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PHMSA pa-2022-gas-program-evaluation
2022 PA NG Program Evaluation - pa-2022-gas-program-evaluation (Pennsylvania; Natural Gas State Program Evaluation)
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PA 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 PENNSYLVANIA PUBLIC UTILITY COMMISSION Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 1#
PA NG Program Evaluation, 2022, page 22022 Gas State Program Evaluation -- CY 2022 Gas State Agency: Pennsylvania Rating: Agency Status: Date of Visit: 05/15/2023 - 06/16/2023 Agency Representative: Mr. Robert Horensky Fixed Utility Valuation Manager PHMSA Representative: Mr. Clint Stephens State Liaison Commission Chairman to whom follow up letter is to be sent: Name/Title: Ms. Gladys Brown Dutrieuille, Chair Agency: Pennsylvania Public Utility Commission Address: 400 North Street City/State/Zip: Harrisburg, Pennsylvania 17120 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 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 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: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 2#
PA 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: 1a. Data in Attachment 1 of Progress Report seems accurate. 1b. Data in Attachment 2 of Progress Report seems accurate. 1c. Data in Attachment 3 of Progress Report seems accurate. 1d. Data in Attachment 4 of Progress Report seems accurate. 1e. Data is accurate in Attachment 5 of Progress Report. 1f. Information in Attachment 6 of Progress Report is included in the PA PUC inspection manual. 1g. Information in Attachment 7 of Progress Report seems accurate. 1h. PA PUC has automatic adoption of federal regulations. 1i. The PA PUC has outlined performance (Past and Present) in Attachment 10 of Progress Report. No issues. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 3#
PA 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: Standard Inspection procedures are found in Section 9.16, Construction inspection procedures are found in Section 9.19, OQ inspection procedures are found in Section 9.20, Damage prevention procedures are found in Section 9.21, IM inspection procedures are found in Section 9.22, DIMP inspection procedures are found in Section 9.23, LNG inspection procedures are found in Section 9.24, and On-Site Operator Training procedures are found in Section 9.6 (c). No issues. 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: The procedures to identify steps to be taken from discovery to resolution of a probable violation is found in Sections 7.3, the process to routinely review progress of compliance actions is included in each type of inspection procedure (recommend using as a general process in procedures); and procedures regarding closing outstanding probable violations is found in Section 7.4. No issues. 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: The procedures to identify steps to be taken from discovery to resolution of a probable violation is found in Sections 7.3, the process to routinely review progress of compliance actions is included in each type of inspection; and procedures regarding closing outstanding probable violations is found in Section 7.4. No issues. 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 3 3 DUNS: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 4#
PA NG Program Evaluation, 2022, page 5a. 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: Section 6.2.3 includes procedures for afterhours reports. The PA PUC reports onsite to all reported incidents is found in Section 12.2. Investigation of incident procedures is found in Section 12.0. No issues. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part B of the program evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 5#
PA 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: Yes. Inspectors and program manager fulfilled training requirements to lead inspection types. Inspectors received outside training at the Appalachian Corrosion Control Short Course, Liberty Bell corrosion training, CGA conference, and Energy Association of Pennsylvania conference. 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 Evaluator Notes: The pipeline safety program manager indicated adequate knowledge of PHMSA program and regulations. 5 5 3 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part C of the program evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 6#
PA 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: Reviewed inspection reports form the random operator list for CY2022 to verify inspection intervals. There were no issues. 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: Reviewed the following inspection reports: Standard: KAIB & KAIB, LLC (2022); SAR GAS, INC. (2022); TUCKER ENERGY SOLUTIONS, LLC (2022); ELLWOOD REALTY ACQUISITION COMPANY (ERAC) (2022); NFG MIDSTREAM COVINGTON, LLC (2022); SWEPI LP (NFG Midstream Wellsboro, LLC) (2022); EQUITRANS MIDSTREAM CORPORATION (2022); SUPERIOR APPALACHIAN PIPELINE, L.L.C. (2022); NFG MIDSTREAM TROUT RUN, LLC (2022); ALLIANCE PETROLEUM CORPORATION (2022); PENNSYLVANIA GENERAL ENERGY COMPANY, LLC (2022); VISTA ENERGY, INC (2022); MARKWEST LIBERTY BLUESTONE, L.L.C. (2022); HEP PENNSYLVANIA GATHERING, LLC (2022) PAP: KAIB & KAIB, LLC (2022); SAR GAS, INC. (2022); ELLWOOD REALTY ACQUISITION COMPANY (ERAC) (2022); NFG MIDSTREAM COVINGTON, LLC (2022); ALLIANCE PETROLEUM CORPORATION (2022); PENNSYLVANIA GENERAL ENERGY COMPANY, LLC (2022); VISTA ENERGY, INC (2022); MARKWEST LIBERTY BLUESTONE, L.L.C. (2022); HEP PENNSYLVANIA GATHERING, LLC (2022) D&A: PINE ROE NATURAL GAS (2022); KAIB & KAIB, LLC (2022); SAR GAS, INC. (2022); TUCKER ENERGY SOLUTIONS, LLC (2022); ELLWOOD REALTY ACQUISITION COMPANY (ERAC) (2022); NFG MIDSTREAM COVINGTON, LLC (2022); SUPERIOR APPALACHIAN PIPELINE, L.L.C. (2022); PENNSYLVANIA GENERAL ENERGY COMPANY, LLC (2022); VISTA ENERGY, INC (2022); MARKWEST LIBERTY BLUESTONE, L.L.C. (2022); HEP PENNSYLVANIA GATHERING, LLC (2022) CRM: NFG MIDSTREAM COVINGTON, LLC (2022); EQUITRANS MIDSTREAM CORPORATION (2022) Part 193: PECO ENERGY CO (2022); PHILADELPHIA GAS WORKS LNG (2022); UGI ENERGY SERVICES (2022) OQ: PINE ROE NATURAL GAS (2022); SAR GAS, INC. (2022); TUCKER ENERGY SOLUTIONS, LLC (2022); ELLWOOD REALTY ACQUISITION COMPANY (ERAC) (2022); NFG MIDSTREAM COVINGTON, LLC (2022); SUPERIOR APPALACHIAN PIPELINE, L.L.C. (2022); ALLIANCE PETROLEUM CORPORATION (2022); PENNSYLVANIA GENERAL ENERGY COMPANY, LLC (2022); MARKWEST LIBERTY BLUESTONE, L.L.C. (2022); HEP PENNSYLVANIA GATHERING, LLC (2022) DIMP: LEATHERSTOCKING GAS COMPANY (2022) ? operator had not responded to NOPVs; NATIONAL FUEL GAS SUPPLY CORP (2022); KAIB & KAIB, LLC (2022)DUNS: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 7#
PA NG Program Evaluation, 2022, page 8IM: TUCKER ENERGY SOLUTIONS, LLC (2022); ELLWOOD REALTY ACQUISITION COMPANY (ERAC) (2022); NFG MIDSTREAM COVINGTON, LLC (2022); SUPERIOR APPALACHIAN PIPELINE, L.L.C. (2022); ALLIANCE PETROLEUM CORPORATION (2022). 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 2 1 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 OQ inspections performed in 2022. OQ inspection records for Green Leaf Gas Co. could not be located at time of inspection. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This 2 2 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? c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? Evaluator Notes: Yes. The state is verifying operator's integrity management Program. The state is verifying operators with any plastic pipe and components have shown record defects/leaks; and including low pressure distribution systems is included in the DIMP inspection form. 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: Yes. The PAPUC emailed data request FL-1-22 to operators on March 28,2022, to communicate NTSB recommendations to the operator which analyzes the data for trends or risk factors associated with threats in included in their DIMP/IMP programs. The PAPUC has state code 59.18 to remove regulators outside buildings. DUNS: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 8#
PA NG Program Evaluation, 2022, page 96 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: There is an ADB link on the PA PUC pipeline safety webpage. This being updated on a semi-annual basis. 1 1 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) 10 10 Evaluator Notes: Yes. The state did follow compliance procedures and adequately document all probable violations including resolution and next course of action. LEATHERSTOCKING GAS COMPANY (2022) ? operator had not responded to NOPVs. Requested state email update on communication with Leatherstocking Gas Co. 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: Reviewed incident reports for Peoples Natural Gas Co. (07282022) and UGI Utilities Inc.(11072022), which were thoroughly documented but the investigations are ongoing. 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 DUNS: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 9#
PA NG Program Evaluation, 2022, page 10Evaluator Notes: Chair letter sent July 20, 2022; response received on September 13, 2022. No issue. 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: Info Only Info Only The PA PUC had it last pipeline safety seminar on September 7 ? 8, 2022. Presentation is put out on the PA PUC website. 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: The PA PUC has verified transmission operators have submitted information to NPMS through the PDM and by email request. 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: All enforcement cases are on the state website. The PA PUC meets with operators on an annual basis at the Energy Association of Pennsylvania conference to discuss any issues pertaining to pipeline safety. 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 an open SRCR with UGI Utilities pertaining to an ILI tool run report. The PA PUC has added notes on April 13, 2023, in WMS indicating the operator has lowered pressure to 13 psi and will decide to repair pipeline or abandon. Suggest the PA PUC contact operator to get status update. The state has contacted operator for update. 14 Was the State responsive to: 1 1 Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? Evaluator Notes: The state has been responsive to surveys or information requests from NAPSR or PHMSA. Additionally, the state has performed WMS tasks. 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: The PA PUC has one open waivers/special permits. Verified the PA PUC is monitoring the status of the waiver with Johnstown Regional Energy. The was no report due in CY2022. 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes. The pipeline program files were well organized and accessible. 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? 3 3 DUNS: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 10#
