psc national grid

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STATE OF NEW YORK DEPARTMENT OF PUBLIC SERVICE THREE EMPIRE STATE PLAZA, ALBANY, NY 12223-1350 PUBLIC SERVICE COMMISSION AUDREY ZIBELMAN Chair PATRICIA L. ACAMPORA GARRY A. BROWN GREGG C. SAYRE DIANE X. BURMAN Commissioners Mr. Robert A. Demarinis Vice President Operations, NY National Grid 175 E. Old Country Road Hicksville, NY 11801 www .dps.ny .gov September 5, 20 14 Re: 2014 National Grid- Gas Operations and Maintenance Audit Dear Mr. Demarinis, KIMBERLY A. HARRIMAN General Counsel KATHLEEN H. BURGESS Secretary Enclosed for your review are the final2014 National Grid record audit reports prepared by Staff of the New York State Department ofPublic Service, Office of Electric, Gas, and Water. The reports are specific in outlining instances of non-compliance where National Grid failed to adhere to the requirements of 16 NYCRR 255- Transmission and Distribution of Gas and 16 NYCRR 261- Piping Beyond the Meter. Staffs Syracuse office conducted the audit ofNational Grid Central territories and Staff's Albany office conducted the audit ofNational Grid Eastern service territories. Please note that Staffs audits were based on a sample review of operation and maintenance activities, and findings were discussed in detail with National Grid management during compliance meetings. National Grid was afforded five business days to provide documentation to cure record deficiencies surrounding Staffs findings presented as the subject of the compliance meetings. The Violations Performance Measure in Case 12-G-0202 classifies violations as either High Risk or Other Risk. The violations found by the Syracuse and the Albany offices have been combined into two documents. Attachment 1 contains the details of the High Risk violations. Attachment 2 contains the details of the Other Risk violations. With respect to the Violations Performance Measure in Case 12-G-0202, violations pertaining to documentation or actions performed, or required to be performed, on or after April1, 2013, will constitute an occurrence under the metric. These are noted in the two attachments by (Post 4/1/13) following each post April 1, 2013 violation. Staff has identified 179 High Risk and 263 Other Risk violations after April 1, 2013. Please respond within 30 days of this letter detailing what actions have and/or will be taken by National Grid to remediate noted violations and concerns, and insure future compliance. If you have any questions

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PSC National Grid

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STATE OF NEW YORK DEPARTMENT OF PUBLIC SERVICE THREE EMPIRE STATE PLAZA, ALBANY, NY 12223-1350

PUBLIC SERVICE COMMISSION

AUDREY ZIBELMAN Chair

PATRICIA L. ACAMPORA GARRY A. BROWN GREGG C. SAYRE DIANE X. BURMAN

Commissioners

Mr. Robert A. Demarinis Vice President Operations, NY National Grid 175 E. Old Country Road Hicksville, NY 11801

www .dps.ny .gov

September 5, 20 14

Re: 2014 National Grid- Gas Operations and Maintenance Audit

Dear Mr. Demarinis,

KIMBERLY A. HARRIMAN General Counsel

KATHLEEN H. BURGESS Secretary

Enclosed for your review are the final2014 National Grid record audit reports prepared by Staff of the New York State Department ofPublic Service, Office of Electric, Gas, and Water. The reports are specific in outlining instances of non-compliance where National Grid failed to adhere to the requirements of 16 NYCRR 255-Transmission and Distribution of Gas and 16 NYCRR 261- Piping Beyond the Meter.

Staffs Syracuse office conducted the audit ofNational Grid Central territories and Staff's Albany office conducted the audit ofNational Grid Eastern service territories. Please note that Staffs audits were based on a sample review of operation and maintenance activities, and findings were discussed in detail with National Grid management during compliance meetings. National Grid was afforded five business days to provide documentation to cure record deficiencies surrounding Staffs findings presented as the subject of the compliance meetings.

The Violations Performance Measure in Case 12-G-0202 classifies violations as either High Risk or Other Risk. The violations found by the Syracuse and the Albany offices have been combined into two documents. Attachment 1 contains the details of the High Risk violations. Attachment 2 contains the details of the Other Risk violations.

With respect to the Violations Performance Measure in Case 12-G-0202, violations pertaining to documentation or actions performed, or required to be performed, on or after April1, 2013, will constitute an occurrence under the metric. These are noted in the two attachments by (Post 4/1/13) following each post April 1, 2013 violation. Staff has identified 179 High Risk and 263 Other Risk violations after April 1, 2013.

Please respond within 30 days of this letter detailing what actions have and/or will be taken by National Grid to remediate noted violations and concerns, and insure future compliance. If you have any questions

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regarding these or any other gas safety concerns, please do not hesitate to call Chris Stolicky at (518) 473-9994 or Bill Wade at (518) 486-2820.

cc: Secretary Kevin Speicher Robyn Adair

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Sincerely,

Christopher Stolicky Utility Supervisor (Safety) Office of Electric, Gas, and Water

William D. Wade Utility Supervisor Office ofElectric, Gas, & Water

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Attachment 1 High Risk Violations

Violation Specifics

Albany Record Audits Nineteen violations of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261 were noted. 16 NYCRR Part 255.603(d) - General Provisions - 1 Violation, 11 Occurrences

One violation of 255.603(d), which states, “Each operator shall prepare and file a detailed written operating and maintenance plan.” “Each operator shall satisfactorily conform with the program submitted.” The following are cited as examples where this requirement was not met:

Retention Period of Forms

National Grid – Albany failed to conform to National Grid GOPB 206, dated 2/15/11, which was the procedure in place at the time of the violation states, “Retention period of both forms is 6 years.” (Post 4/1/13) The following is an example where National Grid’s procedure was not followed: Regulator Inspection Report # 215963 - 12 Red-Lane Dr, Colonie -

The Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report states, “Not Ok cannot locate curb valve GRO 187134.” Staff requested a copy of the GRO on 6/25/14, but the Company could not produce one. The Company failed to retain the GRO.

CGI Calibration Check

National Grid – Albany failed to conform to National Grid SHE01003, Using and Maintaining Portable Gas Monitors, Rev 1, dated 6/15/12, states, “CGIs, carbon monoxide analyzers, oxygen-deficiency analyzers, and multi-function instruments should have maintenance and calibration checks at least once every month in order to correct potential calibration drifts. These checks should be completed monthly, unless a particular instrument manufacturer indicates that a longer calibration frequency interval is acceptable; however, in no case shall the frequency of calibrations exceed three (3) months.” (Post 4/1/13)

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The following are examples where National Grid’s procedure was not followed: CGI # 1243-303075 - Records show a gap in calibration from

12/28/12 to 4/9/13.

CGI # 1243-303074 - Records show a gap in calibration from 11/15/12 to 4/9/13.

CGI # 1243-303055 - Records show a gap in calibration from 11/15/12 to 4/9/13.

Leakage Surveys Intervals

National Grid – Albany failed to conform to National Grid CNST02002, Leakage Surveys, Rev 1, dated 05/15/13, states, “A leakage survey of the gas facility in Company defined business district shall be performed once each calendar year and at intervals not to exceed fifteen (15) months.” (Post 4/1/13) The following is an example where National Grid’s procedure was not followed: Map 189977, Zone 12-12 (Glenmont Plaza), Glenmont - Records

show that a section of business district pipe was surveyed on 5/5/09 and not again until 6/18/13. The Company failed to survey this business district pipe at intervals not exceeding 15 months.

Service Regulator Inspection

National Grid – Albany failed to conform to National Grid CMS06001, Inspecting High Pressure Service Regulating Equipment, Rev 2, dated 02/01/13, states, “Check for proper size and location of vent terminus.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: Regulator Inspection Report # 227901 - 11 Cary St, Ravena -

Records from 5/10/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection.

Regulator Inspection Report # 12192335 - 3 Sycamore Dr, Albany - Records from 1/2/13 indicate “No” for “Screening/Piping” in the

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“Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection.

Regulator Inspection Report # 13288207 - 10 Lakeshore Dr, Rensselaer - Records from 8/2/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection.

Type 1 Leak Classification

National Grid – Albany failed to conform to National Grid GDx 050001-PL, Rev 0, dated 12/15/10, which was the procedure in place at the time of the violation states, “A Class 1 leak migration pattern is a gas leak that represents an existing or probable hazard to persons or property, and requires immediate repair or continuous action until the condition is no longer hazardous. Class 1 leak migration patterns include but are not limited to the following: 1) Damage to gas facilities resulting in leakage. ” The following is an example where National Grid’s procedure was not followed: GRO # 194954 - 89 Delaware Ave, Albany - This Type 2A leak,

classified on 1/30/13, was a result of contractor damage to a 1 inch drip line off of a main. The Company failed to correctly classify this leak as a Type 1.

Leak Surveillance

National Grid – Albany failed to conform to National Grid CNST02009, Classifying Gas Leaks, Rev 1, dated 06/01/13, the current procedure, states, “Surveillance: Surveillance of a Class 2A leak shall be at intervals not to exceed 14 days until the source of the leak has been corrected, or reclassified.” (Post 4/1/13) The following is an example where National Grid’s procedure was not followed: GRO # 231764 - 34 Genesee Ave, East Greenbush - This leak

history card shows that a Type 2A leak was surveyed on 8/21/13. It was siphoned on 8/22/13, and was not surveyed again until 9/17/13. The Company failed to survey this leak with a frequency not to exceed two weeks.

Leak Classification Downgrade

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National Grid – Albany failed to conform to National Grid GDx 050001-PL, Rev 0, dated 12/15/10, which was the procedure in place at the time of the violation, states, “In situations in which no repair has been affected, the classification of a leak migration pattern may be downgraded after two consecutive decreased readings, in the level of natural gas, at its normal surveillance cycle.” The following is an example where National Grid’s procedure was not followed: GRO # 207771 - 119 Orchard St, Delmar - This leak history card

showed Type 2A readings on 2/28/13. It was reclassified to a Type 2 Leak on 3/11/13 with no surveillances in between. There were no repairs made until after this reclassification. The Company failed to perform at least one additional surveillance at the normal interval before downgrading to a lower classification.

Type 2A Leak Classification

National Grid – Albany failed to conform to National Grid GDx 050001-PL, Rev 0, dated 12/15/10, which was the procedure in place at the time of the violation, Attachment 2: Leak Classification Guide - Massachusetts, New York State and Rhode Island, depicts that Type 2A leaks include gas readings greater than 20% within 20 feet of a building, inside the curb, in an unpaved area. The following is an example where National Grid’s procedure was not followed: GRO # 202934 - 143 Woodlawn Ave, Albany - This leak was

originally classified as a Type 2 leak on 2/23/13. The leak history card shows readings of 25% gas at 20 feet from a building, inside the curb, in an unpaved area. The Company failed to correctly classify this leak as a Type 2A.

Type 2 Leak Classification

National Grid – Albany failed to conform to National Grid GDx 050001-PL, Rev 0, dated 12/15/10, which was the procedure in place at the time of the violation, Attachment 2: Leak Classification Guide - Massachusetts, New York State and Rhode Island, the current procedure, depicts that Type 2 leaks include gas readings greater than 30% within 50 feet of a building, inside the curb, in an unpaved area. The following is an example where National Grid’s procedure was not followed:

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GRO # 208102 – 55 Nathaniel Blvd, Delmar - This leak was

originally classified as a Type 3 leak on 7/9/12. The leak history card shows readings of 67% gas within 50 feet from a building, inside the curb, in an unpaved area. The Company failed to correctly classify this leak as a Type 2 leak.

Replacement of Exposed Cast Iron Pipe

National Grid – Albany failed to conform to National Grid GOPB 417, Protection and Replacement of Exposed Cast Iron Pipe, dated 2/1/03, and DAM01007, Cast Iron Encroachment Policy for Long Island and Upstate New York, Revision 0, dated 12/15/13, requires, “Any cast iron pipe eight (8) inches or less in diameter, exposed and undermined by an excavation 36 inches or greater in width, the purpose of which is for work other than normal gas operation and maintenance work being performed on the exposed cast iron main, shall be replaced by steel or plastic pipe. For crossings, the pipe replaced shall be at least the length of exposed pipe plus twice the product of the exposed pipe length and the distance from the top of the main to the bottom of the trench divided by the trench width. Replacements shall extend approximately equally on both sides of said excavations. (Post 4/1/13). The following is an example where National Grid’s procedure was not followed: DSNY Ticket # 1204314800600 - 462 1st St, Albany - Records

from 12/4/13 indicate that 10 feet of the 6 inch cast iron main was exposed. Records also indicate that only 10 feet of the main was replaced. The Company did not replace the correct length of the main.

Replacement of Exposed Cast Iron Pipe

National Grid – Albany failed to conform to National Grid GOPB 417, Protection and Replacement of Exposed Cast Iron Pipe, dated 2/1/03 states, “Un-exposed Pipe Parallels Excavation (Angle of Repose): The length of pipe replaced shall be at least the length of pipe in the angle of repose plus twice the distance from the top of the main to the bottom of the trench.” (Post 4/1/13). The following is an example where National Grid’s procedure was not followed: DSNY Ticket # 1022315402100 - 765 Madison Ave - Premier’s

Cast Iron Report from 10/30/13 states, “it was determined that the

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6”CI gas main will be in the angle of repose for a total length of 26ft.” Records indicate that only 14 feet of main was replaced. The Company did not replace the correct length of the main.

16 NYCRR Part 255.723(b)(1) - Distribution systems: Leakage surveys and procedures - 1 Violation, 1 Occurrence

One violation of 255.723(b)(1), which states, “A leakage survey shall be conducted at intervals not exceeding 15 months, but at least once each calendar year, in business districts within the operator's gas franchise area including tests of the atmosphere of accessible manholes, at cracks in pavement, at the curbline, in the sidewalk including the service line area up to the building wall, and at other locations where it would be reasonable to expect a gas leak to be found.”

The following is cited as an example where this requirement was not met:

Map 189977, Zone 12-12 (Glenmont Plaza), Glenmont - Records show that a

section of business district pipe was surveyed on 5/5/09 and not again until 6/18/13. The Company failed to survey this business district pipe at intervals not exceeding 15 months. (Post 4/1/13)

16 NYCRR Part 255.756(b) - Replacement of Cast Iron Mains Paralleling Excavations - 1 Violation, 1 Occurrence

One violation of 255.756(b), which states, “(b) For right angle crossings of cast iron mains, the length replaced shall be equal to at least the width of the excavation plus twice the distance from the top of the main to the bottom of the trench.”

The following is cited as an example where this requirement was not met:

DSNY Ticket # 1204314800600 - 462 1st St, Albany - Records from 12/4/13

indicate that 10 feet of the 6 inch cast iron main was exposed and undermined. Records also indicate that only 10 feet of the main was replaced. The Company did not replace the correct length of the main. (Post 4/1/13)

16 NYCRR Part 255.757(a) - Replacement of Cast Iron Mains Paralleling Excavations - 1 Violation, 1 Occurrence

One violation of 255.757(a), which states, “(a) If an excavation is made parallel to any cast iron gas main, eight inches or less in nominal diameter, and said excavation is not adequately shored to protect the cast iron main against movement, the cast iron main must be replaced where more than half the pipe diameter lies above a line projected at an angle above the horizontal equal to the angle of repose for the soil conditions being encountered, starting from the bottom of the excavation at the side nearest the main.”

The following is cited as an example where this requirement was not met:

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DSNY Ticket # 1022315402100 - 765 Madison Ave, Albany - Premier’s Cast

Iron Report from 10/30/13 states, “it was determined that the 6”CI gas main will be in the angle of repose for a total length of 26ft.” Staff questioned the Company about the main and the local supervisor provided documentation showing that only 14 feet was replaced. The Company did not replace the correct length of the main. (Post 4/1/13)

16 NYCRR Part 255.809(b) - Leaks: Instrument sensitivity verification - 1 Violation, 3 Occurrences

One violation of 255.809(b), which states, “Each instrument utilized for leakage surveys and investigations must be tested against a known sample or in accordance with the manufacturer's recommended instructions as follows: (a) after any repair or replacement of parts other than normal maintenance; (b) once every three months for CGI's and solid state leak detection instruments and yearly for Hydrogen Flame Ionization (HFI) instruments; and (c) any time it is suspected that the calibration has changed.”

The following are cited as examples where this requirement was not met:

CGI # 1243-303075 - Records show a gap in calibration from 12/28/12 to

4/9/13. (Post 4/1/13)

CGI # 1243-303074 - Records show a gap in calibration from 11/15/12 to 4/9/13. (Post 4/1/13)

CGI # 1243-303055 - Records show a gap in calibration from 11/15/12 to

4/9/13. (Post 4/1/13)

16 NYCRR Part 255.811(e)(1) - Leaks: Type 1 classification - 1 Violation, 1 Occurrence

One violation of 255.811(e)(1) which states, “Type 1 leaks include but are not limited to: damage by contractors or outside sources resulting in leakage.”

The following is cited as an example where this requirement was not met:

GRO # 194954 - 89 Delaware Ave, Albany - This Type 2A leak, classified on

1/30/13, was a result of contractor damage to a 1” drip line off of a main. The Company failed to correctly classify this leak as a Type 1.

16 NYCRR Part 255.813(c) - Leaks: Type 2A classification - 1 Violation, 1 Occurrence

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One violation of 255.813(c), which states, “Type 2A leaks shall be maintained under surveillance with a frequency not to exceed two weeks until repaired.”

The following is cited as an example where this requirement was not met:

GRO # 231764 - 34 Genesee Ave, East Greenbush - This Type 2A leak was

surveyed on 8/21/13. It was siphoned on 8/22/13, and was not surveyed again until 9/17/13. The Company failed to survey this leak with a frequency not to exceed two weeks. (Post 4/1/13)

16 NYCRR Part 255.813(d)(2) - Leaks: Type 2A classification - 1 Violation, 1 Occurrence

One violation of 255.813(d)(2), which states, “Type 2A leaks include, but are not limited to: any reading, in an unpaved area, of 20 percent or greater gas-in-air which is more than 5 feet (1.5 meters) but within 20 feet (6.1 meters) of a building and inside the curb or shoulder of the road.”

The following is cited as an example where this requirement was not met:

GRO # 202934 - 143 Woodlawn Ave, Albany - This leak was originally

classified as a Type 2 leak on 2/23/13. The leak history card shows readings of 25% gas at 20 feet from a building, inside the curb, in an unpaved area. The Company failed to correctly classify this leak as a Type 2A.

16 NYCRR Part 255.815(d)(3) - Leaks: Type 2 classification - 1 Violation, 1 Occurrence

One violation of 255.815(d)(3) which states, “Type 2 leaks include, but are not limited to: any reading of 30 percent or greater gas-in-air in an unpaved area which is more than 20 feet (6.1 meters) from but within 50 feet (15.2 meters) of the building and inside the curbline or shoulder of the road.”

The following is cited as an example where this requirement was not met:

GRO # 208102 – 55 Nathaniel Blvd, Delmar - This leak was originally

classified as a Type 3 leak on 1/23/13. The leak history card shows readings of 67% gas within 50 feet from a building, inside the curb, in an unpaved area. The Company failed to correctly classify this leak as a Type 2 leak.

16 NYCRR Part 261.53 - HEFPA liaison - 1 Violation, 19 Occurrences

One violation of 261.53, which states, “Whenever the disconnection results in a customer being unable to use the heating facilities, the operator shall notify its Home Energy Fair Practices Act (HEFPA) liaison with local social services departments (section 11.5(c)(2)(v) of this Title).”

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The following are cited as examples where this requirement was not met:

156 Madison Ave, Albany - Records indicate that the heating facilities were

disconnected on 1/2/13. The Company failed to notify HEFPA.

403 Madison Ave, Albany - Records indicate that the heating facilities were disconnected on 1/18/13. The Company failed to notify HEFPA.

30 Lori Lane, Latham - Records indicate that the heating facilities were disconnected on 1/20/13. The Company failed to notify HEFPA.

285 Clinton Ave, Albany - Records indicate that the heating facilities were disconnected on 2/4/13. The Company failed to notify HEFPA.

293 Clinton Ave, Albany - Records indicate that the heating facilities were disconnected on 3/13/13. The Company failed to notify HEFPA.

268 Manning Blvd, Albany - Records indicate that the heating facilities were disconnected on 4/2/13. The Company failed to notify HEFPA. (Post 4/1/13)

467 Kentwood Ave, Delmar - Records indicate that the heating facilities were disconnected on 4/9/13. The Company failed to notify HEFPA. (Post 4/1/13)

14 May St, Rensselaer - Records indicate that the heating facilities were disconnected on 4/12/13. The Company failed to notify HEFPA. (Post 4/1/13)

24 Fleetwood Ave, Albany - Records indicate that the heating facilities were disconnected on 4/13/13. The Company failed to notify HEFPA. (Post 4/1/13)

15 Lancil Lane, Albany - Records indicate that the heating facilities were disconnected on 11/1/13. The Company failed to notify HEFPA. (Post 4/1/13)

1234 Trouble St, Albany - Records indicate that the heating facilities were disconnected on 11/8/13. The Company failed to notify HEFPA. (Post 4/1/13)

7 Henry-Johnson Blvd, Albany - Records indicate that the heating facilities were disconnected on 11/12/13. The Company failed to notify HEFPA. (Post 4/1/13)

3 Watervliet-Ave Ext, Albany - Records indicate that the heating facilities were disconnected on 11/16/13. The Company failed to notify HEFPA. (Post 4/1/13)

118 Winthrop Ave, Albany - Records indicate that the heating facilities were disconnected on 11/17/13. The Company failed to notify HEFPA. (Post 4/1/13)

167 3rd Ave, Albany - Records indicate that the heating facilities were disconnected on 11/20/13. The Company failed to notify HEFPA. (Post 4/1/13)

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27 Dowling Ave, Albany - Records indicate that the heating facilities were disconnected on 11/27/13. The Company failed to notify HEFPA. (Post 4/1/13)

47 Hollywood Ave, Albany - Records indicate that the heating facilities were disconnected on 12/2/13. The Company failed to notify HEFPA. (Post 4/1/13)

89 S Allen St, Albany - Records indicate that the heating facilities were disconnected on 12/3/13. The Company failed to notify HEFPA. (Post 4/1/13)

9 Locust Park, Albany - Records indicate that the heating facilities were disconnected on 12/30/13. The Company failed to notify HEFPA. (Post 4/1/13)

16 NYCRR Part 261.57(b)(3) - Warning Tag: Class A Condition - 1 Violation, 1 Occurrence

One violation of 261.57(b)(3), which states, “(b) Class A conditions include, but are not limited to:”…“(3) any venting system used to convey flue gases, that is defective, obstructed or inoperable.” The following is cited as an example where this requirement was not met:

MWork Order # 13982933 - 171 Quail St Fl 1, Albany - Records indicate that a

Class B Warning Tag was issued on 12/3/13. The “Plugged or Defective Vent” section states, “Yes.” The Company failed to accurately classify the Warning Tag. (Post 4/1/13)

Corporate - Capital and Northeast Record Audits Two violations of 16 NYCRR Part 255 and zero violations of 16 NYCRR Part 261 were noted. 16 NYCRR Part 255.465(e) - External corrosion control: Monitoring - 1 Violation, 1 Occurrence

One violation of 255.465(e), which states, “After the initial evaluation required by subdivisions (b) and (c) of section 255.455 and subdivision (b) of section 255.457, each operator shall, at intervals not exceeding 3 years, reevaluate its unprotected pipelines and cathodically protect them in accordance with this Part in areas in which active corrosion is found. The operator must determine the areas of active corrosion by electrical survey. However, on distribution lines and where an electrical survey is impractical on transmission lines, areas of active corrosion may be determined by other means that include review and analysis of leak repair and inspection records, corrosion monitoring records, exposed pipe inspection records, and the pipeline environment.”

