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SCHEjj[_, ArTORNE1S Al LAW
17 North Second Street 12th Floor Harrisburg, PA 17101-1601 717-731-1970 Main 717-731-1985 Main Fax www.postschell.com
Michael W. Hassell
[email protected] 717-612-6029 Direct 717-731-1985 Direct Fax File#: 153886
January 2, 2013
Rosemary Chiavetta Secretary Pennsylvania Public Utility Commission Commonwealth Keystone Building 400 North Street, 2nd Floor North P.O. Box 3265 Harrisburg, PA 17105-3265
RE: Petition of Columbia Gas of Pennsylvania, Inc. for Approval of a Distribution System improvement Charge Docket No. P-2012-2338282
Dear Secretary Chiavetta:
Enclosed for filing please find the Petition of Columbia Gas of Pennsylvania, Inc. for Approval of a Distribution System Improvement Charge. Also enclosed is a CD containing a copy of this filing. Copies will be provided as indicated on the Certificate of Service.
Respectfully submitted, ,
Michael W. Hassell
MWH/skr Enclosures cc: Paul T. Diskin
Robert D. Horensky Bohdan Pankiw Esquire Certificate of Service
ALLENTOWN HAISHUHG LANCASTER PEILADELPBA PFUrSBURGH PRINCETON WAS HNGTON, D.C.
A PENN5YLVARA PRFSINAL CORPoRA1cN
10327756v1
CERTIFICATE OF SERVICE
I hereby certify that true and correct copies of the foregoing have been served upon the following persons, in the manner indicated, in accordance with the requirements of § 1.54 (relating to service by a participant).
VIA FIRST CLASS MAIL:
Regina L. Matz Esquire Allison C. Kaster, Esquire Bureau of Investigation and Enforcement Commonwealth Keystone Building 400 North Street, 2nd Floor West P0 Box 3265 Harrisburg, PA 17105-3265
Daniel G. Asmus, Esquire Office of Small Business Advocate 300 North Second Street, Suite 1 102 Harrisburg, PA 17101
Tanya J. McCloskey, Esquire Brandon J. Pierce, Esquire Office of Consumer Advocate 555 Walnut Street Forum Place, 5th Floor Harrisburg, PA 17101-1923
Joseph L. Vullo, Esquire Burke Vullo Reilly Roberts 1460 Wyoming Avenue Forty Fort, PA 18704
Patrick M. Cicero, Esquire Harry S. Geller, Esquire Peimsylvania Utility Law Project 118 Locust Street Harrisburg, PA 17101
Thomas J. Sniscak, Esquire William E. Lehman, Esquire Hawke McKeon & Sniscak LLP 100 North Tenth Street P0 Box 1778 Harrisburg, PA 17105
Todd S. Stewart, Esquire Steven K. Haas, Esquire Hawke McKeon & Sniscak LLP 100 N, 10th Street P0 Box 1778 Harrisburg, PA 17101
Charis Mincavage, Esquire Elizabeth P. Trinkle, Esquire MeNees Wallace & Nurick LLC 100 Pine Street P0 Box 1166 Harrisburg, PA 17108-1166
Anastasia Stratigos a/k/a Stacy Stratigos 1410 Key Avenue Pittsburgh, PA 15216
Date: January 2, 2013 Michael W. Flassell
10274843v1
BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION
Petition of Columbia Gas of Pennsylvania, Inc. for Approval of a Distribution System : Docket No. P-2012-23 38282 Improvement Charge
Petition of Columbia Gas of Pennsylvania for Approval of a Distribution System Improvement Charge
Pursuant to 66 Pa. C.S. § 1353, Columbia Gas of Pennsylvania, Inc. ("Columbia" or the
"Company") hereby files this Petition seeking approval of a Distribution System Improvement
Charge ("DSIC"). This filing is being made pursuant to the Final Implementation Order of the
Pennsylvania Public Utility Commission (the "Commission") entered at Docket No. M-2012-
2293611 on August 2, 2012. Columbia has undertaken a significant distribution system
infrastructure evaluation, repair and replacement program that is focused primarily on those
portions of its system that were constructed using cast iron and bare steel pipe. The DSIC will
allow Columbia to continue this process without the risk of uncertainty or delay.
By this Petition, the Company respectfully requests that the Commission approve
Columbia's Distribution System Improvement Charge effective March 1, 2013.
I. INTRODUCTION
1. Columbia is a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania. Columbia is engaged in the business of selling and distributing
natural gas to retail customers within the Commonwealth, and is therefore a "public utility"
Implementation ofAct 11 of2012, Docket No. M-20 12-2293611, entered on August 2, 2012. ("Final Implementation Order").
I I 0327585v1
within the meaning of Section 102 of the Public Utility Code, 66 Pa. C.S. § 102, subject to the
regulatory jurisdiction of the Commission. Columbia provides natural gas service to
approximately 415,000 customers in 26 counties of Pennsylvania, pursuant to certificates of
public convenience granted by the Commission.
2. The names, addresses and telephone numbers of Columbia's attorneys for
purposes of this filing are as follows:
Michael W. Hassefl (ID # 34851) Jessica R. Rogers (ID # 309842) Post & Schell, P.C. 17 North Second Street 121h Floor Harrisburg, PA 1710 1-1601 Phone: 717-731-1970 Fax: 717-731-1985 E-mail: [email protected] E-mail: [email protected]
Theodore J. Gallagher (ID # 90842) Kimberly S. Cuccia (ID # 308216) NiSource Corporate Services Company Energy Distribution Group Legal 121 Champion Way, Suite 100 Canonsburg, PA 15317
Columbia's attorneys are authorized to receive all notices and communications regarding this
filing.
3. On February 14, 2012, Governor Corbett signed into law Act Il of 2012 ("Act
11"), which amends Chapters 3, 13 and 33 of Title 66 of the Public Utility Code ("Code")
Pertinent to this Petition, Act 11 authorizes natural gas distribution companies ("NGDCs") to
establish a distribution system improvement charge ("DSIC")
4. Act 11 provides utilities with the ability to implement a DSIC to recover
reasonable and prudent costs incurred to repair, improve or replace certain eligible distribution
2 I O327585vJ
property that is part of the utility's distribution system. Eligible property for NGDCs is defined
in § 1351 of the statute. See 66 Pa. C.S. § 1351(2). As a precondition to the implementation of a
DSIC, each utility must file a Long Term Infrastructure Improvement Plan ("LTIIP") with the
Commission that is consistent with the provisions of § 1352 of the statute. See 66 Pa. C.S. §
13 52(a).
5. On May 10, 2012, the Commission issued its Tentative Implementation Order,
and solicited comments and input. Columbia responded to the Commission's request and filed
comments on the Tentative Implementation Order on June 6, 2012,
6. On August 2, 2012, the Commission issued the Final Implementation Order
establishing procedures and guidelines necessary to implement Act 11. The Implementation
Order adopts the requirements established in Section 1353 for the DSIC filing. In addition, the
Commission provided a model tariff which the utilities were instructed to use in preparing their
DSIC tariff.
7. Specifically, Section 1353 requires utilities to file a petition seeking Commission
approval of a DSIC. The statute lays out four major requirements including the following:
(a) An initial tariff that complies with the model tariff adopted by the Commission, which will include:
(i) A description of eligible property;
(ii) The effective date of the DSIC;
(iii) Computation of the DSJC;
(iv) The method for quarterly updates of the DSIC; and
(v) A description of consumer protections.
(b) Testimony, affidavits, exhibits, and other supporting evidence demonstrating that the DSIC is in the public interest;
(c) A LTIIP, as described in Section 1352; and
3 1 03275 85v1
(d) Certification that a base rate case has been filed within five years prior to the filing of the DSIC petition.
8. Columbia's Petition addresses each of the elements listed in the statute.
II. COLUMBIA'S DSLC
A. COLUMBIA'S TARIFF COMPLIES WITH THE COMMISSION'S MODEL TARIFF
9. Columbia's proposed Tariff Supplement No. 194 is included with this Petition,
and is discussed in detail in the testimony of Nancy Krajovic, Columbia Statement No. 1.
Columbia developed its proposed tariff in compliance with the model tariff included in the
Commission's Implementation Order, as required by § 1353. As described below, Columbia's
proposed tariff contains all of the statutory elements listed in § I 353(b)(1), and, therefore, should
be approved by the Commission.
1. Description of Eligible Property
10. Columbia has included the same eligible property in both its DSTC and its LTIIP,
as that term is defined in § 135 1(2). Eligible property includes the following: piping, couplings,
gas service lines, valves, excess flow valves, risers, meter bars, meters, unreimbursed costs
related to highway relocation projects, and other related capitalized costs. Columbia's LTIIP
describes in detail its plans for replacing the DSIC-eligible property described in § 1351(2) and
contained in the DSIC.
2. Effective Date of the DSIC
11. Columbia is requesting permission to implement its DSIC for bills rendered on
and after March 3, 2013.
3. Computation of USIC
12. Columbia's DSIC will be calculated consistent with the Commission's model
tariff. Columbia has used a rate of return on equity ("ROE") of 10.4% in calculating its DSIC,
10327585v1
which is based on the Commission's decision in PPL Electric Utilities Corporation's fully-
litigated base rate proceeding at Docket No. R-201 2-2290597. Columbia selected this number
based on its consistency with the DSIC ROE of 10.46% proposed by the Utility Sub-Group in
the Commission's Act 11 ROE Working Group. When the Commission publishes an ROE to be
used for DSIC purposes, Columbia will revise its compliance filing to reflect the allowed ROE.
13. Columbia has based its projected quarterly revenues on one-fourth of its projected
annual distribution revenues, which is consistent with one of the two options made available to
utilities in the Commission's model tariff. Columbia has chosen to use one-fourth of its
projected annual distribution revenues in order to make the DSIC more simple and reflective of
the fixed nature of Columbia's investments.
4. Quarterly Updates
14. The DSIC will be updated on a quarterly basis to reflect eligible plant additions
placed in service during the three-month period ending one month prior to the effective date of
any DSIC update. Columbia has provided a chart of the effective dates of its proposed DSIC
updates, and the corresponding period for eligible plant additions that will be reflected in each
update, as part of the DSIC tariff language included in Supplement No. 194..
15. Once Columbia has implemented its DSIC, customers will receive notice of
quarterly changes in the DSIC through bill messages. This is consistent with Act 1 1 and the
Commission's Final Implementation Order.
