records 2006 · web viewmike dewine, governor asim z. haque, chairman 10 puco transmission...

Public Utilities Commission of OhioService Monitoring and Enforcement

Department180 East Broad Street, 7th Floor

Columbus, OH 43215Mike DeWine, GovernorAsim Z. Haque, Chairman

Gas Transmission / Gathering System Inspection ReportField Operations and Records

Audit Information

Starting Date of Inspection Ending Date of Inspection Total # of Field Days Date of Exit Interview Notified of probable violations? Yes No Investigator

Company Information

Company Headquarters Operator ID #: Address Not required for Gas Gathering operatorsCity State/Zip Executive Officer Title Phone Fax

Inspection Unit Information

Division/Area/Region Address City State/Zip Audit Contact Title Phone Fax

PersonnelPersonnel Contacted Title

Exit Interview held with:

1PUCO Transmission Gathering System Inspection FormVersion 19.1

Summary of Code Requirements for Gathering Systems

Type A Gathering LinesMust comply with the requirements of 49 CFR 192 applicable to Transmission lines, except for 192.150 (Passage of Internal Inspection Devices) and Subpart O (Gas Transmission Pipeline Integrity Management).

Type B Gathering LinesMust comply with the following requirements applicable to Transmission lines:

Design, install, construct, initially inspect, and initially test the pipeline in accordance with the requirements of 49 CFR 192 (Subparts B-H and J).

Subpart I (Corrosion Control) 192.614 (Damage Prevention) 192.616 (Public Awareness) 192.619 (MAOP) 192.706 (Leakage Surveys – as of 10/1/15) 192.707 (Line Markers)

Both Type A and Type B lines that are new, replaced, relocated, or otherwise changed on or after April 14, 2006 must comply with design, installation, construction, initial inspection, and initial testing requirements of 49 CFR 192 applicable to Transmission lines (Subparts B-H and J).

Gas Gathering LinesGas Gathering lines are regulated through the Ohio Revised Code, section 4905.90 and 4905.911. Requirements only apply to lines that are completely constructed on or after September 10, 2012. Gas Gathering lines must comply with the following requirements applicable to Transmission lines:

Design, install, construct, initially inspect, and initially test the pipeline in accordance with the requirements of 49 CFR 192 (Subparts B-H and J).

Subpart I (Corrosion Control) 192.614 (Damage Prevention) 192.616 (Public Awareness) 192.619 (MAOP) 192.706 (Leakage Surveys) 192.707 (Line Markers)

Gas Gathering lines that are new, replaced, relocated or otherwise changed on or after September 10, 2012 must comply with design, installation, construction, initial inspection, and initial testing requirements of 49 CFR 192 applicable to Transmission lines (Subparts B-H and J).


System Description:

Audit Summary / Findings:


General – Determination of Jurisdiction N/A = Not Applicable

Does the Operator have Transmission lines? Yes No Mileage:

Are any Transmission lines within a High Consequence Area (HCA)? Yes No Mileage:

Does the Operator use API RP 80 to determine if they have onshore Gathering lines? Yes No

Does the Operator have Type A Gathering lines? (Type A lines are metallic lines ≥20% SMYS or plastic lines >125 psig in a Class 2, 3, or 4 location)

Yes No Mileage:

Does the Operator have Type B Gathering lines?(Type B lines are metallic lines < 20% SMYS or plastic lines ≤125psig in a Class 3 or 4 location, or in some Class 2 locations (see 192.8)

Yes No Mileage:

Does the Operator have Gas Gathering lines regulated through the Ohio Revised Code, section 4905.911?(Regulated Gas Gathering lines are Gathering lines other than Type A or Type B lines, that were completely constructed on or after September 10, 2012 and transports gas produced by a horizontal well).

