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PHMSA vt-2018-gas-program-evaluation
2018 VT NG Program Evaluation - vt-2018-gas-program-evaluation (Vermont; Natural Gas State Program Evaluation)
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VT NG Program Evaluation, 2018, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2018 Gas State Program Evaluation for VERMONT DEPARTMENT OF PUBLIC SERVICE 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: 809376791 2018 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 1#
VT NG Program Evaluation, 2018, page 22018 Gas State Program Evaluation -- CY 2018 Gas State Agency: Vermont Rating: Agency Status: Date of Visit: 07/30/2019 - 08/01/2019 Agency Representative: Bill Jordan, Director of Engineering Matt Hecklinger, Inspector PHMSA Representative: Rex Evans Commission Chairman to whom follow up letter is to be sent: Name/Title: Ms. June Tierney, Commissioner Agency: Vermont Department of Public Service Address: 112 State Street City/State/Zip: Montpelier, VT 05620 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2018 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 13 13 C Program Performance 45 43 D Compliance Activities 15 13 E Incident Investigations 5 5 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 107 103 State Rating................................................................................................................................................... 96.3 DUNS: 809376791 2018 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 2#
VT NG Program Evaluation, 2018, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The information listed in progress report appears accurate. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were 101 days reported on Attachment 2. The required days entered was 111, 2 points were lost on progress report scoring. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Information appears accurate. No issues. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No incidents in 2018. All ok. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The information listed appears accurate. Previous years compliance action counts have been corrected from previous periods, no deductions due to correcting and getting up to date on information provided and providing us quarterly progress reports. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: All official files were accessible and organized. Depth and count of files is such that they were actually provided to us for review. No issues. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. 1 1 DUNS: 809376791 2018 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 3#
VT NG Program Evaluation, 2018, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. 1 1 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 809376791 2018 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 4#
VT NG Program Evaluation, 2018, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 2 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Starting in Section 5, Page 7 of procedures it appears all elements are covered. Frequency on Page 9 and types of inspections covering all areas on Page 10. This continues through Section 6 to page 13. No issues. 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Starting in Section 5, Page 7 of procedures it appears all elements are covered. Frequency on Page 9 and types of inspections covering all areas on Page 10. This continues through Section 6 to page 13. No issues. 3 OQ Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Starting in Section 5, Page 7 of procedures it appears all elements are covered. Frequency on Page 9 and types of inspections covering all areas on Page 10. This continues through Section 6 to page 13. No issues. 4 Damage Prevention Inspection procedures should give guidance to state inspectors that 1 1 insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Starting in Section 5, Page 7 of procedures it appears all elements are covered. Frequency on Page 9 and types of inspections covering all areas on Page 10. This continues through Section 6 to page 13. No issues. 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Starting in Section 5, Page 7 of procedures it appears all elements are covered. Frequency on Page 9 and types of inspections covering all areas on Page 10. This continues through Section 6 to page 13. Done as necessary. No issues. 6 Construction Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Starting in Section 5, Page 7 of procedures it appears all elements are covered. Frequency on Page 9 and types of inspections covering all areas on Page 10. This continues through Section 6 to page 13. Recommend noting annual effort and to try and have a day goal. No issues. DUNS: 809376791 2018 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 5#
VT NG Program Evaluation, 2018, page 67 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: Outlined in Section 6 of procedures. Procedures appear appropriate based on size of program and limited number of operators. No issues. 8 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: As noted above, the program procedures are appropriate and satisfactory for the size of program and limited number of operators. No issues with procedures. Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 809376791 2018 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 6#
VT NG Program Evaluation, 2018, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 101.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 0.50 = 110.00 Ratio: A / B 101.00 / 110.00 = 0.92 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Only a total of .5 person years and 101 days. Ratio was .92 therefore full points in this section. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: One inspector program during 2018. GC Morris left the program at the end of 2018. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 2 1 Evaluator Notes: This is a transition period for the program, although the basis of this evaluation is a continuance of previous improvement being needed in this area. Will be looking for the program to continue improvement and transition to new program manager and staff is headed in the right direction. Recommend continual learning of application of regulations and reaching out when questions arise to the various resources we have offered. 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, response has been received and sufficient progress has been made on issues that have been noted. The program has also continued to provide quarterly progress reports on inspection and compliance efforts. 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: New England combined seminar is held. Last one was in October 2018. No issues. 1 1 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 DUNS: 809376791 2018 Gas State Program Evaluation 5 5 Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 7#
VT NG Program Evaluation, 2018, page 8Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: I was provided electronic copies of all inspection for all operators. It appears the documentation is in place satisfying that all have been inspected in their five year interval. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the forms appear to have covered all requirements. Making notation on next round, since now using IA forms that all the NTSB type questions are covered also. These have been covered on Vermont Gas, who is system applicable. 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 Yes = 1 No = 0 Evaluator Notes: No cast iron, NA 1 NA 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 Yes = 1 No = 0 Evaluator Notes: No case iron, NA 1 NA 10 Did the state review operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes, this is covered with VGS 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 Yes = 1 No = 0 Evaluator Notes: Yes, VGS covered 192.617 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? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: VGS is only applicable operator. No issues 2 2 13 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues, VGS only. DUNS: 809376791 2018 Gas State Program Evaluation 1 1 Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 8#
