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PHMSA ri2009ngprogramevaluation
2009 RI NG Program Evaluation - ri2009ngprogramevaluation (Rhode Island; Natural Gas State Program Evaluation)
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RI NG Program Evaluation, 2009, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2009 Natural Gas State Program Evaluation for RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS Document Legend PART: O -- Representative Date and Title Information A -- General Program Qualifications B -- Inspections and Compliance - Procedures/Records/Performance C -- Interstate Agent States D -- Incident Investigations E -- Damage Prevention Initiatives F -- Field Inspection G -- PHMSA Initiatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 957925464 2009 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 1#
RI NG Program Evaluation, 2009, page 22009 Natural Gas State Program Evaluation -- CY 2009 Natural Gas State Agency: Rhode Island Rating: Agency Status: Date of Visit: 05/10/2010 - 05/14/2010 Agency Representative: Don Ledversis PHMSA Representative: Dino N.Rathod, P.E. Commission Chairman to whom follow up letter is to be sent: Name/Title: Thomas Ahern, Administrator Agency: Rhode Island Division pf Public Utilities and Carriers Address: 89 Jefferson Blvd City/State/Zip: Warwick, 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 2009 (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 certification/agreement attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART F): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART F, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A General Program Qualifications 25 25 B Inspections and Compliance - Procedures/Records/Performance 24.5 21.5 C Interstate Agent States 0 0 D Incident Investigations 6 6 E Damage Prevention Initiatives 9 9 F Field Inspection 12 12 G PHMSA Initiatives - Strategic Plan 8.5 8 H Miscellaneous 3 3 I Program Initiatives 6 5 TOTALS 94 89.5 State Rating................................................................................................................................................... 95.2 DUNS: 957925464 2009 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 2#
RI NG Program Evaluation, 2009, page 3PART A - General Program Qualifications Points(MAX) Score 8 8 1 Did the state submit complete and accurate information on the attachments to its most current 60105(a) Certification/60106 (a) Agreement? (NOTE: PHMSA Representative to verify certification/agreement attachments by reviewing appropriate state documentation. Score a deficiency in any one area as "needs improvement". Attachment numbers appear in parenthesis) Previous Question A.1, Items a-h worth 1 point each Yes = 8 No = 0 Needs Minor Improvement = 3-7 Needs Major Improvement = 2 a. State Jurisdiction and agent status over gas facilities (1) b. Total state inspection activity (2) c. Gas facilities subject to state safety jurisdiction (3) d. Gas pipeline incidents (4) e. State compliance actions (5) f. State record maintenance and reporting (6) g. State employees directly involved in the gas pipeline safety program (7) h. State compliance with Federal requirements (8) SLR Notes: Discussed with Don the need for better documentation to deleneate person days charged between Program Manager/ Supervision duties and Pipeline Inspector activities. Don to review Attachments 2 and 7 and adjust, as necessary. 80 percent time to be split to reflect XX % as Program Manager/ Supervisor and remaining YY % as DPUC Inspector. Per discussions with Zach Barrett, currrent PHMSA Guideline Manual instructions will be evluated and modified later. 2 Did the state have an adequate mechanism to receive operator reporting of incidents to ensure state compliance with 60105(a) Certification/60106(a) Agreement requirements (fatality, injury requiring hospitalization, property damage exceeding $50,000 - Mechanism should include receiving "after hours" reports)? (Chapter 6) Previous Question A.2 Yes = 1 No = 0 1 1 SLR Notes: 3 Has the state held a pipeline safety TQ seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar or if state requested seminar, but T&Q could not provide, indicate date of state request for seminar. Seminars must be held at least once every 3 calendar years.) (Chapter 8.5) Previous Question A.4 Yes = 2 No = 0 SLR Notes: RI is part of NEPSR States in New England conduting Joint TQ seminar in Oct 2009 2 2 4 Were pipeline safety program files well-organized and accessible?(NOTE: This also includes electronic files) (Chapter 5) Previous Question A.5 Yes = 1 No = 0 1 1 SLR Notes: DPUC maintains inspection foldders in an organized and accessible manner in a secure Bldg. DPUC was advised and agreed to consider electonic file back up data. (such as External hard drive) 5 Did state records and discussions with the state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? (Chapter 4.1, Chapter 8.1) Previous Question A.6 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: DOn Ledversis performs dual funcitons- Program Manager as well as Pipeline Safety Inspector. Hehas completed all required TQ courses and gained valuable regulatory gas safety experience. He works with NAPSR committees /PHMSA HQ/ ER Region 6 Did the state respond in writing within 60 days to the requested items in the Chairman's letter following the Region's last program evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8 Yes = 1 No = 0 1 1 SLR Notes: DPUC letter dated Jan 13, 2010 DUNS: 957925464 2009 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 3#