5. Consumer Protections
16. The Commission's model tariff includes customer safeguards in its structure
which Columbia has adopted as part of its proposed tariff. These safeguards include: (1) a 5.0%
cap on the total amount of revenue that can be collected by the Company as determined on an
annualized basis, (2) annual reconciliations performed by Columbia, (3) audits conducted by the
5 I 0327585v1
Commission, (4) customer notice of any changes in the DSIC, (5) a reset of the DSIC to zero as
of the effective date of new base rates that include the DSTC-eligible plant, and (6) provisions for
the charge to be set at zero if, in a quarter, Columbia's most recent earnings report shows that
Columbia is earning a rate of return that exceeds the allowable rate of return used to calculate its
fixed costs under the DSIC.
B. COLUMBIAS ftSIC IS IN THE PUBLIC INTEREST
17. Implementing Columbia's proposed DSIC tariff is in the public interest because
the DSIC will ensure that customers will continue to receive safe and reliable service in the
future as required by 66 Pa. C.S. § 1501.
18. Portions of Columbia's system date back to the late 1800s. Construction
materials used for natural gas pipelines have evolved dramatically over the more than 100 years
since the first pipelines in Columbia's system were constructed, and many of the historic
materials used for constructing pipelines have subsequently been found to weaken significantly
as they age. In the oldest portions of Columbia's system, cast iron was used because at the time
of construction it was considered relatively strong and easy to install. Cast iron, however, is
vulnerable to breakage from ground movement. As a result, the industry transitioned to bare
steel and wrought iron piping by the early 1900s, which was popular until the 1960s. A
significant portion of Columbia's system is composed of bare steel. Bare steel is subject to
corrosion. Finally, as the industry moved to the use of plastic piping starting in the 1970s, a
material called Aldyl-A was used. However, Aldyl-A is vulnerable to stress propagation
cracking.
19. Columbia determined that there are an increasing number of leaks in areas with a
high concentration of aging pipe. In fact, corrosion on first generation mains and services
represents over 85% of all the leakage that occurs annually on mains in the Columbia
6 03275 85v1
distribution system. Bare steel and cast iron mains are at least 16 times more likely to experience
leakage than plastic or cathodicaily protected facilities. In 2007, Columbia determined that it
needed to address the situation with a major distribution infrastructure replacement program.
20. Columbia has replaced approximately 2,595,167 feet of pipe since the beginning
of 2007. In 2011 alone, Columbia replaced 533,765 feet of bare steel and cast iron pipe.
Another 510,000 feet are anticipated to be replaced by year end 2012. As a result of its program,
the Company has reduced open Class 2 leaks by nearly 50% since 2007.
21. Columbia believes that replacement of aging distribution equipment and facilities
will reduce the number of leaks on its system, allow it to install additional safety mechanisms,
and will generally improve service to its customers. The DSIC will allow Columbia to continue
its already accelerated pace for replacing its distribution infrastructure.
22. Columbia's infrastructure replacement program will also allow the distribution
system to operate at higher pressures. Higher pressures will substantially reduce the current need
for pressure regulators, thereby making the system safer, easier and more reliable to operate. A
distribution system operating at these higher pressures also will enable Columbia to install
additional new safety devices in areas to be upgraded. This includes excess flow valves, which
will shut off gas to a residence or business in the event of a large pressure differential, which is
typically indicative of a major gas leak or a service damaged by excavation. The DSIC will
allow Columbia to remove deteriorating portions of its system and enhance the safety of its
system by ensuring replacement of facilities with new, longer lasting and safer materials. The
public will receive better service, with fewer interruptions.
23. Further details with regard to why the DSIC is in the public interest are provided
in Columbia's LTIIP.
VA I 03215 85v1
C. COLUMBIA'S LTIIP COMPLIES WITH SECTION 1352 01? ACT 11
24. Columbia's LTIIP, which is attached as Exhibit NJDK-2 to Ms. Krajovic's
testimony, was filed with the Commission on December 7, 2012 at Docket No. P-2012-233 8282.
Columbia's LTIIP is in accordance with the Commission's Implementation Order and the
statute.
25. Based on Columbia's LTIIP, over the next 5 years, the Company anticipates
replacing approximately 2,800,000 feet of cast iron and bare steel main. In addition to its mains,
Columbia anticipates that it will replace 7,000 to 9,000 service lines per year and approximately
2,000 to 4,000 meters annually over the next five years.
26. Starting in 2007, Columbia doubled the rate at which it replaced its aging mains.
Columbia's LTIIP proposes that the Company maintain its accelerated main replacement
program, with more than 500,000 feet of main replacement proposed for each of the plan's five
years. The projected average annual spending of $131,480,000 on infrastructure replacement
from 2013 through 2017 represents a significant increase over the average annual investment of
$78,338,500 during the years 2007 through 2012.
27. Columbia reassesses its system, and projects are reprioritized each year based on
the most current data available. As such, the list of distribution improvement projects is a
dynamic roster that is subject to modification based on emerging conditions. Columbia
maximizes efficiencies and minimizes costs by addressing large segments of the system, and
carrying out replacements on a planned, systemic basis. Not only does this process ensure
effective use of resources, it minimizes disruption to the customers and municipalities that
Columbia serves, By including the integration of Columbia's program work with State and
municipal improvements in the systemic approach, costs are minimized.
8 I 03275 85v I
D. BASE RATE CASE CERTIFICATION
28. As part of its filing, a utility is required to certify that it has filed a base rate case
within the five years prior to the date of its DSIC petition. 66 Pa.C.S. §1353(b) (4).
29. Columbia has provided the required certification as Exhibit NJDK-3 to Ms.
Krajovic's testimony. Columbia filed its last base rate case under which Columbia's current
base rates were established on January 14, 2011. The case was substantially settled with no
specification of a rate of return on equity. The Commission entered its Final Order in
Columbia's rate case on October 14, 2011, at Docket No. R-2010-2215623. In addition,
Columbia has currently pending before the Commission a base rate case at Docket No. R-2012-
2321748, which was filed on September 28, 2012.
E. CUSTOMER NOTICE
Consistent with Act 11 and the Commission's Final Implementation Order, customers will
receive notice of the initial filing of the proposed DSIC through bill inserts beginning at the time
of filing and continuing throughout a 30-day billing cycle. Columbia will begin the bill insert
process on January 2, 2013, concurrent with this filing.
9 I 0327585v1
IlL CONCLUSION
WHEREFORE, Columbia Gas of Pennsylvania. Inc. respectfully requests that the
Pennsylvania Public Utility Commission find that its Distribution System Improvement Charge
contains all necessary items identified in § 1353, and that the Pennsylvania Public Utility
Commission approve Columbia's Distribution System Improvement Charge with an effective
date of March 1, 2013.
Respectfully submitted,
,1 /7CeJt4.Jt (,i) fbA-1Li
Theodore J. Gallagher (ID #90842) Michael W. Hassell (ID #34851) Kimberly S. Cuceia (ID # 308216) Jessica R. Rogers (ID # 309842) Columbia Gas of Pennsylvania, Inc. Post & Schell, P.C. 121 Champion Way, Suite 100 17 North Second Street Canonsburg, PA 15317 12th Floor Phone: 724-416-6347 Harrisburg, PA 17101-1601 Fax: 724-416-6384 Phone: 717-731-1970 E-mail: [email protected] Fax: 717-731-1985
[email protected] E-mail: [email protected] E-mail: jrogerspostschell.com
Of Counsel:
Post & Schell, P.C. Attorneys for Columbia Gas of Pennsylvania, Inc.
Date: January 2, 2013
10 10327585v!
VERIFICATION
I, Nancy J. D. Ktajovic, hereby state that the facts above set forth are true
and correct (or are true and correct to the best of my knowledge, information and
belief) and that I expect to be able to prove the same at a hearing held in this
matter. I understand that the statements made herein are made subject to the
penalties of i8 Pa. C.S. § 4904 (relating to unsworn falsification to authorities).
Date: January 2, 2013
Nancy J. 6. Krajovic Director, Rates and Regulatory Affairs Columbia Gas of Pennsylvania, Inc.
Supplement No. 194 to Tariff Gas - Pa. P.U.C.No. 9
COLUMBIA GAS OF PENNSYLVANIA, INC.
121 Champion Way, Suite 100 Canonsburg 1 Pennsylvania
RATES AND RULES
FOR
FURNISHING GAS SERVICE
IN
THE TERRITORY AS DESCRIBED HEREIN
ISSUED: January 2, 2013
EFFECTIVE: March 3, 2013
ISSUED BY: M. R. KEMPIC, PRESIDENT 121 CHAMPION WAY, SUITE 100
CANONSBURG, PENNSYLVANIA 15317
NOTICE
This Tariff Supplement Makes Changes to the Existing Tariff —See Page No. 2
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
One-Hundred Sixty-ninth Revised Page No. 2 Columbia Gas of Pennsylvania, Inc. Canceling One-Hundred Sixty-eighth Revised Page No. 2
LIST OF CHANGES MADE BY THIS TARIFF SUPPLEMENT Page Page Description Revision Description
Cover Tariff Cover Page Supplement #, Effective & Issue Date.
2 LIstof Changes List of Changes.
4 Table of ContenLs Added Rider DSIC - Distribution System Improvement Charge.
16 Rate Summary Pages Added a footnote to include Rider DSIC where applicable.
17 Rate Summary Pages Added a footnote to include Rider DSIC where applicable.
18 Rate Summary Pages Added a footnote to include Rider DSIC where applicable.
19 Rate Surrimary Pages Added a footnote to include Rider OSlO where applicable.
20 Rate Summary Pages Added a footnote to Include Rider OSlO where applicable.
21 Rider Summary Page Added Rider DSIC.
68 Flexible Rate Provisions Added Rider DSIC.
76 Rate RSS Added Distribution System Improvement Charge.
78 Rate RDS Added Distribution System Improvement Charge.
82 Rate RDGSS Added Distribution System Improvement Charge.
85 Rate RDGDS Added Distribution System improvement Charge.
87 Rate SGSS Added Distribution System Improvement Charge.
90 Rate SGDS Added Distribution System Improvement Charge.
94 Rate SCD Added Distribution System improvement Charge.
97 Rate SDS Added Distribution System Improvement Charge.
101 Rate LGSS Added Distribution System Improvement Charge.
105 Rate LDS Added Distribu lion System Improvement Charge.
lOB Rate MLSS Added Distribution System Improvement Charge.
112 Rate MLDS Added Distribution System Improvement Charge.
177- 180
Rider DSIC-Distribution System Improvement Charge
Added entire text.