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The following is cited as an example where this requirement was not met:

The Company could not provide documentation showing that this evaluation was performed. (Post 4/1/13)

16 NYCRR Part 255.605(i) – General Provisions - 1 Violation, 1 Occurrence

One violation of 255.605(i), which states, “Each operator shall include, as a minimum, the following in its operating and maintenance plan as applicable:”…“details of how an operator plans to comply with any requirement of this Part that is written in non-specific language. For example 255.805(b) of this Part states, "Each operator shall...establish a means by which it determines the appropriate surveillance interval at leak locations under frost conditions..." the details required by this subdivision would necessitate the operator to specify the established "means".” The following is cited as an example where this requirement was not met: National Grid GOPB 410, Inactive Gas Services, dated 7/14/2008, states,

“GROUP 2. All other Inactive service lines may remain for a period of not more than six years, provided there is a definite plan for future use. These services must be leakage surveyed and maintained according to all applicable procedures. If these services are not re- activated by the end of the fifth year of inactivity, they must be physically disconnected from the gas supply at the main or if the main is located under pavement service line may be disconnected in an unpaved area but no closer than 10 feet from the building by the end of the sixth year. These partial services shall be clearly noted on maps or records of gas distribution system.”

16 NYCRR Part 255.726 states, “All inactive service lines, including stubs, must be inspected, leakage surveyed and maintained according to the applicable provisions of this Part. Inactive steel service lines not under cathodic protection, including stubs, may remain under the conditions established by subdivision 255.727(d) for a period of not more than six years subject to the following conditions. During the third year of inactivity, the operator must conduct a survey for potential future use and, if there is no definite plan for future use, disconnect the service at the main or in compliance with subdivision 255.726(d), purge the service and seal the open end.”

The Company’s procedure does not provide sufficient detail on how to conduct and document the survey for potential use. (Post 4/1/13)

Glens Falls Record Audits

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Five violations of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261 were noted. 16 NYCRR Part 255.603(d) - General Provisions - 1 Violation, 5 Occurrences

One violation of 255.603(d), which states, “Each operator shall prepare and file a detailed written operating and maintenance plan.” “Each operator shall satisfactorily conform with the program submitted.” The following are cited as examples where this requirement was not met:

Retention Period of Forms

National Grid – Glens Falls failed to conform to National Grid GOPB 206, dated 2/15/11, which was the procedure in place at the time of the violation states, “Retention period of both forms is 6 years.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: Regulator Inspection Report # 13577533 - 162 Sherman Ave,

Queensbury - The Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report states, “Not Ok could not locate turned in GRO to gas op.” Staff requested a copy of the GRO on 6/25/14, but the Company could not produce one. The Company failed to retain the GRO.

Regulator Inspection Report # 13948176 - 2 Angel Lane, Queensbury - The Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report states, “Not Ok GRO for gas op.” Staff requested a copy of the GRO on 6/25/14, but the Company could not produce one. The Company failed to retain the GRO.

Service Regulator Inspection

National Grid – Glens Falls failed to conform to National Grid CMS06001, Inspecting High Pressure Service Regulating Equipment, Rev 2, dated 02/01/13, states, “Check for proper size and location of vent terminus.” (Post 4/1/13) The following is an example where National Grid’s procedure was not followed: Regulator Inspection Report # 210294 - 19 Jackson Ave, South

Glens Falls - Records from 1/4/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection

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box. The Company failed to conduct and/or document a vent inspection.

Leak Repair Identification

National Grid – Glens Falls failed to conform to National Grid GOPB 206, Leak, Maintenance, and Repair Records, dated 2/15/11 states, “A “Leak History Record” card (Example on page 11) is to be used as a supplement to the Gas Repair Order form.” (Post 4/1/13) The following is an example where National Grid’s procedure was not followed: GRO # 181608 - 46 William St, Glens Falls - Repairs were made

on 7/28/13. The Company failed to document the nature of the repair on the GRO.

Leak History Card

National Grid – Glens Falls failed to conform to National Grid GOPB 206, Leak, Maintenance, and Repair Records, dated 2/15/11 states, “A “Leak History Record” card (Example on page 11) is to be used as a supplement to the Gas Repair Order form.” The following is an example where National Grid’s procedure was not followed: GRO # 181847 - 86 Blvd, Queensbury - The Company identified a

leak in a curb box on 12/30/12. The Company failed to complete a leak history card with the GRO.

Gas Repair Order Form

National Grid – Glens Falls failed to conform to National Grid GOPB 206, Leak, Maintenance, and Repair Records, dated 2/15/11, the procedure in place at the time, states, “A Gas Repair Order (GRO) Form is also to be prepared when maintenance is required to correct conditions, other than gas leaks, on Company facilities that cannot be made at the time of discovery. See GAS REPAIR ORDER — MAINTENANCE below, for instructions related to completion of GRO's associated with Maintenance not related to gas leaks. When a GRO is prepared for maintenance, it shall be prioritized for repair as follows:”…“WITHIN 1 YEAR - Repairs of lesser importance that still require scheduling and completion date. This includes, but is not limited to: G. Heavy Corrosion.” (Post 4/1/13)

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The following is an example where National Grid’s procedure was not followed: GRS # 205 - Grant Ave, Glens Falls - The Company noted heavy

corrosion on the 10/2/12 gas regulator station inspection form. Staff requested a copy of the associated GRO, but the Company could not produce one. The Company failed to write a GRO for the heavy corrosion noted and to make repairs within 1 year.

16 NYCRR 261.53 - HEFPA - 1 Violation, 11 Occurrence

One violation of 261.53, which states, “Whenever the disconnection results in a customer being unable to use the heating facilities, the operator shall notify its Home Energy Fair Practices Act (HEFPA) liaison with local social services departments (section 11.5(c)(2)(v) of this Title).” The following are cited as examples where this requirement was not met:

35 Dix Ave, Glens Falls - Records indicate that heating facilities were

disconnected on 1/3/13. The Company failed to notify HEFPA.

1 Terrace Pl, Fort Edward - Records indicate that heating facilities were disconnected on 1/4/13. The Company failed to notify HEFPA.

105 Bay St, Glens Falls - Records indicate that heating facilities were disconnected on 1/16/13. The Company failed to notify HEFPA.

19 Raymond Ave, Glens Falls - Records indicate that heating facilities were disconnected on 2/7/13. The Company failed to notify HEFPA.

6 Wilson St, Queensbury - Records indicate that heating facilities were disconnected on 2/11/13. The Company failed to notify HEFPA.

71 Hunter St, Glens Falls - Records indicate that heating facilities were disconnected on 3/6/13. The Company failed to notify HEFPA.

16 Willow St, Glens Falls - Records indicate that heating facilities were disconnected on 3/6/13. The Company failed to notify HEFPA.

86 East St, Fort Edward - Records indicate that heating facilities were disconnected on 3/26/13. The Company failed to notify HEFPA.

30 Treasure Pl, Queensbury - Records indicate that heating facilities were disconnected on 3/28/13. The Company failed to notify HEFPA.

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26 W. Notre Dame St, Glens Falls - Records indicate that heating facilities were disconnected on 11/25/13. The Company failed to notify HEFPA. (Post 4/1/13)

28 Oak St, Hudson Falls - Records indicate that heating facilities were disconnected on 12/2/13. The Company failed to notify HEFPA. (Post 4/1/13)

16 NYCRR 261.57(b)(3) - Warning Tag: Class A Condition - 1 Violation, 1 Occurrence

One violation of 261.57(b)(3), which states, “(b) Class A conditions include, but are not limited to:” “(3) any venting system used to convey flue gases, that is defective, obstructed or inoperable.” The following is cited as an example where this requirement was not met:

MWork Order # 12244372 - 37 Orville St, Glens Falls - Records indicate that a

Class B Warning Tag was issued on 1/12/13. The “Plugged or Defective Vent” section states, “Yes.” The Company failed to accurately classify the Warning Tag.

Gloversville Record Audits Fifteen violations of 16 NYCRR Part 255 and three violations of 16 NYCRR Part 261 were noted. 16 NYCRR 255.603(d) - General Provisions - 1 Violation, 10 Occurrences

One violation of 255.603(d), which states, “Each operator shall prepare and file a detailed written operating and maintenance plan.” “Each operator shall satisfactorily conform with the program submitted.” The following are cited as examples where this requirement was not met:

Retention Period of Records

National Grid – Gloversville failed to conform to National Grid GDx 050001-PL, Rev 0, dated 12/15/10, which was the procedure in place at the time of the violation states, “Records of leak investigations, surveillance, and repairs shall be kept for a period of six (6) years.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed:

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GRO # 28598 - Clizbe Ave, Amsterdam - The Company failed to

retain the leak history record, as of 6/26/14. (“Perm Filed” on 1/23/13. No GRO, leak history card or sketch).

GRO # 79806 - 73 Barclay Rd, Canajoharie - The Company failed to retain the leak history record, as of 6/26/14. (“Perm Filed” on 1/18/13. No leak history card or sketch).

GRO # 163922 - 519 N. Perry St, Johnstown - The Company failed

to retain the leak history record, as of 6/26/14. (“Perm Filed” on 6/24/13. No sketch).

GRO # 163935 - 75 Newman St, Gloversville - The Company

failed to retain the leak history record, as of 6/26/14. (“Perm Filed” on 1/28/13. No GRO, leak history card or sketch).

GRO # 121098 - 180 Fifth Ave, Gloversville - The Company

failed to retain the leak history record, as of 6/26/14. (“Perm Filed” on 5/14/13. No GRO, leak history card or sketch).

GRO # 182761 - 78 Wesleyan Ave, Amsterdam - The Company

failed to retain the leak history record, as of 6/26/14. (“Perm Filed” on 2/6/13. No GRO, leak history card or sketch).

GRO # 14619 - Auto Palace V-347, Johnstown - The Company

failed to retain the leak history record, as of 6/26/14. (“Perm Filed” on 5/14/13. No GRO, leak history card or sketch).

Annual Regulator Inspection for Correct Pressure

National Grid – Gloversville failed to conform to National Grid Regulator Station Annual Inspection Policy 060026-PL, Rev 1, dated 4/15/12, states, “This document covers regulator station inspections and includes, pressure regulators, relief devices, principal station valves, filters, meters, vaults, buildings, and associated equipment. The purpose of these inspections and tests is to determine whether the equipment is: Set to function at the correct operating and relief pressures.” (Post 4/1/13) The following is an example where National Grid’s procedure was not followed: GRS # 816 - Bush Rd, Johnstown - The Company conducted an

annual inspection of its gas regulator station on 8/9/12. At that time, the station was set to operate at 46 psig, but the MAOP is 45 psig. The Company failed to set at the correct pressure.

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Annual Regulator Inspection

National Grid – Gloversville failed to conform to National Grid Regulator Station Annual Inspection Policy INR03002, Rev 1, dated 6/1/13, states, “In New York, all instruments used for telemeter or for recording pressures shall be operated, inspected, and tested, at least annually in accordance with the manufacturer’s recommendations. Any abnormal pressure reading shall immediately be reported to the appropriate regional supervisory personnel.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: East State EOL (End of Line) Pressure Recording Gauge - The

Company tested the recording gauge on 8/13/12 and did not test it again until 11/27/13. The Company failed to test at intervals not exceeding 15 months.

Lafayette EOL (End of Line) Pressure Recording Gauge - The Company tested the recording gauge on 7/16/12 and did not test it again until 11/26/13. The Company failed to test at intervals not exceeding 15 months.

Phelps EOL (End of Line) Pressure Recording Gauge - The

Company tested the recording gauge on 8/13/12 and did not test it again until 11/27/13. The Company failed to test at intervals not exceeding 15 months.

Annual Regulator Inspection Vent Inspection

National Grid – Gloversville failed to conform to National Grid CMS06001, Inspecting High Pressure Service Regulating Equipment, Rev 2, dated 02/01/13, states, “Check for proper size and location of vent terminus.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: Regulator Inspection Report # 13086653 - 22 River St, Fl 3, Fort

Plain - Records from 6/30/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection.

Regulator Inspection Report # 14080411 - 281 Market St, Amsterdam - Records from 12/18/13 indicate “No” for the

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“Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection.

Annual Regulator Inspection Corrective Action

National Grid – Gloversville failed to conform to National Grid CMS06001, Rev 2, dated 2/1/13 states, “If the installation does not pass inspection: Corrective action shall be taken, or: A follow up order shall be given to the appropriate CMS or Operations and Construct area, or: The appropriate Warning Tag shall be issued.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: Regulator Inspection Report # 242935 - 208 Well St, Johnstown -

The Curb Valve/OS Riser, Key Fit, portion of the 2013 Regulator Inspection Report from 9/4/13 states, “Not Ok filled with dirt, could not see valve.” The Company failed to take and/or document corrective action.

Regulator Inspection Report # 245193 - 465 Guy Park Ave, Amsterdam - The Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report from 9/19/13 states, “Not Ok could not locate.” The Company failed to take and/or document corrective action.

Regulator Inspection Report # 13361726 - 444 Guy Park Ave,

Amsterdam - The Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report from 8/15/13 states, “Not Ok can’t find.” The Company failed to take and/or document corrective action.

Regulator Inspection Report # 13934028 - 11 4th Ave, Amsterdam

- The Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report from 11/15/13 states, “Not Ok.” The Company failed to take and/or document corrective action.

Class 1 Leak Repair Recheck

National Grid – Gloversville failed to conform to National Grid CNST02009, Rev 1, dated 6/1/13 states, “A recheck of a Class 1 leak shall be performed 14 to 30 days, after repairs have been made.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed:

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GRO # 113173 - 214 Division St, Amsterdam - Repairs were made on 6/24/13 and a reading of 2% gas was noted at barhole 2 after the repair. The Company failed to conduct a follow-up inspection at least 14 days after but within 30 days.

GRO # 079109 - 215 Division St, Amsterdam - Repairs were made on 6/24/13 and readings of 3% gas at barhole 3 and 2% gas at barhole 7 were noted after repair. The Company failed to conduct a follow-up inspection at least 14 days after but within 30 days.

Class 2A Leak Surveillance

National Grid – Gloversville failed to conform to National Grid CNST02009, Rev 1, dated 6/1/13, states, “Surveillance of a Class 2A leak shall be at intervals not to exceed 14 days until the source of the leak has been corrected, or reclassified.” (Post 4/1/13) The following is an example where National Grid’s procedure was not followed: GRO # 231739 - 324 Forest Ave, Amsterdam - The Company

identified a Type 2A leak on 8/6/13. On 8/26/13 the Company made repairs. The Company failed to maintain the leak under surveillance with a frequency not to exceed two weeks until repairs were made.

Type 2A Leak Classification

National Grid – Gloversville failed to conform to National Grid GDx 050001-PL, Rev 0, dated 12/15/10, which was the procedure in place at the time of the violation, requires gas in air readings of >1% to less than 4% in manholes, vaults, and catch basins be classified as a Type 2A leaks The following is an example where National Grid’s procedure was not followed: GRO # 189665 - 10 Eagle St, Gloversville - On 1/19/13, the

Company found 2% gas in a sewer manhole. The leak was classified as a Type 2 that day. The Company incorrectly classified the leak.

Gas Repair Order Form

National Grid – Gloversville failed to conform to National Grid GOPB 206, dated 2/15/11, the procedure in place at the time, states, “A Gas Repair Order (GRO) Form is also to be prepared when maintenance is

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required to correct conditions, other than gas leaks, on Company facilities that cannot be made at the time of discovery. See GAS REPAIR ORDER — MAINTENANCE below, for instructions related to completion of GRO's associated with Maintenance not related to gas leaks. When a GRO is prepared for maintenance, it shall be prioritized for repair as follows:”…“WITHIN 1 YEAR - Repairs of lesser importance that still require scheduling and completion date. This includes, but is not limited to: E. Operable transmission line or Distribution-critical valves with non-critical repair items (valve is still operable) including missing and/or broken stops.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: GRS # 817 - Homestead, Amsterdam - The Company noted broken

valve stops on the 42 valve during the 10/31/13 gas regulator station inspection. Staff requested a copy of the associated GRO, but the Company could not produce one. The Company failed to write a GRO for the broken stops.

GRS # 903 - Wells, Gloversville - The Company wrote a GRO for broken valve stops (41 valve) on 10/7/11. The broken stops were noted again on the 9/11/13 gas regulator station inspection record. The Company failed to repair the broken stops within 1 year.

CGI Calibration Check

National Grid – Gloversville failed to conform to National Grid SHE01003, Using and Maintaining Portable Gas Monitors, Rev 1, dated 6/15/12, states, “CGIs, carbon monoxide analyzers, oxygen-deficiency analyzers, and multi-function instruments should have maintenance and calibration checks at least once every month in order to correct potential calibration drifts. These checks should be completed monthly, unless a particular instrument manufacturer indicates that a longer calibration frequency interval is acceptable; however, in no case shall the frequency of calibrations exceed three (3) months.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: CGI # 1243-303060 - Records show a gap in calibration from

10/28/12 to 4/9/13.

CGI # 1243-303065 - Records show a gap in calibration from 10/28/12 to 4/9/13.

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CGI # 1243-303068 - Records show a gap in calibration from 10/28/12 to 4/9/13.

CGI # 1243-303077 - Records show gaps in calibration from

10/28/12 to 4/9/13 and 7/5/13 to 11/7/13.

CGI # 1243-303036 - Records show a gap in calibration from 11/15/12 to 4/9/13.

16 NYCRR 255.619(a) - Maximum Allowable Operating Pressure: Steel or Plastic Pipelines - 1 Violation, 1 Occurrence

One violation of 255.619(a), which states, “Except as provided in subdivision (c) of this section, no person may operate a segment of steel or plastic pipeline at a pressure that exceeds” the pre-determined MAOP. The following is cited as an example where this requirement was not met:

GRS # 816 - Bush Rd, Johnstown - The Company conducted an annual

inspection of its gas regulator station on 8/9/12. At that time, the station was set to operate at 46 psig, but the MAOP was 45 psig. Due to the incorrect set pressure, the station periodically operated above the pre-determined MAOP (depending on demand and load) for several months afterwards. The Company lowered the station pressure in April of 2013 following the Company’s implementation of its new MAOP/set pressure policy. (Post 4/1/13)

16 NYCRR 255.739(a)(3) - Pressure limiting and regulating stations: Inspection and testing - 1 Violation, 1 Occurrence

One violation of 255.739(a)(3), which states, “Each pressure limiting station, relief device (except rupture discs), and pressure regulating station and its equipment must be subjected, at intervals not exceeding 15 months, but at least once each calendar year, to inspections and tests to determine that: (3) except as provided in subdivision (b) of this section, it is set to function at the correct pressure consistent with the pressure limits of section 255.201(b) of this Part.” The following is cited as an example where this requirement was not met:

GRS 816 - Bush Rd, Johnstown - The Company conducted an annual

inspection of its gas regulator station on 8/9/12. At that time, the station was set to operate at 46 psig, but the MAOP is 45 psig. The Company failed to set at the correct pressure. (Post 4/1/13)

16 NYCRR 255.809(b) - Leaks: Instrument sensitivity verification - 1 Violation, 5 Occurrences

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One violation of 255.809(b), which states, “Each instrument utilized for leakage surveys and investigations must be tested against a known sample or in accordance with the manufacturer's recommended instructions as follows: (a) after any repair or replacement of parts other than normal maintenance; (b) once every three months for CGI's and solid state leak detection instruments and yearly for Hydrogen Flame Ionization (HFI) instruments; and (c) any time it is suspected that the calibration has changed.” The following are cited as examples where this requirement was not met:

CGI # 1243-303060 - Records show a gap in calibration from 10/28/12 to

4/9/13. (Post 4/1/13)

CGI # 1243-303065 - Records show a gap in calibration from 10/28/12 to 4/9/13. (Post 4/1/13)

CGI # 1243-303068 - Records show a gap in calibration from 10/28/12 to 4/9/13. (Post 4/1/13)

CGI # 1243-303077 - Records show gaps in calibration from 10/28/12 to 4/9/13 and 7/5/13 to 11/7/13. (Post 4/1/13)

CGI # 1243-303036 - Records show a gap in calibration from 11/15/12 to 4/9/13. (Post 4/1/13)

16 NYCRR 255.813(c) - Leaks: Type 2A classification - 1 Violation, 1 Occurrence

One violation of 255.813(c), which states, “Type 2A leaks shall be maintained under surveillance with a frequency not to exceed two weeks until repaired.” The following is cited as an example where this requirement was not met:

GRO # 231739 - 324 Forest Ave, Amsterdam - The Company identified a

Type 2A leak on 8/6/13. On 8/26/13 the Company made repairs. The Company failed to maintain the leak under surveillance with a frequency not to exceed two weeks until repairs were made. (Post 4/1/13)

16 NYCRR 255.819(a) - Leaks: Follow-up inspection - 1 Violation, 2 Occurrences

One violation of 255.819(a), which states, “Each operator shall, upon completing a Type 1, Type 2A or Type 2 leak repair to its underground facilities, conduct a follow-up inspection at least 14 days after but within 30 days of the repair to validate said repair.” The following are cited as examples where this requirement was not met:

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GRO # 113173 - 214 Division St, Amsterdam - Repairs were made on 6/24/13 and a reading of 2% gas was noted at barhole 2 after the repair. The Company failed to conduct a follow-up inspection at least 14 days after but within 30 days. (Post 4/1/13)

GRO # 079109 - 215 Division St, Amsterdam - Repairs were made on 6/24/13 and readings of 3% gas at barhole 3 and 2% gas at barhole 7 were noted after repair. The Company failed to conduct a follow-up inspection at least 14 days after but within 30 days. (Post 4/1/13)

16 NYCRR 261.53 - HEFPA - 1 Violation, 14 Occurrences

One violation of 261.53, which states, “Whenever the disconnection results in a customer being unable to use the heating facilities, the operator shall notify its Home Energy Fair Practices Act (HEFPA) liaison with local social services departments (section 11.5(c)(2)(v) of this Title).” The following are cited as examples where this requirement was not met:

7 Prospect, Gloversville - Records indicate that heating facilities were

disconnected on 1/2/13. The Company failed to notify HEFPA.

20 Oakland Ave, Gloversville - Records indicate that heating facilities were disconnected on 1/11/13. The Company failed to notify HEFPA.

2 Blood St, Amsterdam - Records indicate that heating facilities were disconnected on 1/13/13. The Company failed to notify HEFPA.

230 5th Ave Ext, Gloversville - Records indicate that heating facilities were disconnected on 2/11/13. The Company failed to notify HEFPA.

43 Lincoln Ave, Amsterdam - Records indicate that heating facilities were disconnected on 2/12/13. The Company failed to notify HEFPA.

231 N. Main St, Gloversville - Records indicate that heating facilities were disconnected on 2/15/13. The Company failed to notify HEFPA.

19 McDonnell St, Amsterdam - Records indicate that heating facilities were disconnected on 3/4/13. The Company failed to notify HEFPA.

300 Glebe St, Johnstown - Records indicate that heating facilities were disconnected on 3/27/13. The Company failed to notify HEFPA.

36 Stewart, Amsterdam - Records indicate that heating facilities were disconnected on 3/30/13. The Company failed to notify HEFPA.

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12 5th, Gloversville - Records indicate that heating facilities were disconnected on 4/2/13. The Company failed to notify HEFPA. (Post 4/1/13)

110 Bleeker, Gloversville - Records indicate that heating facilities were disconnected on 12/1/13. The Company failed to notify HEFPA. (Post 4/1/13)

60 2nd Ave, Gloversville - Records indicate that heating facilities were disconnected on 12/2/13. The Company failed to notify HEFPA. (Post 4/1/13)

136 Wallins Corners, Amsterdam - Records indicate that heating facilities were disconnected on 12/16/13. The Company failed to notify HEFPA. (Post 4/1/13)

70 3rd St, Gloversville - Records indicate that heating facilities were disconnected on 12/26/13. The Company failed to notify HEFPA. (Post 4/1/13)

16 NYCRR 261.57(b)(1) - Warning Tag: Class A Condition - 1 Violation, 1 Occurrence

One violation of 261.57(b)(1), which states, “(b) Class A conditions include, but are not limited to: (1) any leaking gas piping inside the building which cannot be stopped by temporary or permanent repair means.” The following is cited as an example where this requirement was not met:

MWork Order # 13462187 - 30 Carmichael St, Amsterdam - Records indicate

that a Class B Warning Tag was issued on 8/29/13. The “Leak - House Piping” section states, “Yes” and there is no indication of a temporary repair. The Company failed to accurately classify the Warning Tag. (Post 4/1/13)

Hudson Record Audits One violation of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were noted. 16 NYCRR 255.603(d) - General Provisions- 1 Violation, 1 Occurrence

One violation of 255.603(d), which states, “Each operator shall prepare and file a detailed written operating and maintenance plan.” “Each operator shall satisfactorily conform with the program submitted.” The following is cited as an example where this requirement was not met:

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Annual Regulator Inspection Vent Inspection

National Grid – Hudson failed to conform to National Grid CMS06001, Inspecting High Pressure Service Regulating Equipment, Rev 2, dated 02/01/13, states, “Check for proper size and location of vent terminus.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: Regulator Inspection Report # 12287890 - 816 Warren St, Hudson

Records from 1/25/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection.

