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PHMSA ri-2018-gas-program-evaluation
2018 RI NG Program Evaluation - ri-2018-gas-program-evaluation (Rhode Island; Natural Gas State Program Evaluation)
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RI NG Program Evaluation, 2018, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2018 Gas State Program Evaluation for RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 1#
RI NG Program Evaluation, 2018, page 22018 Gas State Program Evaluation -- CY 2018 Gas State Agency: Rhode Island Rating: Agency Status: Date of Visit: 09/24/2019 - 09/26/2019 Agency Representative: November 1, 2019 Robert Bailey Gas Safety Program Manager PHMSA Representative: Clint Stephens Commission Chairman to whom follow up letter is to be sent: Name/Title: Ms. Linda George, Interim Administrator Agency: State Of Rhode Island DPUC Address: 89 Jefferson Blvd. City/State/Zip: Warick, Rhode Island 02888 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2018 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 5 B Program Inspection Procedures 13 13 C Program Performance 43 19.5 D Compliance Activities 13 7 E Incident Investigations 5 5 F Damage Prevention 8 8 G Field Inspections 10 8 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 102 65.5 State Rating................................................................................................................................................... 64.2 DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 2#
RI NG Program Evaluation, 2018, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress 1 0 Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The data in Attachment 1opf the Progress Report is inaccurate with LPG and LNG units not correct. The data should indicate 37 LPG units and 2 LNG units. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 0 Evaluator Notes: The information included in Attachment 2 of Progress Report has been deemed invalid. The State of Rhode Island does not have inspection records to validate inspection activity. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The information included in Attachment 3 of Progress Report seems accurate. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no federal reportable incidents in CY2018. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 0 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no inspection records to validate accuracy of compliance activities. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 0 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The State of Rhode Island is in the process of converting all files to electronic versions. Presently, files are not well- organized and easily accessible for review. This is a repeat from the previous year evaluation. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Training records were accurate and complete. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State of Rhode Island had adopted all Rules and Amendments. 1 1 DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 3#
RI NG Program Evaluation, 2018, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State of Rhode Island described its accomplishments in detail which included inspecting all regulator stations in 2018. Will be hiring new inspectors in the future. 10 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: 1) Needs Improvement. The data in Attachment 1 is inaccurate with LPG and LNG units not correct. 2) There were no inspection records to validate data in Attachment 2. 3) There were inspection records to validate accuracy of compliance activities, in Attachment 5. 4) The State of Rhode Island is in the process of converting all files to electronic versions. Presently, files are not easily accessible for review. Total points scored for this section: 5 Total possible points for this section: 10 DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 4#
RI NG Program Evaluation, 2018, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 2 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The procedures for Standard Inspections included on page 10, Part V - Conducting Inspections of the State of Rhode Island Pipeline Safety Procedures. 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The procedures for DIMP Inspections included on page 14, subpart N - Distribution Integrity Management Programs in the State of Rhode Island Pipeline Safety Procedures. 3 OQ Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The procedures for OQ Inspections included on page 14, subpart I - Training and Operator Qualification (OQ) Inspections in the State of Rhode Island Pipeline Safety Procedures. 4 Damage Prevention Inspection procedures should give guidance to state inspectors that 1 1 insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The procedures for Damage Prevention Inspections included on page 14, subpart M - Damage Prevention Activity Inspections in the State of Rhode Island Pipeline Safety Procedures. 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The procedures for Operating Training included on page 14, subpart L - Operator Training in the State of Rhode Island Pipeline Safety Procedures. 6 Construction Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The procedures for Construction Inspections included on page 12-14, subpart H - Construction Inspections in the State of Rhode Island Pipeline Safety Procedures. 7 Does inspection plan address inspection priorities of each operator, and if necessary each unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 DUNS: 623014990 2018 Gas State Program Evaluation 6 6 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 5#
RI NG Program Evaluation, 2018, page 6a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: The procedures for Inspection priorities included on page 18, subpart B - Inspection Priorities in the State of Rhode Island Pipeline Safety Procedures. 8 General Comments: Info Only = No Points Evaluator Notes: There were no issues in Part B of evaluation. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 6#