Issued: January 2, 2013 M. R. Kempic Effective: March 3, 2013 President
Supplement No. 19410 Tariff Gas - Pa. P.U.C. No. 9
Sixty-first Revised Page No. 4 Columbia Gas of Pennsylvania Inc. Canceling Fifty-ninth Revised Page No. 4
Table of Contents (conVd)
Rate Schedules (cont'd): Sheet No.
SGDS - Small General Distribution Service 89
SCD - Small Commercial Distribution 93
SDS - Small Distribution Service 96
LOSS - Large General Sales Service 100
LDS - Large Distribulion Service 103
MLSS - Main Line Sales Service 107
MLDS - Main Line Distribution Service 111
NCS - Negotiated Contract Service 115
NSS - Negottated Sales Service 117
SDSS - Supplier Default Sales Service 122
Held for Future Use 124
CDS - Cogeneration Distribution Service 125
GDS - Generation Distribution Service 127
NGV - Natural Gas Vehicle Service 129
PS - Propane Service 132
SS - Standby Service 134
Held for Future Use 136
DGDS —Distributed Generation Distribution Service 137
CAP - Customer Assistance Plan 139
Held for Future Use 144- 145
Rider USP - Universal Service Plan 146
Rider CC - Customer Choice 148
Rider EDS - Economic Development Service Rider 149
Purchased Gas Cost Rider 151
Held for Future Use 160
Held for Future Use 161 -164
State Tax Adjustment Surcharge - STAS 165
Rider EBS - Elective Balancing Service 166
Held for Future Use 174- 176
Rider DSIC - Distribution System Improvement Charge 171- 180
Rules Applicable to Distribution Service - RADS:
1. Definitions 181
2, Rules Applicable to All Distribution Service 186
2.2. Electronic Communications 186
2.3. Initial Gas Application 186
2.4. NGS Creditworthiness 187
2.5. Character of Distribution Service 188b
(C)
(C)
(C) Indicates Change
Issued: January 2, 2013 - M. R. Kempic Effective: March 3, 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Sixty-ninth Revised Page No. 16
Columbia Gas of Pennsytvania, Inc. Canceling Ixty-eiglitl1 EeviSed rage NO. lb
Rates per thm
Total Distribution Gas Supply Gas Cost Effective
Retail Service Rate Schedules Charge Charge Adjustment Rate 1/ 3141
Rate RSS - Residential Sales Service Monthly Customer Charge $ 18.73 - - 18.73
Commodity Charge: First2l thms per month 0.1621D 0.42150 2/ 0.00177 0.58537 Over 21 thms per month $ 0.42918 0.42150 2/ 0.00177 0.85245
Customer Transferring from Rate Schedule RDS First 21 thrns per month $ 0.16210 0.42150 2/ - 0.58360 Over 21 thms per month $ 0.42918 0.42150 2/ - 0.85068
Rate SGSS - Small General Sales Service Monthly Customer Charge:
Annual Throughput< 6438thms $ 20.18 - - 20.18 Annual Throughput >= 6438 thms and <= 64380 thms $ 32.09 - - 32.09
Commodity Charge $ 0.32197 0.42150 21 0.00177 0.74524
Customers Transferring from Rate ScheduLe SCD $ 0.32197 0.42150 21 - 0.74347
1/Includes applicable charges for Riders CC, POC, and USP. 2/ Does not reflect the unbundling of uncollectibles related to gas costs. See applicable rate schedule for details. 3/ Excludes State Tax Adjustment Surcharge. See Page 165 herein for detail. 4) Does not include the Rider DSIC. See Page 21 and Pages 177-1 80 herein for details.
Issued: January 2, 2013 M. R. Kempic - President Effective: March 3, 2013
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Thirty-ninth Revised Page No. 17 Uolumbla cias el Iennsylvania, inc. tanceiing I nlriy-elgntn mevisea rage rio.
Rates per thm
Total Distribution Gas Supply Gas Cost Effective
Retail Service Rate Schedules
Charge Charge Adjustment Rate 1/2/
Rate LGSS - Large General Sales Service
Monthly Customer Charge: Annual Throughput < 107300 thms $ 125.12 - - 125.12
Annual Throughput >= 1 07,300 thms but < 536489 thms $ 469.34 - 469.34
Annual Throughput > 536,489 thms but < 1072.989 thms $ 1149.00 - - 1149.00 Annual Throughput >= 1072,989 thms but <3,219000 thms $ 2,050.00 - - 2,050.00 Annual Throughput >= 3219,000 thms but < 7,510,990 thms $ 4,096.00 - - 4,096.00 AnnualThroughput> 7,510,989thms $ 7,322.00 - - 7,322.00
Commodity Charge: First 10,730 thms per Month $ 0.28628 0.39302 0.00177 0.68107
Next 42,920 thms per Month $ 0.28094 0.39302 0.00177 0.67573 Next 53,650 thms per Month $ 0.27777 0.39302 0.00177 0.67256 All thm per Month Over 107,300 $ 0.25803 0.39302 0.00177 0.65282
Rate MLSS - Main Line Sales Service Monthly Customer Charge:
Annual Throughput > 268250 thms but < 536,500 thms $ 469.34 - - 469.34 Annual Throughput >= 536,500 thms but < 1,073,000 thms $ 1,149.00 - - 1,149.00 Annual Throughput >= 1073,000 thms but < 3,219,000 thms $ 2,050.00 - - 2,050.00 Annual Throughput > 3,219,000 thms but <7,611,000 thms $ 4,096.00 - - 4,096.00 Annual Throughput > 7,511,000 thms $ 7,322.00 - - 7,322.00
Commodity Charge: MLS-1 $ 0.15322 0.39302 0.00177 0.54801
MLS-ll AnnualThroughput< 1,073,000thms $ 0.19651 0.39302 0.00177 0.59130 Annual Throughput >= 1,073,000 thms but < 3,219,000 thms 0.18858 0.39302 0.00177 0.58337 Annual Throughput >= 3,219,000 tbms but < 7,511,000 thms $ 0.18253 0.39302 0.00177 0.57732 Annual Throughput >= 7,511,000 thma $ 0.17736 0.39302 0.00177 0.57215
Rate SS - Standby Service $0.77306 per thm based on a customer's Maximum Daily Firm I Requirement. See Pages 134-136 herein for detail.
11 Excludes State Tax Adjustment Surcharge. See Page 165 herein for detail, 2/Does not include the Rider DSIC. See Page 21 and Pages 177-180 herein for details.
lsi.pd .laniiaru 2 7 n1_'I Effective: March 3. 2013
M. R. Kempic - President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Sixty-sixth Revised Page No. 18 LolumIa ias ci Pennsyivania, Inc.
Distribution Service Rate Schedules
Canceling Sixty-fifth Revised Page No. 18
Rates per thm
Total Distribution Gas Supply Gas Cost Effective
Charge Charge Adjustment Rate 1/ 3/4/
Rate RDS - Residential Distribution Service Monthly Customer Charge $ 18.73 Distribution Charge:
Customers Electing CHOICE - 1st Year First 21 thms per month $ 0.16210 Over 21 thms per month $ 0.42918
Customers Electing CHOICE - 2nd Year First 21 thms per month $ 0.16210 Over 21 thms per month $ 0.42918
Rate SCD - Small Commercial Distribution Monthly Customer Charge:
Annual Throughput < 6,438 thms $ 20.18 Annual Throughput >= 6,438 and <= 64,380 thms $ 32.09
Distribution Charge: Customers Electing CHOICE - 1st Year $ 0.32197 Customers Electing CHOICE - 2nd Year $ 0.32197
Rate SGDS - Small General Distribution Service Monthly Customer Charge:
Annual Throughput < 6,438 thms $ 20.18 Annual Throughput >= 6,438 and <64380 thms $ 32.09
Distribution Charge: Priority One DS $ 0.35045 Non-Priority One DS $ 0.20658
Monthly Customer Charge: Annual Throughput >= 64,380 thms and < 107,300 thms $ 125.12 Annual Throughput >= 101,300 thms and <536,490 thms $ 469.34
Distribution Charge $ 0.11416
11Includes applicable charges for Riders CC, PGC, and USP. 2) Subject to the terms and provisions of Rider EBS. 31 Excludes State Tax Adjustment Surcharge. See Page 165 herein for detail. 41 Does not include the Rider DS[C. See Page 21 and Pages 177-180 herein for details.