RI NG Program Evaluation, 2009, page 47 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the previous year? Did actions correct or address deficiencies from previous year's evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8/A.9 Yes = 1 No = 0 SLR Notes: RI enacted 15 changes to enhance current Dig Safe requirements effective Nov 1, 2009. 1 1 Personnel and Qualifications 8 Has each inspector fulfilled the 3 year TQ training requirement? If No, has the state been granted a waiver regarding TQ courses by the Associate Administrator for Pipeline Safety? (NOTE: If the State has new inspectors who have not attended all TQ courses, but are in a program which will achieve the completion of all applicable courses within 3 years of taking first course (5 years to sucessfully complete), or if a waiver has been granted by the applicable Region Director for the state, please answer yes.) (Chapter 4.4) Previous Question A.10 Yes = 3 No = 0 SLR Notes: Don Ledversis has completed required TQ courses. 3 3 9 Brief Description of Non-TQ training Activities: Info Only = No Points For State Personnel: Info Only Info Only For Operators: For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: SLR Notes: 10 SLR Notes: Did the lead inspectors complete all required T&Q OQ courses and Computer Based Training (CBT) before conducting OQ Inspections? (Chapter 4.4.1) Previous Question A.12 Yes = 1 No = 0 1 1 11 Did the lead inspectors complete all required TQ Integrity Management (IMP) Courses/Seminars and CBT before conducting IMP Inspections? (Chapter 4.4.1) Previous Question A.13 Yes = 1 No = 0 SLR Notes: RI does not have jurisdiciotnal Gas Transmission IMP pipeline. 1 NA 12 Was the ratio acceptable of Total inspection Person-days to Total Person-days charged to the program by state inspectors? (Region Director may modify points for just cause) (Chapter 4.3) Previous Question B.12 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 124.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 0.80 = 176.00 Ratio: A / B 124.00 / 176.00 = 0.70 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 5 5 SLR Notes: DUNS: 957925464 2009 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 4#
RI NG Program Evaluation, 2009, page 513 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Info Only Info Only Question B.13 Info Only = No Points SLR Notes: No changes 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 25 Total possible points for this section: 25 DUNS: 957925464 2009 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 5#
RI NG Program Evaluation, 2009, page 6PART B - Inspections and Compliance - Procedures/Records/ Performance Points(MAX) Score Inspection Procedures 1 Does the State have a written inspection plan to complete the following? (all types of operators including LNG) 6.5 6 (Chapter 5.1) Previous Question B.1 + Chapter 5 Changes + Incorporate LNG Yes = 6.5 No = 0 Needs Improvement = 50% Deduction a Standard Inspections (Including LNG) (Max points = 2) b IMP Inspections (Including DIMP) (Max points = .5) c OQ Inspections (Max points = .5) d Damage Prevention (Max points = .5) e On-Site Operator Training (Max points = .5) f Construction Inspections (Max points = .5) g Incident/Accident Investigations (Max points = 1) h Compliance Follow-up (Max points = 1) Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement SLR Notes: 1 DPUC has procedure but did not perform any OQ field verification inspections in 2009. This issue was re-emphasized. DPUC agreed to begin performing OQ #9 inspections effective immediately. ( Aslo see Part I Q 6 & 7) 2. Discussed with DPUC a simpler but systematic way to follow-up in a timely manner with necessary compliance actions upon completion of each inspection and resolve compliance issues/ Unsatisfactory items. (LNG inspection of 12-11-09). DPUC agreed to review and revise accordingly 2 Did the written Procedures for selecting operators adequately address key concerns? (Chapter 5.1) Previous 2 2 Question B.2, items a-d are worth .5 point each Yes = 2 No = 0 Needs Improvement = 50% Deduction a Length of time since last inspection Yes No Needs Improvement b History of Operator/unit and/or location (including leakage , incident and compliance history) Yes No Needs Improvement c Type of activity being undertaken by operator (construction etc) Yes No Needs Improvement