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PHMSA oh-2022-gas-program-evaluation
2022 OH NG Program Evaluation - oh-2022-gas-program-evaluation (Ohio; Natural Gas State Program Evaluation)
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OH NG Program Evaluation, 2022, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2022 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 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 1#
OH NG Program Evaluation, 2022, page 22022 Gas State Program Evaluation -- CY 2022 Gas State Agency: Ohio Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: Yes Date of Visit: 10/25/2023 - 10/26/2023 Agency Representative: Joe Dragovich, Program Manager Gas Pipeline Safety Section PHMSA Representative: Agustin Lopez, State Evaluator, PHP-50 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 Sreet City/State/Zip: Columbus, 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 2022 (not the status of performance at the time of the evaluation). A deficiency in any one part of a multiple-part question should be scored as “Needs Improvement.” Determine the answer to the question then select the appropriate point value. If a state receives less than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their performance). This evaluation, together with selected factors reported in the state's annual progress report attachments, provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 50 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 100 State Rating................................................................................................................................................... 100.0 DUNS: 046289216 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 2#
OH NG Program Evaluation, 2022, 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. Reviewed PDM and PUCO files to verify operator data and number of units. PUCO is an interstate agent for gas operators. b. Reviewed inspection time kept by the PUCO to verify inspection days. The PUCO met the SICT inspection days and had above 20% of construction time. c. Reviewed PDM and OH PUC files to verify operator data. d. All reportable incidents were investigated and listed in the progress report. e. Reviewed compliance data from PUCO to verify number of compliance issued, corrected and carry over. f.Records are kept electronically and are secured. g. Verified qualifications with TQ Blackboard. h. Have adopted amendments within 2 years. i. List past and planned performance goals and damage prevention iniciatives. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 046289216 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 3#
OH NG Program Evaluation, 2022, 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: Section 5 of Inspection Plan includes pre and post inspection activities to guide inspectors for conducting inspections which include standard, TIMP, DIMP, OQ, Damage Prevention, and CRM. 2 Do written procedures address inspection priorities of each operator, and if necessary each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? 4 4 Evaluator Notes: Section 4.1 of Inspection Plan has inspection intervals established for each type of inspection. Standard inspections have 2 year intervals and HQ inspection have 5 year interval for large operators. Small operators have 5 year intervals. 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 3 3 taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: Section 6 of Inspection Plan includes Enforcement Procedures, describes the process of issuing compliance actions due to probable violations found during inspections. Written compliance actions are sent to company officials. Section 6.2 states that inspection documents to be submitted to Program Manager within 14 days of completions of the exit interview. Section 6.5 has 30 day and 90 day verbal and written notice to operators if probable violations are found. Recommend to add timeline for operator response as written in compliance letters. 4 (Incident/Accident Investigations) Does the state have written procedures to address state actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports 3 3 DUNS: 046289216 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 4#
OH NG Program Evaluation, 2022, page 5b. 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: Section 5.3 Incident Investigations has detailed procedures to guide inspectors in responding and conducting incident investigations. Section 5.3.1 has mechanism for receiving, recording and responding to incident notifications. Operators are required to report Incidents to the United States Coast Guard National Response Center (NRC) within one hour of confirmed discovery (49 CFR 191.5). Operators must also provide a telephonic notice to the Program Manager on all incidents per the Ohio Administrative Code section 4901:1-16-05(A). 5 General Comments: Info Only = No Points Evaluator Notes: The PUCO is mainly complying with Part B of the evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 046289216 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 5#
OH NG Program Evaluation, 2022, 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 4.3 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: Verified with TQ Blackboard to assure inspectors are qualified to lead inspections. Also revied randomly selected inspection reports to verify the leads were qualified. There are no jurisdicational LNG facilities in OH. 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Yes, Mr. Joseph Dragovich is knowledgeable of the pipeline sasfety program and regulations. He has completed all required TQ courses and has experience in pipeline safety. He was previously an inspector with the PUCO and has been the Program Manager for several years. 3 General Comments: Info Only = No Points Evaluator Notes: The PUCO is mainly complying with Part C of the evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 046289216 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 6#
