258 from previous year of 286. Hazardous leaks eliminated was down to 99 from previous year of 126. Leaks scheduled for repair was down from 84 to 81 per 1,000 miles. Information clearly shows a downward trend in leak management. 19 DUNS: 046289216 2020 Gas State Program Evaluation 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/ Info Only Info Only Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 11#
OH NG Program Evaluation, 2020, page 12b. Reference AGA recommendation to members May 20, 2019 Evaluator Notes: Yes. This is accomplished by three methods. 1 Training meetings with the operator and discussion about implementation of PSMS.; 2. The use of PUCO Headquarters' form . and 3. PUCO Enforcement program letters requiring the operator to participate in PSMS and provided updates to the agency. 20 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: A loss of one point occurred in question D.1. PUCO did not achieve 20% of total construction person-days for the evaluation period under review. Due to COVID-19 restrictions established by Governor Mike DeWine, a loss of only one point instead of two points occurred. Total points scored for this section: 49 Total possible points for this section: 50 DUNS: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 12#
OH NG Program Evaluation, 2020, page 13PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Info Only Info Only Evaluator Notes: Two days were spend observing two different construction projects. On June 1st CenterPoint Energy (formerly Vectren) was replacing their Bare Steel/Cast Iron piping in the City of Germantown on Pennsylvania Street. The project number for this replacement program was v-1335. The last time this unit was inspected was May 10-11, 2021. On June 4th, the other construction project was with Duke Energy on their project C-350 line (central corridor), which was a 15 +/- mile 20" steel High pressure distribution line. The line was being installed to allow Duke Energy to retire the last active Propane Peaker plant in Ohio. The pipeline runs through various densely populated areas and due to the size of the line was designed as a transmission line but used as a high-pressure distribution pipeline. 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 2 2 Evaluator Notes: Yes, the inspector was using PUCO Natural Gas Pipeline Construction/Replacement form. Each item listed in the document was checked relative to the items observed at each construction site. Observed inspector asking questions and taking pictures of the construction boring and tie-in welding joints. 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: Mr. Knox checked in with CenterPoint Energy and Duke Energy representatives on his arrival at the sites. He asked a lot of questions on the companies procedures and documentation on the pipeline material being installed. Mr. Knox reviewed the operator's OQ plan and personnel performing the construction work at each site. Safety clothing and eye protection was observed being worn by all construction personnel and observing all safety waring signs. The directional drilling personnel were observed marking and observing all traffic before painting the location of the drilling bit boring thru the soil. Both construction sites were of adequate length to observe Mr. Knox and the inspection work being performed. He conducting himself in a very professional and knowledge manner. 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: Yes, Mr. Knox demonstrated himself as a subject matter expert in pipeline construction. He has attended TQ and completed four courses. He previously worked for Duke Energy Gas Company. At Duke Energy, he was the construction crew foreman for 9 years dealing with pipeline construction and maintenance work. DUNS: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 13#
OH NG Program Evaluation, 2020, page 145 Did the inspector conduct an exit interview, including identifying probable violations? (If inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, at both site locations and exit interviews this was noted. No areas of concern or violations were found. 1 1 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 b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Info Only Info Only Evaluator Notes: Yes, all safety precautions and practices were followed by all individuals at each construction site. No unsafe acts were observed and the relationship with the operator and public was very cordial. 7 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 14#
OH NG Program Evaluation, 2020, page 15PART 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: Annual reports are reviewed by one staff member that develops a spreadsheet showing the number of damages occurring on the systems. Additionally, information on the annual report is review with the operator by the inspector on the PUCO Headquarters Inspection form, Section 192.614 Damage Prevention Program. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, information is discussed with the operator during the PUCO Headquarter Inspection form Section 192.614. 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation 4 4 Damage? Yes = 4 No = 0 Needs Improvement = 1-3 a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: a. Yes. One PUCO inspector is reviewing all annual reports for accuracy. Information in the annual reports are posted into an Excel spreadsheet that is used to monitor damage prevention, miles of pipe & other data. b. Yes, this item is review in PUCO Headquarter Inspection form on pages 20-21 under sub-title Damage Prevention Program Procedures. c. Yes, this item is review in PUCO Headquarter Inspection form on pages 20-21 under sub-title Damage Prevention Program Procedures. d. Yes, this item is review in PUCO Headquarter Inspection form on pages 20-21 under sub-title Damage Prevention Program Procedures. e. Yes, operators are taking action to re-qualify individuals when marking errors occur. f. Approximately 33% of the damages are from larger operators. g. Approximately 24% h.Yes, the larger operators are on a time schedule to update their mapping system based on agreement with PUCO. i. Yes, when mapping errors occur the operator is making timely corrections in accordance to their written procedures. j. Yes, this item is checked in PUCO Headquarter Inspection form on page 21, sub-title Damage Prevention Program Procedures. DUNS: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 15#
OH NG Program Evaluation, 2020, page 164 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? 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. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? Evaluator Notes: a. Third party contractors and operator mapping errors. b. Yes, the operators are looking at High risk factors and targeting contractors or individuals who damage their facilities. c. Yes, operator or their contractor are not following written procedures on locating facilities. d. Yes, damage prevention is reviewed with the operator during inspections and meetings. 5 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 16#
OH NG Program Evaluation, 2020, page 17PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant Info Only Info Only program for documenting inspections? Info Only = No Points Evaluator Notes: Information was provided from PHMSA Eastern Region Office on May 11, 2021 by Rob Burrough: Yes, all inspections were conducted using Inspection Assistant (IA). All planned questions were answered, required forms were completed and necessary documents were attached within IA. 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: Information was provided from PHMSA Eastern Region Office on May 11, 2021 by Rob Burrough: Independent PHMSA team inspections were not conducted in 2020. Notifications that inspection was complete and probable violations were/were not identified was provided on time for inspections with PHMSA teams. 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA Info Only Info Only immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: Information was provided from PHMSA Eastern Region Office: Independent PHMSA team inspections were not conducted in 2020. 4 If inspections were conducted independent of a PHMSA team inspection did the state Info Only Info Only coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: Information was provided from PHMSA Eastern Region Office: Additional independent inspections were not conducted in 2020. PHMSA inspection Work Plan was coordinated between OH and PHMSA (all Regions thru Eastern Region) prior to issuance of 2020 Inspection Plan. 5 Did the state take direction from and cooperate with PHMSA for all incident Info Only Info Only investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: Information was provided from PHMSA Eastern Region Office: Failure investigations were conducted by OH and coordinated with appropriate PHMSA Region including PHMSA's AID. 6 General Comments: Info Only = No Points Evaluator Notes: No lose of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 046289216 2020 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 17#
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