d For large operators, rotation of locations inspected Yes No Needs Improvement SLR Notes: Inspection Performance 3 Did the state inspect all types of operators and inspection units in accordance with time intervals established in its written procedures? (Chapter 5.1) Previous Question B.3 Yes = 2 No = 0 SLR Notes: DPUC inspects all jurisdicitonal operators 2 2 4 Did the state inspection form cover all applicable code requirements addressed on the Federal Inspection forms? (Chapter 5.1 (3)) Previous Question B.4 Yes = 1 No = 0 1 1 SLR Notes: 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 1 0 Yes = 1 No = 0 SLR Notes: DPUC did not fill in LNG form (12-11-09) completely and correctly. Items were left un-resolved from this inspection, and DPUC agreed to perform another "Follow-up" inspection and resolve all un-resolved inspection items and make a concise documention for these items 6 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.6 Yes = .5 No = 0 DUNS: 957925464 2009 Natural Gas State Program Evaluation .5 NA Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 6#
RI NG Program Evaluation, 2009, page 7SLR Notes: None in Cy 2009 7 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Previous Question B.7 Yes = .5 No = 0 .5 .5 SLR Notes: 8 Did the state review 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) (NTSB) Previous Question B.8 Yes = .5 No = 0 SLR Notes: .5 .5 9 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) Previous Question B.9 Yes = .5 No = 0 .5 .5 SLR Notes: 10 SLR Notes: Did the state review 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? (NTSB) Previous Question B.10 Yes = 1 No = 0 1 1 Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous 1 .5 Question B.14 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Discussed with DPUC and recommended simplify Compliance letters (PHMSA compliance letters as examples). DPUC will follow and avoid unnecessary / unrelated information in body of these letters. 12 SLR Notes: Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a probable violation as specified in the "Guidelines for State Participating in the Pipeline Safety Program"? (Chapter 5.1) Previous Question D(1).1 Yes = 1 No = 0 Needs Improvement = .5 1 1 13 SLR Notes: Does the state have written procedures to notify an operator when a noncompliance is identified as specified in the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(4)) Previous Question D (1).2 Yes = 1 No = 0 Needs Improvement = .5 1 1 14 SLR Notes: DUNS: 957925464 2009 Natural Gas State Program Evaluation Does the state have a written procedure for routinely reviewing the progress of compliance actions to prevent delays or breakdowns of the enforcement process, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(5)) Previous Question D(1).3 Yes = 1 No = 0 Needs Improvement = .5 1 .5 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 7#
RI NG Program Evaluation, 2009, page 8Discussed with DPUC to have timelyresolution of of pending compliance actions and prepare appropriate letters to operators, preferably within 90 days upon completion of inspection 15 SLR Notes: Has the State issued compliance actions for all probable violations discovered? (Note : PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation) Previous Question D(1).4 Yes = 1 No = 0 1 1 16 SLR Notes: Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that prompt corrective actions were taken by operators, within the time frames established by the procedures and compliance correspondence, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? Previous Question D(1).5 Yes = 1 No = 0 Needs Improvement = .5 1 1 17 SLR Notes: If compliance could not be established by other means, did state pipeline safety program staff request formal action, such as a "Show Cause Hearing" to correct pipeline safety violations? (check each states enforcement procedures) Previous Question D(1).6 No = 0 Yes = 1 1 1 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question D(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: DPUC was advised to have timely and adequate resolution of probable violations. 1 .5 19 SLR Notes: Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question D(1).8 Yes = .5 No = 0 .5 .5 20 SLR Notes: Did the compliance proceedings give reasonable due process to all parties? (check each states enforcement procedures) Previous Question D(1).9 Yes = 1 No = 0 Needs Improvement = .5 1 1 Compliance - 60106(a) States 21 Did the state use the current federal inspection form(s)? Previous Question D(2).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: 1 NA 22 SLR Notes: Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question D(2).2 Yes = 1 No = 0 Needs Improvement = .5 1 NA 23 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.) Previous Question D(2).3 Yes = 1 No = 0 Needs Improvement = .5 DUNS: 957925464 2009 Natural Gas State Program Evaluation 1 NA Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 8#
