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PHMSA ri2013ngprogramevaluation
2013 RI NG Program Evaluation - ri2013ngprogramevaluation (Rhode Island; Natural Gas State Program Evaluation)
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RI NG Program Evaluation, 2013, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2013 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: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 1#
RI NG Program Evaluation, 2013, page 22013 Natural Gas State Program Evaluation -- CY 2013 Natural Gas State Agency: Rhode Island Rating: Agency Status: Date of Visit: 07/14/2014 - 07/16/2014 Agency Representative: Don Ledversis, Gas Pipeline Safety Engineer PHMSA Representative: Rex Evans 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, RI 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 2013 (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 10 10 B Program Inspection Procedures 15 15 C Program Performance 42 41 D Compliance Activities 15 15 E Incident Investigations 8 8 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 109 108 State Rating................................................................................................................................................... 99.1 DUNS: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 2#
RI NG Program Evaluation, 2013, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress 1 1 Report Attachment 1 (A1a) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The information listed appears correct. The LNG operator was inspected, national grid is the operator and since they are listed previously there was some confusion about what was needed, but inspection units are correct. Full point. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Time sheet information reviewed appears to show adequate information to substantiate Attachment 2 information 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress 1 1 Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Information appears correct. only one primary LDC which owns the LNG plant, remainder are small MM and LPG. There is a pending Intrastate Transmission pipeline, already listed in system as Douglas Pipeline that operates gas coming out of a landfill. They are in process of determining jurisdiction due to the line is only on landfill property -but crosses public highway. 4 Were all federally reportable incident reports listed and information correct? - Progress 1 1 Report Attachment 4 (A1d) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, information listed was correct. There were no incidents that met reporting requirements. Although there was a National Grid incident on 8/13/13 that was still in PHMSA system, but did not meet reporting threshold. Discussed with Don that company might want to rescind. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: The information reviewed was acceptable. Compliance activities are listed on sheet included in folder with copies of compliance action letters. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues. 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: Don is only employee, program manager and inspector 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: DUNS: 623014990 2013 Natural Gas State Program Evaluation 1 1 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 3#
RI NG Program Evaluation, 2013, page 4Automatic adoption. General law 39 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 (H1-3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues 1 1 10 General Comments: Info Only = No Points Evaluator Notes: No issues Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 4#
RI NG Program Evaluation, 2013, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Outlines in pages 6-8 of procedures 2 2 2 IMP Inspections (including DIMP) (B1b) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: issues These are included - limited IMP and very small numbers of DIMP. National Grid is shared operator with other states. No 3 OQ Inspections (B1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: page 8 of procedures. may want to look at doing a combined program inspection. 1 1 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues, page 21 5 On-Site Operator Training (B1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: no issues 1 1 6 Construction Inspections (B1f) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues 1 1 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Starting page 8, no issues 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: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 5#
RI NG Program Evaluation, 2013, page 6f. Are inspection units broken down appropriately? Evaluator Notes: Yes No Needs Improvement Primarily page 13-14 of procedures. No issues as limited numbers. Only one major LDC which is visited regularly. 9 General Comments: Info Only = No Points Evaluator Notes: Recommend overall update Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 6#
RI NG Program Evaluation, 2013, 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): 115.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 0.95 = 209.00 Ratio: A / B 115.00 / 209.00 = 0.55 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: 115 person days achieved. 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: All required classes are taken. Again recommend review and take IMP curriculum even though no applicable operators. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues 2 2 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 2 1 Evaluator Notes: The letter was not responded to within 60 days. One point deduction, but issue about letters appears to have been resolved. 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) Yes = 2 No = 0 Evaluator Notes: Joint seminar with other New England programs conducted every year. No issues. 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 5 5 Evaluator Notes: Review of all operators listed and files of last inspections, it appears all have been inspected within time frames. No issues DUNS: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 7#
RI NG Program Evaluation, 2013, 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: The information reviewed showed no issues. PHMSA form 2 is used on the National Grid inspection 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: Cast iron encroachment program in place with National Grid, no issues. 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: 1 1 as in previous question, they have cast iron encroachment program with only operator. National Grid, no issues. 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: This is verified on PHMSA form 2 inspection checklist 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: 192.617 is covered on inspection checklist 1 1 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Data Initiative (G6-9,G16) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Only applicable operator is National Grid. trends and data are being adequately addressed. No issues 2 2 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: No issues. OQ program inspection with National Grid is uploaded. 2 2 14 DUNS: 623014990 2013 Natural Gas State Program Evaluation 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 1 NA Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 8#