Issued: January 2. 2013
- - 18.73
- 0.00177 0.16387 - 0.00177 0.43095
- - 0.16210 - - 0.42918
- - 20.18 - - 32.09
- 0.00177 0.32374 - - 0.32197
- - 20.18 - - 32.09
- - 035045 21 - 0.20658
- - 125.12 - - 46934
21 - 0.11416
Fffpctivp Mrh A 9511
M. R. Kern pic - President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Eleventh Revised Page No. 19 Columbia Uas ot Pennsylvania, Inc. Canceling Ninth Revised Page No. 19
Rates per thm
Total Distribution Gas Supply Gas Cost Effective
Charge Charge Adjustment Rate 2/3/
$ 1,227.00 - - 1,227.00 $ 2,190.00 - - 2190.00 $ 4,526.00 - - 4526.00 $ 7,322.00 - - 7322.00
$ 0.09270 1/ - 0.09270 $ 0.08114 1/ - 0.08114 $ 0.06716 1/ - 0.06716
Distribution Service Rate Schedules
Rate LDS - Large Distribution Service Monthly Customer Charge:
Annual Throughput => 536,500 thms but < 1,073000 thms Annual Throughput >= 1,073,000 thms but <3,219,000 thms Annual Throughput >= 3,219,000 thms but <7,511000 thms Annual Throughput >= 7,511,000 thms
Distribution Charge: Annual Throughput => 536,500 thms and < 1073,000 thms Annual Throughput >= 1073,000 thms but < 3,219,000 thms Annual Throughput >= 3,219,000 thrns
Rate MLDS - Main Line Distribution Service Monthly Customer Charge:
Annual Throughput >= 268,250 thms and < 536,500 thms $ 469.34 - - 469.34 Annual Throughput >= 536,500 thms but < 1073,000 thms $ 1,149.00 - - 1,149.00 Annual Throughput >= 1,073,000 thms but <3,219,000 thms $ 2,050.00 - - 2,050.00 Annual Throughput >= 3,219,000 thms but < 7,511,000 thms $ 4096.00 - - 4,096.00 Annual Throughput >= 7,511,000 thms $ 7,322.00 - - 7,322.00
Distribution Charge: MLS-1 $ 0.00935 1/ - 0.00935 MLS-Il
Annual Throughput < 1,073, 000 thms $ 0.05264 1/ - 0.05264 Annual Throughput >= 1073,000thms but< 3,219,000 thms $ 0.04471 11 - 0.04471 Annual Throughput > 3,219,000 thms but < 7,511000 thms $ 0.03866 1/ - 0.03866 Annual Throughput > 7,511,000 thms $ 0.03349 1/ - 0.03349
11 Subject to the terms and provisions of Rider EBS. 2/ Does not reflect the State Tax Adjustment Surcharge. See Page 165 herein for detail. 3/ Does not include the Rider DSIC. See Page 21 and Pages 177-180 heretn for details. ued: January 2, 2013 Effective: March 3, 2013
Issued by: M. R. Kempic - President
Supplement No. 194 to Tariff Gas - Pa P.U.C. No. 9
Sixty-sixth Revised Page No. 20 (.;oiumLHa (ias ot F'ennsylvania, Inc. (.;ancellng ixty-Tu1tfl hevisec1 iage NO. ZU
Rates per thrn
Total Distribution Gas Supply Gas Cost Effective
Retail Service and Distribution Service Rate Schedules Charge Charge Adjustment Rate 1/ 2/ 3141
Rate RDGSS - Residential Distrbuted Generation Sales Service Monthly Customer Charge 18.73 - - 18.73
Commodity Charge; First 21 thms per month 0.16210 0.42150 2/ 0.00177 0.58537 Over 21 thms per month $ 0.42918 0.42150 21 0.00177 0.85245
Customers Transferring from RDGDS or RDS Commodity Charge: $ 0.16210 0.42150 21 - 0.58360
First 21 thms per month $ 0.42918 0.42150 2/ - 0.85068 Over 21 thms per month
Rate RDGDS - Residential Distrbuted Generation Distribution Service Monthly Customer Charge $ 18.73 - - 18.73
Commodity Charge: First 21 thms per month $ 0.16210 - - 0.16210 Over 21 thms per month $ 0.42918 - - 0.42918
1/Includes applicable charges for Riders CC, PGC, and USP. 21 Does not reflect the unbundling of uncollectibles related to gas costs. See applicable rate schedule for details 3/ Excludes State Tax Adjustment Surcharge. See Page 165 herein for detail. 4/ Does not include the Rider DSIC. See Page 21 and Pages 177- 180 herein for details. ued: January 2. 2013 Effective: March 3, 2013
M. R. Kempic - President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Seventy-fourth Revised Page No. 21
Columbia Gas ot Pennsylvania, Inc. Gancelin
Revised E'age NO. Zi
Rates per thm
Riders Rate
Applicable Rate Schedules
$1 thm
Customer Choice - Rider CC Capacity Choice Administration
Columbia Gulf Transmission Refund
Columbia Gulf and Columbia Gas Transmission Casho ut/Penalty Credit Proceeds
Universal Service Plan - Rider USP
Distribution System Improvement Charge - Rider DSIC
Elective Balancing Service - Rider EBS Option 1 - Small Customer Option 1 - Large Customer
Option 2- Small Customer Option 2 - Large Customer
Purchased Gas Cost - Rider PGC Demand
Cost of Gas E-Factor Total
Commodity Cost of Gas E-Factor Total
Total Purchased Gas Cost Rate
January 2.
- RSSIRDS - SGS/SGDS/SCD/PS
(0.00133) SGSS
(0.00053) SGSS/SGDSISCD
0.04671 RSS/RDS/RDGSS/RDGDS
1.9% This percentage is applied to a portion of the Distribution Charge and the Customer Charge. See Pages 177-180 for Rider DSIC details.
0.02103 SGDS/SDS 0.00896 LDS1MLS
0.00697 SGDS/SDS 0.00226 LDS/MLS
0.13097 0.01290 0.14387
0.39302 0.00177
RSS/RDGSSJSGS/LGSS/M LSS
Effective: March 3. 2013
M. R. Kern plc - President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No.9
Third Revised Page No. 68 Columbia Gas of Pennsylvania, Inc. Canceling Second Page No. 68
RULES AND REGULATIONS GOVERNING THE DISTRIBUTION AND SALE OF GAS (Continued)
20. Flexible Rate Provisions
20.1 Applicability
Customers receiving service under Rate Schedules SDS, LDS, RSS, RDS, RDGSS, RDGDS, DGDS, PS, SGSS, LGSS, SGDS, SCE, SS, NSS, MLSS, and MLDS ("Primary Schedule") may be charged a flexible distribution charge with respect to competition from alternate fuels.. Service under Rate RSS, RDS, RDGSS and RDGDS shall be firm and the Company will maintain firm capacity to serve such customers. Gas Costs to Rate Schedules RSS and RDS will not be flexed.
20.2 Election of Flexible Rate
Components of a customer's rate may be lowered when the customer submits a sworn affidavit that a lower rate is required to meet competition from an alternate fuel. Rate components eligible for a downward adjustment include the distribution charge, the elective balancing service charge for distribution service, the Rider DSIC and the retainage percentage for distribution service. (C)
Prior to flexing distribution charges for distribution service customers, the Company may reduce charges that are for recovery of balancing service charges under Rider EBS and/or the retainage percentage applied to the gas received on behalf of the distribution service customer. However, any discount to the retainage percentage undertaken to compete with another NGDC will not be recoverable by the Company in its annual 1307(f) filing.
The Company reserves the right to verify the accuracy of statements included in this affidavit and the right to make final determination as to the quantities of natural gas used in each billing period in place of alternate fuels. The Company will notify customer of the applicable charge, if lower than the applicable distribution charge in the Primary Rate Schedule, that the Company determines is required to meet the delivered price of the alternate fuel four (4) days prior to the beginning of each billing month unless the rate is the same as charged by the Company in the prior month.
The Company will only lower its distribution charge below the maximum rate under the Primary Rate Schedule as a last resort, and only to the extent it is necessary to meet (he demonstrated competitive alternate fuel price. Any lowered distribution charge shall be offered regardless of whether the customer is receiving sales or distribution service. For customers eligible for service under Rate RDS and SCD, the Company will advise NGSs upon request whether a particular customer is receiving or is eligible to receive a lowered distribution charge.
(C) Indicates Change
Issued: January 2, 2013 M. R. Kempic Effective: March 3, 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Forty-first Revised Page No. 76 Columbia Gas of Pennsylvania, Inc. Canceling Thirty-ninth Revised page No. 76
RATE RSS - RESIDENTIAL SALES SERVICE
APPLICABILITY
Throughout the territory served under this Tariff.
AVAILABILITY
Available, at one location, for the total requirements of any residential customer.
RATE
The customers under this rate schedule shall be subject to a monthly customer charge, a natural gas supply charge and a distribution charge.
The rate information is detailed in the Rate Summary pages of this tariff.
If a customer transfers to this rate from Rate RIDS-Residential Distribution Service then for a period of twelve months, the rate shall be adjusted to exclude the amount per thrn equal to the E' Factor for the twelve months ended September30 included in the then applicable Purchased Gas Commodity Rate.
The above distribution charge may be flexed in accordance with the Flexible Rate Provisions set forth in the Rules and Regulations of this Tariff.
The PGCC and Capacity Assignment Credit (aka the Price-to-Compare) will be increased by 1 .52% to reflect the unbundling of uncollectibles related to gas costs.
MINIMUM MONTHLY CHARGE
The minimum monthly charge shall be the customer charge.
STATE TAX ADJUSTMENT SURCHARGE
The charges described in this rate schedule are subject to a State Tax Adjustment Surcharge as set forth in this tariff.
PURCHASED GAS COST RIDER
The distribution and natural gas supply charges include recovery of purchased gas costs pursuant to the Purchased Gas Cost Rider of this tariff.
USP COSTS AND CUSTOMER CHOICE COSTS
The distribution charge is subject to Rider Universal Services Plan and Rider Customer Choice as specified within Rider USP and Rider Customer Choice in this tariff.
DISTRIBUTION SYSTEM IMPROVEMENT CHARGE
(C)
Rate RSS is subject to a Distribution System Improvement Charge as specified within Rider DSIC of this tariff.
(C) Indicates Change
Issued: January 2, 2013 M. R. Kempic Effective: March 3, 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Thirty-eighth Revised Page No. 78 Columbia Gas of Pennsylvania, Inc. Canceling Thirty-sixth Revised Page No. 78
RATE RDS - RESIDENTIAL DISTRIBUTION SERVICE
APPLICABILITY
Throughout the territory served under this Tariff.
AVAILABILITY
Available to any residential customer meeting the following conditions:
1. The customer does not take service under any other rate schedule.
2. The customer or group of customers have an aggregate annual demand of at least 53,650 thms or a minimum of 50 customers and in compliance with the aggregation provisions in the Rules Applicable to Distribution Service elects an NGS to provide natural gas commodity service. The gas supply for each aggregation must enter the Companys system at a city gate(s) used by the Company to serve the customers unless otherwise permitted by Columbia.
CHARACTER OF SERVICE
Service furnished pursuant to this rate schedure shall be considered firm service.
RATE
The customers under this rate schedule shall be subject to a monthly customer charge and a distribution charge.
The rate information is detailed in the Rate Summary pages of this tariff.
The Distribution Charges include the applicable Purchase Gas Demand Cost rate. The distribution charge may be flexed in accordance with the Flexible Rate Provisions set forth in the Rules and Regulations of this Tariff.
In addition, if the customer transfers to this rate from rate RSS-Residential Sales Service, then for a period of twelve months, the rate shall be adjusted to include the amount per thm equal to the "E" Factor for the twelve months ended September 30 included in the then-applicable Purchased Gas Commodity Cost rate.
MINIMUM MONTHLY CHARGE
The minimum monthly charge shall be the Customer Charge.
PURCHASED GAS COST RIDER
The above distribution charges include recovery of purchased gas demand costs pursuant to the Purchased Gas Cost Rider as set forth in this Tariff.
STATE TAX ADJUSTMENT SURCHARGE
The charges described in this rate schedule are subject to a State Tax Adjustment Surcharge as set forth in this tariff.
USP COSTS AND CUSTOMER CHOICE COSTS
The distribution charges are subject to Rider Universal Service Plan and Rider Customer Choice as specified within Rider USP and Rider Customer Choice in this tariff.
DISTRiBUTION SYSTEM IMPROVEMENT CHARGE
(C)
Rate RDS is subject to a Distribution System Improvement Charge as specified within Rider DSIC of this tariff.
