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PHMSA ri2011ngprogramevaluation
2011 RI NG Program Evaluation - ri2011ngprogramevaluation (Rhode Island; Natural Gas State Program Evaluation)
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RI NG Program Evaluation, 2011, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2011 Natural 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: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 1#
RI NG Program Evaluation, 2011, page 22011 Natural Gas State Program Evaluation -- CY 2011 Natural Gas State Agency: Rhode Island Rating: Agency Status: Date of Visit: 09/10/2012 - 09/14/2012 Agency Representative: Don A. Ledversis PHMSA Representative: Dinubhai (Dino) N. Rathod Commission Chairman to whom follow up letter is to be sent: Name/Title: Thomas Ahern, Administrator Agency: Rhode Island Division of Public Utilities & 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 2011 (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. Field Inspection (PART G): 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 G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 9 8.5 B Program Inspection Procedures 15 14 C Program Performance 40 40 D Compliance Activities 14 13 E Incident Investigations 4 4 F Damage Prevention 8 8 G Field Inspections 11 11 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 101 98.5 State Rating................................................................................................................................................... 97.5 DUNS: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 2#
RI NG Program Evaluation, 2011, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 (A1a) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 1 0.5 Evaluator Notes: DPUC will review and revise Attachmnet 2 Inspection Person Days for Category: On-Site Inspection Person Days. DPUC will contact Zach and seek his concurrence for making changes in FedStar Attachments (2 & 7) 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 (A1d) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No Reportable Incidents in CY 2011 1 NA 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DPUC found 11 Probable Violations in Cy 2011 1 1 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Files are accessible and organized (hard copies as well as electronic) 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 (A1g) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 (A1h) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 (H1-3) 1 1 DUNS: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 3#
RI NG Program Evaluation, 2011, page 4Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 DPUC initiated Compliance Aciton of LDC. RI initiated Farm Tap replacement program and inside meter relocation to outsie of dwelling. 3. RI instituted aboveground vnet for 220 Underground Reg Stations 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 8.5 Total possible points for this section: 9 DUNS: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 4#
RI NG Program Evaluation, 2011, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 2 IMP Inspections (including DIMP) (B1b) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 3 OQ Inspections (B1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 5 On-Site Operator Training (B1e) 1 0 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Discussed with DPUC to have a brief description of "OnSite Training (per PHMSA Guideline Manual Glossary Definition and Chapter 5- pages 26-28, as necessary) 6 Construction Inspections (B1f) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 8 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? (B2a-d, G1,2,4) Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection 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) DUNS: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 5#
RI NG Program Evaluation, 2011, page 6f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: 9 General Comments: Info Only = No Points Evaluator Notes: up-dated versions) Info Only Info Only DPUC agreed t review and revise Inspection Procedures Manual ( follow PHMSA's current Guideline Manual Dec 2011 or Total points scored for this section: 14 Total possible points for this section: 15 DUNS: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 6#
RI NG Program Evaluation, 2011, 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 (A12) Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 139.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 0.94 = 206.80 Ratio: A / B 139.00 / 206.80 = 0.67 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Revised ratio: 103/ (220*0.94)= 0.498, ok 5 points 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines for requirements) Chapter 4.4 (A8-A11, G19) 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 Evaluator Notes: Don Ledverisis has completed required T&Q training. 3 Did state records and discussions with state pipeline safety program manager indicate 2 2 adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Don Ledversis has gained valuable Pipeline safety regulatory expereince and completed necessary T&Q training requirements. he works closely with PHMSA and actively participated in NASPR committees. 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 (A6-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DPUC response letter dated 10/28/2011. DPUC adopted federal limits for civil penalty effective May 2012 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) Yes = 2 No = 0 Evaluator Notes: DPUC attended and participated in a joint NEPSR T&Q seminar held at Cape Cod, MA in Oct 2011 2 2 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 (B3) Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: 5 5 DUNS: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 7#
