# 2010 RI NG Program Evaluation - ri2010ngprogramevaluation (Rhode Island; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA ri2010ngprogramevaluation
- **title:** 2010 RI NG Program Evaluation - ri2010ngprogramevaluation (Rhode Island; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2010-01-01
- **effective on:** Not available
- **summary:** 2010 PHMSA natural gas program evaluation for Rhode Island.
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1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2010 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 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 1

2010 Natural Gas State Program Evaluation -- CY 2010 Natural Gas State Agency: Rhode Island Rating: Agency Status: Date of Visit: 05/02/2011 - 05/06/2011 Agency Representative: Don Ledversis PHMSA Representative: Dino N.Rathod, P.E. Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. Thomas Ahern, Administrator Agency: Rhode Island Division of Public Utilities and Carriers Address: 89 Jefferson Blvd City/State/Zip: Warwick, R I 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 2010 (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 26 25 B Inspections and Compliance - Procedures/Records/Performance 24.5 24.5 C Interstate Agent States 0 0 D Incident Investigations 2.5 2.5 E Damage Prevention Initiatives 9 9 F Field Inspection 11 11 G PHMSA Initiatives - Strategic Plan 8.5 8.5 H Miscellaneous 3 3 I Program Initiatives 5.5 5.5 TOTALS 90 89 State Rating................................................................................................................................................... 98.9 DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 2

PART A - General Program Qualifications Points(MAX) Score 8 7 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: 1) DPUC to review and Reviese Attchments 1 & 3 for possible discrepancy in Number of Insepction Units. 2) Attachment 8- Items 1 and 7h: DPUC to Cite RI Law/Regulation, Effective Date and Actual Civil Penalty Limits for Items 1 and 7h. Provide this information in Attachment 8 Notes (last page) 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 was part of NEPSR for a seminar hosted in Oct 2010 in Maine. 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 SLR Notes: PUC inspection files(hard copies) were organized, accessible and kept in a secure bldg. 1 1 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: closely with PHMSA. Don Ledversis has gained valuable pipeline safety regulatory experience. He actively participated in many NAPSR and PHMSA initiatives. He works 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 SLR Notes: DPUC Administrator response dated August 11, 2010 1 1 7 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 DUNS: 957925464 2010 Natural Gas State Program Evaluation 1 1 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 3

Yes = 1 No = 0 SLR Notes: 1 DPUC has active program for CI and bare steel pipe replacement. 2. No budgetary constraints for training and inspection activities anticipated. 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 3 3 SLR Notes: 9 Brief Description of Non-TQ training Activities: Info Only = No Points For State Personnel: For Operators: For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: Info Only Info Only SLR Notes: 10 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 SLR Notes: 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: PL 1297 in Jan 2011 1 1 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): 120.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 0.92 = 202.40 Ratio: A / B 120.00 / 202.40 = 0.59 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 5 5 SLR Notes: 13 DUNS: 957925464 2010 Natural Gas State Program Evaluation Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Question B.13 Info Only = No Points Info Only Info Only Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 4

SLR Notes: 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: 26 DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 5

PART 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) (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) SLR Notes: RI DPUC Pipeline Safety Program Procedures Manual- Rev April 2011 6.5 6.5 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 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: RI Inspection Procedure Manual Page # 7 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: RI Inspection Procedure Manual Page # 13 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: RI DPUC uses combination of State inspection Check Lists and Federal Inspection Forms and QO Protocols. DPUC reviews and updates check lists, as necessary to reflect applicable Code rrequirements. 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 Yes = 1 No = 0 1 1 SLR Notes: 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 SLR Notes: DUNS: 957925464 2010 Natural Gas State Program Evaluation .5 NA Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 6

No SRC in CY 2010 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 SLR Notes: RI Inspection Procedure Manual Page # 7 .5 .5 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: RI Inspection Procedure Manual Page # 7 .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 Question B.14 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: In CY 2011 Certification, DPUC reported 10 NOPVs and Compliance Actions 1 1 12 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 SLR Notes: RI Inspection Procedure Manual Section VI 1 1 13 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 SLR Notes: RI Inspection Procedure Manual Section VI, Page # 14 1 1 14 SLR Notes: 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 1 DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 7