RI NG Program Evaluation, 2009, page 9SLR Notes: 24 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(2).4 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 25 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(2).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 26 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Previous Question D(2).6 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 27 Part B: General Comments/Regional Observations Info Only = No Points Info Only NA SLR Notes: Total points scored for this section: 21.5 Total possible points for this section: 24.5 DUNS: 957925464 2009 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 9#
RI NG Program Evaluation, 2009, page 10PART C - Interstate Agent States Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Previous Question D(3).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: RI DPUC is not an interstate Agent 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Previous Question D(3).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: RI DPUC 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? Previous Question D(3).3 Yes = 1 No = 0 SLR Notes: RI DPUC is not an interstate Agent 1 NA 4 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.) Previous Question D(3).4 Yes = 1 No = 0 SLR Notes: RI DPUC 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? Previous Question D(3).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: RI DPUC is not an interstate Agent 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(3).6 Yes = 1 No = 0 SLR Notes: RI DPUC is not an interstate Agent 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Previous Question D(3).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: RI DPUC is not an interstate Agent 1 NA 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: RI DPUC is not an interstate Agent Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 957925464 2009 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 10#
RI NG Program Evaluation, 2009, page 11PART D - Incident Investigations Points(MAX) Score 1 Are state personnel following the procedures for Federal/State cooperation in case of an incident? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6.1) Previous Question E.1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: 1 1 2 Are state personnel familiar with the jurisdictional authority and Memorandum of Understanding between NTSB and PHMSA? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6 ? Appendix D) Previous Question E.2 Yes = .5 No = 0 SLR Notes: .5 .5 3 Did the state keep adequate records of incident notifications received? Previous Question E.3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: DPUC maintains a log of incoming telephone calls. In addition, DPUC follows up to make a determination for further actions. 1 1 4 If an onsite investigation of an incident was not made, did the state obtain sufficient information by other means to determine the facts and support the decision not to go on-site? Previous Question E.4 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: actions. DPUC maintains a log of incoming telephone calls. In addition, DPUC follows up by e-mail and or telephone calls to make a determination for further 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? Previous Question E.5, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Observations and Document Review 2 2 b. Contributing Factors c. Recommendations to prevent recurrences where appropriate SLR Notes: Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement in 2009 DPUC investigated May 9, 2009 incident with National Grid. It was caused by a vehicle damaging gas merer fedding fire as a result. 6 Did the state initiate enforcement action for violations found during any incident investigation(s)? Previous Question E.6 Variation Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: DPUC did not find any violations upon completion of incident investigation 1 NA 7 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate annual report data from operators concerning incidents/accidents and investigate discrepancies) (Chapter 6) Previous Question E.7/E.8 Yes = .5 No = 0 SLR Notes: DPUC works closely with ER SLR and PHMSA. When necesary, DPUC provides additional information. .5 0.5 8 Part D: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only DUNS: 957925464 2009 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 11#
RI NG Program Evaluation, 2009, page 12Total points scored for this section: 6 Total possible points for this section: 6 DUNS: 957925464 2009 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 12#