(C) Indicates Change
Issued: January 2, 2013 M. R. Kempic Effective: March 3,2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9 Eighth Revised Page No 82
Columbia Gas of Pennsylvania, Inc. Canceling Sixth Revised Page No. 82
RATE RDGSS - RESiDENTIAL DISTRIBUTED
GENERATION SALES SERVICE (Continued)
MINIMUM MONTHLY CHARGE
Where the Company incurs additional costs to establish service under this rate schedule, a minimum monthly charge may be determined individually for each customer served under this rate schedule and the amount shall be included in the customers service agreement. The service agreement will be for a term ol not less than three (3) years, unless mutually agreed to between the Company and the customer. The minimum charge will be based on the actual additional costs to the Company, if applicable, to serve a generation customer. The payment of such minimum charge does not relieve the customer from any minimum charge obligation applicable to service received by the customer under any of the Company's other rate schedules.
STATE TAX ADJUSTMENT SURCHARGE
The charges described in this rate schedule are subject to a State Tax Adjustment Surcharge as set forth in this tariff.
PURCHASED GAS COST RiDER
The distribution and commodity charges include recovery of purchased gas costs pursuant to the Purchased Gas Cost Rider of this tariff.
UNIVERSAL SERVICE PLAN AND CUSTOMER CHOICE COSTS
The distribution charge is subject to Rider USP costs and Rider CC costs as specified within Rider USP and Rider Customer Choice in this tariff.
DISTRIBUTION SYSTEM IMPROVEMENT CHARGE
Rate RDGSS is subject to a Distribution System Improvement Charge as specified within Rider DSIC of this tariff.
TERMS OF PAYMENT
Bills for sales service will be rendered monthly and are due and payable upon presentation. All bills shall be paid on or before the final date of payment shown on the bill, which date shall be not less than twenty (20) days after presentation (date of postmark). If the customer fails to pay the full amount of any bill a delayed payment penalty charge of one and one-quarter percent (1 1/4%) per month will accrue on the portion of the bill that is unpaid on the due date.
(C)
(C) Indicates Change
Issued: January 2, 2013 M. R. Kempic Effective: March 3, 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Ninth Revised Page No. 85 Columbia Gas of Pennsylvania, Inc. Canceling Seventh Revised Page No. 85
RATE RDGDS - RESIDENTIAL DISTRIBUTEDGENERATION DISTRIBUTION SERVICE (Continued)
MINIMUM MONTHLY CHARGE
Where the Company incurs additional costs to establish service under this rate schedule, a minimum monthly charge may be determined individually for each customer served under this rate schedule and the amount shall be included in the customer's service agreement. The service agreement will be for a term of not less than three (3) years, unless mutually agreed to between the Company and the customer. The minimum charge will be based on the actual additional costs to the Company, if applicable, to serve a generation customer. The payment of such minimum charge does not relieve the customer from any minimum charge obligation applicable to service received by the customer under any of the Company's other rate schedules.
TERMS OF PAYMENT
Bills for distribution service will be rendered monthly and are due and payable upon presentation. All bills shall be paid on or before the final date of payment shown on the bill, which date shall not be less than twenty (20) days after presentation (date of postmark). If the customer fails to pay the full amount of any bill a delayed payment penalty charge of one and one-quarter percent (1 1/4%) per month will accrue on the portion of the bill that is unpaid on the due date.
SPECIAL PROVISIONS
1. If service under this rate schedule is discontinued at the request of the Customer, the Company shall be under no obligation to reconnect service to the same Customer on the same premises until the Customer pays the monthly customer charge for each month of the intervening period, but not to exceed twelve (12) months, and any amount due to the Company under a service agreement. Restoration of service will not be denied for the nonpayment of NGS charges.
2. Where a Customer has installed a gas light(s) in lighting devices approved by the Company, and the gas used by such light(s) is unmetered, the gas consumed by such light(s) shall be assumed to be twenty-one (21) thms per month when the Btu/hr input rating for such light(s) is 2700 or less. For each additional 1,350 Btulhr or fraction thereof, the assumed consumption shall be increased by eleven (11) thms per month. Such assumed consumption shall be billed under the rates contained herein, or if in combination with metered usage under this rate schedule, shall be added to the Customer's metered usage and the total billed under the rates contained herein.
UNIVERSAL SERVICE PLAN AND CUSTOMER CHOICE COSTS
The distribution charges are subject to Rider USP costs and Rider CC costs as specified within Rider USP and Rider Customer Choice in this tariff.
STATE TAX ADJUSTMENT SURCHARGE
The charges described in this rate schedule are subject to a State Tax Adjustment Surcharge as set forth in this tariff.
APPLICABLE SALES SERVICE RATE
Except as otherwise provided under the Rules Applicable to Distribution Service, a customer or its NGS under this Rate Schedule desiring to purchase gas or to replace under-deliveries of gas or over consumption of gas by the customer, to which the Rules Applicable to Distribution Service would otherwise be applicable, shall be charged the current month's average daily city gate rate, as published in Gas Daily, times 120%, plus applicable taxes and the delivery charge.
DISTRIBUTION SYSTEM IMPROVEMENT CHARGE
Rate RDGDS is subject to a Distribution System Improvement Charge as specified within Rider DSIC of this tariff.
(C) indicates Change
(C)
Issued January 2, 2013 M. R. Kempic Effective: March 3, 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Seventh Revised Page No. 87 Columbia Gas of Pennsylvania, Inc. Canceling Fifth Revised Page No. 87
RATE SGSS - SMALL GENERAL SALES SERVICE (Continued)
STATE TAX ADJUSTMENT SURCHARGE
The State Tax Adjustment Surcharge will be applied to the non-Purchased Gas Cost portion of the charges set forth in this rate schedule.
PURCHASED GAS COST RIDER
The distribution and natural gas supply charges for sales service include recovery of purchased gas costs pursuant to the Purchased Gas Cost Rider as set forth in this tariff.
CUSTOMER CHOICE COSTS
The distribution charge is subject to a Customer Choice charge pursuant to Rider CC.
DISTRIBUTION SYSTEM IMPROVEMENT CHARGE
(C)
Rate SGSS is subject to a Distribution System Improvement Charge as specified within Rider DSIC of this tariff.
TERMS OF PAYMENT
Bills for distribution service will be rendered monthly and are due and payable upon presentation. All bills shall be paid on or before the final date of payment shown on the bill, which date shall be not less than fifteen (15) days after presentation (date of postmark).
If the customer fails to pay the full amount of any bill a delayed payment penalty charge of one and one-quarter percent (1 114%) per month will accrue on the portion of the bill that is unpaid on the due date.
CUSTOMER DEVELOPMENTIRETENTION PROVISIONS
1. An existing Customer currently receiving service under this rate schedule or a potential Customer eligible to receive service under this rate schedule is eligible to receive special development/retention rates, if the customer meets the following conditions:
a. The Customer agrees to enter into a three-year contract for service under this rate schedule.
(C) Indicates Change
Issued: January 2, 2013 M. R. Kempic Effective: March 3, 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Sixth Revised Page No. 90 Columbia Gas of Pennsylvania, Inc. Canceling Fourth Revised Page No. 90
RATE SGDS - SMALL GENERAL DISTRIBUTION SERVICE (Continued)
DETERMINATION OF MONTHLY CUSTOMER CHARGE
The Customer Charge will be determined based upon the Customer's actual throughput quantities, including sales and distribution, measured in therms (thms), for the most recent twelve-month period ended October 31. If a Customer does not have sufficient consumption history to determine its customer charge based on twelve months, the Customer Charge will be developed by annualizing the consumption history available. In the instance where a customer has no consumption history, the Company will request the Customer to submit estimated annual gas requirements, including sales and distribution, upon which to develop the Customer Charge. The Company in all cases retains the right to review and modify the Customer's estimate where necessary. A customer's Customer Charge will remain constant annually, subject to change January 1 of each year.
In all cases, the Company reserves the right to review the Customer Charge and, upon receipt of satisfactory proof, to adjust the Customer Charge to reflect the installation and use of energy efficient gas burning equipment, or the implementation of energy conservation practices or measures, which results in a measurable permanent change in the customer's requirement or consumption.
MINIMUM MONTHLY CHARGE
The minimum monthly charge shall be the sum of (a) the Customer Charge; plus (b) purchase gas demand charges, if any, under Rate SS. In the event of curtailment in the delivery of gas by the Company below the Maximum Daily Firm Requirement of the Customer, if any, under Rate 55, or complete or partial suspension of operation by the customer due to strikes, fires, floods, explosions or other similar casualties, the Customer Charge shall be reduced in direct proportion to the ratio which the number of days of curtailed service or complete or partial suspension of operation bears to the number of days in the billing period.
STATE TAX ADJUSTMENT SURCHARGE
The charges are subject to a State Tax Adjustment Surcharge as set forth in this tariff.
PURCHASED GAS COST RIDER
The distribution charges for Priority One Service include recovery of Purchased Gas Demand Costs pursuant to the Purchased Gas Cost Rider as set forth in this tariff.
ELECTIVE BALANCING SERVICE RIDER
Distribution service under this rate schedule shall be subject to the provisions of Rider EBS as set forth in this tariff.
CUSTOMER CHOICE COSTS
The distribution charge is subject to a Customer Choice charge pursuant to Rider CC.
DISTRIBUTION SYSTEM IMPROVEMENT CHARGE
Rate SGDS is subject to a Distribution System Improvement Charge as specified within Rider DSIC of this tariff.
APPLiCABLE SALES SERVICE RATE
Priority One customers desiring to purchase gas shall be charged an amount for recovery of purchased gas costs as set forth in the Rules Applicable to Distribution Service, plus the Priority One Service rate.
(C) Indicates Change
(C)
Issued: January 2, 2013 M. R. Kempic Effective: March 3, 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Ninth Revised Page No. 94 Columbia Gas of Pennsylvania, Inc. Canceling Seventh Revised Page No. 94
RATE SCD - SMALL COMMERCIAL DISTRIBUTION (Continued)
CUSTOMER CHOICE COSTS
The distribution charges are subject to a Customer Choice charge pursuant to Rider CC.
DISTRIBUTION SYSTEM IMPROVEMENT CHARGE
Rate SCD is subject to a Distribution System Improvement Charge as specified within Rider DSIC of this tariff.
PURCHASED GAS COST RIDER
The distribution charges include recovery of purchased gas demand costs pursuant to the Purchased Gas Cost Rider as set forth in this Tariff.