15 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 SLR Notes: In CY 2011 Certification RI DPUC reported 10 Compliance Actions 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 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 SLR Notes: RI Inspection Procedure Manual Section VIII,Page # 15 1 1 18 SLR Notes: 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 1 1 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 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 SLR Notes: RI Inspection Procedure Manual Page, Section VII, # 14-15 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 SLR Notes: 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 1 NA DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 8

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 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) Info Only = No Points Info Only NA SLR Notes: 28 Part B: General Comments/Regional Observations Info Only = No Points Info Only NA SLR Notes: Total points scored for this section: 24.5 Total possible points for this section: 24.5 DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 9

PART 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 1 NA SLR Notes: 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 1 NA SLR Notes: 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 1 NA SLR Notes: 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 1 NA SLR Notes: 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: 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: 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: 1 NA 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: RI is only 60105(a) Intrastate Gas Program Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 10

PART 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: No Reportable Incidents in CY 2010 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 SLR Notes: No Reportable Incidents in CY 2010 1 NA 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 b. Contributing Factors c. Recommendations to prevent recurrences where appropriate SLR Notes: No Reportable Incidents in CY 2010 2 NA Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement 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: No Reportable Incidents in CY 2010 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: No Reportable Incidents in CY 2010 .5 NA 8 Part D: General Comments/Regional Observations Info Only = No Points SLR Notes: No Reportable Incidents in CY 2010 Info Only Info Only DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 11

Total points scored for this section: 2.5 Total possible points for this section: 2.5 DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 12

PART 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: RI Dig Safe Regulations 39-1.2-1 (c) Excavation covers drilling/tunneling activities. PUC reviews LDC procedures for this activity. 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 SLR Notes: DPUC checks while performing inspection activities - Check Lists EN-33 & EN-34 2 2 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.7 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: DPUC actively participates in Dig Safe Board Meeting and Regional MUST meetings. 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 1 1 SLR Notes: DPUC collects and reviews/analyzes data. 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 reviews LDC records of incidents and excavation damages routinely 6 Part E: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: DPUC actively promotes and participates in Damage Prevention activities. Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 13

PART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: National Grid (NG) Name of State Inspector(s) Observed: Don Ledversis Location of Inspection: Martin Ave,Barrington// Woodlane Date of Inspection: 05/02/2011 Name of PHMSA Representative: Dino N.Rathod, P.E. SLR Notes: Observed bare still Replacement with 4-in and 2-in main HDPE- two locations in Providence metro area 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: NG Rep was present at job site 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 Conctruction Check List and PHMSA OQ Field Vertification Protocol # 9 form 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 SLR Notes: Don checked pipe fusion equipment- heating iron surfacew temp, joint bead measurement caliper, contact pyrometer 1 1 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 SLR Notes: Pipe replacement, plastic pipe installation and OQ Field Verification Info Only Info Only 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 d. Other (Please Comment) 2 2 SLR Notes: DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 14

Field Verification of Operator Qualification OQ #9 for 4-inch HDPE Pipe butt joint fusion 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: No probable violations were found. 1 NA 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: Don observed NG Contractor crew of AGI Construction --Bare steel main and services replacement with 4-inch main HDPE plastic pipe, approximately 3000 ft and 30 services. Don used Check list to document his observations. He checked validity of Dig Safe ticket, markouts for "pre-marking, water. He verified pipe handling & storage, sand padding and pipe trench depth, tracer wire and yellow warning tape. He checked OQ procedures and Covered Tasks related to pipe fusion- butt joint. No issues were found. 12 Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only Info Only = No Points SLR Notes: RI DPUC shares best practices with NASPR ER states and NEPSR members (CT, MA, ME, NH) Info Only 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 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 Info Only Info Only DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 15