RI NG Program Evaluation, 2009, page 13PART E - Damage Prevention Initiatives Points(MAX) Score 1 Has the state reviewed 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? Previous Question B.11 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: In Cy 2009 RI DPUC reviewed Damage Prevention Program procedure #32 (for Part 192.614). 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? New 2008 Yes = 2 No = 0 2 2 SLR Notes: In RI, Gas operators are required to be part of Dig Safe (One Call) system. Excavator "re-marks" proposed excavation area. Dig Safe issues ticket for locating and utilities mark 15 ft beyond pre-mark area. Company locator marks and enter DigTrack on-line and it confirms Status- such as "Complete". 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to 2 2 its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.7 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: 1) DPUC worked to push for 15 changes in Dig Safe. These were ebnacted in Nov 2009. 2) DPUC is CGA member 3) Don Ledversis is participating as Alternate Committee Member of CGA. 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? New 2008 Yes = 1 No = 0 SLR Notes: RI receved Pipe damage data form LDC National Grid in CY 2009. 1 1 5 Did the state review operators' records of accidents and failures due to excavation damage to ensure causes of failure are addressed to minimize the possibility of recurrence as required by 192.617? Yes = 2 No = 0 2 2 SLR Notes: DPUC had only 1 reportable incidnet in 2009. However, RI reviewed "non-reportable" hits data of National Grid. DOn checked 149 hits (below reportable threshold). Analysis revealed four mismarks. DPUC followed these for resolution. 6 Part E: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: 15 New Dig Safe Law Changes- marking requirements for Cable TV, Active/ inactive and abandoned services, ticket validity to 60 days and 72 hr waiting period, "pre-marking requirements"and 15- ft all around marking; increased fines - 1 st offence 350, subsequent- $500-2500; sewer systems need "as-built Dwgs from 2012/ Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 957925464 2009 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 13#
RI NG Program Evaluation, 2009, page 14PART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: National Grid Name of State Inspector(s) Observed: Don Ledversis Location of Inspection: Providence, Cranston and East Providence Date of Inspection: 05/11/2010 Name of PHMSA Representative: Dino N. Rathod, P.E. SLR Notes: Multile field activities observed in Providence, Cranston and East Providence. Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? New 2008 Yes = 1 No = 0 SLR Notes: At various locations, NG inspectors were present 1 1 3 Did the inspector use an acceptable inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Previous Question F.2 Yes = 2 No = 0 SLR Notes: DPUC inspector Don used State Inspection Check Lists and PHMSA OQ Protocols for Field Verification 2 2 4 Did the inspector thoroughly document results of the inspection? Previous Question F.3 Yes = 2 No = 0 2 2 SLR Notes: 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.) New 2008 Yes = 1 No = 0 1 1 SLR Notes: Don observed that NG cew performing Pressure Reg Station maintenance failed to provide diagram of station layout or similar documentation. Crew also did not have Company O&M or detailed procedures to perform O&M activities. DPUC was advised to pursue these concerns. 6 What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) New 2008 Info Only = No Points Info Only Info Only SLR Notes: -Pipe replacement, new service and main plastic pipe installation. -3rd party damage investigation -Pressure Reg Station Maintenance - Pressure Reg Station steel pipe- welding 4 and 6-inch by AGI Contractor welder. 7 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) New 2008, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities/Facilities DUNS: 957925464 2009 Natural Gas State Program Evaluation 2 2 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 14#
RI NG Program Evaluation, 2009, page 15d. Other (Please Comment) SLR Notes: 8 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Liaison will document reasons if unacceptable) Previous Question F.8 Yes = 2 No = 0 2 2 SLR Notes: 9 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) Previous Question F.10 Yes = 1 No = 0 1 1 SLR Notes: 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous Question F.11 Yes = 1 No = 0 SLR Notes: Don expressed concerns for several issues/ concerns duirng exit interview. 1 1 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector Info Only Info Only performed) Info Only = No Points SLR Notes: Here is a recap of several items I observed with you during today's field evaluation of various activities by National Grid. 1. Third Party Damage- at Westminster and Brigham Roads, Providence. National Grid Contractor Lynch installing electrical steel conduit. ? No Gas service records to indicate the existence of gas supply line to Columbia Auto Repair facility. ? NG locator for this gas supply line marked no gas service. ? Why no warning tape was found or observed? What was date of installation of this service line? Who installed it? What happened to all as-built dwgs and maps? What did NG or previous owners do to update newly installed gas service to this auto repair shop? ? All auto repair parts- junk piled all around two gas meters. NG did not express any worry initially until DPUC pointed out why this was not being addressed by NG while responding to this situation. NG person at site provided a lame excuse about language (Spanish) by persons at this facility. 