TERMS OF PAYMENT
Bills for distribution service will be rendered monthly and are due and payable upon presentation. All bills shall be paid on or before the final date of payment shown on the bill, which date shall not be less than fifteen (15) days after presentation (date of postmark).
If the customer fails to pay the full amount of any bill a delayed payment penalty charge of one and one-quarter percent (1 1/4%) per month will accrue on the portion of the bill that is unpaid on the due date.
SPECIAL PROVISIONS
1. If service under this rate schedule is discontinued at the request of the customer, the Company shall be under no obligation to reconnect service to the same customer on the same premises until the customer pays the monthly minimum charge for each month of the intervening period, but not to exceed twelve (12) months.
2. Where a customer has installed a gas light(s) in lighting devices approved by the Company, and thegas used by such light(s) is unrnetered, the gas consumed by such light(s) shall be assumed to be twenty-one (21) thms per month when the Btu/hr input rating for such light(s) is 2,700 or Less. For each additional 1.350 Btufhr or fraction thereof, the assumed consumption shall be increased by eleven (11) thms per month. Such assumed consumption shall be billed under the rates contained herein, or if in combination with metered usage under this rate schedule, shall be added to the customer's metered usage and the total billed under the rates contained herein.
3. The customer, at its option, may receive a separate bill from its NGS for services provided by the NGS. Otherwise, all charges for natural gas service to the customer will be billed by the Company. When the Company bills for the NGS, the Company will have the right to terminate service for failure to pay the NGS's Natural Gas Supply Services charges in compliance with all applicable laws and regulations regarding termination of service.
4. Before participating in Choice Service, customers with arrears, who are not already subject to a payment plan, shall be required to enter into a payment plan with the Company.
5. The Company will purchase at a discount the accounts receivable from NGSs who elect to have the Company bill the NGS's Natural Gas Supply Service charges.
6. Effective eighteen (18) months after the Public Utility Commission issues a final order in Docket No. P-2009-2099333, an NGS may choose the Company's consolidated billing option or issue its own bills for Gas Supply Service charges (Billing Option 1 or Billing Option 2 as described in the Rules Applicable Only to Choice Service) for all or a portion of its customers eligible for Rate SCD.
(C) Indicates Change
(C)
Issued: January 2, 2013 - M. R. Kempic Effective: March 3, 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Ninth Revised Page No. 97 Columbia Gas of Pennsylvania, Inc. Canceling Seventh Revised Page No. 97
RATE SDS - SMALL DISTRIBUTION SERVICE (Continued)
RATE
The customers under this rate schedule shall be subject to a monthly customer charge and a distribution charge.
The rate information is detailed in the Rate Summary pages of this tariff.
The customer charge will be determined based upon the customer's actual throughput quantities, including sales and distribution, measured in therrns (thms), for the most recent twelve-month period ended October 31. If a customer does not have sufficient consumption history to determine its customer charge based on twelve months, the customer charge will be developed by annualizing the consumption history available. In the instance where a customer has no consumption history, the Company will request the customer to submit estimated annual gas requirements, including sales and distribution, upon which to develop the customer charge. The Company in all cases retains the right to review and modify the customer's estimate where necessary. A customer's customer charge will remain constant annually, subject to change January I of each year.
In all cases, the Company reserves the right to review the customer charge and, upon receipt of satisfactory proof, to adjust the customer charge to reflect the installation and use of energy efficient gas burning equipment, or the implementation of energy conservation practices or measures, which results in a measurable permanent change in the customer's requirement or consumption.
The above distribution rates may be flexed in accordance with the Flexible Rate Provisions set forth in the Rules and Regulations of this Tariff.
MINIMUM MONTHLY CHARGE
The minimum monthly charge shall be the sum of (a) the customer charge; plus (b) purchased gas demand charges, if any, under Rate SS. In the event of curtailment in the delivery of gas by the Company below the Maximum Daily Firm Requirement of the customer, if any, under Rate SS, or complete or partial suspension of operation by the customer due to strikes, fires, floods, explosions or other similar casualties, the customer charge shall be reduced in direct proportion to the ratio which the number of days of curtailed service or complete or partial suspension of operation bears to the number of days in the billing period.
STATE TAX ADJUSTMENT SURCHARGE
The above charges are subject to a State Tax Adjustment Surcharge as set forth in the tariff.
ELECTIVE BALANCING SERVICES RIDER
Distribution service under this rate schedule shall be subject to the provisions of Rider EBS as set forth within this tariff.
DISTRIBUTION SYSTEM IMPROVEMENT CHARGE
(C)
Rate SDS is subject to a Distribution System Improvement Charge as specified within Rider DSIC of this tariff.
(C) Indicates Change
Issued: January 2, 2013 M. R. Kempic Effective: March 3, 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Thirty-sixth Revised Page No. 101 Columbia Gas of Pennsylvania, Inc. Canceling Thirty-fourth Revised Page No. 101
RATE LGSS - LARGE GENERAL SALES SERVICE (Continued)
MINIMUM MONTHLY CHARGE
The minimum monthly charge shall be the customer charge, except that in the event of curtailment in the delivery of gas by the Company or complete or partial suspension of operation by the customer due to strikes, fires, floods, explosions or other similar casualties, the Customer Charge shall be reduced in direct proportion to the ratio which the number of days of curtailed service or complete or partial suspension of operation bears to the number of days in the billing period.
STATE TAX ADJUSTMENT SURCHARGE
The charges described in this rate schedule are subject to a State Tax Adjustment Surcharge as set forth in this tariff.
PURCHASED GASCOST RIDER
The distribution and commodity charges include recovery of purchased gas costs pursuant to the Purchased Gas Cost Rider as set forth in this tariff.
DISTRI BUTION SYSTEM IMPROVEMENT CHARGE
(C)
Rate LGSS is subject to a Distribution System Improvement Charge as specified within Rider DSIC of this tariff.
TERMS OF PAYMENT
Bills for sales service will be rendered monthly and are due and payable upon presentation. All bills shall be paid on or before the final date of payment shown on the bill, which date shall be not less than fifteen (15) days after presentation (date of postmark).
If the customer fails to pay the full amount of any bill, a delayed payment penalty charge of one and one-quarter percent (1 1/4%) per month will accrue on the portion of the bill that is unpaid on the due dale.
(C) Indicates Change
Issued: January 2, 2013 M. R. Kempic Effective: March 3, 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9 Tenth Revised Page No. 105
Columbia Gas of Pennsylvania, Inc. Canceling Eighth Revised Page No. 105
RATE LDS - LARGE DISTRIBUTION SERVICE (Continued)
MINIMUM MONTHLY CHARGE
The minimum monthly charge shall be the sum of (a) the Customer Charge; plus (b) purchased gas demand charges, if any, under Rate SS. In the event of curtailment in the delivery of gas by the Company below the Maximum Daily Firm Requirement of the Customer, if any, under Rate SS, or complete or partial suspension of operation by the customer due to strikes, fires, floods, explosions or other similar casualties, the Customer Charge shall be reduced in direct proportion to the ratio which the number of days of curtailed service or complete or partial suspension of operation bears to the number of days in the billing period.
STATE TAX ADJUSTMENT SURCHARGE
The charges described in this rate schedule are subject to a State Tax Adjustment Surcharge as set forth in the tariff.
ELECTIVE BALANCING SERVICES RiDER
Distribution service under this rate schedule shall be subject to the provisions of Rider EBS as set forth in this tariff.
DISTRIBUTION SYSTEM IMPROVEMENT CHARGE
Rate LDS is subject to a Distribution System Improvement Charge as specified within Rider DSIC of this tariff.
APPLICABLE SALES SERVICE RATE
Customers under this Rate Schedule desiring to purchase gas shall be charged an amount for recovery of purchased gas costs as set forth in the Rules Applicable to Distribution Service plus the non-gas portion of distribution rates contained in the first block of Rate SGS - Small General Service.
Provided, however, that sales service hereunder shall be considered imbalance gas as defined in the Consumption in Excess of Deliveries section in Paragraph 3 of the Rules Applicable to Distribution Service of this tariff. The Company undertakes no responsibility to obtain sufficient gas supplies to avoid interruption of sales service on a daily basis, and sales service is totally interruptible on any day when the Company gives notice to the customer that gas supply is inadequate to supply the customer's requirements, except to the extent the customer nominates Maximum Daily Firm Requirement under Rate SS.
The Company shall give the customer 2 hours advance notice of interruption. Customer agrees that Company shall not be liable for any loss or damage that may be sustained by the customer by reason of any interruption of service.
On any day when the Customer has been given notice by the Company to interrupt, any quantity of gas taken in excess of the quantity specified to be made available that day shall constitute unauthorized takes and shall be subject to the charges set forth in the Rules Applicable to Distribution Service. Payment of such penalty charge shall be in addition to the charges specified herein.
(C)
(C) Indicates Change
issued: January 2, 2013 M. R. Kempic Effective: March 3, 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Eighth Revised Page No. 108 Columbia Gas of Pennsylvania, Inc. Canceling Sixth Revised Page No. 108
RATE MLSS - MAIN LINE SALES SERVICE (Continued)
DETERMINATION OF MONTHLY CUSTOMER CHARGE
The customer charge will be determined based upon the customer's actual throughput quantities, including sales and distribution if the customer previously contracted for distribution service, measured in therms (thms), for the most recent twelve-month period ended October 31. If a customer does not have sufficient consumption history to determine its customer charge based on twelve months, the Customer Charge wiLl be developed by annualizing the consumption history available. In the instance where a customer has no consumption history, the Company will request the customer to submit estimated annual gas requirements, upon which to develop the Customer Charge. The Company in all cases retains the right to review and modify the customer's estimate where necessary. A customer's customer charge will remain constant annually, subject to change January 1 of each year.
In all cases, the Company reserves the right to review the customer charge and, upon receipt of satisfactory proof, to adjust the customer charge to reflect the installation and use of energy efficient gas burning equipment, or the implementation of energy conservation practices or measures, which results in a measurable permanent change in the customer's requirement or consumption.
MINIMUM MONTHLY CHARGE
The minimum monthly charge shall be the Customer Charge. In the event of curtailment in the delivery of gas by the Company or complete or partial suspension of operation by the customer due to strikes, fires, floods, explosions or other similar casualties, the Customer Charge shall be reduced in direct proportion to the ratio which the number of days of curtailed service or complete or partial suspension of operation bears to the number of days in the billing period.
STATE TAX ADJUSTMENT SURCHARGE
The charges described in this rate schedule are subject to a State Tax Adjustment Surcharge as set forth in the tariff.