Regulator Inspection Report # 12343222 - 345 Union St, Hudson Records from 2/28/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection.

Regulator Inspection Report # 12447091 - 555 State St, Hudson

Records from 3/4/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection.

Regulator Inspection Report # 12627582 - 36 N 3rd St, Hudson

Records from 4/3/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection.

16 NYCRR 261.53 - HEFPA liaison - 1 Violation, 1 Occurrence

One violation of 261.53, which states, “Whenever the disconnection results in a customer being unable to use the heating facilities, the operator shall notify its Home Energy Fair Practices Act (HEFPA) liaison with local social services departments (section 11.5(c)(2)(v) of this Title).” The following is cited as an example where this requirement was not met:

42 Parkwood Blvd, Hudson - Records indicate that the heating facilities were

disconnected on 3/19/13. The Company failed to notify HEFPA.

Saratoga Record Audits

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Seven violations of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261 were noted. 16 NYCRR 255.603(d) - General Provisions - 1 Violation, 4 Occurrences

One violation of 255.603(d), which states, “Each operator shall prepare and file a detailed written operating and maintenance plan.” “Each operator shall satisfactorily conform with the program submitted.” The following are cited as examples where this requirement was not met:

Annual Regulator Inspection Vent Inspection

National Grid – Saratoga failed to conform to National Grid CMS06001, Inspecting High Pressure Service Regulating Equipment, Rev 2, dated 02/01/13, states, “Check for proper size and location of vent terminus.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: Regulator Inspection Report # 12783064 - 139 Nelson Ave,

Saratoga - Records from 5/8/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection.

Regulator Inspection Report # 12612073 - 2560 State Route 9, Ballston Spa - Records from 4/1/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection.

Regulator Inspection Report # 12535040 - 1 Stonebreak Rd, Malta

- Records from 3/15/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection.

Regulator Inspection Report # 12535028 - 16 Stonebreak Rd,

Malta - Records from 3/15/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection.

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Regulator Inspection Report # 213577 - 110 Brookline Rd, Ballston Spa - Records from 1/29/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection.

Regulator Inspection Report # 12502767 - 11 Anyhow Ln,

Gansevoort - Records from 3/8/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection.

Regulator Inspection Report # 12279445 - 738 Route 9,

Gansevoort - Records from 1/21/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection.

Regulator Inspection Report # 13238482 - 60 Lake Ave, Saratoga -

Records from 7/26/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection.

Class 2A Leak Surveillance

National Grid – Saratoga failed to conform to National Grid CNST02009, Rev 1, dated 6/1/13 states, “Surveillance of a Class 2A leak shall be at intervals not to exceed 14 days until the source of the leak has been corrected, or reclassified.” (Post 4/1/13) The following is an example where National Grid’s procedure was not followed: GRO # 202464 - 186 Spring St, Saratoga - The Type 2A leak was

surveyed on 9/27/13 and did not get surveyed again until 10/14/13. The Company failed to maintain the leak under surveillance with a frequency not to exceed two weeks.

CGI Calibration Check

National Grid – Saratoga failed to conform to National Grid SHE01003, Using and Maintaining Portable Gas Monitors, Rev 1, dated 6/15/12, states, “CGIs, carbon monoxide analyzers, oxygen-deficiency analyzers, and multi-function instruments should have maintenance and calibration checks at least once every month in order to correct potential calibration drifts. These checks should be completed monthly, unless a particular

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instrument manufacturer indicates that a longer calibration frequency interval is acceptable; however, in no case shall the frequency of calibrations exceed three (3) months.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: CGI # 1243-303046 - Records show a gap in calibration from

10/28/12 to 4/9/13.

CGI # 1243-303049 - Records show a gap in calibration from 10/28/12 to 4/9/13.

CGI # 1243-303050 - Records show a gap in calibration from

10/28/12 to 4/9/13.

CGI # 1243-303051 - Records show gaps in calibration from 10/28/12 to 4/9/13 and 7/5/13 to 11/7/13.

Building of Public Assembly Inspections

National Grid – Saratoga failed to conform to National Grid CNST02003, Building of Public Assembly Inspection, Rev 1, dated 2/1/13, states, “If the curb valve is not visible or accessible, a curb valve repair ticket must be completed. The repair ticket should be addressed within 90 days.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: GRO # 157847 - Hamilton St, Saratoga - Records indicate that the

Company attempted to inspect this public building valve on 2/26/13. The record also states, “No” for accessibility and key alignment. GRO 157847 was written that same day. On 1/29/14, almost a year later, the Company made repairs. The ticket should have been addressed within 90 days.

GRO # 157848 - 22 Whitney Pl, Saratoga - Records indicate that the Company attempted to inspect this public building valve on 3/4/13. The record also states, “No” for accessibility and key alignment. GRO 157848 was written that same day. On 6/19/13, more than 90 days later, the Company made repairs. The ticket should have been addressed within 90 days.

16 NYCRR 255.757(a) - Replacement of Cast Iron Mains Paralleling Excavations - 1 Violation, 1 Occurrence

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One violation of 255.757(a), which states, “(a) If an excavation is made parallel to any cast iron gas main, eight inches or less in nominal diameter, and said excavation is not adequately shored to protect the cast iron main against movement, the cast iron main must be replaced where more than half the pipe diameter lies above a line projected at an angle above the horizontal equal to the angle of repose for the soil conditions being encountered, starting from the bottom of the excavation at the side nearest the main.” The following is cited as an example where this requirement was not met:

DSNY Ticket # 725322206000 - Front St @ Low St, Ballston Spa - Premier’s

Cast Iron Report, dated 7/25/13, states, “4" cast iron gas main is 2' from the premarked work area and is paralleling the premarked work area for a length of 7'. Cast iron replacement.” Staff questioned the Company about the main and the local supervisor stated that it was never encroached. Staff also requested documentation to verify the disposition, but it could not be provided by the Company. (Post 4/1/13)

16 NYCRR 255.809(b) - Leaks: Instrument sensitivity verification - 1 Violation, 4 Occurrences

One violation of 255.809(b), which states, “Each instrument utilized for leakage surveys and investigations must be tested against a known sample or in accordance with the manufacturer's recommended instructions as follows: (a) after any repair or replacement of parts other than normal maintenance; (b) once every three months for CGI's and solid state leak detection instruments and yearly for Hydrogen Flame Ionization (HFI) instruments; and (c) any time it is suspected that the calibration has changed.” The following are cited as examples where this requirement was not met:

CGI # 1243-303046 - Records show a gap in calibration from 10/28/12 to

4/9/13. (Post 4/1/13)

CGI # 1243-303049 - Records show a gap in calibration from 10/28/12 to 4/9/13. (Post 4/1/13)

CGI # 1243-303050 - Records show a gap in calibration from 10/28/12 to 4/9/13. (Post 4/1/13)

CGI # 1243-303051 - Records show gaps in calibration from 10/28/12 to 4/9/13 and 7/5/13 to 11/7/13. (Post 4/1/13)

16 NYCRR 255.813(c) - Leaks: Type 2A classification - 1 Violation, 1 Occurrence

One violation of 255.813(c), which states, “Type 2A leaks shall be maintained under surveillance with a frequency not to exceed two weeks until repaired.”

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The following is cited as an example where this requirement was not met:

GRO # 202464 - 186 Spring St, Saratoga - The Type 2A leak was surveyed on

9/27/13 and did not get surveyed again until 10/14/13. The Company failed to maintain the leak under surveillance with a frequency not to exceed two weeks. (Post 4/1/13)

16 NYCRR 261.53 - HEFPA - 1 Violation, 9 Occurrences

One violation of 261.53, which states, “Whenever the disconnection results in a customer being unable to use the heating facilities, the operator shall notify its Home Energy Fair Practices Act (HEFPA) liaison with local social services departments (section 11.5(c)(2)(v) of this Title).” The following are cited as examples where this requirement was not met:

1 Spring St, Schuylerville - Records indicate that heating facilities were

disconnected on 1/20/13. The Company failed to notify HEFPA.

26 Albany Ave, Round Lake - Records indicate that heating facilities were disconnected on 2/7/13. The Company failed to notify HEFPA.

96 Quevic Dr, Saratoga - Records indicate that heating facilities were disconnected on 2/17/13. The Company failed to notify HEFPA.

1234 Trouble St, Saratoga - Records indicate that heating facilities were disconnected on 2/19/13. The Company failed to notify HEFPA.

8 Quiet - Harbor Dr, Saratoga - Records indicate that heating facilities were disconnected on 2/23/13. The Company failed to notify HEFPA.

17 Clarks Mills, Greenwich - Records indicate that heating facilities were disconnected on 1/14/13. The Company failed to notify HEFPA.

1234 Trouble St, Saratoga - Records indicate that heating facilities were disconnected on 2/19/13. The Company failed to notify HEFPA.

8 Hillcrest Ln, Saratoga - Records indicate that heating facilities were disconnected on 11/18/13. The Company failed to notify HEFPA. (Post 4/1/13)

22 Hearthstone Dr, Ganesvoort - Records indicate that heating facilities were disconnected on 11/21/13. The Company failed to notify HEFPA. (Post 4/1/13)

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16 NYCRR 261.57(b)(1) - Warning Tag: Class A Condition - 1 Violation, 5 Occurrences

One violation of 261.57(b)(1), which states, “(b) Class A conditions include, but are not limited to: (1) any leaking gas piping inside the building which cannot be stopped by temporary or permanent repair means.” The following are cited as examples where this requirement was not met:

MWork Order # 12230501 - 2453 Saratoga-Albany Rd, Ballston Spa - Records

indicate that a Class B Warning Tag was issued on 1/9/13. The “Leak - House Piping” section states, “Yes” and there is no indication of a temporary repair. The Company failed to accurately classify the Warning Tag.

MWork Order # 12874506 - 118 Deer-Run Dr, Ballston Spa - Records indicate that a Class B Warning Tag was issued on 5/21/13. The “Leak - House Piping” section states, “Yes” and there is no indication of a temporary repair. The Company failed to accurately classify the Warning Tag. (Post 4/1/13)

MWork Order # 13012300 - 16 Snowberry Rd, Ballston Spa - Records indicate that a Class B Warning Tag was issued on 6/14/13. The “Leak - House Piping” section states, “Yes” and there is no indication of a temporary repair. The Company failed to accurately classify the Warning Tag. (Post 4/1/13)

MWork Order # 13143507 - 65 Pepperbush Pl, Ballston Spa - Records indicate that a Class B Warning Tag was issued on 7/10/13. The “Leak - House Piping” section states, “Yes” and there is no indication of a temporary repair. The Company failed to accurately classify the Warning Tag. (Post 4/1/13)

MWork Order # 12706144 - 641 Colebrook Rd, Gansevoort - Records indicate that a Class C Warning Tag was issued on 4/19/13. The “Leak - House Piping” section states, “Yes” and there is no indication of a temporary repair. The Company failed to accurately classify the Warning Tag. (Post 4/1/13)

Schenectady Record Audits Four violations of 16 NYCRR Part 255 and three violations of 16 NYCRR Part 261 were noted. 16 NYCRR 255.603(d) - General Provisions - 1 Violation, 2 Occurrences

One violation of 255.603(d), which states, “Each operator shall prepare and file a detailed written operating and maintenance plan.” “Each operator shall satisfactorily conform with the program submitted.”

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The following are cited as examples where this requirement was not met:

CGI Calibration Check

National Grid – Schenectady failed to conform to National Grid SHE01003, Using and Maintaining Portable Gas Monitors, Rev 1, dated 6/15/12, states, “CGIs, carbon monoxide analyzers, oxygen-deficiency analyzers, and multi-function instruments should have maintenance and calibration checks at least once every month in order to correct potential calibration drifts. These checks should be completed monthly, unless a particular instrument manufacturer indicates that a longer calibration frequency interval is acceptable; however, in no case shall the frequency of calibrations exceed three (3) months.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: CGI # 1243-303073 - Records show a gap in calibration from

10/28/12 to 4/9/13.

CGI # 1315-303251 - Records show a gap in calibration from 1/1/13 to 4/15/13 and 6/7/13 to 12/31/13.

CGI # 1243-303071 - Records show a gap in calibration from

1/1/13 to 7/3/13. Class 2A Leak Surveillance

National Grid – Schenectady failed to conform to National Grid CNST02009, Classifying Gas Leaks, Rev 1, dated 06/01/13, states, “Surveillance: Surveillance of a Class 2A leak shall be at intervals not to exceed 14 days until the source of the leak has been corrected, or reclassified.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: GRO # 218096 - 104 Irving St, Schenectady - This Type 1 leak

history record shows 20% gas within 20 feet of a building, in a paved area, in an after repair reading on 10/3/13. This leak was not surveyed again until 10/28/13. The Company failed to survey a leak with Type 2A readings within two weeks.

GRO # 162158 - 54 Haigh Ave, Schenectady - This Type 2A leak history record shows 40% gas at 17 feet from a building, in an

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unpaved area on 10/26/12. This leak was not surveyed again until 11/20/12. The Company failed to survey a leak with Type 2A readings within two weeks.

GRO # 229238 - 361 Georgetta Dix, Schenectady - This Type 2A

leak history record shows 28% gas within 20 feet of a building, in an unpaved area on 8/12/13. This leak was not surveyed again until 8/28/13. The Company failed to survey a leak with Type 2A readings within two weeks.

16 NYCRR 255.809(b) - Leaks: Instrument sensitivity verification - 1 Violation, 3 Occurrences

One violation of 255.809(b), which states, “Each instrument utilized for leakage surveys and investigations must be tested against a known sample or in accordance with the manufacturer's recommended instructions as follows: (a) after any repair or replacement of parts other than normal maintenance; (b) once every three months for CGI's and solid state leak detection instruments and yearly for Hydrogen Flame Ionization (HFI) instruments; and (c) any time it is suspected that the calibration has changed.” The following are cited as examples where this requirement was not met:

CGI # 1243-303073 - Records show a gap in calibration from 10/28/12 to

4/9/13. (Post 4/1/13)

CGI # 1315-303251 - Records show a gap in calibration from 1/1/13 to 4/15/13 and 6/7/13 to 12/31/13. (Post 4/1/13)

CGI # 1243-303071 - Records show a gap in calibration from 1/1/13 to 7/3/13. (Post 4/1/13)

16 NYCRR 255.813(c) - Leaks: Type 2A classification - 1 Violation, 3 Occurrences

One violation of 255.813(c) which states, “Type 2A leaks shall be maintained under surveillance with a frequency not to exceed two weeks until repaired.” 255.813(d)(2) states, “Type 2A leaks include, but are not limited to: any reading, in an unpaved area, of 20 percent or greater gas-in-air which is more than 5 feet (1.5 meters) but within 20 feet (6.1 meters) of the building and inside the curb or shoulder of the road.” The following are cited as examples where this requirement was not met:

GRO # 218096 - 104 Irving St, Schenectady - This Type 1 leak history record

shows 20% gas within 20 feet of a building, in a paved area, in an after repair reading on 10/3/13. This leak was not surveyed again until 10/28/13. The

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Company failed to survey a leak with Type 2A readings within two weeks. (Post 4/1/13)

GRO # 162158 - 54 Haigh Ave, Schenectady - This Type 2A leak history record shows 40% gas at 17 feet from a building, in an unpaved area on 10/26/12. This leak was not surveyed again until 11/20/12. The Company failed to survey a leak with Type 2A readings within two weeks.

GRO # 229238 - 361 Georgetta Dix, Schenectady - This Type 2A leak history record shows 28% gas within 20 feet of a building, in an unpaved area on 8/12/13. This leak was not surveyed again until 8/28/13. The Company failed to survey a leak with Type 2A readings within two weeks. (Post 4/1/13)

16 NYCRR 261.53 - HEFPA liaison - 1 Violation, 16 Occurrences

One violation of 261.53, which states, “Whenever the disconnection results in a customer being unable to use the heating facilities, the operator shall notify its Home Energy Fair Practices Act (HEFPA) liaison with local social services departments (section 11.5(c)(2)(v) of this Title).” The following are cited as examples where this requirement was not met:

1066 Howard St, Schenectady - Records indicate that the heating facilities were

disconnected on 1/22/13. The Company failed to notify HEFPA.

1066 Howard St, Schenectady - Records indicate that the heating facilities were disconnected on 1/24/13. The Company failed to notify HEFPA.

1068 Howard St, Schenectady - Records indicate that the heating facilities were disconnected on 1/24/13. The Company failed to notify HEFPA.

3551 Guilderland Ave, Schenectady - Records indicate that the heating facilities were disconnected on 1/26/13. The Company failed to notify HEFPA.

913 Francis Ave, Schenectady - Records indicate that the heating facilities were disconnected on 1/29/13. The Company failed to notify HEFPA.

5 Dunning Ave, Albany - Records indicate that the heating facilities were disconnected on 2/3/13. The Company failed to notify HEFPA.

555 Nott St, Schenectady - Records indicate that the heating facilities were disconnected on 2/13/13. The Company failed to notify HEFPA.

617 Bluff Ave, Schenectady - Records indicate that the heating facilities were disconnected on 3/5/13. Records also indicate that a referral was sent on 3/4/13. There appears to be an issue with the records.

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2030 Euclid Ave, Schenectady - Records indicate that the heating facilities were disconnected on 11/4/13. The Company failed to notify HEFPA. (Post 4/1/13)

298 Michigan Ave, Schenectady - Records indicate that the heating facilities were disconnected on 11/4/13. The Company failed to notify HEFPA. (Post 4/1/13)

1141 Garner Ave, Schenectady - Records indicate that the heating facilities were disconnected on 11/22/13. The Company failed to notify HEFPA. (Post 4/1/13)

821 Oakwood Ave, Schenectady - Records indicate that the heating facilities were disconnected on 12/4/13. The Company failed to notify HEFPA. (Post 4/1/13)

3 Elbert St, Schenectady - Records indicate that the heating facilities were disconnected on 12/13/13. The Company failed to notify HEFPA. (Post 4/1/13)

13 Fenwick Ave, Schenectady - Records indicate that the heating facilities were disconnected on 12/14/13. The Company failed to notify HEFPA. (Post 4/1/13)

772 Hampshire-Seat, Schenectady - Records indicate that the heating facilities were disconnected on 12/17/13. The Company failed to notify HEFPA. (Post 4/1/13)

125 Donald Ave, Schenectady - Records indicate that the heating facilities were disconnected on 12/14/13. The Company failed to notify HEFPA. (Post 4/1/13)

16 NYCRR 261.57(b)(3) - Warning Tag: Class A Condition - 1 Violation, 2 Occurrences

One violation of 261.57(b)(3), which states, “(b) Class A conditions include, but are not limited to:” “(3) any venting system used to convey flue gases, that is defective, obstructed or inoperable.” The following are cited as examples where this requirement was not met:

MWork Order # 13759521 - 2316 Sheridan Ave, Schenectady - Records indicate

that a Class B Warning Tag was issued on 10/15/13. The “Plugged or Defective Vent” section states, “Yes,” and the Remarks section states, “found water heater vent not pitched correctly.” The Company failed to accurately classify the Warning Tag. (Post 4/1/13)

MWork Order # 14108916 - 756 State St, Schenectady - Records indicate that a Class B Warning Tag was issued on 12/28/13. The Remarks section states, “excessive co in flue pipe 700ppm in pipe needs cleaning and adjustments advised.” The Company failed to accurately classify the Warning Tag. (Post 4/1/13)

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16 NYCRR 261.59(c)(2) - Warning Tag: Class B Condition - 1 Violation, 1 Occurrence

One violation of 261.59(c)(2), which states, “(c) Class B conditions include, but are not limited to:” “(2) any gas appliance with a missing or inoperative required safety device.” The following is cited as an example where this requirement was not met:

MWork Order # 13568414 - 5 Princeton St, Schenectady - Records indicate that

a Class C Warning Tag was issued on 9/17/13. The Remarks section states, “Customer accidently broke off pilot tubing at the pilot assembly. Valve is 100% shut off. Gas off at appliance shut off. Replace tubing.” The Company failed to accurately classify the Warning Tag. (Post 4/1/13)

Syracuse Record Audits One violation of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261 were noted. 16 NYCRR Part 255.603(d) - General provisions – 1 Violation, 2 Occurrences

One violation of 255.603(d), which states that each operator shall satisfactorily conform to the program submitted. The following are cited as examples where this requirement was not met:

Building of Public Assembly Inspections

National Grid – Syracuse failed to conform to National Grid Procedure CNST02003, which states that, “In New York State, BPA inspections / leakage surveys shall be completed annually, and at intervals not to exceed 15 months.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: The building designated as a public building requiring an annual

inspection located at 318 E. Fayette Street, Syracuse was not inspected as required in 2013

The building designated as a public building requiring an annual inspection located at 1228 Teall Street Syracuse failed the requirements for annual inspection by having the 2012 inspection

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conducted on 2/28/2012 and the 2013 inspection conducted on 6/17/2013 which is a period of 69 weeks.

The building designated as a public building requiring an annual inspection located at 65 Albany Street, Cazenovia failed the requirements for annual inspection by having eh 2012 inspection conducted on 3/27/2012 and the 2013 inspection conducted on 7/15/2013 which is a period of 68 weeks.

Service Regulator Inspection

National Grid – Syracuse failed to conform to National Grid Procedure CMS06001 Rev 2 section 5.1 which states that regulators shall be inspected in conjunction with a meter turn-on where the service has been inactive for more than two years. (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: No service regulator inspection record could be located for the

service regulator at 103 East Way in Camillus that was reactivated on 12/3/13 after being inactive since 10/5/11.

No service regulator inspection record could be located for the service regulator at 107 Center St. in Solvay that was reactivated on 12/5/13 after being inactive since 12/14/07.

No service regulator inspection record could be located for the service regulator at 108 Crestview Dr. in Syracuse that was reactivated on 1/22/13 after being inactive since 9/17/07.

No service regulator inspection record could be located for the service regulator at 110 Elk St. in Syracuse that was reactivated on 3/16/13 after being inactive since 2/27/04.

No service regulator inspection record could be located for the service regulator at 111 Pond Ln. in Syracuse that was reactivated on 12/5/13 after being inactive since 8/17/11.

No service regulator inspection record could be located for the service regulator at 116 Churchill Ave. in Syracuse that was reactivated on 10/11/13 after being inactive since 10/6/11.

No service regulator inspection record could be located for the service regulator at 144 Greenland Dr. in Syracuse that was reactivated on 8/22/13 after being inactive since 5/10/11.

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No service regulator inspection record could be located for the

service regulator at 159 Meredith Ave. in Nedrow that was reactivated on 7/18/13 after being inactive since 5/4/11.

No service regulator inspection record could be located for the service regulator at 1912 Teall Ave. in Syracuse that was reactivated on 12/16/13 after being inactive since 9/29/11.

No service regulator inspection record could be located for the service regulator at 198 Longview Ave. in Syracuse that was reactivated on 10/16/13 after being inactive since 3/22/11.

No service regulator inspection record could be located for the service regulator at 200 Mc Kenney Ave. in Syracuse that was reactivated on 7/11/13 after being inactive since 8/12/11.