RI NG Program Evaluation, 2011, page 87 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 (B4-5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DPUC uses a combination of State Check List for Consttrcuction and PHMSA inspection forms 2 2 8 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) Chapter 5.1 (B7) Yes = 1 No = 0 Evaluator Notes: DPUC used PHMSA inspection form # 2, for review/ verification of Part 192.459 & .489 requirements 1 1 9 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) Chapter 5.1 (B8) Yes = 1 No = 0 Evaluator Notes: DPUC used PHMSA inspection form # 2, for review/ verification of Part 192.613 (a) requirements 1 1 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 (B9) Yes = 1 No = 0 Evaluator Notes: DPUC used PHMSA inspection form # 2, for review/ verification of Part 192.615 requirements 1 1 11 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? Chapter 5.1 (B10,E5) Yes = 1 No = 0 Evaluator Notes: DPUC used PHMSA inspection form # 2, for review/ verification of Part 192.617 requirements 1 1 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for 2 2 accuracy and analyzed data for trends and operator issues? Data Initiative (G6-9,G16) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: and operator issues. DPUC reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends 13 Did state input all applicable OQ, IMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 (G10-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: For CY 2011 DPUC completed 4 OQ inspecitons and uploaded results in federal OQDB. 2 2 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? (G14) Yes = 1 No = 0 Needs Improvement = .5 DUNS: 957925464 2011 Natural Gas State Program Evaluation 1 NA Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 8#
RI NG Program Evaluation, 2011, page 9Evaluator Notes: RI does not have intrastate gas transmission pipeline. 15 Is the state verifying operators are conducting drug and alcohol tests as required by regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 (I1-3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 DPUC conducted one D&A inspectionin April 2011 Federal form 3.1.11 (AJn 2010) was used for D&A insepction 16 Is state verifying operators OQ programs are up to date? This should include verification 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 (I4-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DPUC reviewed and uploaded OQ inspection in federal OQDB in CY 2011 2 2 17 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). 49 CFR 192 Subpart 0 (I8-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No intrastate Distribution gas transmission pipeline in RI under IMP rules. 2 NA 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 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). 49 CFR 192 Subpart P Info Only = No Points Evaluator Notes: DPUC performed initial DIMP Program review of National Grid (NG). Info Only Info Only 19 Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. 49 CFR 192.616 (I13-16) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DPUC conducted PAPE inspection of National Grid in Nov 2011 use federal form #21. 2 2 20 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). (G20-21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI State Access to Public Records Regulatoin (APRR) 38-2-1 and 42-35-2(a) 1 1 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 (B6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NO SRC in CY 2011 1 NA DUNS: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 9#
RI NG Program Evaluation, 2011, page 1022 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? (G13) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI operator National Grid has participated in PPDC 1 1 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? (H4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI DPUC particiapted in NAPSR Surveys (Wage Study for Inspectors and Prog Mgrs). 1 1 24 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 40 Total possible points for this section: 40 DUNS: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 10#
RI NG Program Evaluation, 2011, page 11PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 3 resolution of a probable violation? Chapter 5.1 (B12-14, B16, B1h) 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 Evaluator Notes: DPUC agreed to review and revise Written Inspection Procedures. PHMSA recommends sending a notification correspondence to senior officials (example- VP / Sr. VP /President etc. You can always send a copy to other persons you deal at a lower level. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 (B11,B18,B19) 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 Evaluator Notes: 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DPUC found 11 probable violations during Y 2011 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. (B17, B20) Yes = 2 No = 0 Evaluator Notes: 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) (B27) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Don Ledversis is familiar with process for imposing civil penalties. In CY 2011 DPUC imposed $80,000. $10,000 was collected in 2011 and remaining $70,000 collected in March 2012. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety Info Only Info Only violations? (new question) Info Only = No Points Evaluator Notes: 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only DUNS: 957925464 2011 Natural Gas State Program Evaluation Total points scored for this section: 13 Total possible points for this section: 14 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 11#
RI NG Program Evaluation, 2011, page 12PART E - Incident Investigations Points(MAX) Score 1 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 (A2,D1-3) 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: 2 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 (D4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 RI Rules & Regs for Gas Utilites. State can request information from gas operator per Rules & Regulations (page 47) 3 Were all incidents investigated, thoroughly documented, and with conclusions and 3 NA recommendations? (D5) 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: No Reportable Incidents in CY 2011 4 Did the state initiate compliance action for violations found during any incident/accident investigation? (D6) Yes = 1 No = 0 Evaluator Notes: No Reportable Incidents in CY 2011 1 NA 5 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 report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 (D7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No Reportable Incidents in CY 2011 1 NA 6 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) (G15) Yes = 1 No = 0 Evaluator Notes: 1 1 DPUC discussed lessons learned from previous incidents at NAPSR,NEPSR and other stakeholder meetings. 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 957925464 2011 Natural Gas State Program Evaluation Info Only Info Only Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 12#