2. Several field locations- 1060 Oakland Ave, Cranston and ? Crew did not have NG O&M Manual available. Either hard copy and or electronic O&M access by computer at site. ? Lack of appropriate Construction related details- such as plastic pipe joining; proper way of supporting pipe and proper alignment of pipe ends before placing heating iron to complete joining pipe. Ask NG to provide specific details. Some vague generic words do not help. Pressure Reg Station- NG Crew at Boyd and Tripps Lane, East Providence. No Diagram was available. None could be located while we both were at this location. Need better "lock out/ Tag out procedures to minimize possibility of inadvertent opening of isolation valves on loop being serviced for maintenance 12 Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only Info Only Info Only = No Points SLR Notes: RI shares various Pipeline Safety issues with other NAPSR states and also NEPSR states. 13 Field Observation Areas Observed (check all that apply) 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 DUNS: 957925464 2009 Natural Gas State Program Evaluation Info Only Info Only Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 15#
RI NG Program Evaluation, 2009, page 16i. 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 D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other SLR Notes: 14 Part F: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 957925464 2009 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 16#
RI NG Program Evaluation, 2009, page 17PART G - PHMSA Initiatives - Strategic Plan Points(MAX) Score Risk base Inspections - Targeting High Risk Areas 1 Does state have process to identify high risk inspection units? Yes = 1.5 No = 0 1.5 1.5 Risk Factors (criteria) to consider may include: Miles of HCA's, Geographic area, Population Density Length of time since last inspection History of Individual Operator units (leakage, incident and compliance history, etc.) Threats - (Excavation Damage, Corrosion, Natural Forces, Other Outside Forces, Material or Welds, Equipment, Operations, Other) SLR Notes: DPUC has only1 Private Gas operator (National Grid) with two LNG Plants. Multiple MMO and LPG facilities. DPUC considers above listed criteria and performs annual inspections accordingly. 2 Are inspection units broken down appropriately? (see definitions in Guidelines) Yes = .5 No = 0 SLR Notes: National Grid - 1 private operator with two LNG units MMO- 26 operators with 43 units LPG- 11 with 33 units .5 0.5 3 Consideration of operators DIMP Plan? (if available and pending rulemaking) Info Only = No Points Info Only Info Only SLR Notes: 4 Does state inspection process target high risk areas? Yes = .5 No = 0 .5 0.5 SLR Notes: DPUC receives and reviews Leaks Per Mile and History of incidents and number of violations found. Inspection emphasis is placed on these items for subsequent inspection activities. Use of Data to Help Drive Program Priority and Inspections 5 Does state use data to analyze effectiveness of damage prevention efforts in the state? (DIRT or other data, etc) Yes = .5 No = 0 SLR Notes: DPUC collects and analyzes Dig Safe/ Damage Prevention data .5 0.5 6 Has state reviewed data on Operator Annual reports for accuracy? Yes = .5 No = 0 SLR Notes: DPUC receives Annual Report of National Grid and reviews it for accurate information. .5 0.5 7 Has state analyzed annual report data for trends and operator issues? Yes = .5 No = 0 .5 SLR Notes: DPUC reviewed Gas Leaks backlog and observed a downword trend. Similarly DPUC reviews Damage Prevention data each year 0.5 8 Has state reviewed data on Incident/Accident reports for accuracy? Yes = .5 No = 0 SLR Notes: DPUC investigated May 2009 incident caused by a vehicle. DUNS: 957925464 2009 Natural Gas State Program Evaluation .5 0.5 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 17#
RI NG Program Evaluation, 2009, page 189 Does state do evaluation of effectiveness of program based on data? (i.e. performance measures, trends, etc.) .5 0 Yes = .5 No = 0 SLR Notes: RI DPUC does nor perform a formal review to evaluate effectiveness based on data. I discussed and encouraged that DPUC should conduct such evaluation. 