RI NG Program Evaluation, 2018, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 86.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 1.25 = 275.00 Ratio: A / B 86.00 / 275.00 = 0.31 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 0 Evaluator Notes: RI PUC pipeline safety staff did not have enough inspection days to meet the .38 inspection day ratio. 5 0 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 3 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: Lateef Olajide had completed all T Q Training for a program manager in CY 2018. There was a DIMP inspection performed in CY 2108, but Lateef had not taken the DIMP course to lead inspection. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 2 0 Evaluator Notes: The state pipeline safety program manager for CY 2018 was not available to discuss PHMSA program and regulation. He no longer works for the State of Rhode Island. There is a new program manager with the State of Rhode Island who started August 19, 2019. He is on wait list to start taking courses at T&Q, but presently does not have adequate knowledge of PHMSA program and regulations. 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 2 1 Evaluator Notes: Chair letter sent July 24, 2018, response received August 8, 2018; however, the State address those deficiencies based on repeat issues found during the CY 2018 program evaluation. 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 1 1 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: There was a New England Pipeline Safety Seminar held October 9-10, 2018, in Meredith, NH. The State of Rhode Island attended as part of the consortium. DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 7#
RI NG Program Evaluation, 2018, page 86 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 5 2 Evaluator Notes: No. There is no record of the State of Rhode Island performing any type of inspections in 2018. The RI Pipeline Safety Procedures require inspections to be performed on annual basis. The State of Rhode Island representative stated inspections were performed, but was not adequately documented on an inspection checklist form and filed for review. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 0 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: There were no records of inspections being performed in 2018, which indicates no inspection forms were filled out during the inspections. 8 Did the state review operator procedures for determining if exposed cast iron pipe was 1 1 examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: National Grid is the only operator in the State of Rhode Island with cast iron pipe and they are under an accelerated main replacement program. 9 Did the state review operator procedures for surveillance of cast iron pipelines, including 1 1 appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: National Grid is the only operator in the State of Rhode Island with cast iron pipe and they are under an accelerated main replacement program. 10 Did the state review 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? (NTSB) Chapter 5.1 Yes = 1 No = 0 1 0 Evaluator Notes: No. There is no record that the State of Rhode Island reviewed operator emergency response procedures in 2018. 11 Did the state review operator records of previous accidents and failures including 1 0 reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: No. There is no record that the State of Rhode Island reviewed operator records of previous accidents and failures including third party damage and leak response in 2018. 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: There was documentation that showed the State of Rhode Island had reviewed Operator (National Grid) Annual reports for accuracy and analyzed data for trends and operator issues. DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 8#
RI NG Program Evaluation, 2018, page 913 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There are no transmission operators under the jurisdiction of the State of Rhode Island. 1 NA 14 Is the state verifying operators are conducting drug and alcohol tests as required by 2 1 regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No. There is no record that the State of Rhode Island verified operators are conducting drug and alcohol tests as required by regulation in 2018. 15 Is state verifying operators OQ programs are up to date? This should include verification 2 1 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No. There is no record that the State of Rhode Island verified operators OQ programs are up to date in 2018. 16 Is state verifying operator's gas transmission integrity management programs (IMP) are up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually? Are replies to Operator IM notifications addressed? (formerly part of Question C-13)). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: There are no transmission operators under the jurisdiction of the State of Rhode Island. 2 NA 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 1 This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No. There is no record that the State of Rhode Island verified operator's gas distribution integrity management Programs (DIMP) in 2018. 18 Is state verifying operators Public Awareness programs are up to date and being 2 1 followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No. There is no record that the State of Rhode Island verified operators Public Awareness programs are up to date and being followed in 2018. 19 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 623014990 2018 Gas State Program Evaluation 1 1 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 9#