OH NG Program Evaluation, 2022, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction (did state achieve 20% of total inspection person-days?) g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) 5 5 Evaluator Notes: Procedures Setion 4 states the following intervals: Records, Master Meters, and HQ Inspections(large operators)- 2 years Gathering operators-3 years. Propane operators-2 years. CRM, IMP-5 years. Reviewed randomly selected inspection reports to verify inspection intervals were met. 2 Did inspection form(s) cover all applicable code requirements addressed on Federal 10 10 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: Yes, reviewed randomly selected inspection reports to verify applicable code requirements and completion of forms. PUCO has developed very detailed forms for the standard and HQ inspections. They utilized AI equivalent for DIMP and TIMP program evaluations 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: Reviewed randomly selected inspection reports which included OQ inspections. The PUCO reviews OQ programs to very compliance and conduct Protocol 9 field inspections. 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 Subparts O and P Yes = 2 No = 0 Needs Improvement = 1 a. Are the implementation plans of the state's large/largest operators(s) being reviewed annually to ensure they are completing full cycle of the 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? 2 2 DUNS: 046289216 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 7#
OH NG Program Evaluation, 2022, page 8c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? Evaluator Notes: Yes, the PUCO conducts IMP inspections at intervals established in their procedures. A review of large operator IMP plans are conducted on an annual basis. Reviewed random IMP inspection reports to verify IMP plans are being reviewed. 5 Did the state review the following (these items are NTSB recommendations to PHMSA 2 2 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? Evaluator Notes: NTSB questions are addressed throughout the HQ Inspection form with "PHMSA Area of Emphasis" questions. a. Question 192.459 b. Question 192.613 c. Question 192.605 and .615 d. Question 192.614 and .615 e. Question 192.614 f. Question 192.623 g. Question 192.353 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Question on inspeciton form and also covered at annual Ohio Gas Association Technical Seminar Question 192.615(a)(3) natural disasters covers ADB 22-01. 1 1 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? 10 10 DUNS: 046289216 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 8#
OH NG Program Evaluation, 2022, page 9g. 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: Track open compliance in their gas pipeline safety database. Keeps updates and percent of violations still need completion. Inspector enters followup information. Database is well organize and tracking is very detailed. Recommend to include a file or compliance number to each comliance action to tie it back to the inspection. 8 (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: Yes reviewed incident investigation reports which are documented with great detail. There were no compliance actions issued due to an incident. Ohio Administrative Code section 4901:1-16-05(A) has requirement for operators to notify the PUCO telephonically of incidents. Section 5.3 of Insepction Plan has detailed mechanism to receive and respond to incident notifications. 9 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the PUCO responded within the 60 day requirement. 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Info Only Info Only Years? Chapter 8.5 Info Only = No Points Evaluator Notes: Yes - did a virtual Operator Training event in 2020 on October 29/30th and are currently planning one for this year with the Ohio Gas Association who helped with the 2020 event. It will likely be in early December. Have emailed the agenda for the 2020 event and I can share the agenda for the 2023 event when it's finalized. 11 Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only = No Points Info Only Info Only DUNS: 046289216 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 9#
OH NG Program Evaluation, 2022, page 10Evaluator Notes: Yes, question is covered in the HQ inspection form. 12 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Escalated enforcement cases that involve a fine or compliance order are docketed and available via our website. PUCO also attend and speak at the OGA Tech seminar every spring, meet with the OGA Codes and Regs committee a few times a year, and attend other events like the Marcellus Shale Coalition Pipeline Safety Seminar which Mr. Joe Dragovich spoke at in May of this year. Inspection reports are available to the public upon request. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: There is one SRCR-Columbia Gas 22-234976 filed 1/2022 involving intrastate pipeline. SRCR is open but there is an email 9/9/2022 from operators stating it has been corrected. Victor has comments in WMS stating corrections made. 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: Try to complete surveys as often as possible. Are still working through incorporating WMS into our workflow. We only use it for interstate work so it's not a common practice for the PUCO 15 If the State has issued any waivers/special permits for any operator, has the state verified 1 1 conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PUCO is aware of NGO waiver which is being tracked. There are older waivers which teh PUCO will review to check if they are still ongoing and have any followup or conditions that have to be met by the operators. 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes, files were well organized and accessible. Provided all requested items elecronically. 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: No issues with meeting SICT days and 20% construction days. Added a signigicant amount of additional detail for the risk ranking fields based on the feedback the PUCO received last year. 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: Discussed program performance measures with PM. Damages per 1,000 tickets has steadily decreased and it's at 2.5 in 2022. Downward trend on leaks repaired may be due to elimintaing leak prone pipe. DUNS: 046289216 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 10#