10 Did the State input all operator qualification inspection results into web based database provided by PHMSA in a timely manner upon completion of OQ inspections? Previous Question B.15 Yes = .5 No = 0 .5 0.5 SLR Notes: DPUC conducted 20 OQ inspections of MMO and 1 LDC and uploaded in OQDB. However, no field verification inspection was conducted. I discussed with DPUC specifics and reviewed OQ Protocol 9. Emphasis was on observation of several covered tasks being performed by a qualified person (Company and or contractor). Also verify that person is using applicable approved procedures and Company OQ Plan etc. 11 Did the State submit their replies into the Integrity Management Database (IMDB) in response to the Operators notifications for their integrity management program? Previous Question B.16 Yes = .5 No = 0 SLR Notes: RI does not have jurisdictional IMP as part of Gas IMP .5 NA 12 SLR Notes: Have the IMP Federal Protocol forms been uploaded to the IMDB? Previous Question B.17 Yes = .5 No = 0 .5 NA 13 Did the State ask Operators to identify any plastic pipe and components that has shown a record of defects/leaks and what those operators are doing to mitigate the safety concerns? Previous Question B.18 Yes = .5 No = 0 .5 0.5 SLR Notes: Don checked and confirmed with NG (Tom Birminghma- Lead Analyst). He indicated that Nation Grid has not seen any trend other than what PPDC indicated. NG reports thru AGA PPDC on a monthly basis. 14 SLR Notes: Has state confirmed transmission operators have submitted information into National Pipeline Mapping System (NPMS) database along with any changes made after original submission? Yes = .5 No = 0 .5 NA Accident/Incident Investigation Learning and Sharing Lessons Learned 15 Has state shared lessons learned from incidents/accidents? (i.e. NAPSR meetings and communications) Yes = .5 No = 0 SLR Notes: DPUC made a PowerPoint presentation at NAPSR ER meeting in June 2009 and share pertinent details. .5 0.5 16 Does the State support data gathering efforts concerning accidents? (Frequency/Consequence/etc) .5 0.5 Yes = .5 No = 0 SLR Notes: DPUC supports requests from NAPSR as well as PHMSA. 17 SLR Notes: Does state have incident/accident criteria for conducting root cause analysis? Info Only = No Points Info Only Info Only DUNS: 957925464 2009 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 18#
RI NG Program Evaluation, 2009, page 1918 Does state conduct root cause analysis on incidents/accidents in state? Info Only = No Points Info Only Info Only SLR Notes: 19 Has state participated on root cause analysis training? (can also be on wait list) Yes = .5 No = 0 .5 0.5 SLR Notes: Don ledversis completed Root Cause Analysis Training in Aug 2009. Transparency - Communication with Stakeholders 20 Other than pipeline safety seminar does State communicate with stakeholders? (Communicate program data, pub awareness, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: RI DPUC has a website highlighting 811 and Dig Safe Information http://www.ripuc.ri.gov/digsafe 21 Does state share enforcement data with public? (Website, newsletters, docket access, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: Public can request and get information via FOIA. Also www.ripuc.org for Natural gas Dockets 22 Part G: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 8 Total possible points for this section: 8.5 DUNS: 957925464 2009 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 19#
RI NG Program Evaluation, 2009, page 20PART H - Miscellaneous Points(MAX) Score 1 What were the major accomplishments for the year being evaluated? (Describe the accomplishments, NAPSR Activities and Participation, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: 2010. 1. PUC initiated and National Grid (NG) began relocation of inside meters ( inlet > 20 pressure) to outsidedwellings. 2100 in April 2009; 3100 scheduled in 2. RI Dig Safe Rules -enahncements were signed into Law Novemebr 2009. 2 What legislative or program initiatives are taking place/planned in the state, past, present, and future? (Describe initiatives (i.e. damage prevention, jurisdiction/authority, compliance/administrative, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: RI Dig Safe Rules -enahncements were signed into Law Novemebr 2009 3 Any Risk Reduction Accomplishments/Projects? (i.e. Cast iron replacement projects,bare steel,third-party damage reductions, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: Accelerated Replacement Program (ARP) National Grid replaced bare steel and cast iron mains and services- total of 36 miles(approxiamte) 4 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 1 1 SLR Notes: 1 PHMSA and NAPSR request for Dig Safe- Damage Prevention Dec 2009 2. Oct 1, 2009 Fire First Survey input to NAPSR George M. 5 Sharing Best Practices with Other States - (General Program) Yes = .5 No = 0 .5 0.5 SLR Notes: 1. DPUC participated in ER NASPR meeting and shared pipeline safety related issues via PowerPoint presentation. 2.Attended and actively participated in Dig Safe Stakeholders Meeting in MArch 11, 2010 6 Part H: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 957925464 2009 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 20#