RI NG Program Evaluation, 2018, page 10Yes. Information pertaining to pipeline safety is included in the State website; and staff attends excavation contract meetings on quarterly basis. Closed enforcement cases are available by request from the public. 20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no open SRC Reports in CY2018. 1 NA 21 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 0.5 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No. There is no record that the State of Rhode Island asked operators to identify any plastic pipe and components that has shown a record of defects/leaks. 22 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. The State did participate in/respond to surveys or information requests from NAPSR or PHMSA. 1 1 23 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: There no open waivers/special permits. 1 NA 24 Did the state attend the NAPSR National Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes. The NAPSR National Meeting was held in Santa Fe, NM. 1 1 25 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 1 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: - Damage Prevention Program ? Excavation Damages per 1,000 tickets has increased from 2016 to 2018. - Inspection Activity ? Inspection Days per 1,000 miles gas pipelines have decreased from 2017 to 2018. Inspection days per Master meters/LPG has decreased from 2017 to 2018. - Inspector Qualification ? Inspector qualification with % Core Training has decreased from 2017 to 2018. No additional training from 2017 to 2018. Inspector qualification with % 5-year retention has remained the same from 2017 to 2018. 26 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 1 0 Evaluator Notes: SICT. DUNS: 623014990 2018 Gas State Program Evaluation Discussed SICT with State which the SICT was calculated at 111 for CY2018, and Attachment 2 of Progress Report indicates 86 person days in CY2018. Did not meet requirement. State will have to contact Rex to get guidance on how to update Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 10#
RI NG Program Evaluation, 2018, page 1127 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 1 NA Evaluator Notes: There are no transmission pipelines under the jurisdiction of the State of Rhode Island. 28 General Comments: Info Only = No Points Evaluator Notes: The following issues were identified in Part C of evaluation: Info Only Info Only - RI PUC pipeline safety staff did not have enough inspection days to meet the .38 inspection day ratio; - There was a DIMP inspection performed in CY 2108, but Lateef had not taken the DIMP course to lead inspection; - The state pipeline safety program manager for CY 2018 was not available discuss PHMSA program and regulation He no longer works for the State of Rhode Island. There is a new program manager with the State of Rhode Island who started August 19, 2019; - Chair letter sent July 24, 2018, response received August 8, 2018; however, the State address those deficiencies based on repeat issues found during the CY 2018 program evaluation; - There is no record of the State of Rhode Island performing any type of inspections in 2018. The RI Pipeline Safety Procedures require inspections to be performed on annual basis; - Negative trends identified during the discussion of State Program Performance Metrics; and - Discussed SICT with State which the SICT was calculated at 111 for CY2018, and Attachment 2 of Progress Report indicates 86 person days in CY2018. Did not meet requirement. Total points scored for this section: 19.5 Total possible points for this section: 43 DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 11#
RI NG Program Evaluation, 2018, page 12PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: Procedures are included on page 14-16, "Notice of Probable Violation" in the State of RI Pipeline Safety Procedures. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 0 document all probable violations, including what resolution or further course of action is needed to gain compliance? (Incident Investigations do not need to meet 30/90 day requirement) Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: There no inspection records to validate whether state followed compliance procedures from discovery to resolution. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 0 Evaluator Notes: There were no inspection records to determine whether state issued compliance actions for all probable violations discovered. 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: There no inspection records to validate whether compliance actions were warranted. 2 NA 5 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Program manager is familiar with state process for imposing civil penalties. 2 2 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no fines accessed in 2018. DUNS: 623014990 2018 Gas State Program Evaluation 1 1 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 12#
RI NG Program Evaluation, 2018, page 137 General Comments: Info Only = No Points Evaluator Notes: There were no pection records to validate compliance actions were warranted in CY 2018. Info Only Info Only Total points scored for this section: 7 Total possible points for this section: 13 DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 13#
RI NG Program Evaluation, 2018, page 14PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ 2 2 accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Procedures are included on page 16, Part IV - "Investigation of Incidents" in the State of RI Pipeline Safety Procedures. 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: Yes. Each operator has copy of pipeline safety contact list for reports of incidents, including after hours reports. 3 If onsite investigation was not made, did state obtain sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no reportable incidents in 2018. 1 NA 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 NA recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: There were no reportable incidents in 2018. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: There were no reportable incidents in 2018. 1 NA 6 Did the 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? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State of Rhode Island had no request to assist AID in 2018. 1 NA 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: DUNS: 623014990 2018 Gas State Program Evaluation 1 1 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 14#