No service regulator inspection record could be located for the service regulator at 210 Morton St. in Syracuse that was reactivated on 12/9/13 after being inactive since 10/3/11.

No service regulator inspection record could be located for the service regulator at 212 Dorwin Ave. in Syracuse that was reactivated on 6/13/13 after being inactive since 3/31/11.

No service regulator inspection record could be located for the service regulator at 2798 Cold Springs Rd. in Baldwinsville that was reactivated on 9/17/13 after being inactive since 4/6/11.

No service regulator inspection record could be located for the service regulator at 312 Hall Ave. in Solvay that was reactivated on 12/27/13 after being inactive since 11/3/11.

No service regulator inspection record could be located for the service regulator at 313 Bailey Rd. in North Syracuse that was reactivated on 12/18/13 after being inactive since 7/11/07.

No service regulator inspection record could be located for the service regulator at 334 1st St. in Solvay that was reactivated on 10/4/13 after being inactive since 6/17/11.

No service regulator inspection record could be located for the service regulator at 5529 Chateau Ln. in Clay that was reactivated on 6/10/13 after being inactive since 5/5/11.

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No service regulator inspection record could be located for the service regulator at 612 Wright Ave. in Syracuse that was reactivated on 10/3/13 after being inactive since 7/2/11.

No service regulator inspection record could be located for the service regulator at 7 Oriole Path in Liverpool that was reactivated on 12/20/13 after being inactive since 8/8/11.

16 NYCRR Part 261.53 - HEFPA liaison - 1 Violation, 17 Occurrences

One violation of 261.53, which states that whenever the disconnection results in a customer being unable to use the heating facilities, the operator shall notify its Home Energy Fair Practices Act (HEFPA) liaison with local social services departments (section 11.5(c)(2)(v) of this Title). The following are cited as examples where this requirement was not met:

A Class A warning tag was issued on 1/8/13 at 419 East Avenue in Minoa that

resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag was issued on 1/8/13 at 6256 Gulfstream Path in Cicero that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag was issued on 1/21/13 at 116 Chestnut Street in North Syracuse that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag was issued on 1/27/13 at 716 James Street in Syracuse

that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag was issued on 2/11/13 at 422 Garden-City Drive in Syracuse that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class B warning tag was issued on 3/9/13 at 411 Griffith Street in Syracuse that resulted in the customer being unable to use the heating facilities. The

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Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag was issued on 3/18/13 at 859 Lancaster Avenue in

Syracuse that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag was issued on 11/11/13 at 405 Sedgwich Drive in

Syracuse that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class B warning tag was issued on 11/11/13 at 325 DeWitt Street in

Syracuse that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 11/13/13 at 129 Sudbury Drive in

Liverpool that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 11/19/13 at 1021 Park Street in Syracuse

that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 11/22/13 at 3508 South Salina Street in Syracuse that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 11/29/13 at 404 West Ostrander Avenue in Syracuse that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

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A Class A warning tag was issued on 2/18/13 at 101 Piercefield Drive in Syracuse that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag was issued on 3/16/13 at 636 Catherine Street in Syracuse that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag was issued on 3/27/13 at 166 Palmer Avenue in Syracuse that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag was issued on 12/11/13 at 640 West Onondaga Street in Syracuse that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

16 NYCRR Part 261.57(b)(3) - Warning tag: Class A condition – 1 Violation, 4 Occurrence

One violation of 261.57(b)(3), which states that Class A conditions include, but are not limited to any venting system used to convey flue gases, that is defective, obstructed or inoperable. The following are cited as examples where this requirement was not met:

A Class B warning tag was issued on10/25/2013 at 705 Scarboro, Dr.,

Syracuse for a “Plugged chimney” which is a class A condition. (Post 4/1/13)

A Class B warning tag was issued on 9/6/2013 at 323 Kimber Road, Syracuse for a “chimney plugged causing the hot water heater and furnace to spill back into basement” which is a class A condition. (Post 4/1/13)

A Class B warning tag was issued on 11/19/2013 at 729 N. Alvord Street,

Syracuse - for a “cracked heat exchanger” which is a class A condition. (Post 4/1/13)

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A Class B warning tag was issued on 11/14/2013 at 127 Laurel Avenue, Liverpool for a “water heater with no flue pipe” which is a class A condition. (Post 4/1/13)

Troy Record Audits Nine violations of 16 NYCRR Part 255 and six violations of 16 NYCRR Part 261 were noted. 16 NYCRR 255.603(d) - General Provisions - 1 Violation, 1 Occurrence

One violation of 255.603(d) which states, “Each operator shall prepare and file a detailed written operating and maintenance plan.” “Each operator shall satisfactorily conform with the program submitted.” The following are cited as examples where this requirement was not met:

CGI Calibration Check

National Grid – Troy failed to conform to National Grid SHE01003, Using and Maintaining Portable Gas Monitors, Rev 1, dated 6/15/12, states, “CGIs, carbon monoxide analyzers, oxygen-deficiency analyzers, and multi-function instruments should have maintenance and calibration checks at least once every month in order to correct potential calibration drifts. These checks should be completed monthly, unless a particular instrument manufacturer indicates that a longer calibration frequency interval is acceptable; however, in no case shall the frequency of calibrations exceed three (3) months.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: CGI # 1243-303013 - Records show a gap in calibration from

10/28/12 to 4/9/13.

CGI # 1243-303042 - Records show a gap in calibration from 10/28/12 to 4/9/13.

CGI # 1243-303052 - Records show a gap in calibration from

10/28/12 to 4/9/13.

CGI # 1243-303057 - Records show a gap in calibration from 10/28/12 to 4/9/13.

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CGI # 1243-303063 - Records show a gap in calibration from 10/28/12 to 4/9/13.

CGI # 1243-303067 - Records show a gap in calibration from

10/28/12 to 4/9/13.

CGI # 1243-303048 - Records show a gap in calibration from 10/28/12 to 4/9/13.

Gas Repair Order Record

National Grid – Troy failed to conform to National Grid GOPB 206, Leak, Maintenance, and Repair Records, dated 2/15/11 states, “Initial and ALL subsequent repair efforts shall be identified.” The following is an example where National Grid’s procedure was not followed: GRO # 134844 - 30 Hendrix-Hudson Way, Clifton Park - This leak

history record shows that a repair was made on 3/7/13. The GRO shows no detail of the repair and there is no other documentation showing that a repair was performed. The Company failed to document the nature of the repair.

Type Leak 2A Classification

National Grid – Troy failed to conform to National Grid GDx 050001-PL, Rev 0, dated 12/15/10, which was the procedure in place at the time of the violation, Attachment 2: Leak Classification Guide - Massachusetts, New York State and Rhode Island, depicts that Type 2A leaks include gas readings greater than 10% gas, within 30 feet of a building, in a continuously paved area. The following is an example where National Grid’s procedure was not followed: GRO # 187135 - 13 Atlantic Ave, Wynantskill - On 2/14/13, this

leak history record shows 2% gas in a sewer at barhole 7. The leak was classified as a Type 2 leak. The Company failed to correctly classify the leak as a Type 2A.

Type Leak 2A Classification

National Grid – Troy failed to conform to National Grid GDx 050001-PL, Rev 0, dated 12/15/10, which was the procedure in place at the time of the violation, Attachment 2: Leak Classification Guide - Massachusetts, New York State and Rhode Island - Manholes, Vaults, and Catch Basins, the

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current procedure, depicts that Type 2A leaks include gas readings greater than 1% to less than 4% gas in manholes. The following is an example where National Grid’s procedure was not followed: GRO # 191619 - 1224 5th Ave, Watervliet - On 1/18/13, this leak

history record shows 10% gas within 30 feet of a building, in a paved area. The leak was classified as a Type 2 leak. The Company failed to correctly classify the leak as a Type 2A.

Type Leak 2 Classification

National Grid – Troy failed to conform to GDx 050001-PL, Rev 0, dated 12/15/10, which was the procedure in place at the time of the violation, Attachment 2: Leak Classification Guide - Massachusetts, New York State and Rhode Island, depicts that Type 2 leaks include gas readings less than 20% gas, within 20 feet of the building, in an unpaved area. The following is an example where National Grid’s procedure was not followed: GRO # 153759 - 517 3rd Ave, Troy - On 2/9/09, this leak history

record shows 35 LEL at 10 feet from a building, in an unpaved area. The leak was classified as a Type 3 leak. The Company failed to correctly classify the leak as a Type 2 leak.

Annual Regulator Inspection Vent Inspection

National Grid – Troy failed to conform to National Grid CMS06001, Inspecting High Pressure Service Regulating Equipment, Rev 2, dated 02/01/13, states, “Check for proper size and location of vent terminus.” (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: Regulator Inspection Report # 244065 - 263 Bloomingrove Dr,

Troy Records from 9/12/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection.

Regulator Inspection Report # 241917 - 30 Church Hill Rd, Waterford Records from 8/27/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection

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box. The Company failed to conduct and/or document a vent inspection.

Regulator Inspection Report # 13981567 - 7 David Dr, Cohoes

Records from 11/16/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection.

Regulator Inspection Report # 13787765 - 279 Old-Loudon Rd,

Latham Records from 10/18/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection.

16 NYCRR 255.809(b) - Leaks: Instrument sensitivity verification - 1 Violation, 7 Occurrences

One violation of 255.809(b), which states, “Each instrument utilized for leakage surveys and investigations must be tested against a known sample or in accordance with the manufacturer's recommended instructions as follows: (a) after any repair or replacement of parts other than normal maintenance; (b) once every three months for CGI's and solid state leak detection instruments and yearly for Hydrogen Flame Ionization (HFI) instruments; and (c) any time it is suspected that the calibration has changed.” The following are cited as examples where this requirement was not met:

CGI # 1243-303013 - Records show a gap in calibration from 10/28/12 to

4/9/13. (Post 4/1/13)

CGI # 1243-303042 - Records show a gap in calibration from 10/28/12 to 4/9/13. (Post 4/1/13)

CGI # 1243-303052 - Records show a gap in calibration from 10/28/12 to 4/9/13. (Post 4/1/13)

CGI # 1243-303057 - Records show a gap in calibration from 10/28/12 to 4/9/13. (Post 4/1/13)

CGI # 1243-303063 - Records show a gap in calibration from 10/28/12 to 4/9/13. (Post 4/1/13)

CGI # 1243-303067 - Records show a gap in calibration from 10/28/12 to 4/9/13. (Post 4/1/13)

CGI # 1243-303048 - Records show a gap in calibration from 10/28/12 to 4/9/13. (Post 4/1/13)

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16 NYCRR 255.813(d)(1) - Leaks: Type 2A classification - 1 Violation, 1 Occurrence

One violation of 255.813(d)(1) which states, “Type 2A leaks include, but are not limited to: any reading of 10 percent or greater gas-in-air in any area continuously paved from the curb to the building wall, which is more than five feet (1.5 meters) but within 30 feet (9.1 meters) of the building and inside the curbline or shoulder of the road.” The following is cited as an example where this requirement was not met:

GRO # 191619 - 1224 5th Ave, Watervliet - On 1/18/13, this leak history

record shows 10% gas within 30 feet of a building, in a continuously paved area. The leak was classified as a Type 2 leak. The Company failed to correctly classify the leak.

16 NYCRR 255.815(d)(1) - Leaks: Type 2 classification - 1 Violation, 1 Occurrence

One violation of 255.813(d)(1) which states, “Type 2 leaks include, but are not limited to: any reading less than 20 percent gas-in-air in any unpaved area which is more than five feet (1.5 meters) from but within 20 feet (6.1 meters) of a building and inside the curbline or shoulder of the road.” The following is cited as an example where this requirement was not met:

GRO # 153759 - 517 3rd Ave, Troy - On 2/9/09, this leak history record shows

35 LEL at 10 feet from a building, in an unpaved area. The leak was classified as a Type 3 leak. The Company failed to correctly classify the leak as a Type 2 leak.

16 NYCRR 261.53 - HEFPA liaison - 1 Violation, 16 Occurrences

One violation of 261.53, which states, “Whenever the disconnection results in a customer being unable to use the heating facilities, the operator shall notify its Home Energy Fair Practices Act (HEFPA) liaison with local social services departments (section 11.5(c)(2)(v) of this Title).” The following are cited as examples where this requirement was not met:

38 Craig St, Watervliet - Records indicate that the heating facilities were

disconnected on 1/3/13. The Company failed to notify HEFPA.

271 5th Ave, Troy - Records indicate that the heating facilities were disconnected on 1/9/13. The Company failed to notify HEFPA.

1 Irving Pl, Troy - Records indicate that the heating facilities were disconnected on 2/12/13. The Company failed to notify HEFPA.

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428 1st Ave, Watervliet - Records indicate that the heating facilities were disconnected on 2/17/13. The Company failed to notify HEFPA.

23 Central Ave, Troy - Records indicate that the heating facilities were disconnected on 3/31/13. The Company failed to notify HEFPA.

75 Jay St, Troy - Records indicate that the heating facilities were disconnected on 4/5/13. The Company failed to notify HEFPA. (Post 4/1/13)

178 Speigletown Rd, Troy - Records indicate that the heating facilities were disconnected on 11/1/13. The Company failed to notify HEFPA. (Post 4/1/13)

14 113th St, Troy - Records indicate that the heating facilities were disconnected on 11/2/13. The Company failed to notify HEFPA. (Post 4/1/13)

72 Saratoga Ave, Waterford - Records indicate that the heating facilities were disconnected on 11/7/13. The Company failed to notify HEFPA. (Post 4/1/13)

20 25th St, Troy - Records indicate that the heating facilities were disconnected on 12/1/13. The Company failed to notify HEFPA. (Post 4/1/13)

224 Remsen St, Cohoes - Records indicate that the heating facilities were disconnected on 12/12/13. The Company failed to notify HEFPA. (Post 4/1/13)

3 Fairfax St, Troy - Records indicate that the heating facilities were disconnected on 12/16/13. The Company failed to notify HEFPA. (Post 4/1/13)

86 Pinewoods Ave, Troy - Records indicate that the heating facilities were disconnected on 12/17/13. The Company failed to notify HEFPA. (Post 4/1/13)

6 Putnam St, Troy - Records indicate that the heating facilities were disconnected on 12/19/13. The Company failed to notify HEFPA. (Post 4/1/13)

793 4th Ave, Troy - Records indicate that the heating facilities were disconnected on 12/23/13. Records also indicate that a referral was sent on 2/20/13. There appears to be an issue with the records. (Post 4/1/13)

36 Stage Run, Waterford - Records indicate that the heating facilities were disconnected on 12/23/13. The Company failed to notify HEFPA. (Post 4/1/13)

16 NYCRR 261.57(b)(1) - Warning Tag: Class A Condition - 1 Violation, 1 Occurrence

One violation of 261.57(b)(1) which states, “(b) Class A conditions include, but are not limited to: (1) any leaking gas piping inside the building which cannot be stopped by temporary or permanent repair means.” The following is cited as an example where this requirement was not met:

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MWork Order # 13334879 - 15 Patton Rd, Troy - Records indicate that a

Class C Warning Tag was issued on 8/19/13. This tag clearly states, “Leak - House Piping Yes,” and that the cause for the tag was, “red tag at house pipe union.” There are no indications on the tag that a temporary repair was made. The Company failed to correctly classify this Warning Tag. (Post 4/1/13)

16 NYCRR 261.57(b)(3) - Warning Tag: Class A Condition - 1 Violation, 1 Occurrence

One violation of 261.57(b)(3) which states, “(b) Class A conditions include, but are not limited to: (3) any venting system used to convey flue gases, that is defective, obstructed or inoperable.” The following is cited as an example where this requirement was not met:

MWork Order # 13265069 - 1902 7th Ave Fl 1, Watervliet - Records indicate

that a Class C Warning Tag was issued on 8/2/13. This tag clearly states, “Plugged or Defective Vent Yes” for the water heater, and that the cause for the tag was, “Spill at vent, not venting properly.” There are no indications on the tag that a temporary repair was made. The Company failed to correctly classify this Warning Tag. (Post 4/1/13)

16 NYCRR 261.59(c)(1) - Warning Tag: Class B Condition - 1 Violation, 1 Occurrence

One violation of 261.59(c)(1), which states, “(c) Class B conditions include, but are not limited to: (1) any leaking gas appliance inside the building which cannot be stopped by temporary or permanent repair means.” The following is cited as an example where this requirement was not met:

MWork Order # 13320270 - 5 Blue-Creek Ln, Latham - Records indicate that

a Class C Warning Tag was issued on 8/7/13. This tag clearly states, “Leak At Appliance Yes” for the water heater. There are no indications on the tag that a temporary repair was made. The Company failed to correctly classify this Warning Tag. (Post 4/1/13)

16 NYCRR 261.59(c)(5) - Warning Tag: Class B Condition - 1 Violation, 1 Occurrence

One violation of 261.59(c)(5), which states, “(c) Class B conditions include, but are not limited to: (5) open flame burners too close to combustibles.” The following is cited as an example where this requirement was not met:

MWork Order # 12729756 - 382 3rd St Fl 1, Troy - Records indicate that a

Class C Warning Tag was issued on 4/24/13. This tag clearly states that the

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cause for the tag was, “fire at appl due to debris in and on range.” There are no indications on the tag that a temporary repair was made. The Company failed to correctly classify this Warning Tag. (Post 4/1/13)

16 NYCRR 261.59(c)(6) - Warning Tag: Class B Condition - 1 Violation, 1 Occurrence

One violation of 261.59(c)(6), which states, “(c) Class B conditions include, but are not limited to: (6) any unit other than a heating or hot water appliance having visual indications of improper combustion.” The following is cited as an example where this requirement was not met:

MWork Order # 12219515 - 1519 3rd Ave Fl 2, Watervliet - Records indicate

that a Class C Warning Tag was issued on 1/7/13. This tag clearly states that the cause for the tag was, “oven may be a little over gassed.” There are no indications on the tag that a temporary repair was made. The Company failed to correctly classify this Warning Tag.

Utica Record Audits Four violations of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were noted. 16 NYCRR Part 255.465(a) - External corrosion control: Monitoring – 1 Violation, 28 Occurrence

One violation of 255.465(a), which states pipe-to-soil electrical potential tests or other acceptable electrical tests shall be conducted over each pipeline 100 feet (30.5 meters) or longer that is under cathodic protection at least once each calendar year, but with intervals not exceeding 15 months, to determine whether the cathodic protection meets the requirements of section 255.463. These should also be conducted for pipelines shorter than 100 feet (30.5 meters). However, if tests at those intervals are impractical for separately protected short sections of mains or transmission lines, not in excess of 100 feet (30.5 meters), or separately protected service lines, these pipelines may be surveyed on a sampling basis. At least 10 percent of these protected structures, distributed over the entire system must be surveyed each calendar year, with a different 10 percent checked each subsequent year, so that the entire system is tested in each 10-year period. The following are cited as examples where this requirement was not met:

The isolated service located at 3466 Oneida Street (cha:oneida, TS 58) was

tested on 1/1/2001 and not again until 3/19/13. This exceeds the code allowed

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maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 6 Prospect Street (clm:prospect, TS 5) was tested on 1/1/2000 and not again until 2/27/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 15 Marvin Street (cli:marvin, TS 4) was tested

on 1/1/2000 and not again until 2/26/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 8026 Middle Road (flo:middle, TS 3) was

tested on 1/1/1995 and not again until 2/28/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 3692 RT 12b (kir:rte 12b, TS 7) was tested on 1/1/2000 and not again until 4/12/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company. (Post 4/1/13)

The isolated service located at 6341 Pillmore Drive (lee:pillmore, TS 2) was

tested on 1/1/1995 and not again until 2/28/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 8 Regency Road (new:regency, TS 6) was

tested on 1/1/1985 and not again until 3/19/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 35 Parkside Circle (nym:parkside, TS 4) was tested on 1/1/1994 and not again until 2/27/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 41 Parkside Circle (nym:parkside, TS 5) was

tested on 1/1/1994 and not again until 2/27/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 46 Parkside Circle (nym:parkside, TS 6) was

tested on 1/1/1994 and not again until 2/27/13. This exceeds the code allowed

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maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 512 Miller Street (ori:miller, TS 21) was tested

on 1/1/2001 and not again until 1/16/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 202 Ridge Road (ori:ridge, TS 2) was tested on

1/1/2001 and not again until 3/7/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 209 Lyndale Drive (rom:lyndale, TS 8) was

tested on 1/1/1995 and not again until 3/18/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at Building “G” Mustang Road (rom:mustang, TS 7) was tested on 1/1/1995 and not again until 3/14/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 454 Oakdale Avenue (uti:oakdale, TS 8) was

tested on 1/1/1990 and not again until 3/26/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 1623 Oneida Street (uti:oneida, TS 6) was tested on 1/1/2001 and not again until 3/28/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 2600 Oneida Street (uti:oneida, TS 13) was tested on 1/1/1990 and not again until 3/28/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 2821 Oneida Street (uti:oneida, TS 23) was

tested on 1/1/1990 and not again until 3/28/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 505 Parklane Drive (uti:parklane, TS 6) was

tested on 1/1/1989 and not again until 3/26/13. This exceeds the code allowed

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maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 508 Parklane Drive (uti:parklane, TS 9) was tested on 1/1/1989 and not again until 3/26/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 517 Parklane Drive (uti:parklane, TS 17) was

tested on 1/1/1989 and not again until 3/26/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 6 Patricia Court (uti:patricia, TS 3) was tested on 1/1/1989 and not again until 3/25/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 16 Olean Drive (wht:olean, TS 16) was tested on 1/1/1987 and not again until 3/8/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 1 Perimeter Road (wht:perimeter, TS 1) was

tested on 1/1/1994 and not again until 3/13/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 31 Perimeter Road (wht:perimeter, TS 13) was

tested on 1/1/1994 and not again until 3/13/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 8 Perimeter Road (wht:perimeter, TS 16) was tested on 1/1/1992 and not again until 5/4/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company. (Post 4/1/13)

The isolated service located at 12 Pillar Drive (wht:pillar, TS 2) was tested on 1/1/1992 and not again until 3/8/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 51 Meyers Avenue (yor:myers, TS 12) was

tested on 1/1/1992 and not again until 3/7/13. This exceeds the code allowed

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maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

16 NYCRR Part 255.603(d) - General provisions - 1 Violation, 5 Occurrences

One violation of 255.603(d), which states that each operator shall satisfactorily conform to the program submitted. The following are cited as examples where this requirement was not met:

Record Retention

National Grid – Utica failed to conform to National Grid Procedure GOPB 206, dated 12/15/10, which was the procedure in place at the time of the violation states: “Retention period of both forms is 6 years”. (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: Mwork order number 12656299: On the service regulator

inspection form for 2011 Genesee Street in Utica the Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report states “Not Ok curb box full of stones GRO 180152”. Staff requested a copy of the GRO, but the Company could not produce one. The Company failed to retain the GRO.

Mwork order number 12722963: On the service regulator inspection form for 25 Tindall Manor in Clinton the Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report states “Not Ok curb box under driveway GRO 180137”. Staff requested a copy of the GRO, but the Company could not produce one. The Company failed to retain the GRO.

Mwork order number 12723653: On the service regulator inspection form for 419 Richmond Road in Utica the Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report states “Not Ok full of dirt, wrote up GRO”. Staff requested a copy of the GRO, but the Company could not produce one. The Company failed to retain the GRO.

Mwork order number 12723517: On the service regulator inspection form for 9 Edna Terrace in New Hartford the Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report states “Not Ok cb under driveway GRO 180144”. Staff requested a copy of the GRO, but the Company could not produce one. The Company failed to retain the GRO.