DISTRI BUTION SYSTEM IMPROVEMENT CHARGE
Rate MLSS is subject to a Distribution System Improvement Charge as specified within Rider DSIC of this tariff.
(C)
(C) Indicates Change
lssued January 2, 2013 M. R. Kempic Effective: March 3, 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9 Tenth Revised Page No. 112
Columbia Gas of Pennsylvania, Inc. Canceling Eighth Revised Page No. 112
RATE MLDS - MAIN LINE DISTRIBUTION SERVICE (Continued)
RATE
The customers under this rate schedule shall be subject to a monthly customer charge, and a distribution charge.
The rate information is detailed in the Rate Summary pages of this tariff.
The applicable distribution charge for all distribution quantities for MLDS Class II customers shall be determined based upon the Customer Charge group in which the Customer is placed, as established annually.
The distribution rates may be flexed in accordance with the Flexible Rate Provisions set forth in the Rules and Regulations of this Tariff.
STATE TAX ADJUSTMENT SURCHARGE
The charges described in this rate schedule are subject to a State Tax Adjustment Surcharge as set forth in the tariff.
ELECTIVE BALANCiNG SERVICES RIDER
Distribution service under this rate schedule shall be subject to the provisions of Rider EBS as set forth in this tariff.
DISTRIBUTION SYSTEM IMPROVEMENT CHARGE
Rate MLDS is subject to a Distribution System Improvement Charge as specified within Rider DS1C of this tariff.
DETERMINATION OF MONTHLY CUSTOMER CHARGE
The customer charge will be determined based upon the customer's actual throughput quantities, including sales and distribution, measured in therms (thms), for the most recent twelve-month period ended October 31. If a customer does not have sufficient consumption history to determine its customer charge based on twelve months, the customer charge will be developed by annualizing the consumption history available. In the instance where a customer has no consumption history, the Company will request the customer to submit estimated annual gas requirements, including sales and distribution, upon which to develop the customer charge. The Company in all cases retains the right to review and modify the customer's estimate where necessary. A customer's customer charge will remain constant annually, subject to change January 1 of each year.
In all cases, the Company reserves the right to review the customer charge and, upon receipt of satisfactory proof, to adjust the customer charge to reflect the installation and use of energy efficient gas burning equipment, or the implementation of energy conservation practices or measures, which results in a measurable permanent change in the customer's requirement or consumption.
MINIMUM MONTHLY CHARGE
The minimum monthly charge shall be the sum of (a) the Customer Charge; plus (b) purchased gas demand charges, if any, under Rate SS. In the event of curtailment in the delivery of gas by the Company below the Maximum Daily Firm Requirement of the Customer, if any, under Rate SS, or complete or partial suspension of operation by the customer due to strikes, fires, floods, explosions or other similar casualties, the Customer Charge shall be reduced in direct proportion to the ratio which the number of days of curtailed service or complete or partial suspension of operation bears to the number of days in the billing period.
(C) Indicates Change
(C)
Issued January 2, 2013 M. R. Kempic Effective: March 3, 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Columbia Gas of Pennsylvania, Inc. Original Page No. 177
RIDER DSIC - DISTRIBUTION SYSTEM IMPROVEMENT CHARGE (C)
In addition to the net charges provided for in this Tariff, a charge of 1.9% will apply consistent with the Commission Order dated at Docket No. P-2012-2338282 approving the DSIC.
GENERAL DESCRIPTION
Purpose
To recover the reasonable and prudent costs incurred to repair, improve, or replace eligible property which is completed and placed in service and recorded in the individual accounts, as noted below, between base rate cases and to provide the Utility with the resources to accelerate the replacement of aging infrastructure, to comply with evolving regulatory requirements and to develop and implement solutions to regional supply problems.
The costs of extending facilities to serve new customers are not recoverable through the DSIC.
Eligible Property
The DSIC-eligible property will consist of the following:
- Piping (account 376); - Couplings (account 376); - Gas services lines (account 380) and insulated and non-insulated fittings (account 378); - Valves (account 376); - Excess flow valves (account 376); - Risers (account 376); - Meter bars (account 382); - Meters (account 381); - Unreimbursed costs related to highway relocation projects where a natural gas distribution
company or city natural gas distribution operation must relocate its facilities; and - Other related capitalized costs.
Effective Date
The DSIC will become effective March 3, 2012.
(C) Indicates Change
Issued: January 2, 2013 M. R. Kempic Effective: March 3, 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No.9
Columbia Gas of Pennsylvania, Inc. Original Page No. 178
RIDER DSIC - DISTRIBUTION SYSTEM IMPROVEMENT CHARGE (Continued) (C)
COMPUTATION OF THE DSIC
Calculation
The initial DSIC, effective March 3, 2013, shall be carculated to recover the fixed costs of eligible plant additions that have not previously been reflected in the rates or rate base and will have been placed in service b.etween November 1, 2012 and January 31, 2013. Thereafter, the DSIC will be updated on a quarterly basis to reflect eligible plant additions placed in service during the three-month periods ending one month prior to the effective date of each DSIC update. Thus, changes in the DSIC rate will occur as follows:
Effective Date of Change Date to which DSIC-Eliqible Plant Additions Reflected March November through January June February through April
September May through July December August through October
Determination of Fixed Costs
The fixed costs of eligible distribution system improvements projects will consist of depreciation and pre-tax return, calculated as follows:
1. Depreciation: The depreciation expense shall be calculated by applying the annual accrual rates employed in the Utility's most recent base rate case for the plant accounts in which each retirement unit of DSIC-eligibte property is recorded to the original cost of DSIC-eligible property.
2. Pre-tax return: The pre-tax return shall be calculated using the statutory state and federal income tax rates, the Utility's actual capital structure and actual cost rates for long-term debt and preferred stock as of the last day for the three-month period ending one month prior to the effective date of the DS1C and subsequent updates. The cost of equity will be the equity return rate approved in the last fully litigated base rate proceeding for which a final order was entered not more than two years prior to the effective date of the DS1C. If more than two years shall have elapsed between the entry of such a final order and the effective date of the DSIC, then the equity return rate used in the calculation will be the equity return rate calculated by the Commission in the most recent Quarterly Report on the Earnings of Jurisdictional Utilities released by the Corn mission.
(C) Indicates Change
Issued: January 2, 2013 M. R. Kempic Effective: March 3, 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No.9
Columbia Gas of Pennsylvania, Inc. Original Page No. 179
RIDER DSIC - DISTRIBUTION SYSTEM IMPROVEMENT CHARGE (Continued) (C)
COMPUTATION OF THE DSIC - continued
Application of DSIC
The DSIC will be expressed as a percentage carried to two decimal places and will be applied to the total amount billed to each customer for distribution service under the otherwise applicable rates and charges, excluding amounts billed for the State Tax Adjustment Surcharge (STAS). To calculate the DSIC, one-fourth of the annual fixed costs associated with all property eligible for cost recovery under the DSIC will be divided by the projected revenue for distribution service (including all applicable clauses and riders) for the quarterly period during which the charge wHI be collected, exclusive of the STAS.
Formula:
The formula for calculation of the DSIC is as follows:
DSIC = (DSl * PTRR)+DeD+e PQR
Where:
DSI = Original cost of eligible distribution system improvement projects net of accrued depreciation.
PTRR = Pre-tax return rate applicable to DSIC-eligible property. Dep = Depreciation expense related to DSIC-eligible property. e = Amount calculated under the annual reconciliation feature or Commission audit,
as described below. POR = Projected quarterly revenues for distribution service (including all applicable
clauses and riders) from existing customers plus netted revenue from any customers which will be gained or lost by the beginning of the applicable service period.
Revenues will be determined as one-fourth (1/4) of projected annual revenues.
QUARTERLY UPDATES
Supporting data for each quarterly update will be filed with the Commission and served upon the Commission's Bureau of Investigation and Enforcement, the Office of Consumer Advocate, and the Office of Small Business Advocate at least ten (10) days prior to the effective date of the update.
(C) Indicates Change
Issued: January 2, 2013 M. R. Kempic Effective: March 3 2013 President
Supplement No. 194 to Tariff Gas - Pa. P.U.C. No. 9
Columbia Gas of Pennsylvania, Inc. Original Page No. 180
RIDER DSIC - DiSTRIBUTiON SYSTEM IMPROVEMENT CHARGE (Continued) (C)
CUSTOMER SAFEGUARDS
1. Cap: The DSIC is capped at 5.0% of the amount billed to customers for distribution service (including alL applicable clauses and riders) as determined on an annualized basis.
2. Audit/Reconciliation: The DSIC is subject to audit at intervals determined by the Commission. Any cost determined by the Commission not to comply with any provision of 66 Pa C.S. §§ 1350, et seq., shall be credited to customer accounts. The DSIC is subject to annual reconciliation based on a reconciliation period consisting of the twelve months ending December 31 of each year. The revenue received under the DSIC for the reconciliation period will be compared to the Company's eligible costs for that period. The difference between revenue and costs will be recouped or refunded, as appropriate, in accordance with Section 1307(e), over a one-year period commencing on April 1 of each year. If DSIC revenues exceed DSIC-eligible costs, such over-collections will be refunded with interest. Interest on over-collections and credits will be calculated at the residential mortgage lending specified by the Secretary of Banking in accordance with the Loan Interest and Protection Law (41 P.S. §§ 101, et seq.) and will be refunded in the same manner as an over-collection.
3. New Base Rates: The DSIC will be reset at zero upon application of new base rates to customer billings that provide for prospective recovery of the annual costs that had previously been recovered under the DS1C. Thereafter, only the fixed costs of new eligible plant additions that have not previously been reflected in the Utility's rates or rate base will be reflected in the quarterly updates of the DSIC.
4. Customer Notice: Customers shall be notified of changes in the DSIC by including appropriate information on the first bill they receive following any change. An explanatory bill insert shall also be included with the first billing.
5. All customer classes: The DSIC shall be applied equally to all customer classes, except that the Company may reduce or eliminate the Rider DSIC to any customer with competitive alternatives or potential competitive alternatives and customers having negotiated contracts with the Company, if it is reasonably necessary to do so.
6. Earning Reports: The DSIC will also be reset at zero if, in any quarter, data filed with the Commission in the Utility's then most recent Annual or Quarterly Earnings reports show that the Utility would earn a rate of return that would exceed the allowable rate of return used to calculate its fixed costs under the DSIC as described in the pre-tax return section.