VT NG Program Evaluation, 2018, page 914 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, D&A inspections included in files reviewed. 2 2 15 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: OQ program inspections were in files reviewed. Looks like most were done in CY2015 2 2 16 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually? Are replies to Operator IM notifications addressed? (formerly part of Question C-13)). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This applies to VGS only, plan review is due however PHMSA will be sending Chris McLaren to mentor and assist. Various IMP activities have occurred with new transmission line installation over past 3-4 years. Full points for now. 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 2 This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: First round of DIMP plans had been completed. Also looks like most done in CY2015, Chris McLaren will also be assisting on making sure appropriate progress is made on this in upcoming months. 18 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. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Public Awareness inspections appear to be complete in each operator electronic documents. No issues. 2 2 19 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the state has relevant information available on their website. 1 1 20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 809376791 2018 Gas State Program Evaluation 1 NA Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 9#
VT NG Program Evaluation, 2018, page 10No SRC's 21 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? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: VGS is part of PPDC. No issues. 1 1 22 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. 1 1 23 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: None according to previous discussions with staff. 1 1 24 Did the state attend the NAPSR National Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: No, GC had announced retirement and neither him or Bill Jordan attended. 1 0 25 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: There was a change in how VGS reported damages three years ago vs today. Trend is dependent on three years and relatively steady on damages. The other metrics with issues are program performance, which have been addressed with previous evaluations. 26 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: 1 1 We have had discussions on reasonable SICT numbers, they appear to be in line with the program needs at the moment. 27 Evaluator Notes: N/A Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 1 NA 28 General Comments: Info Only = No Points Evaluator Notes: DUNS: 809376791 2018 Gas State Program Evaluation Info Only Info Only Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 10#
VT NG Program Evaluation, 2018, page 11Total points scored for this section: 43 Total possible points for this section: 45 DUNS: 809376791 2018 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 11#
VT NG Program Evaluation, 2018, page 12PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: Adequate procedures are in place for program to get compliance actions resolved and the other elements necessary. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 2 document all probable violations, including what resolution or further course of action is needed to gain compliance? (Incident Investigations do not need to meet 30/90 day requirement) Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: Their score has previously been zero on this question. There has been significant process. Doing a two point deduction since outstanding issues from prior years have yet to be resolved, however progress is again being made and fully expect the program to catch up on these and resolve by follow-up soon. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: It appears necessary actions on probable violations discovered are in process. And review indicated satisfactory progress. 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes, there are no issues with due process 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) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, no issues. 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: DUNS: 809376791 2018 Gas State Program Evaluation 1 1 Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 12#
VT NG Program Evaluation, 2018, page 13Yes, they have exercised their fining authority. No issues. 7 General Comments: Info Only = No Points Evaluator Notes: Significant progress has been made to clean up outstanding issues. DUNS: 809376791 2018 Gas State Program Evaluation Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 15 Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 13#
VT NG Program Evaluation, 2018, page 14PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Written procedures are in Section 8 starting on page 14 of their procedures. No issues. 2 2 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: No issues here. 3 If onsite investigation was not made, did state obtain sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No incidents 2018 1 NA 4 Were all incidents investigated, thoroughly documented, and with conclusions and recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review 3 NA 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 incidents 2018 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: Not applicable 1 NA 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Not applicable for 2018 period 1 NA 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: DUNS: 809376791 2018 Gas State Program Evaluation 1 1 Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 14#
VT NG Program Evaluation, 2018, page 15Although no incidents 2018, as part of region report state did share information. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 5 Total possible points for this section: 5 DUNS: 809376791 2018 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 15#
VT NG Program Evaluation, 2018, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: VGS would be only distribution operator conducting boring. No issues. 2 2 2 Did the state inspector verify pipeline operators are following their written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This has been part of checklist. No issues again with limited # of operators. 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.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, staff and contract staff are heavily involved in state damage prevention efforts. No issues. 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) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This is part of metrics that were reviewed. VGS only LDC and no present issues. 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: 809376791 2018 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 16#
VT NG Program Evaluation, 2018, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: Bourne's Propane - July 31, Vermont Gas System - August 1, 2019 Name of State Inspector(s) Observed: Bill Jordan, Matt Hecklinger Location of Inspection: Bournes - Stowe,Morrisonville Vermont, VGS - Milton, VT Date of Inspection: Bourne - July 31, 2019, VGS - August 1, 2019 Name of PHMSA Representative: Rex Evans Evaluator Notes: Concluded record audit of Bournes Propane and did field visit on small propane system on July 31. Observed construction, new service installation at VGS in Milton Vermont. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 Evaluator Notes: Operator was present at both visits. 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues, information appeared to be documented appropriately at both locations. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues with documentation. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: 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) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: All relevant information was documented. No issues. 2 2 DUNS: 809376791 2018 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 17#
VT NG Program Evaluation, 2018, page 187 Did the inspector have adequate knowledge of the pipeline safety program and 2 2 regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Bill Jordan has adequate knowledge, Matt Hecklinger new inspector. Spent time coaching new inspector for things to look for. No issues on progress or capabilities observed. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: Yes, an adequate review was done in both field visits for what we reviewed. 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Nothing pending from current field visits. 1 NA 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping Info Only Info Only DUNS: 809376791 2018 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 18#
VT NG Program Evaluation, 2018, page 19D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 809376791 2018 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 19#
VT NG Program Evaluation, 2018, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 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: 809376791 2018 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 20#
VT NG Program Evaluation, 2018, page 21PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 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: 809376791 2018 Gas State Program Evaluation Vermont VERMONT DEPARTMENT OF PUBLIC SERVICE, Page: 21#
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