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Corrosion Inspection

National Grid – Utica failed to conform to National Grid Procedure 040020– PL (rev 1)–Section 5 which states that isolated service inventory shall have at least 10 percent of these protected structures, distributed over the entire system surveyed each calendar year, with a different 10 percent checked each subsequent year, so that the entire system is tested in each 10-year period. (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: The isolated service located at 3466 Oneida Street (cha:oneida, TS

58) was tested on 1/1/2001 and not again until 3/19/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 6 Prospect Street (clm:prospect, TS 5) was tested on 1/1/2000 and not again until 2/27/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 15 Marvin Street (cli:marvin, TS 4) was tested on 1/1/2000 and not again until 2/26/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 8026 Middle Road (flo:middle, TS 3) was tested on 1/1/1995 and not again until 2/28/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 3692 RT 12b (kir:rte 12b, TS 7) was tested on 1/1/2000 and not again until 4/12/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 6341 Pillmore Drive (lee:pillmore, TS 2) was tested on 1/1/1995 and not again until 2/28/13. This exceeds the code allowed maximum interval of 10 years. This

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service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 8 Regency Road (new:regency, TS 6) was tested on 1/1/1985 and not again until 3/19/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 35 Parkside Circle (nym:parkside, TS 4) was tested on 1/1/1994 and not again until 2/27/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 41 Parkside Circle (nym:parkside, TS 5) was tested on 1/1/1994 and not again until 2/27/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 46 Parkside Circle (nym:parkside, TS 6) was tested on 1/1/1994 and not again until 2/27/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 512 Miller Street (ori:miller, TS 21) was tested on 1/1/2001 and not again until 1/16/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 202 Ridge Road (ori:ridge, TS 2) was tested on 1/1/2001 and not again until 3/7/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 209 Lyndale Drive (rom:lyndale, TS 8) was tested on 1/1/1995 and not again until 3/18/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

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The isolated service located at Building “G” Mustang Road (rom:mustang, TS 7) was tested on 1/1/1995 and not again until 3/14/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 454 Oakdale Avenue (uti:oakdale, TS 8) was tested on 1/1/1990 and not again until 3/26/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 1623 Oneida Street (uti:oneida, TS 6) was tested on 1/1/2001 and not again until 3/28/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 2600 Oneida Street (uti:oneida, TS 13) was tested on 1/1/1990 and not again until 3/28/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 2821 Oneida Street (uti:oneida, TS 23) was tested on 1/1/1990 and not again until 3/28/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 505 Parklane Drive (uti:parklane, TS 6) was tested on 1/1/1989 and not again until 3/26/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 508 Parklane Drive (uti:parklane, TS 9) was tested on 1/1/1989 and not again until 3/26/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 517 Parklane Drive (uti:parklane, TS 17) was tested on 1/1/1989 and not again until 3/26/13. This exceeds the code allowed maximum interval of 10 years. This

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service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 6 Patricia Court (uti:patricia, TS 3) was tested on 1/1/1989 and not again until 3/25/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 16 Olean Drive (wht:olean, TS 16) was tested on 1/1/1987 and not again until 3/8/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 1 Perimeter Road (wht:perimeter, TS 1) was tested on 1/1/1994 and not again until 3/13/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 31 Perimeter Road (wht:perimeter, TS 13) was tested on 1/1/1994 and not again until 3/13/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 8 Perimeter Road (wht:perimeter, TS 16) was tested on 1/1/1992 and not again until 5/4/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 12 Pillar Drive (wht:pillar, TS 2) was tested on 1/1/1992 and not again until 3/8/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

The isolated service located at 51 Meyers Avenue (yor:myers, TS 12) was tested on 1/1/1992 and not again until 3/7/13. This exceeds the code allowed maximum interval of 10 years. This service was included on the list of isolated and protected services that was provided by the Company.

Inactive Gas Services

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National Grid – Utica failed to conform to National Grid Procedure GOPB 410 Section (B)(3)(a) which states that all other service lines, including stubs, not under cathodic protection must be reviewed after two years of inactivity. (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: The inactive service located at 4360 Acme Road in the village of

Ilion became inactive on 2/19/10. No documentation was provided showing that the service was reviewed after two years of inactivity.

Service Regulator Inspection

National Grid – Utica failed to conform to National Grid Procedure CMS06001 Rev 2 section 5.1 which states that regulators shall be inspected in conjunction with a meter turn-on where the service has been inactive for more than two years. (Post 4/1/13) The following are examples where National Grid’s procedure was not followed:

No service regulator inspection record could be located for the service regulator at 108 Onondaga Avenue in Canastota that was reactivated on 8/23/13 after being inactive since 7/29/11.

No service regulator inspection record could be located for the

service regulator at 112 Bruno Road in Canastota that was reactivated on 11/22/13 after being inactive since 10/5/11.

No service regulator inspection record could be located for the

service regulator at 123 Seneca Street in Utica that was reactivated on 10/29/13 after being inactive since 3/24/11.

No service regulator inspection record could be located for the

service regulator at 1305 Maple Street in Utica that was reactivated on 10/2/13 after being inactive since 9/12/11.

No service regulator inspection record could be located for the

service regulator at 144 Bono Boulevard in Frankfort that was reactivated on 10/28/13 after being inactive since 10/24/11.

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No service regulator inspection record could be located for the service regulator at 203 Roberts Street in Canastota that was reactivated on 11/7/13 after being inactive since 7/5/11.

No service regulator inspection record could be located for the

service regulator at 2043 Genesee Street in Utica that was reactivated on 10/8/13 after being inactive since 8/15/11.

No service regulator inspection record could be located for the

service regulator at 2903 RT 12B in Deansboro that was reactivated on 6/25/13 after being inactive since 6/9/11.

No service regulator inspection record could be located for the

service regulator at 416 Race Street in Chittenango that was reactivated on 9/24/13 after being inactive since 6/27/11.

No service regulator inspection record could be located for the

service regulator at 423 West Dominick Street in Rome that was reactivated on 9/19/13 after being inactive since 2/17/09.

No service regulator inspection record could be located for the

service regulator at 507 ½ Floyd Avenue in Rome that was reactivated on 11/26/13 after being inactive since 5/25/11.

No service regulator inspection record could be located for the

service regulator at 5870 Columbus Drive in Marcy that was reactivated on 12/18/13 after being inactive since 4/19/10.

No service regulator inspection record could be located for the

service regulator at 613 2nd Avenue in Frankfort that was reactivated on 11/25/13 after being inactive since 7/18/11.

No service regulator inspection record could be located for the

service regulator at 75 Bedford Drive in Whitesboro that was reactivated on 11/5/13 after being inactive since 5/12/11.

No service regulator inspection record could be located for the

service regulator at 9647 River Drive in Marcy that was reactivated on 9/17/13 after being inactive since 8/25/11.

Outside Leak Report Diagram

National Grid– Utica failed to conform to National Grid Procedure CNST02009 – attachment 2 which shows that any reading less than 20% gas between 5’ and 20’ of the building wall is a Class 2 leak. (Post 4/1/13)

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The following are examples where National Grid’s procedure was not followed: GRO #228678 was issued on 5/28/13 at 601 Jay St., Utica for a

leaking cap on a service tee. The operator found 11 LEL 12 feet from a building, during a recheck made on 6/12/13. The leak was re-classified as a Type 3 leak on this date. This was not classified properly; it should have been reclassified to a Type 2 leak because the 11 LEL was within 20 feet a building.

GRO #216843 was issued on 8/22/12 at 4046 Bristol Rd., Kirkland

for an 8” STL dresser that was leaking. The initial investigation found 25% gas at barhole #3 at 40 feet from the building. During the surveillance on 7/23/13 a reading of 36% gas was found at barhole #3. This reading would have required the leak to be reclassified to a Type 2. There was no indication on the record that the leak was ever re-classified.

16 NYCRR Part 255.815(d)(2) - Leaks: Type 2 classification - 1 Violation, 1 Occurrence

One violation of 255.815(d)(2), which states that any reading less than 20 percent gas-in-air in any unpaved area which is more than five feet (1.5 meters) from but within 20 feet (6.1 meters) of a building and inside the curbline or shoulder of the road. The following is cited as an example where this requirement was not met:

GRO #228678 was issued on 5/28/13 at 601 Jay St., Utica for a leaking cap on

a service tee. The operator found 11 LEL 12 feet from a building, during a recheck made on 6/12/13. The leak was re-classified as a Type 3 leak on this date. This was not classified properly; it should have re classified to a Type 2 leak because the 11 LEL was within 20 feet a building. (Post 4/1/13)

16 NYCRR Part 255.815(d)(3) - Leaks: Type 2 classification - 1 Violation, 1 Occurrence

One violation of 255.815(d)(3), which states any reading of 30 percent or greater gas-in-air in an unpaved area which is more than 20 feet (6.1 meters) from but within 50 feet (15.2 meters) of a building and inside the curbline or shoulder of the road.

The following is cited as an example where this requirement was not met:

GRO #216843 was issued on 8/22/12 at 4046 Bristol Rd., Kirkland for an 8”

STL dresser that was leaking. The initial investigation found 25% gas at

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barhole #3 at 40 feet from the building. During the surveillance on 7/23/13 a reading of 36% gas was found at barhole #3. This reading would have required the leak to be reclassified to a Type 2. There was no indication on the record that the leak was ever re-classified. (Post 4/1/13)

16 NYCRR Part 261.53 - HEFPA liaison - 1 Violation, 27 Occurrences

One violation of 261.53, which states that whenever the disconnection results in a customer being unable to use the heating facilities, the operator shall notify its Home Energy Fair Practices Act (HEFPA) liaison with local social services departments (section 11.5(c)(2)(v) of this Title). The following are cited as examples where this requirement was not met:

A Class A warning tag was issued on 3/1/2013 at 228 West Main Street in

Frankfort that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class B warning tag was issued on 11/5/2013 at 5 Webster Street in Little Falls that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 11/5/2013 at 18 Fulmer Street in

Mohawk that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 1/4/2013 at 401 South James Street in

Rome that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag was issued on 1/7/2013 at 117 West Walnut Street in Oneida that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag was issued on 12/18/2013 at 7105 Herkimer Avenue in

Rome that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison

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with local social services departments was contacted as required. (Post 4/1/13)

A Class B warning tag was issued on 1/22/2013 at 1201 Kellogg Avenue in Utica that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag was issued on 2/18/2013 at 2 Beechwood Road in New

Hartford that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag was issued on 4/3/2013 at 8516 Westmoreland Road in

Whitesboro that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 4/14/2013 at 2405 Sunset Avenue in Utica that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class B warning tag was issued on 11/2/2013 at 306 Hillside Drive in Oriskany that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 11/3/2013 at 1207 Bleecker Street in Utica that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 11/4/2013 at 1414 Herkimer Road in Utica that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 11/5/2013 at 721 Plant Street in Utica

that resulted in the customer being unable to use the heating facilities. The

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Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 11/7/2013 at 511 Eagle Street in Utica

that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 11/8/2013 at 407 Nichols Street in Utica that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 11/12/2013 at 153 James Street in Utica

that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class B warning tag was issued on 11/12/2013 at 1002 Blandina Street in

Utica that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class B warning tag was issued on 11/12/2013 at 1130 Bleecker Street in Utica that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 11/27/2013 at 108 Thomas Street in Utica that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 11/27/2013 at 108 ½ Thomas Street in

Utica that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

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A Class A warning tag was issued on 12/10/2013 at 27 Kernan Avenue in Utica that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 12/10/2013 at 25 Kernan Avenue in Utica that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 12/12/2013 at 504 Arthur Street in Utica that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag was issued on 12/19/2013 at 151 Marnie Street in Utica that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class B warning tag was issued on 12/24/2013 at 3 Chestnut Road in New Hartford that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class B warning tag was issued on 12/31/2013 at 510 Albany Street in

Utica that resulted in the customer being unable to use the heating facilities. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

Volney Record Audits One violation of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were noted. 16 NYCRR Part 255.603(d) - General provisions - 1 Violation, 4 Occurrences

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One violation of 255.603(d), which states that each operator shall satisfactorily conform to the program submitted. The following are cited as examples where this requirement was not met:

Record Retention

National Grid – Utica failed to conform to National Grid Procedure GOPB 206, dated 12/15/10, which was the procedure in place at the time of the violation states: “Retention period of both forms is 6 years”. (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: GRO #165747 was issued for a Type 1 Leak on 7/24/13 at 28 Ellen

St. in Oswego. A Gas Repair Order and Leak History Record could not be produced for Staff review. Therefore, all details pertaining to this leak and follow-up are not adequately documented and unable to be reviewed. The Company failed to retain the GRO.

GRO#165748 was issued for a Type 1 Leak on 8/27/13 at 10 Prospect St. in Oswego. A Gas Repair Order and Leak History Record could not be produced for Staff review. Therefore, all details pertaining to this leak and follow-up are not adequately documented and unable to be reviewed. The Company failed to retain the GRO.

GRO#184659 was issued for a Type 2 Leak on 6/11/13 at 72 Park in Pulaski. A Gas Repair Order and Leak History Record could not be produced for Staff review. Therefore, all details pertaining to this leak and follow-up are not adequately documented and unable to be reviewed. The Company failed to retain the GRO.

Service Regulator Inspection

National Grid – Fulton failed to conform to National Grid Procedure CMS06001 Rev 2 section 5.1 which states that regulators shall be inspected at the time of a meter change and in conjunction with a meter turn-on where the service has been inactive for more than two years. (Post 4/1/13) The following are examples where National Grid’s procedure was not followed:

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The meter at 579 1/2 S. 1st. St. in Fulton was a scheduled meter change on 1/22/2013. No service regulator inspection record could be located

The meter at 220 Seneca St. in Fulton was a scheduled meter

change on 6/28/2013. No service regulator inspection record could be located

The meter at 156 S. 3rd St. in Fulton was a scheduled meter change on 12/3/2013. No service regulator inspection record could be located

The meter at 223 W. Seneca St. in Fulton was a scheduled meter change on 9/16/2013. No service regulator inspection record could be located.

No service regulator inspection record could be located for the service at 422 S. 3rd St. in Fulton that was reactivated on 9/23/13 after two years of inactivity (service terminated on 4/27/11).

No service regulator inspection record could be located for the service at 9477 Oswego Rd. in Phoenix that was reactivated on 10/2/13 after two years of inactivity (service terminated on 6/27/11).

Service Valve Inspection

National Grid – Fulton failed to conform to National Grid Procedure CMS06001 Rev 2 section 5.1 which states that the curb valves on high pressure services shall be inspected at the time of the regulator inspection. (Post 4/1/13) The following is an example where National Grid’s procedure was not followed: The meter at 463 W. 4th St. S in Fulton was a scheduled meter

change on 10/302013. An MWork Regulator Inspection Report was produced for the service regulator, vent and valve inspections to be performed at the time of meter change, however it is indicated that no inspection was done on the curb valve as the valve could not be located.

Service Valve Inspection

National Grid – Fulton failed to conform to National Grid Procedure CMS06001 Rev 2 which states if the installation does not pass inspection

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corrective action shall be taken, or a follow up order shall be given to the appropriate CMS or Operations and Construct area. (Post 4/1/13)

The following is an example where National Grid’s procedure was not followed: The meter at 463 W. 4th St. S in Fulton was a scheduled meter

change on 10/302013. An MWork Regulator Inspection Report was produced for the service regulator, vent and valve inspections to be performed at the time of meter change, however it is indicated that no inspection was done on the curb valve as the valve could not be located. It was not indicated on the inspection record that a follow up order was given to the appropriate CMS or Operations and Construct area.

16 NYCRR Part 261.53 - HEFPA liaison - 1 Violation, 5 Occurrences

One violation of 261.53, which states that whenever the disconnection results in a customer being unable to use the heating facilities, the operator shall notify its Home Energy Fair Practices Act (HEFPA) liaison with local social services departments (section 11.5(c)(2)(v) of this Title). The following are cited as examples where this requirement was not met:

A Class A warning tag (MWork Order Number 12317193) was issued on

1/29/2013 at 83 Ridgeway-Sites Ave. in Oswego. The warning tag was issued for a plugged heat exchanger and the appliance was isolated. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag (MWork Order Number 12408251) was issued on 2/18/2013 at 74 W Cayuga St. in Oswego. The warning tag was issued for rusted flue pipe on the furnace and the appliance was isolated. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag (MWork Order Number 12463053) was issued on 2/28/2013 at 187 Ellen St. in Oswego. The warning tag was issued for a hole in the heat exchanger and the appliance was isolated The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag (MWork Order Number 12555558) was issued on 3/20/2013 at 613 S 4th St. in Fulton. The warning tag was issued for a boiler with flame rollout and the appliance was isolated. The Company was unable

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to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag (MWork Order Number 14082037) was issued on 12/19/2013 at 144 E 3rd St. in Oswego. The warning tag was issued for the furnace not venting and the appliance was isolated. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

Watertown Record Audits Two violations of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261 were noted. 16 NYCRR Part 255.603(d) - General provisions - 1 Violation, 4 Occurrences

One violation of 255.603(d), which states that each operator shall satisfactorily conform to the program submitted. The following are cited as examples where this requirement was not met:

Service Regulator Inspection

National Grid – Watertown failed to conform to National Grid Procedure CMS06001 Rev 2 section 5.1 which states that regulators shall be inspected at the time of a meter change and in conjunction with a meter turn-on where the service has been inactive for more than two years. (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: The meter at 139 Cedar St. in Watertown was a scheduled meter

change on 4/12/2013. No service regulator inspection record could be located

The meter at 955 Gotham St. in Watertown was a scheduled meter change on 9/9/2013. No service regulator inspection record could be located

The meter at 148 E. Main St. in Watertown was a scheduled meter change on 9/16/2013. No service regulator inspection record could be located

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The meter at 508 New York Ave. in Watertown was a scheduled meter change on 10/28/2013. No service regulator inspection record could be located.

No service regulator inspection record could be located for the service at 21794 Floral Dr. in Watertown that was reactivated on 6/24/13 after two years of inactivity (service terminated on 4/7/09).

Service Valve Inspection

National Grid – Watertown failed to conform to National Grid Procedure CMS06001 Rev 2 section 5.1 which states that the curb valves on high pressure services shall be inspected at the time of the regulator inspection. (Post 4/1/13) The following are examples where National Grid’s procedure was not followed: The meter at 161 Paddock St. in Watertown was a scheduled meter

change on 3/12/2013. An MWork Regulator Inspection Report was produced for the service regulator, vent and valve inspections to be performed at the time of meter change, however it is indicated that no inspection was done on the curb valve as the valve could not be located.

The meter at 231 Paddock St. in Watertown was a scheduled meter change on 10/9/2013. An MWork Regulator Inspection Report was produced for the service regulator, vent and valve inspections to be performed at the time of meter change, however it is indicated that no inspection was done on the curb valve as the valve could not be located.

The meter at 227 S. Meadow St. in Watertown was a scheduled meter change on 2/1/13/2013. An MWork Regulator Inspection Report was produced for the service regulator, vent and valve inspections to be performed at the time of meter change, however it is indicated that no inspection was done on the curb valve as the valve could not be located.

Service Valve Inspection

National Grid – Watertown failed to conform to National Grid Procedure CMS06001 Rev 2 which states if the installation does not pass inspection corrective action shall be taken, or a follow up order shall be given to the appropriate CMS or Operations and Construct area. (Post 4/1/13)

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The following are examples where National Grid’s procedure was not followed: The meter at 161 Paddock St. in Watertown was a scheduled meter

change on 3/12/2013. An MWork Regulator Inspection Report was produced for the service regulator, vent and valve inspections to be performed at the time of meter change, however it is indicated that no inspection was done on the curb valve as the valve could not be located. It was not indicated on the inspection record that a follow up order was given to the appropriate CMS or Operations and Construct area.

The meter at 231 Paddock St. in Watertown was a scheduled meter change on 10/9/2013. An MWork Regulator Inspection Report was produced for the service regulator, vent and valve inspections to be performed at the time of meter change, however it is indicated that no inspection was done on the curb valve as the valve could not be located. It was not indicated on the inspection record that a follow up order was given to the appropriate CMS or Operations and Construct area.

The meter at 227 S. Meadow St. in Watertown was a scheduled meter change on 2/1/2013. An MWork Regulator Inspection Report was produced for the service regulator, vent and valve inspections to be performed at the time of meter change, however it is indicated that no inspection was done on the curb valve as the valve could not be located. It was not indicated on the inspection record that a follow up order was given to the appropriate CMS or Operations and Construct area.

Leak, Maintenance, and Repair Records

National Grid – Watertown failed to conform to National Grid Procedure GOPB 206 which states that migration of leak should be established in all direction. Record lowest readings used to establish perimeter of leak pattern. Location point of bar holes utilized to establish the leak migration pattern and the classification of the leak are to be referenced on the Leak History Card by showing distances from building lines, curb lines, edge of pavement and/or nearest intersecting street. (Post 4/1/13)

The following is an example where National Grid’s procedure was not followed:

GRO#138674 is for a Type 1 leak on 11/4/13 at Creekwood Dr. in

Watertown. There is no reading to the North of bar hole #1 to determine the extent of hazardous gas migration.

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16 NYCRR Part 255.807(d) - Leaks: Records - 1 Violation, 1 Occurrence

One violation of 255.807(d), which states the gas leak record shall contain an adequate number of readings from the sample points tested during the leakage investigation to depict the extent of hazardous gas migration, expressed in percent gas-in-air or percent LEL found at the time of classification, reclassification if applicable, surveillance investigations, during leak repair activities, after completion of repairs, and at any follow-up inspections.

The following is cited as an example where this requirement was not met:

GRO#138674 is for a Type 1 leak on 11/4/13 at Creekwood Dr. in

Watertown. There is no reading to the North of bar hole #1 to determine the extent of hazardous gas migration. (Post 4/1/13)

16 NYCRR Part 261.53 - HEFPA liaison - 1 Violation, 4 Occurrences

One violation of 261.53, which states that whenever the disconnection results in a customer being unable to use the heating facilities, the operator shall notify its Home Energy Fair Practices Act (HEFPA) liaison with local social services departments (section 11.5(c)(2)(v) of this Title). The following are cited as examples where this requirement was not met:

A Class A warning tag (MWork Order Number 12536309) was issued on

3/15/2013 at 409 Flower Ave E. in Watertown. The warning tag was issued for a possible pinhole in the furnace heat exchanger with excessive CO and the appliance was isolated. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required.