Yes No Mileage:

If the Operator has Transmission lines, Type A and/or Type B Gathering lines, have they submitted an Annual Report to the Office of Pipeline Safety in accordance with 49 CFR 191? Yes No N/A

If the Operator has Transmission lines, Type A and/or Type B Gathering lines, have they submitted a Throughput Report to the Commission that accurately reports the total Mcf supplied or delivered in Ohio during the previous calendar year? (R.C. 4905.92)

Yes No N/A

Has the operator submitted a twenty-four hour contact report to the Commission no later than March 15th of each year, containing emergency contact information and any available emergency hotline number? (OAC 4901:1-16-04)

Yes No

Has the operator met compliance deadlines established for regulated Gathering lines? 1. New, replaced, relocated or changed lines must be compliant by the date the line

goes into service.2. Type B lines existing on April 14, 2006 and considered regulated Gathering must

meet the compliance deadlines established in 192.9(e)(2).3. Type A and/or Type B lines existing on April 14, 2006 and becoming regulated

Gathering after that date due to a change in class location or increase in dwelling density have 2 years for Type A lines and 1 year for Type B lines to comply.

Yes No N/A

Does the Operator maintain service lines (“farm taps”) to customers?(Services off otherwise unregulated Gathering are also considered farm taps)

Yes No How Many:

If the operator maintains farm taps, are they operating and maintaining the associated service lines following at a minimum:

1. Corrosion Control – Subpart I.2. Damage prevention program under 192.614.3. Establish MAOP under 192.619.4. Install and maintain line markers under 192.707.5. Establish a public education program under 192.616.6. Leakage survey under 192.723.

Yes No N/A

Note – 49 C.F.R. 192.740 “Pressure regulating, limiting, and overpressure protection – Individual service lines directly connected to production, gathering, or transmission pipelines” came into effect on January 23, 2017. This rule requires inspection and testing of pressure regulating and relief devices used on farm taps. The Ohio GPS section will start enforcing this requirement during CY 2020.


Description Mark checkbox or indicate documents reviewed to verify compliance

Subpart B Materials192.55, .59 Is steel and plastic pipe manufactured in accordance with the listed

specifications? Yes No

192.63 Are all components marked as prescribed in the specifications or standard to which it was manufactured? Yes No

Comments.

Subpart E Welding of Steel in Pipelines192.225

192.227

192.229

Has the operator qualified welding procedures under Section 5 of API 1104 or Section IX of the ASME Boiler and Pressure Vessel Code? Yes No N/A

Are welders qualified under Section 6 of API 1104 or Section IX of ASME? (Welders may qualify under Appendix C for piping operating at < 20% SMYS) Yes No N/A

For operators using API 1104 or ASME has each welder engaged in the welding process within the past 6 months? Yes No N/A

(c) For welders who are qualified using API 1104 or ASME, has welding been done in the preceding 6 months and has one weld been tested and found acceptable under Section 6 or 9 of API 1104 or Section IX of the ASME Boiler and Pressure Vessel Code? (Alternately, welders may maintain ongoing qualification by making a weld and having it tested to the above standards at least twice a year at intervals not exceeding 7½ months).

Yes No N/A

(d) For Appendix C welders, did the operator cut out a production weld and test it to Appendix C within the preceding 7 1/2 months or is the welder re-qualified to Appendix C annually at intervals not exceeding 15 months.

Yes No N/A

Comments.

Subpart F Joining of Materials Other Than by Welding192.285 Are joining qualification records complying with 192.285?

(List joining methods used in the Comments section) Yes No N/A

Comments.

Subpart H Customer Meters, Service Regulators, and Service Lines192.353

192.383 (b)

Is each meter and service regulator installed in a readily accessible location and protected from corrosion and other damage (including vehicular damage) that may be reasonably anticipated?

Yes No N/A

Has the operator installed an EFV on any new or replaced service line serving a single-family residence after Feb 12, 2010? (see 192.383(b) for exceptions) Yes No N/A

Comments.


Subpart I Requirements for Corrosion Control

192.452(b)

192.455(c)

Is the operator applying 192.452(b) to determine cathodic protection requirements for regulated onshore Gathering lines? Yes No N/A

Are buried or submerged pipelines regulated under 192.452(b)(2) protected from external corrosion, including an external protective coating and a cathodic protection system?

Yes No N/A

192.457 Are buried or submerged pipelines regulated under 192.452(b)(1) with an effective external coating cathodically protected? Yes No N/A

Has the operator cathodically protected bare or ineffectively coated lines in areas where active corrosion is found? Yes No N/A

192.459 Are buried pipelines examined for corrosion when exposed? Yes No N/A

192.463 Appendix D Cathodic Criteria Used:

192.465 (a)

Each pipeline under cathodic protection must be tested at least once each calendar year, but with intervals not exceeding 15 months. Yes No N/A

Are short sections of lines, not in excess of 100 feet, or separately protected service lines (including risers) monitored on a 10% per year basis? Yes No N/A

(b) Each rectifier or other impressed current power source must be inspected six times each calendar year, with intervals not exceeding 2 ½ months. Yes No N/A

(c) Critical bonds electrically checked for proper performance six times each calendar year, with intervals not exceeding 2 ½ months. Other bonds checked annually, NTE 15 months.