PA NG Program Evaluation, 2022, page 11Yes = 3 No = 0 Needs Improvement = 1-2 Evaluator Notes: Discussed with the state the accuracy of inspection day information submitted into SICT. No issues. 18 Discussion on State Program Performance Metrics found on Stakeholder Communication site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Info Only Info Only Discussed State Program Performance Metrics with PA PUC with no negative trends. 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Info Only Info Only Evaluator Notes: Yes. The PA PUC has confirmed that all their larger operators have adopted some type of Safety Management System. The PA PUC is continually having conversation with the operator on SMS during their Energy Pennsylvania conference. 20 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: There was on issued identified in Part D of the program evaluation: OQ inspection records for Green Leaf Gas Co. could not be located at time of inspection. Total points scored for this section: 49 Total possible points for this section: 50 DUNS: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 11#
PA 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: Operators: PECO Energy Company and Philadelphia Gas Works (LNG) Inspectors: Nick Nagle (L), Scott Orr (L), and Terri Smith Locations: Cynwd, PA and Philadelphia, PA Dates: May 16-17, 2023 PHMSA Rep.: Clint Stephens Info Only Info Only The inspection type was construction on PECO Energy and standard field on PGW. The pipeline operator was present during both inspections. 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 inspectors used the appropriate inspection forms as a guide during the inspections. A field plastic pipeline construction inspection form was used for the PECO inspection. A standard LNG inspection form was used for the PGW inspection. There were no issues. 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: Yes. The inspectors adequately reviewed procedures, such as fusion, pressure test, as-built drawings, GIS mapping, and O&M procedures. The inspectors reviewed records, such as OQ, pressure test, calibration, and LNG equipment test records. The inspectors observed butt fusion, control room monitoring, condition of water hoses, ESD signs, fire extinguishers, and fire suppression equipment. The inspections were not complete during the program evaluation; but it was of adequate length to observe the inspectors perform their job functions. There were no issues. 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: From my observation, the inspectors had adequate knowledge of the pipeline safety program and regulations. 5 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) 1 1 DUNS: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 12#
PA NG Program Evaluation, 2022, page 13Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: inspections. The inspectors conducted an exit brief-out at each location communicating with the operator any issues found during the 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: The inspections were performed in a safe, positive, and constructive manner. The inspectors observed butt fusion, control room monitoring, condition of water hoses, ESD signs, fire extinguishers, and fire suppression equipment. There were no issues. 7 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part E of the program evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 13#
PA 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: and operator issues. The state has reviewed operator annual reports, along with incident/accident reports for accuracy and analyzed data for trends 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: The PA PUC has broken out the damage prevention section in the DIMP/IM inspections in order analyze damages for the purpose determining root causes. The state has verified with the operators the excavators who have repeatedly violated one- call laws and damaged their facilities. 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: Yes. The PAPUC is capturing the data from One-Call field investigations, non-compliance letters, and analyzing data from annual reports formatted on charts. The PAPUC has formulated charts showing root causes, such as "One-Call Notifications Practices not Sufficient", "Locating Practices Not Sufficient", mismarks, mapping inaccuracies, and "Excavation Practices Not Sufficient". 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. 2 2 DUNS: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 14#
PA NG Program Evaluation, 2022, page 15d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? Evaluator Notes: Yes. The Damage Prevention Section, along with the pipeline safety office collects data and evaluate trends on the number of pipeline damages per 1,000 tickets. The PA PUC has determined that contractors are causing the highest number of damages to the pipelines. The large operators have provided training for those stakeholders that perform excavation and cause the most damages. The PA PUC has evaluated trends to determine the root cause of most excavation damages. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part F of the program evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 15#
PA 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 program for documenting inspections? Info Only = No Points Evaluator Notes: PA PUC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days? Info Only = No Points Evaluator Notes: PA PUC is not an interstate agent and does not have a 60106 agreement with PHMSA. 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: PA PUC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: PA PUC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: PA PUC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: PA PUC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 796091569 2022 Gas State Program Evaluation Pennsylvania PENNSYLVANIA PUBLIC UTILITY COMMISSION, Page: 16#
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