A Class A warning tag (MWork Order Number 12641653) was issued on 4/5/2013 at 609 Bronson St. in Watertown . The warning tag was issued for a cracked heat exchanger on the furnace and the appliance was isolated. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

A Class A warning tag (MWork Order Number 13871237) was issued on 11/1/2013 at 931 S James St in Carthage. The warning tag was issued for a defective auto pilot on furnace and the appliance was isolated. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

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A Class B warning tag (MWork Order Number 13879153) was issued on 11/4/2013 at 214 Schley Dr. in Watertown. The warning tag was issued for a cracked heat exchanger on the furnace and the appliance was isolated. The Company was unable to provide a record showing that the HEFPA liaison with local social services departments was contacted as required. (Post 4/1/13)

16 NYCRR Part 261.57(b)(4) - Warning tag: Class A condition - 1 Violation, 1 Occurrence

One violation of 261.57(b)(4) which states that Class A conditions include, but are not limited to: heat exchangers which are corroded or cracked beyond repair or blocked and which cause products of combustion to enter the warm air distribution system. The following is cited as an example where this requirement was not met:

A Class B warning tag (MWork Order Number 13879153) was issued on

11/4/13 at 214 Schley Dr. in Watertown. The warning tag was issued for a cracked heat exchanger on the furnace. This is not a class B condition, however, and a Class A warning tag should have been issued. (Post 4/1/13)

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Attachment 2 Other Risk

Violation Specifics

Albany Record Audits Four violations of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were noted. 16 NYCRR Part 255.17(a) - Preservation of records - 1 Violation, 1 Occurrence

One violation of 255.17(a), which states, “Notwithstanding the requirements of Part 293 or Part 733 of this Title, the minimum period of retention of records required by this Part shall be at least 3 years.” The following is cited as an example where this requirement was not met:

Regulator Inspection Report # 215963 - 12 Red-Lane Dr, Colonie - The Curb

Valve/OS Riser portion of the 2013 Regulator Inspection Report states, “Not Ok cannot locate curb valve GRO 187134.” Staff requested a copy of the GRO on 6/25/14, but the Company could not produce one. The Company failed to retain the GRO. (Post 4/1/13)

16 NYCRR Part 255.726(a) - Inactive service lines - 1 Violation, 13 Occurrences

One violation of 255.726(a), which states, “All inactive service lines, including stubs, must be inspected, leakage surveyed and maintained according to the applicable provisions of this Part. Inactive steel service lines not under cathodic protection, including stubs, may remain under the conditions established by subdivision 255.727(d) for a period of not more than six years subject to the following conditions. During the third year of inactivity, the operator must conduct a survey for potential future use and, if there is no definite plan for future use, disconnect the service at the main or in compliance with subdivision 255.726(d), purge the service and seal the open end.” The following are cited as examples where this requirement was not met:

481 3rd St, Albany (meter # 1262131) - The Company failed to conduct and/or

document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 3/15/10. (Post 4/1/13)

9 Dana Ave, Albany (meter # 0L497698) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 3/8/10. (Post 4/1/13)

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36 Sparkill Ave, Albany (meter # 3165974 and meter # 1173619) - The

Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 1/18/10 and 1/7/10, respectively. (Post 4/1/13)

69 Beverly Ave, Albany (meter # 1970070) - The Company failed to conduct

and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 12/18/09. (Post 4/1/13)

537 1st St, Albany (meter # 0P593074) - The Company failed to conduct

and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 11/3/09. (Post 4/1/13)

2 Central Ave, Albany (meter # 0Z290890) - The Company failed to conduct

and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 7/19/09. (Post 4/1/13)

24 S Pine Ave, Albany (meter # 0H545006) - The Company failed to conduct

and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 7/9/09. (Post 4/1/13)

268 3rd St, Albany (meter # 14381021) - The Company failed to conduct

and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 7/7/09. (Post 4/1/13)

139 3rd Ave, Albany (meter # 9568968) - The Company failed to conduct

and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 6/10/09. (Post 4/1/13)

132 Central Ave, Albany (meter # 267601) - The Company failed to conduct

and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 6/8/09. (Post 4/1/13)

452 Hamilton St, Albany (meter # 3301965) - The Company failed to conduct

and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 5/27/09. (Post 4/1/13)

410 Clinton Ave, Albany (meter # 0L622172) - The Company failed to

conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 5/5/09. (Post 4/1/13)

45 Prospect Ave, Albany (meter # 9928234) - The Company failed to conduct

and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 4/14/09. (Post 4/1/13)

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16 NYCRR 255.744(e) - Service Regulators and Vents: Inspection - 1 Violation, 3 Occurrences

One violation of 255.744(e), which states, “Each operator shall inspect each service regulator associated vent whenever the service regulator is inspected. This inspection shall include a test for the presence of gas, proper location of vent terminus, proper size, and proper installation of a weather-insect resistant fitting and verification by an inside the building inspection that the vent line piping is continuous and is properly connected to the regulator. Immediate remedial action shall be taken if any of these items do not pass inspections.” The following are cited as examples where this requirement was not met:

Regulator Inspection Report # 227901 - 11 Cary St, Ravena - Records from

5/10/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection. (Post 4/1/13)

Regulator Inspection Report # 12192335 - 3 Sycamore Dr, Albany - Records from 1/2/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection. (Post 4/1/13)

Regulator Inspection Report # 13288207 - 10 Lakeshore Dr, Rensselaer - Records from 8/2/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection. (Post 4/1/13)

16 NYCRR Part 255.805(g) - Leaks: General - 1 Violation, 1 Occurrence

One violation of 255.805(g), which states, “Prior to downgrading a leak without any repair, at least one additional surveillance at the normal interval is required to verify that a lower class of hazard exists.”

The following is cited as an example where this requirement was not met:

GRO # 207771 - 119 Orchard St, Delmar - This leak was a Type 2A leak on

2/28/13. It was reclassified to a Type 2 leak on 3/11/13 with no surveillances in between. There were no repairs made until after the reclassification. The Company failed to perform at least one additional surveillance at the normal interval before downgrading to a lower classification.

16 NYCRR Part 261.63(a)(1) - Warning Tag: Action and Follow-up - 1 Violation, 7 Occurrences

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One violation of 261.63(a)(1), which states, “When a Class A condition is discovered, the operator shall lock off the gas supply at the meter, unless the affected piping or gas fired appliance can be effectively isolated and secured from the rest of the system, and issue a Warning Tag. If the operator is not advised by the customer within 10 calendar days that the condition has been corrected and service is ready to be reinstituted, the operator shall contact the customer no later than the end of the first business day after the 10-day period to determine the status of service.” Following are examples where this requirement was not met: The following are cited as examples where this requirement was not met:

MWork Order # 12470463 - 6 Taylor Dr, East Greenbush - Records indicate

that a Class A Warning Tag was issued on 3/3/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period.

MWork Order # 12971184 - 465 Hamilton St Fl 1, Albany - Records indicate that a Class A Warning Tag was issued on 6/7/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 13105534 - 638 Park Ave, Albany - Records indicate that a Class A Warning Tag was issued on 7/2/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 13733398 - 107 Park St Apt 2, Altamont - Records indicate that a Class A Warning Tag was issued on 10/14/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 13705149 - 37 The Crossway, Delmar - Records indicate that a Class A Warning Tag was issued on 10/7/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13).

MWork Order # 14119600 - 552 Route 9W, Glenmont - Records indicate that a Class A Warning Tag was issued on 12/31/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

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MWork Order # 13968547 - 224 Washington Ave Fl 3, Albany - Records indicate that a Class A Warning Tag was issued on 11/27/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

Corporate - Capital and Northeast Record Audits Zero violations of 16 NYCRR Part 255 and zero violations of 16 NYCRR Part 261 were noted. Glens Falls Record Audits Four violations of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261 were noted. 16 NYCRR Part 255.17(a) - Preservation of records - 1 Violation, 2 Occurrences

One violation of 255.17(a), which states, “Notwithstanding the requirements of Part 293 or Part 733 of this Title, the minimum period of retention of records required by this Part shall be at least 3 years.” The following are cited as examples where this requirement was not met:

Regulator Inspection Report # 13577533 - 162 Sherman Ave, Queensbury -

The Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report states, “Not Ok could not locate turned in GRO to gas op.” Staff requested a copy of the GRO on 6/25/14, but the Company could not produce one. The Company failed to retain the GRO. (Post 4/1/13)

Regulator Inspection Report # 13948176 - 2 Angel Lane, Queensbury - The Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report states, “Not Ok GRO for gas op.” Staff requested a copy of the GRO on 6/25/14, but the Company could not produce one. The Company failed to retain the GRO. (Post 4/1/13)

16 NYCRR Part 255.726(a) – Inactive service lines – 1 Violation, 1 Occurrence

One violation of 255.726(a), which states “All inactive service lines, including stubs, must be inspected, leakage surveyed and maintained according to the applicable provisions of this Part. Inactive steel service lines not under cathodic protection, including stubs, may remain under the conditions established by subdivision

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255.727(d) for a period of not more than six years subject to the following conditions. During the third year of inactivity, the operator must conduct a survey for potential future use and, if there is no definite plan for future use, disconnect the service at the main or in compliance with subdivision 255.726(d), purge the service and seal the open end.” The following is cited as an example where this requirement was not met:

18 Mccrea, Fort Edward (meter # 13298657) - The Company failed to conduct

and/or document a future use survey during the third year of inactivity. “Last Final Read Date” was 8/13/09. (Post 4/1/13)

16 NYCRR Part 255.744(e) - Service Regulators and Vents: Inspection - 1 Violation, 1 Occurrence

One violation of 255.744(e), which states, “Each operator shall inspect each service regulator associated vent whenever the service regulator is inspected. This inspection shall include a test for the presence of gas, proper location of vent terminus, proper size, and proper installation of a weather-insect resistant fitting and verification by an inside the building inspection that the vent line piping is continuous and is properly connected to the regulator. Immediate remedial action shall be taken if any of these items do not pass inspections.” The following is cited as an example where this requirement was not met:

Regulator Inspection Report # 210294 - 19 Jackson Ave, South Glens Falls -

Records indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection. (Post 4/1/13)

16 NYCRR Part 255.807(b) - Leaks: Records - 1 Violation, 1 Occurrence

One violation of 255.807(b), which states, “The record shall contain information as to the nature of the repair and follow-up results.” The following is cited as an example where this requirement was not met:

GRO # 181608 - 46 William St, Glens Falls - Repairs were made on 7/28/13.

The Company failed to document the nature of the repair on the GRO. (Post 4/1/13)

16 NYCRR 261.63(a)(1) - Warning Tag: Action and Follow-up - 1 Violation, 3 Occurrences

One violation of 261.63(a)(1), which states, “When a Class A condition is discovered, the operator shall lock off the gas supply at the meter, unless the affected piping or gas

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fired appliance can be effectively isolated and secured from the rest of the system, and issue a Warning Tag. If the operator is not advised by the customer within 10 calendar days that the condition has been corrected and service is ready to be reinstituted, the operator shall contact the customer no later than the end of the first business day after the 10-day period to determine the status of service.” The following are cited as examples where this requirement was not met:

MWork Order # 13299920 - 5 Bonner Dr, Queensbury - Records indicate that

a Class A Warning Tag was issued on 8/5/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 14088980 - 6 Pearl St, Apt 3, Hudson Falls - Records indicate that two Class A Warning Tags were issued on 12/21/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 14004069 - 17 Baker Ave, South Glens Falls - Records indicate that a Class A Warning Tag was issued on 11/29/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

16 NYCRR 261.63(f) - Warning Tag: Action and Follow-up - 1 Violation, 3 Occurrences

One violation of 261.63(f), which states, “In the case of Class A or B conditions in apartment buildings, the operator shall post a notice in a conspicuous place at or within the dwelling stating that a Warning Tag has been issued and including a description of the condition.” The following are cited as examples where this requirement was not met:

MWork Order # 12262795 - 105 Bay St, Glens Falls - A Class A Warning

Tag was issued on 1/16/13. The record indicates that notice was posted at the leak. The Company failed to post notice in a conspicuous place.

MWork Order # 13128619 - 453 Glen St, Apt 5, Glens Falls - A Class A Warning Tag was issued on 7/12/13. The record indicates that notice was posted with the tenant. The Company failed to post notice in a conspicuous place. (Post 4/1/13)

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MWork Order # 14024991 - 22 Pine St, Apt A, Hudson Falls - A Class B Warning Tag was issued on 12/4/13. The record indicates that notice was posted at the hot water heater. The Company failed to post notice in a conspicuous place. (Post 4/1/13)

Gloversville Record Audits Five violations of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were noted. 16 NYCRR Part 255.17(a) - Preservation of records - 1 Violation, 7 Occurrences

One violation of 255.17(a), which states, “Notwithstanding the requirements of Part 293 or Part 733 of this Title, the minimum period of retention of records required by this Part shall be at least 3 years.” The following are cited as examples where this requirement was not met:

GRO # 28598 - Clizbe Ave, Amsterdam - The Company failed to retain the

leak history record, as of 6/26/14. (“Perm Filed” on 1/23/13. No GRO, leak history card or sketch). (Post 4/1/13)

GRO # 79806 - 73 Barclay Rd, Canajoharie - The Company failed to retain the leak history record, as of 6/26/14. (“Perm Filed” on 1/18/13. No leak history card or sketch). (Post 4/1/13)

GRO # 163922 - 519 N. Perry St, Johnstown - The Company failed to retain the leak history record, as of 6/26/14. (“Perm Filed” on 6/24/13. No sketch). (Post 4/1/13)

GRO # 163935 - 75 Newman St, Gloversville - The Company failed to retain

the leak history record, as of 6/26/14. (“Perm Filed” on 1/28/13. No GRO, leak history card or sketch). (Post 4/1/13)

GRO # 121098 - 180 Fifth Ave, Gloversville - The Company failed to retain

the leak history record, as of 6/26/14. (“Perm Filed” on 5/14/13. No GRO, leak history card or sketch). (Post 4/1/13)

GRO # 182761 - 78 Wesleyan Ave, Amsterdam - The Company failed to

retain the leak history record, as of 6/26/14. (“Perm Filed” on 2/6/13. No GRO, leak history card or sketch). (Post 4/1/13)

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GRO # 14619 - Auto Palace V-347, Johnstown - The Company failed to retain the leak history record, as of 6/26/14. (“Perm Filed” on 5/14/13. No GRO, leak history card or sketch). (Post 4/1/13)

16 NYCRR 255.726(a) - Inactive service lines - 1 Violation, 8 Occurrences

One violation of 255.726(a), which states, “All inactive service lines, including stubs, must be inspected, leakage surveyed and maintained according to the applicable provisions of this Part. Inactive steel service lines not under cathodic protection, including stubs, may remain under the conditions established by subdivision 255.727(d) for a period of not more than six years subject to the following conditions. During the third year of inactivity, the operator must conduct a survey for potential future use and, if there is no definite plan for future use, disconnect the service at the main or in compliance with subdivision 255.726(d), purge the service and seal the open end.” The following are cited as examples where this requirement was not met:

172 Forbes St, Amsterdam (meter # 0C804427) - The Company failed to

conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 3/10/10. (Post 4/1/13)

40 Union St, Amsterdam (meter number # 0Y156597) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 9/28/09. (Post 4/1/13)

20 Academy, Amsterdam (meter # T4815606) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 6/19/09. (Post 4/1/13)

11 Willow, Amsterdam (meter # 00816584) - The Company failed to conduct

and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 5/13/09. (Post 4/1/13)

31 Storrie St, Amsterdam (meter # 0Z290133) - The Company failed to

conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 4/14/09. (Post 4/1/13)

8 Carman Ct, Palentine Bridge (meter # 0K901610) - The Company failed to

conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 4/23/09. (Post 4/1/13)

296 N. Main, Gloversville (meter # 0L315397) - The Company failed to

conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 12/2/09. (Post 4/1/13)

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3 Wells St, Gloversville (meter # 0K202553) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 8/26/09. (Post 4/1/13)

16 NYCRR 255.741(d) - Pressure limiting and regulating stations: Telemetering or recording gauges - 1 Violation, 3 Occurrences

One violation of 255.741(d), which states, “(a) Each distribution system supplied by more than one district pressure regulating station must be equipped with telemetering or recording pressure gauges to indicate the gas pressure in the district… (d) The accuracy of each recording pressure gauge provided and maintained by each operator at the locations required herein shall be tested at intervals not exceeding 15 months, but at least once each calendar year. The results of the tests shall be recorded.” The following are cited as examples where this requirement was not met:

East State EOL (End of Line) Pressure Recording Gauge - The Company tested

the recording gauge on 8/13/12 and did not test it again until 11/27/13. The Company failed to test at intervals not exceeding 15 months. (Post 4/1/13)

Lafayette EOL (End of Line) Pressure Recording Gauge - The Company tested the recording gauge on 7/16/12 and did not test it again until 11/26/13. The Company failed to test at intervals not exceeding 15 months. (Post 4/1/13)

Phelps EOL (End of Line) Pressure Recording Gauge - The Company tested the recording gauge on 8/13/12 and did not test it again until 11/27/13. The Company failed to test at intervals not exceeding 15 months. (Post 4/1/13)

16 NYCRR 255.744(e) - Service Regulators and Vents: Inspection - 1 Violation, 2 Occurrences

One violation of 255.744(e), which states, “Each operator shall inspect each service regulator associated vent whenever the service regulator is inspected. This inspection shall include a test for the presence of gas, proper location of vent terminus, proper size, and proper installation of a weather-insect resistant fitting and verification by an inside the building inspection that the vent line piping is continuous and is properly connected to the regulator. Immediate remedial action shall be taken if any of these items do not pass inspections.” The following are cited as examples where this requirement was not met:

Regulator Inspection Report # 13086653 - 22 River St, Fl 3, Fort Plain -

Records from 6/30/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection. (Post 4/1/13)

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Regulator Inspection Report # 14080411 - 281 Market St, Amsterdam - Records from 12/18/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection. (Post 4/1/13)

16 NYCRR 255.748(c) - Valve maintenance: Service line valves - 1 Violation, 4 Occurrences

One violation of 255.748(c), which states, “(a) Except as provided in subdivision 255.748(b), buried high pressure service line valves or exposed exterior high pressure service line valves shall be inspected in conjunction with the service regulator inspection required under section 255.744. (c) Each buried service line valve inspection shall determine accessibility, key alignment and tests for external leakage. Each exposed exterior service line valve shall be inspected for accessibility and external leakage.” The following are cited as examples where this requirement was not met:

Regulator Inspection Report # 242935 - 208 Well St, Johnstown - The Curb

Valve/OS Riser, Key Fit, portion of the 2013 Regulator Inspection Report from 9/4/13 states, “Not Ok filled with dirt, could not see valve.” The Company failed to verify accessibility and key alignment. (Post 4/1/13)

Regulator Inspection Report # 245193 - 465 Guy Park Ave, Amsterdam - The Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report from 9/19/13 states, “Not Ok could not locate.” The Company failed to verify accessibility, key alignment and leakage. (Post 4/1/13)

Regulator Inspection Report # 13361726 - 444 Guy Park Ave, Amsterdam - The Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report from 8/15/13 states, “Not Ok can’t find.” The Company failed to verify accessibility, key alignment and leakage. (Post 4/1/13)

Regulator Inspection Report # 13934028 - 11 4th Ave, Amsterdam - The Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report from 11/15/13 states, “Not Ok.” The Company failed to verify accessibility and key alignment. (Post 4/1/13)

16 NYCRR 261.63(a)(1) - Warning Tag: Action and Follow-up - 1 Violation, 5 Occurrences

One violation of 261.63(a)(1), which states, “When a Class A condition is discovered, the operator shall lock off the gas supply at the meter, unless the affected piping or gas fired appliance can be effectively isolated and secured from the rest of the system, and issue a Warning Tag. If the operator is not advised by the customer within 10 calendar

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days that the condition has been corrected and service is ready to be reinstituted, the operator shall contact the customer no later than the end of the first business day after the 10-day period to determine the status of service.” The following are cited as examples where this requirement was not met:

MWork Order # 233701 - 177 Spring St, Gloversville - Records indicate that a

Class A Warning Tag was issued on 6/20/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 240519 - 125 S. Main St, Gloversville - Records indicate that a Class A Warning Tag was issued on 8/17/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 14103032 - 70 3rd St, Gloversville - Records indicate that a Class A Warning Tag was issued on 12/26/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 14096669 - 102 Prospect St, Johnstown - Records indicate that a Class A Warning Tag was issued on 12/23/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 13496050 - 40 Mcclellan Ave, Amsterdam - Records indicate that a Class A Warning Tag was issued on 9/5/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

16 NYCRR 261.63(f) - Warning Tag: Action and Follow-up - 1 Violation, 1 Occurrence

One violation of 261.63(f), which states, “In the case of Class A or B conditions in apartment buildings, the operator shall post a notice in a conspicuous place at or within the dwelling stating that a Warning Tag has been issued and including a description of the condition.” The following is cited as an example where this requirement was not met:

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MWork Order # 12438809 - 144 S Main St, Gloversville - A Class A Warning Tag was issued on 2/25/13. The record indicates that no notice was posted. The Company failed to post notice in a conspicuous place.

Hudson Record Audits One violation of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were noted. 16 NYCRR 255.744(e) - Service Regulators and Vents: Inspection - 1 Violation, 4 Occurrences

One violation of 255.744(e), which states, “Each operator shall inspect each service regulator associated vent whenever the service regulator is inspected. This inspection shall include a test for the presence of gas, proper location of vent terminus, proper size, and proper installation of a weather-insect resistant fitting and verification by an inside the building inspection that the vent line piping is continuous and is properly connected to the regulator. Immediate remedial action shall be taken if any of these items do not pass inspections.” The following are cited as examples where this requirement was not met:

Regulator Inspection Report # 12287890 - 816 Warren St, Hudson - Records

from 1/25/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection. (Post 4/1/13)

Regulator Inspection Report # 12343222 - 345 Union St, Hudson - Records from 2/28/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection. (Post 4/1/13)

Regulator Inspection Report # 12447091 - 555 State St, Hudson - Records from 3/4/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection. (Post 4/1/13)

Regulator Inspection Report # 12627582 - 36 N 3rd St, Hudson - Records from 4/3/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection. (Post 4/1/13)

16 NYCRR 261.63(a)(1) - Warning Tag: Action and Follow-up - 1 Violation, 3 Occurrences

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One violation of 261.63(a)(1), which states, “When a Class A condition is discovered, the operator shall lock off the gas supply at the meter, unless the affected piping or gas fired appliance can be effectively isolated and secured from the rest of the system, and issue a Warning Tag. If the operator is not advised by the customer within 10 calendar days that the condition has been corrected and service is ready to be reinstituted, the operator shall contact the customer no later than the end of the first business day after the 10-day period to determine the status of service.” The following are cited as examples where this requirement was not met:

MWork Order # 12205880 - 128 N 2nd St, Hudson - Records indicate that a

Class A Warning Tag was issued on 1/3/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period.

MWork Order # 13606410 - 63 N 5th St Fl 1, Hudson - Records indicate that a Class A Warning Tag was issued on 9/23/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 13693432 - 42 Parkwood Blvd Fl 1, Hudson - Records indicate that a Class A Warning Tag was issued on 10/3/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

Saratoga Record Audits Two violations of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were noted. 16 NYCRR 255.17(a) - Preservation of records - 1 Violation, 3 Occurrences

One violation of 255.17(a), which states, “Notwithstanding the requirements of Part 293 or Part 733 of this Title, the minimum period of retention of records required by this Part shall be at least 3 years.” The following are cited as examples where this requirement was not met:

GRO # 157854 - 390/392 Broadway, Saratoga - Public building valve

inspection records indicate that a GRO was written on 4/11/13. Staff

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requested a copy of the GRO, but the Company could not produce one, as of 6/25/14. The Company failed to retain the GRO. (Post 4/1/13)

GRO # 157863 - 390/392 Broadway, Saratoga - Public building valve inspection records indicate that a GRO was written on 2/24/12. Staff requested a copy of the GRO, but the Company could not produce one, as of 6/25/14. The Company failed to retain the GRO. (Post 4/1/13)

GRO # 157848 - 358 Broadway, Saratoga - Public building valve inspection records indicate that a GRO was written on 3/4/13. Staff requested a copy of the GRO, but the Company could not produce one, as of 6/25/14. The Company failed to retain the GRO. Note: It’s unknown why GRO # 157848 was documented for this address. GRO # 157848 was actually written for 22 Whitney Place. (Post 4/1/13)

16 NYCRR 255.744(e) - Service Regulators and Vents: Inspection - 1 Violation, 8 Occurrences

One violation of 255.744(e), which states, “Each operator shall inspect each service regulator associated vent whenever the service regulator is inspected. This inspection shall include a test for the presence of gas, proper location of vent terminus, proper size, and proper installation of a weather-insect resistant fitting and verification by an inside the building inspection that the vent line piping is continuous and is properly connected to the regulator. Immediate remedial action shall be taken if any of these items do not pass inspections.” The following are cited as examples where this requirement was not met:

Regulator Inspection Report # 12783064 - 139 Nelson Ave, Saratoga -

Records from 5/8/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection. (Post 4/1/13)

Regulator Inspection Report # 12612073 - 2560 State Route 9, Ballston Spa - Records from 4/1/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection. (Post 4/1/13)

Regulator Inspection Report # 12535040 - 1 Stonebreak Rd, Malta - Records from 3/15/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection. (Post 4/1/13)

Regulator Inspection Report # 12535028 - 16 Stonebreak Rd, Malta - Records from 3/15/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection. (Post 4/1/13)

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Regulator Inspection Report # 213577 - 110 Brookline Rd, Ballston Spa - Records from 1/29/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection. (Post 4/1/13)

Regulator Inspection Report # 12502767 - 11 Anyhow Ln, Gansevoort - Records from 3/8/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection. (Post 4/1/13)

Regulator Inspection Report # 12279445 - 738 Route 9, Gansevoort - Records from 1/21/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection. (Post 4/1/13)

Regulator Inspection Report # 13238482 - 60 Lake Ave, Saratoga - Records from 7/26/13 indicate “No” for the “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document the service regulator associated vent inspection. (Post 4/1/13)

16 NYCRR 261.63(a)(1) - Warning Tag: Action and Follow-up - 1 Violation, 3 Occurrences

One violation of 261.63(a)(1), which states, “When a Class A condition is discovered, the operator shall lock off the gas supply at the meter, unless the affected piping or gas fired appliance can be effectively isolated and secured from the rest of the system, and issue a Warning Tag. If the operator is not advised by the customer within 10 calendar days that the condition has been corrected and service is ready to be reinstituted, the operator shall contact the customer no later than the end of the first business day after the 10-day period to determine the status of service.” The following are cited as examples where this requirement was not met:

MWork Order # 12414727 - 1234 Trouble St, Saratoga - Records indicate that

two Class A Warning Tags were issued on 2/19/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period.