Yes No N/A

(d) Prompt remedial action taken to correct deficiencies (PHMSA interpretation is that “prompt” means until the next monitoring cycle) Yes No None Found

(e) How are unprotected pipelines reevaluated every 3 years (at intervals not exceeding 39 months) and cathodically protected in areas where active corrosion is found?

192.467 (a) Each buried or submerged pipeline must be electrically isolated from other underground metallic structures, unless the pipeline and the other structure are electrically interconnected and cathodically protected as a single unit.

Yes No N/A

(d) Operator has record of tests to ensure adequate electrical isolation Yes No N/A

192.475 (a)

What tests have the operator done to determine if they are transporting corrosive gas?

(b)

Whenever any pipe is removed from a pipeline for any reason, is the internal surface inspected for corrosion?How many instances of internal corrosion were found?

Yes No N/A

192.476 Is the operator evaluating the risk of internal corrosion, providing for liquid removal, and monitoring locations with significant potential for internal corrosion?

Yes No N/A

192.479 Are above ground lines protected from atmospheric corrosion? Yes No N/A

192.481 Is exposed piping monitored every three years at intervals not exceeding 39 months, and remedial actions taken? Yes No N/A

192.483 Are segments of buried or submerged pipe replaced or repaired due to external corrosion coated and cathodically protected? Yes No N/A

192.485 (a) Transmission / Type A - Has the operator replaced or repaired corroded segments where the remaining wall thickness is less than required for MAOP? Yes No N/A

(d) Transmission / Type A - Has the operator replaced or repaired areas of localized corrosion pitting to a degree where leakage might result, or reduced MAOP commensurate with the strength of the pipe?

Yes No N/A

192.491 Are corrosion control records and/or maps complete?Yes No N/A

Comments.


Subpart J Test Requirements192.503 Is the Operator testing applicable segments of pipelines with the appropriate leak

test or strength test requirement? Yes No N/A

192.517 Are records kept for the life of the pipeline for tests performed under 192.505 and 192.507? Yes No N/A

Are records kept for at least five years for tests performed under 192.509, 192.511, and 192.513? Yes No N/A

Comments.

Subpart L Operations

192.605(a) Transmission / Type A - Did the operator review its O&M Manual and Emergency Manual once each calendar year, not to exceed 15 months? Yes No N/A

Transmission / Type A - Do the O&M and Emergency Manuals include procedures for responding to abnormal operating conditions? Yes No N/A

192.613 (a)

(b)

Is the operator performing continuing surveillance of its facilities to determine and take appropriate action concerning changes in class location?Transmission – Does the surveillance include identifying new HCA’s? (192.905)

Yes No

Transmission / Type A - Does the operator have a program to recondition or phase out segments of piping found to be in unsatisfactory condition (but no immediate hazard exists), or if the segment cannot be reconditioned or phased out, reduce the maximum allowable operating pressure?

Yes No N/A

192.614 Is the operator following its written procedures for notification of excavation, marking, positive response, and the availability/use of the one call system? Yes No

Does the operator have and follow procedures for determine the cause of excavation damages, including accurately classifying causes of excavation damage? (GPS recommends using categories in the Common Ground Alliance damage report field form)

Yes No

192.615(b) Transmission / Type A - Does the Operator furnish applicable portions of the emergency plan to supervisory personnel who are responsible for emergency action?

Yes No N/A

Transmission / Type A - Is the operator training appropriate personnel on the emergency procedures and reviewing employee’s activities after each emergency?

Yes No N/A

192.617 Transmission / Type A - Has the operator analyzed accidents and failures? Yes No N/A

Transmission / Type A - Does the operator have records to show they investigate accidents, reported third party damage and leak causes to ensure appropriate response?