OH NG Program Evaluation, 2022, page 1119 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Info Only Info Only Evaluator Notes: 2019. Yes, large operators are implementing PSMS and some of the smaller operators have started the process as well. Also included a gap anaylysis with API RP 1173 as part of a large compliance order/action plan after an incident that occurred in 20 General Comments: Info Only = No Points Evaluator Notes: The PUCO is mainly complying with Part D of the evaluation. Info Only Info Only Total points scored for this section: 50 Total possible points for this section: 50 DUNS: 046289216 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 11#
OH NG Program Evaluation, 2022, page 12PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Evaluator Notes: Vectren Energy Delivery of Ohio(Centerpoint) Victor Omameh- Lead Inspector Scott Landon- Inspector Virtual Evaluation September 25-28, 2023 Agustin Lopez- State Evaluator a. Evaluated Mr. Victor Omameh conduct and IM Inspection. b. Last IM was in 2021. c. Yes, operator representatives were present during the inspection. d. Yes, Mr. Victor Omameh hasn't been evaluated in the recent past. Info Only Info Only 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, inspector utilized an IMP form to use as a guide and to document the results of the inspection. 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: a. Inspector verified applicable IMP procedures. b. Records were reviewed which included HCA verification, Tool runs, calibrations, etc c. There was no field inspection associated with this inspection. d. Verified OQ records of personnel involved in IMP. e. Yes the inspection was adequate in length. 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. Victor Omameh demonstrated knowledge of the pipeline safety program and regulations. He demonstrated knowledge of IM processes and regulations. DUNS: 046289216 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 12#
OH NG Program Evaluation, 2022, page 135 Did the inspector conduct an exit interview, including identifying probable violations? (If 1 1 inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Concluded inspection with an exit interview detailing issues and recommendations. Documented findings were noted and provided a copy of exit issues. 6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Evaluator Notes: Yes the inspection was conducted in a safe, positive and constructive manner. Info Only Info Only 7 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Mr. Victor Omameh and Scott Landon conducted a very thorough IMP inspection of Vectren Energy(Centerpoint). Reviewed IMP records and OQ of personnel. Concluded the inspection with en exit briefing. Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 046289216 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 13#
OH NG Program Evaluation, 2022, page 14PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues. Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Reviewe annual reports and use spreadsheets to lanalyze data and check for errors, trends or areas of concern. 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: Have added an excavation damage review section to our forms in the last few years which is reviewed with operator and individual tickets to confirm operators are properly classifying the cause of the damage. Have issued Compliance Orders to operators due to locating issues which operator has high damages due to locating issues. 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: Have always compared operators records to their annual report. For the 2023 forms, for better documenation, added fields to capture the number of damages reported on the annual report to document that they did review the numbers and compare with operator records. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? 2 2 DUNS: 046289216 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 14#
OH NG Program Evaluation, 2022, page 15Evaluator Notes: Yes, and inspector is assigned the task, Victor Omameh, compiles and graphs the annual report data every year and shares with the team. Tom Stikeleather also runs various reports/scenarios/graphs to help identify trends. This year they looked at locator at fault damages per 1000 tickets as a metric because that is the main area we can enforce on. 5 General Comments: Info Only = No Points Evaluator Notes: THe PUCO is mainly complying with Part F of the evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 046289216 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 15#
OH NG Program Evaluation, 2022, page 16PART 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: Region will complete these questions at the end of the calendar year and forward to Zach Barrett for including any issues in letter to the Chair. 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: Region will complete these questions at the end of the calendar year and forward to Zach Barrett for including any issues in letter to the Chair. 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: Region will complete these questions at the end of the calendar year and forward to Zach Barrett for including any issues in letter to the Chair. 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: Region will complete these questions at the end of the calendar year and forward to Zach Barrett for including any issues in letter to the Chair. 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: Region will complete these questions at the end of the calendar year and forward to Zach Barrett for including any issues in letter to the Chair. 6 General Comments: Info Only = No Points Evaluator Notes: letter to the Chair. Info Only Info Only Region will complete these questions at the end of the calendar year and forward to Zach Barrett for including any issues in Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 046289216 2022 Gas State Program Evaluation Ohio PUBLIC UTILITIES COMMISSION OF OHIO, Page: 16#
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192.605 · state program evaluation cites