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: 11 Total possible points for this section: 11 DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 16

PART 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 reviews variety of data- Pipe replacement of CI and unprotected bare steel pipes, Mains leak data history/ Service leaks by category, Leaks per mile, Damages per 1000 One Call Requests, Repair backlog; incident reports/ history etc. DPUC performs basic informal reivew. DPUC will include review process in Inspection Procedures as a separate Appendix document it. 2 Are inspection units broken down appropriately? (see definitions in Guidelines) Yes = .5 No = 0 .5 0.5 SLR Notes: 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: 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 actively collects and reviews Damage data and performs review/ analysis .5 0.5 6 Has state reviewed data on Operator Annual reports for accuracy? Yes = .5 No = 0 .5 0.5 SLR Notes: 7 Has state analyzed annual report data for trends and operator issues? Yes = .5 No = 0 SLR Notes: DPUC uses annual report to review cast iron and unprotected bare steel mains and services for replacement activities .5 0.5 8 Has state reviewed data on Incident/Accident reports for accuracy? Yes = .5 No = 0 .5 0.5 SLR Notes: DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 17

9 Does state do evaluation of effectiveness of program based on data? (i.e. performance measures, trends, etc.) .5 0.5 Yes = .5 No = 0 SLR Notes: DPUC collects variety of data- leak history, replacement of older pipelines (CIa nd bare steel pipes), damage categories, types of activities. history of operators. Based on informal review, DPUC makes necessary adjustments in inspection priorities. I discussed need for a formalized review and document the process, supprting documents and results. This may be very useful tool to verify effectivenss of Pipeline Safety Program. 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 SLR Notes: DPUC performed 26 OQ inspections .5 0.5 11 SLR Notes: 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 .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 SLR Notes: 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 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: RI DPUC has shared pipeline safety issues with others .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: 17 SLR Notes: Does state have incident/accident criteria for conducting root cause analysis? Info Only = No Points Info Only Info Only DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 18

18 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 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: DPUC participation in Regional MUST in June 2010 21 Does state share enforcement data with public? (Website, newsletters, docket access, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: http://www.ripuc.org/eventsactions/docket/d-06-15page.html Example: Rules & Regulations Prescribing Standards for Gas Utilities, Master Meter Systems and Jurisdictional Propane Systems - Docket No. D-06-15 22 Part G: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 8.5 Total possible points for this section: 8.5 DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 19

PART 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: Don Ledversis actively participated in various NAPSR and PHMSA initiatives. Dig Safe Board Mtgs, Distribution Construction, Drug &* Alcohol seminar, MUST mtg, Public Awareness mtg, Pre-DIMP mtg, NAPSR ER and Board Mtgs, NEPSR mtg etc. 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: 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: 2) 1 DPUC encourages pipe replacement of unprotected steel mains and services and cast iron mains. 2)RI DPUC has a 4-year program to change inside gas meters to outside locations. This will help minimize issues with internal gas meters. 4 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 1 1 SLR Notes: PUC reponded to PHMSA request for Staffing formula verification. 5 Sharing Best Practices with Other States - (General Program) Yes = .5 No = 0 .5 0.5 SLR Notes: RI shares useful information pipeline safety issues at NAPSR/NEPSR mtgs 6 Part H: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 957925464 2010 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 20

PART 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 D&A Program inspection in April, 2010 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 D&A Program inspection in April, 2010 .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 D&A Program inspection in April, 2010 .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: In CY 2010 DPUC performed 26 OQ inspections(OQ Program Plan + Field verifications) 1 1 5 Has the state reviewed operator qualification programs for compliance with PHMSA rules and protocols? Yes = .5 No = 0 SLR Notes: DPUC performed OQ Program inspections .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 SLR Notes: PUC performed 4 OQ field verification inspections .5 0.5 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 .5 0.5 SLR Notes: 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: 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 .5 NA SLR Notes: DUNS: 957925464 2010 Natu
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