Yes No N/A

192.619 Maximum Allowable Operating Pressure Has the operator correctly established MAOP?* For Type A and/or Type B Gathering operators using the highest actual operating pressure, use the 5 years proceeding March 15, 2006, or the date the line became subject to this part, whichever is later. For Transmission lines, use the 5 years proceeding July 1, 1970.

Yes No

192.625(b) Transmission / Type A – Is odorization required?If so list the frequency of tests and type of test taken: Yes No N/A

Transmission / Type A – If odorization is required, did any reads exceed 1% gas in air? If so, how many?: Yes No N/A

Comments.


Subpart M Maintenance192.705 Transmission / Type A – Does the Operator have a patrolling program to

observe surface conditions on and adjacent to the right-of-way for indications of leaks, construction activity, and other factors affecting safety and operation?

Yes No N/A

Transmission / Type A – Is the frequency of patrolling at least as frequent as the prescribed intervals in 192.705(b)? Yes No N/A

192.706 Is the operator performing leakage surveys according to the following schedule:(note the requirement for Type B Gathering became effective 10/1/15)- Annually, not to exceed 15 months- Class 3 locations with un-odorized gas, bi-annually not to exceed 7 ½

months- Class 4 locations with un-odorized gas, quarterly not to exceed 4 ½ months

Yes No

Is the operator grading leaks when found according to the criteria in the Ohio Administrative Code (OAC) 4901:1-16-04(H)? Yes No

Are hazardous leaks repaired promptly in accordance with 192.703?Yes No

Are leakage survey records retained for five (5) years or until the next leakage survey is completed, whichever time is longer? Yes No

192.707 Are line markers displayed where necessary? Yes No

Does marker warning have required information? Yes No

192.709 Transmission / Type A – Does the operator maintain repair, patrol, survey, inspection, and test records as required in 192.709? Yes No N/A

192.711

192.719

Transmission / Type A – Is the operator following its written procedures for completing temporary and permanent repairs on its pipeline system? Yes No N/A

Transmission / Type A – Does the operator have records for testing of replacement pipe and repairs made by welding? Yes No N/A

192.731-736 Transmission / Type A – Is the operator meeting the following requirements for Compressor stations:

-Inspection and testing of relief devices-Storage of combustible materials-Gas detection and alarm systems.

Yes No N/A

192.739 Transmission / Type A – Is the operator testing pressure limiting stations, relief devices, and pressure regulating stations as described in 192.739 annually, at intervals not exceeding 15 months?

Yes No N/A

192.743 Transmission / Type A – Is the operator testing or reviewing the capacity of pressure relief devices as described in 192.743 annually, at intervals not exceeding 15 months?

Yes No N/A

192.745 Transmission / Type A – Is the operator inspecting and partially operating valves that may re required during an emergency annually, at intervals not to exceed 15 months?

Yes No N/A

Transmission / Type A – Is the operator taking prompt remedial action to correct any valve found inoperable, unless the operator designates an alternative valve? Yes No N/A

Comments.


Note – 49 CFR 192.9(c) states “An operator of a Type A regulated onshore gathering line in a Class 2 location may demonstrate compliance with Subpart N by describing the process it uses to determine the qualification of persons performing operations and maintenance tasks.” For an operator with no Transmission lines and with Type A Gathering lines in only Class 2 locations, mark “N/A” for the questions below and describe the operator’s compliance with 192.9(c) in the “Comments” section below.

Subpart N Operator Qualifications

192.805 Transmission / Type A - Does the operator have and follow a written qualification program to identify covered tasks, ensure through evaluation that individuals are qualified, and provide training to ensure individuals have necessary knowledge and skills?

Yes No N/A

Transmission / Type A - Did operator and/or contractor personnel who were observed performing covered tasks in the Field Review portion of the inspection appear to be qualified to perform these covered tasks and able to recognize abnormal operating conditions?

Yes No N/A

192.807 Transmission / Type A - Was the operator able to produce records demonstrating that operator and/or contractor personnel who were observed performing covered tasks in the Field Review portion of the inspection were qualified in accordance with the operator’s Operator Qualification plan?

Yes No N/A

Comments:

Field Notes – record the covered tasks observed and the qualified individual(s) performing that covered task below:(Transmission / Type A only)

Name/ID of Individual Observed

Covered Task Name / ID Correct Performance? Correct Performance? Correct Performance?