RI NG Program Evaluation, 2011, page 13Total points scored for this section: 4 Total possible points for this section: 4 DUNS: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 13#
RI NG Program Evaluation, 2011, page 14PART F - Damage Prevention 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? NTSB (E1) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DPUC reviewed National Grid (NG) procedure No. Section 32 Dig Sfe Manual 2 2 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? (E2) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DPUC reviews Dig Safe procedures.on a regular basis each year 2 2 3 Did the state encourage and promote practices for reducing damages to all underground facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) (E3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DPUC participated in MUST and Dig Safe Board Meetings and encourage damage prevention activities. 2 2 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? (This can include DIRT and other data shared and reviewed by the pipeline safety program) (E4,G5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DPUC received and analyzed Dig Safe damage data (1,000 locate requests basis) 2 2 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 14#
RI NG Program Evaluation, 2011, page 15PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: National Grid (NG) gas Name of State Inspector(s) Observed: Don Ledversis Location of Inspection: Providence Date of Inspection: 09/12/2012 Name of PHMSA Representative: Dinubhai (Dino) N.Rathod Evaluator Notes: Field verification of cathodic protection in slected areas in Providence Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? (F2) Yes = 1 No = 0 Evaluator Notes: NG CP tech performed field verification of CP 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) (F3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DPUC inspector Don Ledversis used Check list. 2 2 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Don completed OQ Prtocol # 9 to document his observations 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.) (F5) Yes = 1 No = 0 Evaluator Notes: Don verified that CP Tech had needed equipment to measure CP readings. 1 1 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) (F7) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: CP field verification in Providence area including federal Protocol OQ#9. 2 2 7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) (F8) 2 2 DUNS: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 15#
RI NG Program Evaluation, 2011, page 16Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 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) (F9) Yes = 1 No = 0 Evaluator Notes: Don conducted a brief exit interview. 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) (F10) Yes = 1 No = 0 Evaluator Notes: No probable violations were found. 1 NA 10 General Comments: What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 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 D. Valve Maintenance E. Vault Maintenance F. Welding Info Only Info Only DUNS: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 16#
RI NG Program Evaluation, 2011, page 17G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: OQ #9 Don Ledversis observed NG field tech taking CP readings at various locations within Providence area. He also field verified Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 17#
RI NG Program Evaluation, 2011, page 18PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (C1) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI is not an Interstate Agent State 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? (C2) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI is not an Interstate Agent State 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? (C3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI is not an Interstate Agent State 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.) (C4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI is not an Interstate Agent State 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? (C5) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI is not an Interstate Agent State 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? (C6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI is not an Interstate Agent State 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? (C7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI is not an Interstate Agent State 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: RI is not an Interstate Agent State Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 18#
RI NG Program Evaluation, 2011, page 19PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (B21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI is not an Agrrement State (60106) 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? (B22) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI is not an Agrrement State (60106) 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.) (B23) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI is not an Agrrement State (60106) 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? (B24) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI is not an Agrrement State (60106) 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? (B25) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI is not an Agrrement State (60106) 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? (B26) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: RI is not an Agrrement State (60106) 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: RI is not an Agrrement State (60106) Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 957925464 2011 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 19#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.