RI NG Program Evaluation, 2013, page 9Evaluator Notes: No intrastate transmission designated. Landfill Douglas Pipeline is pending interpretation 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: Yes, D & A Activities are being done. 2 2 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: Yes, plan for National Grid is up to date. all ok 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: N/A no intrastate transmission in RI 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 DIMP ? First round of program inspections should be complete by December 2014 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DIMP inspections are on target 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) PAPEI Effectiveness Inspections should be complete by December 2013 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: PAPEI issues are up to date. 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: Public records are accessible, web-site is place for docketed information. http://www.ripuc.org/utilityinfo/natgas/Pipeline_safety.html 1 1 DUNS: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 9#
RI NG Program Evaluation, 2013, page 1021 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: None in CY2013 1 NA 22 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: No issues and National Grid participates 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: No issues 1 1 24 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Info Only = No Points Evaluator Notes: Info Only Info Only 25 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 41 Total possible points for this section: 42 DUNS: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 10#
RI NG Program Evaluation, 2013, 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 4 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: Items are now sent to company officer. Recommend overall procedure update 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 b. Were probable violations documented? Yes No Needs Improvement c. Were probable violations resolved? Yes No Needs Improvement d. Was the progress of probable violations routinely reviewed? Yes No Needs Improvement Evaluator Notes: There appears to be a full circle process to ensure all compliance activities are taken care of. RI has a list of all compliance activities running through the year and keep on an annual basis. Although some tend to be over and above Federal regulations, all appear to be addressed appropriately. 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: appropriately. Yes, through review of inspection records along with review of compliance activities it appears all violations are addressed 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: Yes, Due process given to parties. 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) (B27) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, civil penalties considered and used. 2 2 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, fines are used. 1 1 7 General Comments: Info Only = No Points Info Only Info Only DUNS: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 11#
RI NG Program Evaluation, 2013, page 12Evaluator Notes: Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 12#
RI NG Program Evaluation, 2013, page 13PART 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: Records are kept, no issues 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: No issues 1 1 3 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 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 issues - incident reported ended up actually not meeting minimum federal amounts. 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, N/A 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 issues. 1 1 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: Yes, Active in sharing in region 1 1 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 623014990 2013 Natural Gas State Program Evaluation Info Only Info Only Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 13#
RI NG Program Evaluation, 2013, page 14Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 14#
RI NG Program Evaluation, 2013, page 15PART 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: all reviewed with National Grid, no issues. 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: No issues, strong program 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: 2 2 Regular attendance at damage prevention meetings, along with DigSafe board meetings and various other activities. 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: As in previous years, reviewed with National Grid and data is gathered by city for specifics. 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: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 15#
RI NG Program Evaluation, 2013, page 16PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: National Grid - Rhode Island Name of State Inspector(s) Observed: Don Ledversis Location of Inspection: Various Rhode Island Locations Date of Inspection: July 15, 2014 Name of PHMSA Representative: Rex Evans Evaluator Notes: No issues found 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: Operator had personnel on-site 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: Checklist was completed at every stop 2 2 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The information appeared to be documented on state construction checklist 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: Yes, no issues 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: Field activities and procedures reviewed 2 2 7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) (F8) DUNS: 623014990 2013 Natural Gas State Program Evaluation 2 2 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 16#
RI NG Program Evaluation, 2013, page 17Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues 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: Each construction site was it's own specific inspection. No really needed and no issues 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: None 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: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 17#
RI NG Program Evaluation, 2013, page 18G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: 1.) Barrington RI 424 New Meadow road 2.) 110 New Rd, East Providence 3.)Omega Pond Fish Ladder 4.) Lyons Ave East Providence 5.) First Ave, Providence, Regulator Station 6.) Summit St Regulator Station, East Providence 7.) 387 High St., Cumberland 8.) 45 Waterman, Cumberland Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 18#
RI NG Program Evaluation, 2013, page 19PART 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: 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: 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: 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: 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: 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: 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: 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: Section Not Applicable Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 19#
RI NG Program Evaluation, 2013, page 20PART 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: 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: 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: 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 1 NA Evaluator Notes: 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: 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: 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Section Not Applicable Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 623014990 2013 Natural Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 20#
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