MWork Order # 14078051 - 10 Reservation Ave, Saratoga - Records indicate that a Class A Warning Tag was issued on 12/18/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

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MWork Order # 14089742 - 527 Leahy Ln, Ballston Spa - Records indicate that a Class A Warning Tag was issued on 12/21/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

Schenectady Record Audits Two violations of 16 NYCRR Part 255 and four violations of 16 NYCRR Part 261 were noted. 16 NYCRR 255.17(a) - Preservation of records - 1 Violation, 6 Occurrences

One violation of 255.17(a), which states, “Notwithstanding the requirements of Part 293 or Part 733 of this Title, the minimum period of retention of records required by this Part shall be at least 3 years.” The following are cited as examples where this requirement was not met:

CGI # 0024-050966 - Staff requested documentation showing when this CGI

was calibrated in 2013. The Company could not provide any records, as of 6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI # 0128-051879 - Staff requested documentation showing when this CGI was calibrated in 2013. The Company could not provide any records, as of 6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI # 0128-051878 - Staff requested documentation showing when this CGI was calibrated in 2013. The Company could not provide any records, as of 6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI # 9328-002256 - Staff requested documentation showing when this CGI was calibrated in 2013. The Company could not provide any records, as of 6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI # 9430-003550 - Staff requested documentation showing when this CGI was calibrated in 2013. The Company could not provide any records, as of 6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI # 9450-004262 - Staff requested documentation showing when this CGI was calibrated in 2013. The Company could not provide any records, as of 6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

16 NYCRR 255.726(a) - Inactive service lines - 1 Violation, 23 Occurrences

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One violation of 255.726(a), which states, “All inactive service lines, including stubs, must be inspected, leakage surveyed and maintained according to the applicable provisions of this Part. Inactive steel service lines not under cathodic protection, including stubs, may remain under the conditions established by subdivision 255.727(d) for a period of not more than six years subject to the following conditions. During the third year of inactivity, the operator must conduct a survey for potential future use and, if there is no definite plan for future use, disconnect the service at the main or in compliance with subdivision 255.726(d), purge the service and seal the open end.” The following are cited as examples where this requirement was not met:

3032 Cox Ave, Schenectady (meter # 02705715) - The Company failed to

conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 9/8/09. (Post 4/1/13)

2617 Hamburg St, Schenectady (meter # 00816595) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 3/10/10. (Post 4/1/13)

2334 Campbell Ave, Schenectady (meter # 08678058) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 10/15/09. (Post 4/1/13)

1009 Hegeman St, Schenectady (meter # 0Z109982) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 6/3/09. (Post 4/1/13)

19 Close St, Schenectady (meter # 0E744688) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 5/20/09. (Post 4/1/13)

294 Altamont Ave, Schenectady (meter # 01653998) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 7/22/09. (Post 4/1/13)

933 Congress St, Schenectady (meter # 03333836) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 11/6/09. (Post 4/1/13)

0 Duanesburg Rd, Schenectady (meter # T4861038) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 9/18/09. (Post 4/1/13)

392 Shannon St, Schenectady (meter # 02264178) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 2/17/10. (Post 4/1/13)

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62 Wylie St, Schenectady (meter # 0K003978) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 3/11/10. (Post 4/1/13)

1128 7th Ave, Schenectady (meter # 0R683386) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 10/21/09. (Post 4/1/13)

86 Western Pkwy, Schenectady (meter # 0V489444) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 6/24/09. (Post 4/1/13)

1111 McClyman St, Schenectady (meter # 0W658698) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 8/11/09. (Post 4/1/13)

43 McClellan St, Schenectady (meter # 0H685646) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 2/3/10. (Post 4/1/13)

550 Summit Ave, Schenectady (meter # 00972415) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 11/16/09. (Post 4/1/13)

41 McClellan St, Schenectady (meter # 03219003) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 12/18/09. (Post 4/1/13)

175 Jay St, Schenectady (meter # 0F601871) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 2/16/10. (Post 4/1/13)

3040 Wellington Ave, Schenectady (meter # 0A320403) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 12/11/09. (Post 4/1/13)

943 Maple Ave, Schenectady (meter # 0Y391086) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 11/9/09. (Post 4/1/13)

1228 8th Ave, Schenectady (meter # 0J606385) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 9/5/09. (Post 4/1/13)

206 5th St, Schenectady (meter # 0V521794) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 7/2/09. (Post 4/1/13)

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1040 Webster St, Schenectady (meter # 0B406349) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 4/27/09. (Post 4/1/13)

219 Linden St, Schenectady (meter # 0R059312) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 4/20/09. (Post 4/1/13)

16 NYCRR 261.63(a)(1) - Warning Tag: Action and Follow-up - 1 Violation, 6 Occurrences

One violation of 261.63(a)(1), which states, “When a Class A condition is discovered, the operator shall lock off the gas supply at the meter, unless the affected piping or gas fired appliance can be effectively isolated and secured from the rest of the system, and issue a Warning Tag. If the operator is not advised by the customer within 10 calendar days that the condition has been corrected and service is ready to be reinstituted, the operator shall contact the customer no later than the end of the first business day after the 10-day period to determine the status of service.” The following are cited as examples where this requirement was not met:

MWork Order # 12605158 - 61 Ingersoll Ave Fl 3, Schenectady - Records

indicate that a Class A Warning Tag was issued on 4/3/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 13713230 - 941 Crane St, Schenectady - Records indicate that a Class A Warning Tag was issued on 10/7/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 14116391 - 1039 Webster St Fl 2, Schenectady - Records indicate that a Class A Warning Tag was issued on 12/31/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 13987276 - 990 O’Brien Ave, Schenectady - Records indicate that a Class A Warning Tag was issued on 11/25/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

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MWork Order #13775931 - 513 Seneca St Fl 1, Schenectady - Records indicate that a Class A Warning Tag was issued on 10/17/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order #13516247 - 39 Beechwood Dr, Clifton Park - Records indicate that a Class A Warning Tag was issued on 9/9/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

16 NYCRR 261.63(d)(1) - Warning Tag: Action and Follow-up - 1 Violation, 1 Occurrence

One violation of 261.63(d)(1), which states, “(d) Whenever a Warning Tag is issued, regardless of the class of the condition, the operator shall attempt to notify the customer and obtain a signature acknowledging receipt of such notice.” “(1) In apartment buildings, the operator shall notify the property owner or agent (such as superintendent, custodian or maintenance worker) of the condition and state the corrections that are required.” The following is cited as an example where this requirement was not met:

MWork Order # 14062742 - 2 Fuller St Apt 12, Schenectady - Records

indicate that a Class B Warning Tag was issued on 12/14/13. The tag clearly states, “Apartment Building Yes,” and “Landlord/Agent Notified No.” The Company failed to notify the landlord/agent of this Warning Tag. (Post 4/1/13)

16 NYCRR 261.63(d)(2) - Warning Tag: Action and Follow-up - 1 Violation, 1 Occurrence

One violation of 261.63(d)(2), which states, “(d) Whenever a Warning Tag is issued, regardless of the class of the condition, the operator shall attempt to notify the customer and obtain a signature acknowledging receipt of such notice.” “(2) If the operator can not obtain a signature, an additional notice shall be provided to the customer stating that a notice of hazardous condition tag has been issued and the corrective actions that are required.” The following is cited as an example where this requirement was not met:

MWork Order # 13514002 - 1233 6th Ave, Schenectady - Records indicate

that a Class C Warning Tag was issued on 9/9/13. No Signature was obtained and there are no records of any notice being provided to the customer. The Company failed to notify the customer of this Warning Tag. (Post 4/1/13)

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16 NYCRR 261.63(f) - Warning Tag: Action and Follow-up - 1 Violation, 1 Occurrence

One violation of 261.63(f), which states, “(f) In the case of Class A or B conditions in apartment buildings, the operator shall post a notice in a conspicuous place at or within the dwelling stating that a Warning Tag has been issued and including a description of the condition.” The following is cited as an example where this requirement was not met:

MWork Order # 14062742 - 2 Fuller St Apt 12, Schenectady - Records

indicate that a Class B Warning Tag was issued on 12/14/13. The tag clearly states, “Apartment Building Yes,” and “Notice Posted No.” The Company failed to post a notice at the apartment building for this Warning Tag. (Post 4/1/13)

Syracuse Record Audits Three violations of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were noted. 16 NYCRR Part 255.744(a) – Service regulators and vents: Inspection - 1 Violation, 20 Occurrences

One violation of 255.744(a) which states that, “Each operator shall inspect each service regulator at the time which a service which has been inactive for a period of two years or more is reactivated to service.” The following are cited as examples where this requirement was not met:

No service regulator inspection record could be located for the service

regulator at 103 East Way in Camillus that was reactivated on 12/3/13 after being inactive since 10/5/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 107 Center St. in Solvay that was reactivated on 12/5/13 after being inactive since 12/14/07. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 108 Crestview Dr. in Syracuse that was reactivated on 1/22/13 after being inactive since 9/17/07.

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No service regulator inspection record could be located for the service regulator at 110 Elk St. in Syracuse that was reactivated on 3/16/13 after being inactive since 2/27/04.

No service regulator inspection record could be located for the service

regulator at 111 Pond Ln. in Syracuse that was reactivated on 12/5/13 after being inactive since 8/17/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 116 Churchill Ave. in Syracuse that was reactivated on 10/11/13 after being inactive since 10/6/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 144 Greenland Dr. in Syracuse that was reactivated on 8/22/13 after being inactive since 5/10/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 159 Meredith Ave. in Nedrow that was reactivated on 7/18/13 after being inactive since 5/4/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 1912 Teall Ave. in Syracuse that was reactivated on 12/16/13 after being inactive since 9/29/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 198 Longview Ave. in Syracuse that was reactivated on 10/16/13 after being inactive since 3/22/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 200 Mc Kenney Ave. in Syracuse that was reactivated on 7/11/13 after being inactive since 8/12/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 210 Morton St. in Syracuse that was reactivated on 12/9/13 after being inactive since 10/3/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 212 Dorwin Ave. in Syracuse that was reactivated on 6/13/13 after being inactive since 3/31/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 2798 Cold Springs Rd. in Baldwinsville that was reactivated on 9/17/13 after being inactive since 4/6/11. (Post 4/1/13)

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No service regulator inspection record could be located for the service regulator at 312 Hall Ave. in Solvay that was reactivated on 12/27/13 after being inactive since 11/3/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 313 Bailey Rd. in North Syracuse that was reactivated on 12/18/13 after being inactive since 7/11/07. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 334 1st St. in Solvay that was reactivated on 10/4/13 after being inactive since 6/17/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 5529 Chateau Ln. in Clay that was reactivated on 6/10/13 after being inactive since 5/5/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 612 Wright Ave. in Syracuse that was reactivated on 10/3/13 after being inactive since 7/2/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 7 Oriole Path in Liverpool that was reactivated on 12/20/13 after being inactive since 8/8/11. (Post 4/1/13)

16 NYCRR Part 255.748(a) - Valve maintenance: Service line valves - 1 Violation, 20 Occurrences

One violation of 255.748(a), which states that except as provided in subdivision 255.748(b), buried high pressure service line valves or exposed exterior high pressure service line valves shall be inspected in conjunction with the service regulator inspection required under section 255.744.

The following are cited as examples where this requirement was not met:

No service valve inspection record could be located for the service valve at 103 East Way in Camillus that was reactivated on 12/3/13 after being inactive since 10/5/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 107 Center St. in Solvay that was reactivated on 12/5/13 after being inactive since 12/14/07. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 108 Crestview Dr. in Syracuse that was reactivated on 1/22/13 after being inactive since 9/17/07.

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No service valve inspection record could be located for the service valve at 110 Elk St. in Syracuse that was reactivated on 3/16/13 after being inactive since 2/27/04.

No service valve inspection record could be located for the service valve at 111 Pond Ln. in Syracuse that was reactivated on 12/5/13 after being inactive since 8/17/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 116 Churchill Ave. in Syracuse that was reactivated on 10/11/13 after being inactive since 10/6/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 144 Greenland Dr. in Syracuse that was reactivated on 8/22/13 after being inactive since 5/10/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 159 Meredith Ave. in Nedrow that was reactivated on 7/18/13 after being inactive since 5/4/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 1912 Teall Ave. in Syracuse that was reactivated on 12/16/13 after being inactive since 9/29/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 198 Longview Ave. in Syracuse that was reactivated on 10/16/13 after being inactive since 3/22/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 200 Mc Kenney Ave. in Syracuse that was reactivated on 7/11/13 after being inactive since 8/12/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 210 Morton St. in Syracuse that was reactivated on 12/9/13 after being inactive since 10/3/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 212 Dorwin Ave. in Syracuse that was reactivated on 6/13/13 after being inactive since 3/31/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 2798 Cold Springs Rd. in Baldwinsville that was reactivated on 9/17/13 after being inactive since 4/6/11. (Post 4/1/13)

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No service valve inspection record could be located for the service valve at 312 Hall Ave. in Solvay that was reactivated on 12/27/13 after being inactive since 11/3/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 313 Bailey Rd. in North Syracuse that was reactivated on 12/18/13 after being inactive since 7/11/07. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 334 1st St. in Solvay that was reactivated on 10/4/13 after being inactive since 6/17/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 5529 Chateau Ln. in Clay that was reactivated on 6/10/13 after being inactive since 5/5/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 612 Wright Ave. in Syracuse that was reactivated on 10/3/13 after being inactive since 7/2/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 7 Oriole Path in Liverpool that was reactivated on 12/20/13 after being inactive since 8/8/11. (Post 4/1/13)

16 NYCRR Part 255.748(b) – Valve maintenance: Service line valves - 1 Violation, 3 Occurrences

One violation of 255.748(b) which states that, buried service line valves used for compliance with section 255.365(b)(2) of this Part, shall be inspected at intervals not exceeding 15 months, but at least once each calendar year, for accessibility, key alignment and external leakage. The following are cited as examples where this requirement was not met:

The building designated as a public building requiring an annual inspection located at 318 E. Fayette Street, Syracuse was not inspected as required in 2013. (Post 4/1/13)

The building designated as a public building requiring an annual inspection located at 1228 Teall Street Syracuse failed the requirements for annual inspection by having the 2012 inspection conducted on 2/28/2012 and the 2013 inspection conducted on 6/17/2013 which is a period of 69 weeks. (Post 4/1/13)

The building designated as a public building requiring an annual inspection located at 65 Albany Street, Cazenovia failed the requirements for annual

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inspection by having eh 2012 inspection conducted on 3/27/2012 and the 2013 inspection conducted on 7/15/2013 which is a period of 68 weeks. (Post 4/1/13)

16 NYCRR Part 261.63(a)(1) - Warning tag: Action and follow-up – 1 Violation, 2 Occurrences

One violation of 261.63(a)(1), which states that if the operator is not advised by the customer within 10 calendar days that the condition has been corrected and service is ready to be reinstituted, the operator shall contact the customer no later than the end of the first business day after the 10-day period to determine the status of service. The following are cited as examples where this requirement was not met:

A Class A warning tag was issued on1/14/2013 and the follow-up on

2/5/2013; exceeding the requirement by 20 days.

A Class A warning tag was issued on 7/24/2013 at 6076 Bay-Hill Circle, Jamesville NY – no follow-up contact effort could be documented. (Post 4/1/13)

Utica Record Audits Five violations of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261 were noted. 16 NYCRR 255.17(a) – Preservation of records - 1 Violation, 4 Occurrences

One violation of 255.17(a), which states “Notwithstanding the requirements of Part 293 or Part 733 of this Title, the minimum period of retention of records required by this Part shall be at least 3 years.” The following are cited as examples where this requirement was not met:

Mwork order number 12656299: On the service regulator inspection form for 2011 Genesee Street in Utica the Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report states “Not Ok curb box full of stones GRO 180152”. Staff requested a copy of the GRO, but the Company could not produce one. The Company failed to retain the GRO. (Post 4/1/13)

Mwork order number 12722963: On the service regulator inspection form for 25 Tindall Manor in Clinton the Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report states “Not Ok curb box under driveway GRO

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180137”. Staff requested a copy of the GRO, but the Company could not produce one. The Company failed to retain the GRO. (Post 4/1/13)

Mwork order number 12723653: On the service regulator inspection form for

419 Richmond Road in Utica the Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report states “Not Ok full of dirt,, wrote up GRO”. Staff requested a copy of the GRO, but the Company could not produce one. The Company failed to retain the GRO. (Post 4/1/13)

Mwork order number 12723517: On the service regulator inspection form for

9 Edna Terrace in New Hartford the Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report states “Not Ok cb under driveway GRO 180144”. Staff requested a copy of the GRO, but the Company could not produce one. The Company failed to retain the GRO. (Post 4/1/13)

16 NYCRR Part 255.726(a) - Inactive service lines – 1 Violation, 1 Occurrence

One violation of 255.726(a), which states that all inactive service lines, including stubs, must be inspected, leakage surveyed and maintained according to the applicable provisions of this Part. Inactive steel service lines not under cathodic protection, including stubs, may remain under the conditions established by subdivision 255.727(d) for a period of not more than six years subject to the following conditions. During the third year of inactivity, the operator must conduct a survey for potential future use and, if there is no definite plan for future use, disconnect the service at the main or in compliance with subdivision 255.726(d), purge the service and seal the open end.

The following is cited as an example where this requirement was not met:

The inactive service located at 4360 Acme Road in the village of Ilion became inactive on 2/19/10. No documentation was provided showing that a three year future use survey was conducted for this inactive service. (Post 4/1/13)

16 NYCRR Part 255.744(a) - Service regulators and vents - 1 Violation, 15 Occurrences

One violation of 255.744(a), which states that each operator shall inspect each service regulator when it is installed, at the time of periodic meter change, and at the time a service which has been inactive for a period of two years or more is reactivated to service.

The following are cited as examples where this requirement was not met:

No service regulator inspection record could be located for the service regulator at 108 Onondaga Avenue in Canastota that was reactivated on 8/23/13 after being inactive since 7/29/11. (Post 4/1/13)

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No service regulator inspection record could be located for the service

regulator at 112 Bruno Road in Canastota that was reactivated on 11/22/13 after being inactive since 10/5/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 123 Seneca Street in Utica that was reactivated on 10/29/13 after being inactive since 3/24/11. (Post 4/1/13)

No service regulator inspection record could be located for the service regulator at 1305 Maple Street in Utica that was reactivated on 10/2/13 after being inactive since 9/12/11. (Post 4/1/13)

No service regulator inspection record could be located for the service regulator at 144 Bono Boulevard in Frankfort that was reactivated on 10/28/13 after being inactive since 10/24/11. (Post 4/1/13)

No service regulator inspection record could be located for the service regulator at 203 Roberts Street in Canastota that was reactivated on 11/7/13 after being inactive since 7/5/11. (Post 4/1/13)

No service regulator inspection record could be located for the service regulator at 2043 Genesee Street in Utica that was reactivated on 10/8/13 after being inactive since 8/15/11. (Post 4/1/13)

No service regulator inspection record could be located for the service regulator at 2903 RT 12B in Deansboro that was reactivated on 6/25/13 after being inactive since 6/9/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 416 Race Street in Chittenango that was reactivated on 9/24/13 after being inactive since 6/27/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 423 West Dominick Street in Rome that was reactivated on 9/19/13 after being inactive since 2/17/09. (Post 4/1/13)

No service regulator inspection record could be located for the service regulator at 507 ½ Floyd Avenue in Rome that was reactivated on 11/26/13 after being inactive since 5/25/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 5870 Columbus Drive in Marcy that was reactivated on 12/18/13 after being inactive since 4/19/10. (Post 4/1/13)

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No service regulator inspection record could be located for the service regulator at 613 2nd Avenue in Frankfort that was reactivated on 11/25/13 after being inactive since 7/18/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 75 Bedford Drive in Whitesboro that was reactivated on 11/5/13 after being inactive since 5/12/11. (Post 4/1/13)

No service regulator inspection record could be located for the service

regulator at 9647 River Drive in Marcy that was reactivated on 9/17/13 after being inactive since 8/25/11. (Post 4/1/13)

16 NYCRR Part 255.748(a) - Valve maintenance: Service line valves - 1 Violation, 15 Occurrences

One violation of 255.748(a), which states that except as provided in subdivision 255.748(b), buried high pressure service line valves or exposed exterior high pressure service line valves shall be inspected in conjunction with the service regulator inspection required under section 255.744.

The following are cited as examples where this requirement was not met:

No service valve inspection record could be located for the service valve at 108 Onondaga Avenue in Canastota that was reactivated on 8/23/13 after being inactive since 7/29/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 112 Bruno Road in Canastota that was reactivated on 11/22/13 after being inactive since 10/5/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at

123 Seneca Street in Utica that was reactivated on 10/29/13 after being inactive since 3/24/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 1305 Maple Street in Utica that was reactivated on 10/2/13 after being inactive since 9/12/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at

144 Bono Boulevard in Frankfort that was reactivated on 10/28/13 after being inactive since 10/24/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 203 Roberts Street in Canastota that was reactivated on 11/7/13 after being inactive since 7/5/11. (Post 4/1/13)

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No service valve inspection record could be located for the service valve at 2043 Genesee Street in Utica that was reactivated on 10/8/13 after being inactive since 8/15/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 2903 RT 12B in Deansboro that was reactivated on 6/25/13 after being inactive since 6/9/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at

416 Race Street in Chittenango that was reactivated on 9/24/13 after being inactive since 6/27/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at

423 West Dominick Street in Rome that was reactivated on 9/19/13 after being inactive since 2/17/09. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 507 ½ Floyd Avenue in Rome that was reactivated on 11/26/13 after being inactive since 5/25/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at

5870 Columbus Drive in Marcy that was reactivated on 12/18/13 after being inactive since 4/19/10. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 613 2nd Avenue in Frankfort that was reactivated on 11/25/13 after being inactive since 7/18/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 75

Bedford Drive in Whitesboro that was reactivated on 11/5/13 after being inactive since 5/12/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at

9647 River Drive in Marcy that was reactivated on 9/17/13 after being inactive since 8/25/11. (Post 4/1/13)

16 NYCRR Part 255.825(b) - Logging and analysis of gas emergency reports - 1 Violation, 3 Occurrences

One violation of 16 NYCRR Part 255.825(b), which states that “a daily log shall be kept and maintained on file recording the receipt and handling of each such report and shall contain the following information:

(1) cross-reference to the related service record number; (2) location of leak or emergency; (3) time report first received by operator;

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(4) description or code designation as to type of leak or emergency; (5) time crew first dispatched to designated location; and (6) time of arrival of such personnel at location.

The following are cited as examples where this requirement was not met:

GRO 195637 (4/6/13) was a type 1 leak located at 1541-1543 St. Vincent

Street in Utica and was not on the Daily Leak Log. (Post 4/1/13)

GRO 216561 (9/18/13) was a type 1 leak located at 18 Faxton Street in Utica and was not on the Daily Leak Log. (Post 4/1/13)

GRO 172060 (6/20/13) was a type 1 leak located at 1926 Oneida Street in Utica and was not on the Daily Leak Log. (Post 4/1/13)

16 NYCRR Part 261.63(a)(1) – Warning tags: Action and follow-up - 1 Violation, 5 Occurrences

One violation of 261.63(a)(1), which states that when a Class A condition is discovered, the operator shall lock off the gas supply at the meter, unless the affected piping or gas fired appliance can be effectively isolated and secured from the rest of the system, and issue a warning tag.