RI NG Program Evaluation, 2009, page 21PART I - Program Initiatives Points(MAX) Score Drug and Alcohol Testing (49 CFR Part 199) 1 Has the state verified that operators have drug and alcohol testing programs? Yes = 1 No = 0 SLR Notes: DPUC conducted Drug & Alcohol inspection of National Grid- LDC on Apr 21, 2009. 1 1 2 Is the state verifying that operators are conducting the drug and alcohol tests required by the operators program (random, post-incident, etc.) Yes = .5 No = 0 SLR Notes: DPUC conducted Drug & Alcohol inspection of National Grid- LDC on Apr 21, 2009 .5 0.5 3 Is the state verifying that any positive tests are responded to in accordance with the operator's program? Yes = .5 No = 0 SLR Notes: DPUC conducted Drug & Alcohol inspection of National Grid- LDC on Apr 21, 2009 .5 0.5 Qualification of Pipeline Personnel (49 CFR Part 192 Subpart N) 4 Has the state verified that operators have a written qualification program? Yes = 1 No = 0 SLR Notes: DPUC conducted OQ inspection of National Grid- LDC on Dec 16, 2009 and MMO throught 2009 and LPG operators. 1 1 5 Has the state reviewed operator qualification programs for compliance with PHMSA rules and protocols? Yes = .5 No = 0 SLR Notes: DPUC used PHMSA Protocols 1 thru 8 for OQ plan review. .5 0.5 6 Is the state verifying that persons who perform covered tasks for the operator are qualified in accordance with the operator's program? Yes = .5 No = 0 .5 0 SLR Notes: DPUC did not perform OQ#9 Field Verificaiton to observe work being performed for various covered tasks. I discussed and re-emphasized need for performing these inspections to be able to cover varierty of O&M activities throughout the year and document compliance with OQ requirements. OQ Protocol #9 and related guidance material was also discussed. Don agreed and will start this activity ASAP. He will keep me advised of progress. 7 Is the state verifying that persons who perform covered task for the operator are requalified at the intervals specified in the operator's program? Yes = .5 No = 0 SLR Notes: DPUC did not perform any OQ filed verification inspections in CY 2009 .5 0 Gas Transmission Pipeline Integrity Management (49 CFR Part 192 Subpart O) 8 Has the state verified that all operators with transmission pipelines have either adopted an integrity management program (IMP), or have properly determined that one is not required? Yes = 1 No = 0 1 NA SLR Notes: RI does not have any jurisdictional gas transmission pipeline facilities. 9 Has the state verified that in determining whether a plan is required, the operator correctly calculated the potential impact radii and properly applied the definition of a high consequence area? Yes = .5 No = 0 SLR Notes: DUNS: 957925464 2009 Natural Gas State Program Evaluation .5 NA Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 21#
RI NG Program Evaluation, 2009, page 22RI does not have any jurisdictional gas transmission pipeline facilities. 10 Has the state reviewed operator IMPs for compliance with Subpart O? (In accordance with State Inspection plan) Yes = .5 No = 0 SLR Notes: RI does not have any jurisdictional gas transmission pipeline facilities. .5 NA 11 Is the state monitoring operator progress on the inspections, tests and remedial actions required by the operator's IMP, including that they are being done in the manner and schedule called for in its IMP? Yes = .5 No = 0 SLR Notes: RI does not have any jurisdictional gas transmission pipeline facilities. .5 NA 12 Is the state verifying that operators are periodically examining their transmission line routes for the appearance of new HCAs? Yes = .5 No = 0 SLR Notes: RI does not have any jurisdictional gas transmission pipeline facilities. .5 NA Public Awareness (49 CFR Section 192.616) 13 Has the state verified that each operator has developed a continuing public awareness program? (due date was 6/20/06 for most operators, 6/20/07 for certain very small operators,6/13/08 for master meters) Yes = .5 No = 0 SLR Notes: RI DPUC performed Public Awareness inspection of NG Sept 2009 using PHMSA Form 2 (pages 5 & 6) .5 0.5 14 Has the state reviewed the content of these programs for compliance with 192.616 (by participating in the Clearinghouse or by other means)? Yes = .5 No = 0 SLR Notes: RI DPUC performed Public Awareness inspection of NG Sept 2009 using PHMSA Form 2 (pages 5 & 6) .5 0.5 15 Is the state verifying that operators are conducting the public awareness activities called for in its program? Yes = .5 No = 0 SLR Notes: RI DPUC performed Public Awareness inspection of NG Sept 2009 using PHMSA Form 2 (pages 5 & 6) .5 0.5 16 Is the state verifying that operators have evaluated their Public Awareness programs for effectiveness as described in RP1162? Info Only = No Points SLR Notes: RI DPUC performed Public Awareness inspection of NG Sept 2009 using PHMSA Form 2 (pages 5 & 6) Info Only Info Only 17 Part I: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Total points scored for this section: 5 Total possible points for this section: 6 DUNS: 957925464 2009 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 22#
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