Yes No Yes No Yes No








Comments (Fully describe the reason for any “No” answer):


Note – Complete the Public Awareness section review below only for Type B and/or Gas Gathering operators. Transmission and Type A Gathering operators will have Public Awareness plans reviewed as part of a scheduled O&M Inspection

192.616 Public Awareness

192.616 (a) Type B / Gas Gathering - Has the operator developed and implemented a written continuing public education program that follows the guidelines provided in the American Petroleum Institute (API) Recommended Practice (RP) 1162?

Yes No N/A

(d) Type B / Gas Gathering - Does the operator‘s program include provisions to identify and educate the following affected stakeholder audience groups:- The affected public (farm tap customers and residents along pipeline ROW);- Emergency officials;- Local public officials; and- Excavators?

Yes No N/A

(d) Type B / Gas Gathering – Do the operators public awareness messages include:- Use of a one-call notification system prior to excavation;- Possible hazards associated with unintended releases from a gas pipeline;- Physical indications of a possible release;- Steps to be taken for public safety in the event of a gas pipeline release; and - Procedures for reporting such an event.

Yes No N/A

(c) Type B / Gas Gathering – Does the operator send out baseline public awareness materials and messages:- Once every 2 years to the affected public;- Once a year to emergency officials;- Once a year to local public officials; and- Once a year to excavators

Yes No N/A

Comments:


Field Review – Transmission & Gathering Systems

Cathodic Protection & Critical Bond Readings (192.465 a & c) N/A (explain: )

Date Line Type: Station Name or Location Reading (mv) Coated or Bare Remarks Coated Bare Coated Bare Coated Bare Coated Bare Coated Bare Coated Bare Coated Bare Coated Bare Coated Bare Coated Bare

Rectifiers (192.465) Check here if the operator has no Rectifiers

DateLine Type: Location

Rectifier Capacity Coated or Bare

VoltsAC DC

AmpsAC DC

Coated Bare

Coated Bare

Coated Bare

Coated Bare

Coated Bare

Coated Bare

Coated Bare

Coated Bare

Coated Bare

Coated Bare


Pipelines Exposed to Atmosphere (192.479) and Line Markers (192.707) N/A (explain: )

Date Location Coating Condition Line Markers Visible Comments

Leak Survey (192.706) N/A (explain: )

Date Street Location Open/Closed Leak Indications Leak Grade Comments


Regulator / Relief Stations (192.739) Click here if the operator has none

Use the following to answer questions:Y= Yes N= No * = N/A

Station Location/#

(B) R

egul

ator

Size

Manufacturer/Type/Orifice Size

Inlet MAOP to regulator station PSIG In Outlet MAOP downstream regulator station PSIG Out

(C) O

verp

ress

ure

Dev

ice

(OP)

Type: (M) monitor, (R) relief, (O) oil seal Size Manufacturer/Type/Orifice size

Set point of Overpressure Device

(D) R

elie

f / L

imiti

ng

Dev

ice

desi

gn

requ

irem

ents

199(c) Can be readily operated / tested 199(d) Non-combustible supports 199(e) Can discharge without undue hazard 199(f) Designed to prevent hammering / impairment 199(g) Protected from single failure 199(h) Unauthorized valve operation prevented

(E)

Con

trol &

Sa

mpl

ing

Pipe 203(b)(2) Shut Off Valve near take-off

203(b)(5) Drains Drips where necessary 203(b)(9) Protected from damage 203(b)(9) Separated Control Lines

(F) G

ener

al

479 Pipeline cleaned and coated 481 Atmospheric corrosion 739 Properly installed/protected 741 telemetering/recording gauges 181(b) Inlet valve installed at an adequate distance from regulator station


(Transmission / Type A) - Critical Valves (192.745) N/A (explain: )

Date Location/Valve # Accessible Comments

Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No

Line Locating and Marking (192.614) Check here if no line locates were scheduled by the operator during the inspection

Date Location3rd party locator

used?Locating Method

(Maps, Tracer Wire, etc.)Comments

Yes No

Yes No

Yes No

Yes No

Yes No

Yes No

Other Areas Reviewed By Staff (including Compressor stations, Odorizaton reads, etc.)

Date Location Comments


records 2006 · web viewmike dewine, governor asim z. haque, chairman 10 puco transmission...

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