RI NG Program Evaluation, 2018, page 15Information is shared during the State of State address at the NAPSR regional meeting. 8 General Comments: Info Only = No Points Evaluator Notes: There were no issues in Part E of evaluation. Info Only Info Only Total points scored for this section: 5 Total possible points for this section: 5 DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 15#
RI NG Program Evaluation, 2018, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Information is included in PowerPoint presentation to National Grid in 2017. Suggested question be added to inspection checklist. 2 Did the state inspector verify pipeline operators are following their written procedures 2 2 pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This is covered in every informal review on DIG Safe Probable Violation meetings. Suggested question be added to inspection checklist. 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The state is encouraging and promoting best practices through its annual meetings with excavators and contractors. 4 Has the agency or another organization within the state collected data and evaluated 2 2 trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The state is storing this information in their dig safe database which is being evaluated for trends based on the number of pipeline d per ticket. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues in Part F of evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 16#
RI NG Program Evaluation, 2018, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: National Grid Name of State Inspector(s) Observed: Ken McCarthy Location of Inspection: Warick, RI, Providence, RI, and Woonsocket, RI Date of Inspection: September 25 & 26, 2019 Name of PHMSA Representative: Clint Stephens Evaluator Notes: Observed National Grid contractor install P/E main and service lines. National Grid is in the process of replacing cast iron pipe within its pipeline system. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 Evaluator Notes: Yes. The operator's representative was notified and was present during the inspection. 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. The inspector used the State of Rhode Island construction inspection form during the inspection. The checklist was used as a guide for determining areas to inspect while on site. 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The inspector thoroughly documented the results of the inspection. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes. The inspector checked fire extinguisher, air monitor, and tapping equipment for operation and calibration. 2 2 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: The inspector reviewed pipeline maps, joining procedures, and tapping procedures. OQ records for contractors were checked to verify they are current. The contractors were observed joining plastic pipe, and checking for leaks DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 17#
RI NG Program Evaluation, 2018, page 187 Did the inspector have adequate knowledge of the pipeline safety program and 2 0 regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The inspector had limited knowledge of pipeline safety program and regulations. The inspector has not completed required T&Q training to lead construction inspection. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: 1 NA The inspector did not conduct an exit interview because there were no issues identified at the time of the inspection. 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: 1 NA The inspector did not conduct an exit interview because there were no issues identified at the time of the inspection. 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping Info Only Info Only DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 18#
RI NG Program Evaluation, 2018, page 19D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: The inspector did a good job of following the construction inspection form based on his limited knowledge of the regulation. The inspector will need to complete required T&Q courses, with the addition of some field experience in order to lead a construction inspection. Total points scored for this section: 8 Total possible points for this section: 10 DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 19#
RI NG Program Evaluation, 2018, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State of Rhode Island is not an Interstate Agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State of Rhode Island is not an Interstate Agent. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State of Rhode Island is not an Interstate Agent. 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State of Rhode Island is not an Interstate Agent. 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State of Rhode Island is not an Interstate Agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State of Rhode Island is not an Interstate Agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State of Rhode Island is not an Interstate Agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: The State of Rhode Island is not an Interstate Agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 20#
RI NG Program Evaluation, 2018, page 21PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State of Rhode Island does not have a 60106 Agreement. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State of Rhode Island does not have a 60106 Agreement. 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State of Rhode Island does not have a 60106 Agreement. 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State of Rhode Island does not have a 60106 Agreement. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 The State of Rhode Island does not have a 60106 Agreement. 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The State of Rhode Island does not have a 60106 Agreement. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: The State of Rhode Island does not have a 60106 Agreement. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 623014990 2018 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 21#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.