(1) If the operator is not advised by the customer within 10 calendar days that the condition has been corrected and service is ready to be reinstituted, the operator shall contact the customer no later than the end of the first business day after the 10-day period to determine the status of service.

The following are cited as examples where this requirement was not met:

A Class A warning tag (MWork Order Number 13115629) was issued

7/5/2013 at 25 Devendorf Street in Mohawk. The warning tag was issued for the furnace and water heater being flooded; the appliances were isolated. The operator did not contact the customer until 7/17/2013 which is the second business day after the 10-day period. (Post 4/1/13)

A Class A warning tag (MWork Order Number 13101794) was issued 7/2/2013 at 327 Williams Street in Herkimer. The warning tag was issued for the furnace and water heater being flooded; the appliances were isolated. There were no records provided that indicated the required “10-day” follow-up by the operator (required by 7/15/2013) occurred. (Post 4/1/13)

A Class A warning tag (MWork Order Number 13105592) was issued

7/2/2013 at 243 Williams Street in Herkimer. The warning tag was issued for the furnace and water heater being flooded; the meter was locked off. There were no records provided that indicated the required “10-day” follow-up by the operator (required by 7/15/2013) occurred. (Post 4/1/13)

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A Class A warning tag (MWork Order Number 13165679) was issued

7/13/2013 at 510 Devereaux Street in Oneida. The warning tag was issued for the furnace being flooded; the appliance was isolated. There were no records provided that indicated the required “10-day” follow-up by the operator (required by 7/24/2013) occurred. (Post 4/1/13)

A Class A warning tag (MWork Order Number 13102473) was issued 7/2/2013 at 154 Sanford Avenue in Clinton. The warning tag was issued for the furnace being flooded; the appliance was isolated. There were no records provided that indicated the required “10-day” follow-up by the operator (required by 7/15/2013) occurred. (Post 4/1/13)

16 NYCRR Part 261.63(d)(1) - Warning tag: Action and follow-up - 1 Violation, 2 Occurrences One violation of 261.63(d)(1), which states that in apartment buildings, the operator shall notify the property owner or agent (such as superintendent, custodian or maintenance worker) of the condition and state the corrections that are required.

The following are cited as examples where this requirement was not met:

A Class B warning tag (MWork Order Number 12977348) was issued on

6/10/2013 at 821 Oswego Street (FL 1) in Utica. The warning tag was issued for a cracked whip hose to range, the appliance was shut off. The warning tag record from MWork indicates that this address is an apartment build and that the landlord/agent was not notified. (Post 4/1/13)

A Class B warning tag (MWork Order Number 13086920) was issued on 7/1/2013 at 218 N Caroline Street (FL 1) in Herkimer. The warning tag was issued for a corroded pilot orifice on the water heater, the appliance was shut off. The warning tag record from MWork indicates that this address is an apartment build and that the landlord/agent was not notified. (Post 4/1/13)

Troy Record Audits Four violations of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261 were noted. 16 NYCRR 255.17(a) - Preservation of records - 1 Violation, 6 Occurrences

One violation of 255.17(a), which states, “Notwithstanding the requirements of Part 293 or Part 733 of this Title, the minimum period of retention of records required by this Part shall be at least 3 years.”

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The following are cited as examples where this requirement was not met:

CGI # 9850-004261 - Staff requested documentation showing when this CGI

was calibrated in 2013. The Company could not provide any records, as of 6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI # 9430-003539 - Staff requested documentation showing when this CGI was calibrated in 2013. The Company could not provide any records, as of 6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI # 9429-003522 - Staff requested documentation showing when this CGI was calibrated in 2013. The Company could not provide any records, as of 6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI # 9450-004257 - Staff requested documentation showing when this CGI was calibrated in 2013. The Company could not provide any records, as of 6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI # 9429-003520 - Staff requested documentation showing when this CGI was calibrated in 2013. The Company could not provide any records, as of 6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

GRO # 134818 - 34 114th St, Troy - Staff requested documentation for a leak repair on the Public Building Valve on 6/25/14. The Company failed to retain this GRO. (Post 4/1/13)

16 NYCRR 255.726(a) - Inactive service lines - 1 Violation, 5 Occurrences

One violation of 255.726(a), which states, “All inactive service lines, including stubs, must be inspected, leakage surveyed and maintained according to the applicable provisions of this Part. Inactive steel service lines not under cathodic protection, including stubs, may remain under the conditions established by subdivision 255.727(d) for a period of not more than six years subject to the following conditions. During the third year of inactivity, the operator must conduct a survey for potential future use and, if there is no definite plan for future use, disconnect the service at the main or in compliance with subdivision 255.726(d), purge the service and seal the open end.” The following are cited as examples where this requirement was not met:

559 2nd Ave, Troy (meter # 14380753) - The Company failed to conduct

and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 5/14/09. (Post 4/1/13)

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450 8th Ave, Troy (meter # 14380935) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 2/19/10. (Post 4/1/13)

509 2nd Ave, Troy (meter # 0M161725) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 2/12/10. (Post 4/1/13)

31 State St, Troy (meter # 0X652897) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 5/6/09. (Post 4/1/13)

1606 3rd Ave, Watervliet (meter # 1660548) - The Company failed to conduct and/or document a future use survey during the third year of inactivity, as of 6/26/14. “Last Final Read Date” was 10/20/09. (Post 4/1/13)

16 NYCRR 255.744(e) - Service Regulators and Vents: Inspection - 1 Violation, 4 Occurrences

One violation of 255.744(e), which states, “Each operator shall inspect each service regulator associated vent whenever the service regulator is inspected. This inspection shall include a test for the presence of gas, proper location of vent terminus, proper size, and proper installation of a weather-insect resistant fitting and verification by an inside the building inspection that the vent line piping is continuous and is properly connected to the regulator. Immediate remedial action shall be taken if any of these items do not pass inspections.” The following are cited as examples where this requirement was not met:

Regulator Inspection Report # 244065 - 263 Bloomingrove Dr, Troy -

Records from 9/1/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection. (Post 4/1/13)

Regulator Inspection Report # 241917 - 30 Church Hill Rd, Waterford - Records from 8/27/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection. (Post 4/1/13)

Regulator Inspection Report # 13981567 - 7 David Dr, Cohoes - Records from 11/16/13 indicate “No” for “Screening/Piping” in the “Service Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection. (Post 4/1/13)

Regulator Inspection Report # 13787765 - 279 Old-Loudon Rd, Latham - Records from 10/18/13 indicate “No” for “Screening/Piping” in the “Service

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Regulator and Vent” inspection box. The Company failed to conduct and/or document a vent inspection. (Post 4/1/13)

16 NYCRR 255.807(b) - Leaks: Records - 1 Violation, 1 Occurrence

One violation of 255.807(b) which states, “The record shall contain information as to the nature of the repair and follow-up results.” The following is cited as an example where this requirement was not met:

GRO # 134844 - 30 Hendrix-Hudson Way, Clifton Park - This leak history

record shows that a repair was made on 3/7/13. The GRO shows no detail of the repair and there is no other documentation showing that a repair was performed. The Company failed to document the nature of the repair.

16 NYCRR 261.63(a)(1) - Warning Tag: Action and Follow-up - 1 Violation, 10 Occurrences

One violation of 261.63(a)(1), which states, “When a Class A condition is discovered, the operator shall lock off the gas supply at the meter, unless the affected piping or gas fired appliance can be effectively isolated and secured from the rest of the system, and issue a Warning Tag. If the operator is not advised by the customer within 10 calendar days that the condition has been corrected and service is ready to be reinstituted, the operator shall contact the customer no later than the end of the first business day after the 10-day period to determine the status of service.” The following are cited as examples where this requirement was not met:

MWork Order # 12748619 - 25 Deer-Run Hollow, Clifton Park - Records

indicate that a Class A Warning Tag was issued on 4/29/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 12449144 - 29 Roosevelt Blvd, Cohoes - Records indicate that a Class A Warning Tag was issued on 2/26/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period.

MWork Order # 12501215 - 33 George St Fl 1, Green Island - Records indicate that a Class A Warning Tag was issued on 3/13/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period.

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MWork Order #12449150 - 1624 6th Ave Fl 1, Watervliet - Records indicate that a Class A Warning Tag was issued on 2/26/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period.

MWork Order # 13053109 - 64 Moreland Dr, Clifton Park - Records indicate that a Class A Warning Tag was issued on 6/23/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 14062033 - 156 2nd St Fl 2, Troy - Records indicate that a Class A Warning Tag was issued on 12/13/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 14096662 - 19 Linden Ave, Troy - Records indicate that a Class A Warning Tag was issued on 12/23/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 13516496 - 13 Elm St, Cohoes - Records indicate that a Class A Warning Tag was issued on 9/9/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 13606263 - 220 Grenadier Ct, Clifton Park - Records indicate that a Class A Warning Tag was issued on 9/23/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

MWork Order # 14013388 - 58 Remsen St, Cohoes - Records indicate that a Class A Warning Tag was issued on 12/2/13. The customer did not advise the Company that the condition was corrected within 10 calendar days and the Company failed to contact the customer by the end of the first business day after the 10-day period. (Post 4/1/13)

16 NYCRR 261.63(f) - Warning Tag: Action and Follow-up - 1 Violation, 1 Occurrence

One violation of 261.63(f), which states, “(f) In the case of Class A or B conditions in apartment buildings, the operator shall post a notice in a conspicuous place at or

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within the dwelling stating that a Warning Tag has been issued and including a description of the condition.” The following is cited as an example where this requirement was not met:

MWork Order # 13311614 - 2100 6th Ave, Troy - Records indicate that a

Class A Warning Tag was issued on 8/6/13. The tag clearly states, “Apartment Building Yes,” “Notice Posted Yes,” and “Location At Appliance.” The Company failed to post notice at the apartment building in a conspicuous place for this Warning Tag. (Post 4/1/13)

Volney Record Audits Four violations of 16 NYCRR Part 255 and three violations of 16 NYCRR Part 261 were noted. 16 NYCRR 255.17(a) – Preservation of records - 1 Violation, 3 Occurrences

One violation of 255.17(a), which states “Notwithstanding the requirements of Part 293 or Part 733 of this Title, the minimum period of retention of records required by this Part shall be at least 3 years.” The following are cited as examples where this requirement was not met:

GRO #165747 was issued for a Type 1 Leak on 7/24/13 at 28 Ellen St. in Oswego. A Gas Repair Order and Leak History Record could not be produced for Staff review. Therefore, all details pertaining to this leak and follow-up are not adequately documented and unable to be reviewed. The Company failed to retain the GRO. (Post 4/1/13)

GRO#165748 was issued for a Type 1 Leak on 8/27/13 at 10 Prospect St. in

Oswego. A Gas Repair Order and Leak History Record could not be produced for Staff review. Therefore, all details pertaining to this leak and follow-up are not adequately documented and unable to be reviewed. The Company failed to retain the GRO. (Post 4/1/13)

GRO#184659 was issued for a Type 2 Leak on 6/11/13 at 72 Park in Pulaski. A Gas Repair Order and Leak History Record could not be produced for Staff review. Therefore, all details pertaining to this leak and follow-up are not adequately documented and unable to be reviewed. The Company failed to retain the GRO. (Post 4/1/13)

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16 NYCRR Part 255.744(a) - Service regulators and vents - 1 Violation, 6 Occurrences

One violation of 255.744(a), which states that each operator shall inspect each service regulator when it is installed, at the time of periodic meter change, and at the time a service which has been inactive for a period of two years or more is reactivated to service.

The following are cited as examples where this requirement was not met:

The meter at 579 1/2 S. 1st. St. in Fulton was a scheduled meter change on 1/22/2013. No service regulator inspection record could be located

The meter at 220 Seneca St. in Fulton was a scheduled meter change on

6/28/2013. No service regulator inspection record could be located. (Post 4/1/13)

The meter at 156 S. 3rd St. in Fulton was a scheduled meter change on

12/3/2013. No service regulator inspection record could be located. (Post 4/1/13)

The meter at 223 W. Seneca St. in Fulton was a scheduled meter change on

9/16/2013. No service regulator inspection record could be located. (Post 4/1/13)

No service regulator inspection record could be located for the service at 422

S. 3rd St. in Fulton that was reactivated on 9/23/13 after two years of inactivity (service terminated on 4/27/11). (Post 4/1/13)

No service regulator inspection record could be located for the service at 9477

Oswego Rd. in Phoenix that was reactivated on 10/2/13 after two years of inactivity (service terminated on 6/27/11). (Post 4/1/13)

16 NYCRR Part 255.748(a) – Valve maintenance: Service line valves – 1 Violation, 7 Occurrence

One violation of 255.748(a), which states that except as provided in subdivision 255.748(b), buried high pressure service line valves or exposed exterior high pressure service line valves shall be inspected in conjunction with the service regulator inspection required under section 255.744. The following are cited as examples where this requirement was not met: The meter at 579 1/2 S. 1st. St. in Fulton was a scheduled meter change on

1/22/2013. No service regulator inspection record could be located

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The meter at 220 Seneca St. in Fulton was a scheduled meter change on 6/28/2013. No service regulator inspection record could be located. (Post 4/1/13)

The meter at 156 S. 3rd St. in Fulton was a scheduled meter change on

12/3/2013. No service regulator inspection record could be located. (Post 4/1/13)

The meter at 223 W. Seneca St. in Fulton was a scheduled meter change on

9/16/2013. No service regulator inspection record could be located. (Post 4/1/13)

No service regulator inspection record could be located for the service at 422

S. 3rd St. in Fulton that was reactivated on 9/23/13 after two years of inactivity (service terminated on 4/27/11). (Post 4/1/13)

No service regulator inspection record could be located for the service at 9477

Oswego Rd. in Phoenix that was reactivated on 10/2/13 after two years of inactivity (service terminated on 6/27/11). (Post 4/1/13)

The meter at 463 W. 4th St. S in Fulton was a scheduled meter change on 10/30/2013. An MWork Regulator Inspection Report was produced for the service regulator, vent and valve inspections to be performed at the time of meter change, however it is indicated that no inspection was done on the curb valve as the valve could not be located. (Post 4/1/13)

16 NYCRR Part 255.825(b) - Logging and analysis of gas emergency reports - 1 Violation, 3 Occurrences

One violation of 16 NYCRR Part 255.825(b), which states that “a daily log shall be kept and maintained on file recording the receipt and handling of each such report and shall contain the following information:

(1) cross-reference to the related service record number; (2) location of leak or emergency; (3) time report first received by operator; (4) description or code designation as to type of leak or emergency; (5) time crew first dispatched to designated location; and (6) time of arrival of such personnel at location.

The following are cited as examples where this requirement was not met:

GRO#184673 (11/1/13) was a type 1 leak located at 106 S. 5th St. in Fulton and was not on the Daily Leak Log. (Post 4/1/13)

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GRO#184675 (11/4/13) was a type 1 leak located at 756 State Rt. 48 in Granby and was not on the Daily Leak Log. (Post 4/1/13)

GRO#184665(8/7/13) was a type 1 leak located at 159 City Line in Scriba and was not on the Daily Leak Log. (Post 4/1/13)

16 NYCRR Part 261.63(a)(1) - Warning tag: Action and follow-up - 1 Violation, 1 Occurrence

One violation of 261.63(a)(1) which states that when a Class A condition is discovered, the operator shall lock off the gas supply at the meter, unless the affected piping or gas fired appliance can be effectively isolated and secured from the rest of the system, and issue a warning tag. If the operator is not advised by the customer within 10 calendar days that the condition has been corrected and service is ready to be reinstituted, the operator shall contact the customer no later than the end of the first business day after the 10-day period to determine the status of service. The following is cited as an example where this requirement was not met:

A Class A warning tag (MWork Order Number 12261521) was issued on

1/6/13 at 152 County-Route-24 in Minetto. The warning tag was issued for a plugged boiler and the appliance was isolated. There was no record produced to show that this warning tag was followed up on within the required time frame.

16 NYCRR Part 261.63(d)(1) – Warning tag: Action and follow-up 1 Violation, 1 Occurrence

One violation of 261.63(d)(1), which states that in apartment buildings, the operator shall notify the property owner or agent (such as superintendent, custodian or maintenance worker) of the condition and state the corrections that are required. The following is cited as an example where this requirement was not met:

A Class B warning tag was issued on 6/1/13 at 87 E. 5th St., Oswego for a gas

leak on the ovens pilot. The customer signed the warning tag, but the landlord was never contacted. Since this is an apartment building the owner should have been contacted letting them know what was wrong. (Post 4/1/13)

16 NYCRR Part 261.63(f) - Warning tag: Action and follow-up - 1 Violation, 1 Occurrence

One violation of 261.63(f), which states that in the case of Class A or B conditions in apartment buildings, the operator shall post a notice in a conspicuous place at or within the dwelling stating that a warning tag has been issued and including a description of the condition.

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The following is cited as an example where this requirement was not met:

A Class A warning tag (MWork Order Number 1264314) was issued on

4/7/13 at 1020 County-Route 25 Apt.1 in Oswego. The warning tag was issued for a furnace that was not venting properly and the appliance was isolated. The warning tag record from MWork indicates that this location is an apartment building and that no notice was posted. (Post 4/1/13)

Watertown Record Audits Three violations of 16 NYCRR Part 255 and three violations of 16 NYCRR Part 261were noted. 16 NYCRR Part 255.744(a) - Service regulators and vents - 1 Violation, 5 Occurrences

One violation of 255.744(a), which states that each operator shall inspect each service regulator when it is installed, at the time of periodic meter change, and at the time a service which has been inactive for a period of two years or more is reactivated to service. The following are cited as examples where this requirement was not met: The meter at 139 Cedar St. in Watertown was a scheduled meter change on

4/12/2013. No service regulator inspection record could be located. (Post 4/1/13)

The meter at 955 Gotham St. in Watertown was a scheduled meter change on 9/9/2013. No service regulator inspection record could be located. (Post 4/1/13)

The meter at 148 E. Main St. in Watertown was a scheduled meter change on 9/16/2013. No service regulator inspection record could be located. (Post 4/1/13)

The meter at 508 New York Ave. in Watertown was a scheduled meter change on 10/28/2013. No service regulator inspection record could be located. (Post 4/1/13)

No service regulator inspection record could be located for the service at 21794 Floral Dr. in Watertown that was reactivated on 6/24/13 after two years of inactivity (service terminated on 4/7/09). (Post 4/1/13)

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16 NYCRR Part 255.748(a) – Valve maintenance: Service line valves – 1 Violation, 8 Occurrences

One violation of 255.748(a), which states that except as provided in subdivision 255.748(b), buried high pressure service line valves or exposed exterior high pressure service line valves shall be inspected in conjunction with the service regulator inspection required under section 255.744. The following are cited as examples where this requirement was not met: The meter at 139 Cedar St. in Watertown was a scheduled meter change on

4/12/2013. No service valve inspection record could be located. (Post 4/1/13)

The meter at 955 Gotham St. in Watertown was a scheduled meter change on 9/9/2013. No service valve inspection record could be located. (Post 4/1/13)

The meter at 148 E. Main St. in Watertown was a scheduled meter change on

9/16/2013. No service valve inspection record could be located. (Post 4/1/13)

The meter at 508 New York Ave. in Watertown was a scheduled meter change on 10/28/2013. No service valve inspection record could be located. (Post 4/1/13)

No service valve inspection record could be located for the service at 21794 Floral Dr. in Watertown that was reactivated on 6/24/13 after two years of inactivity (service terminated on 4/7/09). (Post 4/1/13)

The meter at 161 Paddock St. in Watertown was a scheduled meter change on 3/12/2013. An MWork Regulator Inspection Report was produced for the service regulator, vent and valve inspections to be performed at the time of meter change, however it is indicated that no inspection was done on the curb valve as the valve could not be located.

The meter at 231 Paddock St. in Watertown was a scheduled meter change on 10/9/2013. An MWork Regulator Inspection Report was produced for the service regulator, vent and valve inspections to be performed at the time of meter change, however it is indicated that no inspection was done on the curb valve as the valve could not be located. (Post 4/1/13)

The meter at 227 S. Meadow St. in Watertown was a scheduled meter change on 2/1/13/2013. An MWork Regulator Inspection Report was produced for the service regulator, vent and valve inspections to be performed at the time of meter change, however it is indicated that no inspection was done on the curb valve as the valve could not be located.

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16 NYCRR Part 255.825(b) - Logging and analysis of gas emergency reports - 1 Violation, 5 Occurrences

One violation of 16 NYCRR Part 255.825(b), which states that “a daily log shall be kept and maintained on file recording the receipt and handling of each such report and shall contain the following information:

(1) cross-reference to the related service record number; (2) location of leak or emergency; (3) time report first received by operator; (4) description or code designation as to type of leak or emergency; (5) time crew first dispatched to designated location; and (6) time of arrival of such personnel at location.

The following are cited as examples where this requirement was not met:

GRO#138674 (11/4/13) was a type 1 leak located at Creekwood Dr. in Watertown and was not on the Daily Leak Log. (Post 4/1/13)

GRO#215057 (8/5/13) was a type 1 leak located at 629 Factory St. in Watertown and was not on the Daily Leak Log. (Post 4/1/13)

GRO#138515 (11/6/13) was a type 1 leak located at 610 Mohawk St. in Watertown and was not on the Daily Leak Log. (Post 4/1/13)

GRO#189326 (5/28/13) was a type 1 leak located at 23762 Route 12 (Bradley St.) in Watertown and was not on the Daily Leak Log. (Post 4/1/13)

GRO#138679 (9/9/13) was a type 1 leak located at 26177 State Route 3 in Watertown and was not on the Daily Leak Log. (Post 4/1/13)

16 NYCRR Part 261.63(a)(1) - Warning tag: Action and follow-up - 1 Violation, 1 Occurrence

One violation of 261.63(a)(1) which states that when a Class A condition is discovered, the operator shall lock off the gas supply at the meter, unless the affected piping or gas fired appliance can be effectively isolated and secured from the rest of the system, and issue a warning tag. If the operator is not advised by the customer within 10 calendar days that the condition has been corrected and service is ready to be reinstituted, the operator shall contact the customer no later than the end of the first business day after the 10-day period to determine the status of service. The following is cited as an example where this requirement was not met:

A Class A warning tag (MWork Order Number 12219070) was issued on

1/7/13 at 110 Maple St. in Black River. The warning tag was issued for an

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improperly venting water heater. The first attempt at contact was 2/5/13 which exceeds the 10-day period to determine the status of service.

16 NYCRR Part 261.63(d)(2) – Warning tag: Action and follow-up 1 Violation, 1 Occurrence

One violation of 261.63(d)(2), which states that if the operator cannot obtain a signature, an additional notice shall be provided to the customer stating that a notice of hazardous condition tag has been issued and the corrective actions that are required. The following is cited as an example where this requirement was not met:

A Class B warning tag (MWork Order Number 14005461) was issued on

11/30/13 at 160 Breen Ave., Watertown for a delayed ignition on the customers’ furnace. No signature was ever obtained when the warning tag was issued. No additional notice was ever provided to the customer explaining the hazardous conditions that were found. (Post 4/1/13)

16 NYCRR Part 261.63(f) - Warning tag: Action and follow-up - 1 Violation, 1 Occurrence

One violation of 261.63(f), which states that in the case of Class A or B conditions in apartment buildings, the operator shall post a notice in a conspicuous place at or within the dwelling stating that a warning tag has been issued and including a description of the condition. The following is cited as an example where this requirement was not met:

A Class A warning tag (MWork Order Number 12219070) was issued on

1/7/2013 at 110 Maple St. in Black River. The warning tag was issued for a water heater that is too tall for the cellar and an exhaust vent that is not venting at an uphill pitch. The warning tag record from MWork indicates that this location is an apartment building and that no notice was posted.