(C) Indicates Change
Issued: January 2, 2013 M. R. Kempic Effective: March 3, 2013 President
COLUMBIA STATEMENT NO. 1
BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION
Pennsylvania Public Utility Commission
vs. Docket No. P-2012- 2338282
Columbia Gas of Pnnsy1vania, Inc.
DIRECT TESTIMONY OF NANCYJ. D. KRAJOVIC
ON BEHALF OF COLUMBIA GAS OF PENNSYLVANIA, INC.
January 2, 2013
NancyJ. D. Krajovic Statement No. 6
Page 1 of 14
1 Q. Please state your name and business address.
2 A. Nancy J. D. Krajovic, 121 Champion Way, Canonsburg, PA 15317
3 Q. By whom are you employed and in what capacity?
4 A. I am employed by Columbia Gas of Pennsylvania, Inc. ("Columbia" or the
5 "Company") as Director of Rates and Regulatory Affairs.
6 Q. What are your responsibilities as Director of Rates and Regulatory Affairs?
7 A. I am responsible for developing and directing rate activity on behalf of the
8 Company before the Pennsylvania Public Utility Commission ("Commission") as
9 well as coordinating and representing the Company's position in a variety of
10 regulatoiy matters and proceedings.
11 Q. What is your educational and professional background?
12 A. I hold a Bachelors of Science Degree in Accounting from Duquesne University and
13 a Master of Business Administration from the University of Pittsburgh's Katz
14 Graduate School of Business. I was employed by the Pennsylvania Public Utility
15 Commission from 1984 through 1987 as an auditor. From 1988 through 2007, I
16 held various regulatory positions at Duquesne Light Company including Regulatory
17 Analyst, Rate Design Coordinator, Project Manager, Director of Regulatory Affairs
18 and Manager of Regulatory Affairs. In those positions I acted as the primary
19 interface with the Commission in the conduct of financial and management audits
20 of Duquesne Light. Additionally, I was responsible for the interpretation and
21 administration of Duquesne's retail and supplier tariffs. In 2007, 1 assumed the
Nancy J. D. Krajovic Statement No. 6
Page 2 of 14
1 role of Manager, Commercial and Industrial Customers for Duquesne Light and
2 held that position until May, 2009. In November of 2009, I joined Columbia Gas
3 of Pennsylvania as Senior Regulatory Analyst and was promoted to my current
4 position in June of 2011.
5 Q. Have you previously testified before this Commission?
6 A. Yes, I submitted written testimony before the Commission on Duquesne's behalf at
7 the following dockets: 1-900005, M-00930404Cool, R-000l6854Co01, M-
8 FACE0302, R-00061346 and P-00072247. I also presented oral testimony in
9 several formal customer complaint actions and at en bane hearings sponsored by
10 the Commission on energy conservation issues. At Columbia Gas of Pennsylvania I
11 have submitted written testimony before the Commission at the following dockets:
12 R-2011-2215623, R-2012-2293303 and C-2011-224837o/A-2011-227678o and R-
13 2012-2321748.
14 Q. What is the purpose of your testimony?
15 A. My testimony will describe the Distribution System Improvement Charge ("DSIC")
16 tariff and supporting documentation that the Company has filed for the
17 Commission's approval. I will discuss Columbia's Long Term Infrastructure
18 Improvement Plan ("LTIIP"). I will also explain how the Company seeks to utilize
19 all of the tools provided by Act i1 to recover the ongoing costs of its accelerated
20 infrastructure replacement program initiated in 2007.
21 Q. Why has Columbia filed for a DSIC?
NancyJ. D. Krajovic Statement No. 6
Page 3 of 14
1 A. Columbia has long supported the need for a recovery mechanism that would
2 address regulatory lag. In the face of Columbia's decades-long priority pipe
3 replacement program and an environment where it competes for capital, a
4 mechanism granting timely recovery is critical to ensuring that such a significant
5 replacement program is implemented in the most expeditious and cost-effective
6 manner. While infrastructure replacement will result in rate increases for
7 Columbia's customers, the availability of the DSIC will enable the Company to
8 attract lower cost capital. Columbia is most appreciative of the collaborative effort
9 among the utilities and the Commission and lawmakers for moving HB 1294
10 through to the passage of Act ii. This filing seeks to use the DSIC as specified in
11 Act 11 to support the accelerated infrastructure program that the Company began
12 over five years ago.
13 Q. Please describe the filing that Columbia has submitted in this proceeding.
14 A. Columbia has submitted Supplement No. 194 to Tariff Gas Pa. P.U.C. No. 9
15 ("Supplement No. 194") to introduce a DSIC into its tariff. Supplement No. 194 is
16 issued January 2, 2013, to be effective March 3, 2013. The language included in
17 Supplement No. 194 closely reflects the language of the proposed model tariff
18 included in the Commission's August 2, 2012 Final Implementation Order at M-
19 2012-2293611.
20 Q. Does Columbia propose any differences in its filing from the proposed model
21 tariff?
NancyJ. D. Krajovic Statement No. 6
Page 4 of 14
A. Consistent with the Final Implementation Order, a provision has been added that
specifies that the DSIC will not be applied to any customer with competitive
alternatives or negotiated contracts.
Q. Is there anything else about the tariff that you would like to specifically describe?
A. Yes. Columbia is filing for a DISC at the earliest time permitted by Act ii.
Because tariff supplements are filed on sixty days' notice, the soonest that the
DSIC could become effective is March 3, 2013, As such, the applicable calendar
quarters that Columbia's initial DSIC will be effective will be March - May, June
- August, September - November and December - February.
Q. How will Columbia's DSIC be calculated?
A. Consistent with the model tariff proposed by the Commission, the formula for
Columbia's DSIC is:
DSIC = (DSI * PTRR)+Dep+e PQR
Where:
DSI Original cost of eligible distribution system improvement projects net of accrued depreciation.
PTRR Pre-tax return rate applicable to DSIC-eligible property. Dep = Depreciation expense related to DSIC-eligible property. e = Amount calculated under the annual reconciliation feature or
Commission audit, as described below. PQR = Projected quarterly revenues (based on one-fourth of
projected annual revenues) for distribution service (including all applicable clauses and riders) from existing customers plus netted revenue from any customers which will be gained or lost by the beginning of the applicable service period.
I
2
3
4
5
6
7
8
9
10
11
12
13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29
NancyJ. D. Krajovic Statement No. 6
Page 5 of 14
Q. Can Columbia currently calculate the DSIC rate to be effective March 31, 2013 if
2 Supplement No. 194 is approved as filed by the Commission?
3 A. No. By statute, the DSIC will commence recovery of eligible property placed into
4 service during the three-month period ending thirty days prior to the effective
5 date of the DSIC. For a DSIC effective March 3, 2013, that three-month period is
6 November 2012 through January 31, 2013. Currently, the only actual data for
7 that period is the eligible property placed into service in November 2012.
8 Q. Has Columbia made an estimate of the March 3, 2013 DSTC rate?
9 A. Yes. Exhibit NJDK-1 is a representation of what Columbia proposes to file on a
10 quarterly basis ten days prior to the effective date of the quarterly updates. In it,
11 Columbia has included actual data for November 2012 and projected data for
12 December 2012 and January 2013 in regard to eligible property placed into
13 service. The estimated DSIC for March 3, 2013 is 1.90%.
14 Q. What capital structure and debt rates were used in the estimate?
15 A. The estimate is based on the Company's current capital structure and actual cost
16 rates for long-term debt and preferred stock as of November 30, 2012. Those
17 rates will be updated to reflect the capital structure and cost rates as of January
18 31, 2013 when the filed-for DSIC is submitted on February 19, 2013.
19 Q. What cost of equity is used in the calculation of the estimated DSIC?
20 A. The Commission has not yet published a rate of return on equity ("ROE") to be
21 used by gas utilities for purposes of a DSIC in the absence of a ROE from a fully
NancyJ. U. Krajovic Statement No. 6
Page 6 of 14
1 litigated base rate proceeding within the last two years. In addition, Columbia's
2 last base rate case was settled without a specified ROE. Therefore, for purposes
3 of this estimate, Columbia has used an ROE of 10.4%, which is the ROE granted
4 by the Commission in its order entered December 28, 2012 in PPL Electric
5 Utilities Corporation's fully-litigated base rate proceeding at Docket No. R-2012-
6 2290597. This rate is highly consistent with the DSIC ROE of 10.46% proposed
7 by the Utility Sub-Group in the Commission's Act ii ROE Working Group. It is
8 the position of that sub-group that the DSIC ROE should be reflective of the
9 ROE's approved in base rate proceedings since the purpose of the DSIC is to
10 encourage investment in rate base property. When the Commission publishes an
11 ROE to be used for DSIC purposes, Columbia's compliance filing will reflect the
12 allowed ROE.
13 Q. On what basis will Columbia be projecting its quarterly revenues?
14 A. A significant portion of Columbia's load is driven by heating service. Given that
15 Columbia's current rate design is largely volumetric, its revenue stream is largely
16 seasonal. In order to apply the DSIC in a fashion that more closely reflects the
17 fixed nature of the investment that the DSIC will be recovering and to make the
18 DSIC administratively simpler to apply, Columbia will be basing its projected
19 quarterly revenues on one-fourth of its projected annual distribution revenues.
20 Q. How will Columbia notify its customers of the quarterly updates to the DSIC?
Nancy J. D. Krajovic Statement No. 6
Page 7 of 14
1 A. As directed by the Commission's August 2, 2012 Implementation Order and
2 model tariff, the Company will include bill messages following any quarterly
3 changes in the DSIC.
4 Q. Has Columbia notified its customers of this filing?
5 A. Yes. Beginning with hills issued on the date of this filing and continuing for a full
6 billing cycle, Columbia is including a bill insert to all customers informing them
7 of the filing, the estimated impact of a DSIC on their bills and their rights to
8 intervene in the proceeding. The language on the insert was circulated to, and
9 reflects comments provided by, the Commission's Communications Office,
10 Bureau of Consumer Services and the Office of Consumer Advocate.
11 Q. Has Columbia included any customer safeguards in its DSIC?
12 A. The amounts billed to customers via the DSIC are capped at 5% of annualized
13 distribution revenues. Additionally, the DSIC is subject to audit by the
14 Commission and annual reconciliation of recoveries and costs, with
15 overcollections subject to refund with interest. The DSIC will be reset to zero
16 upon application of new base rates that will prospectively recover costs that had
17 previously been recovered through the DSIC. It will also be reset to zero in any
18 quarter that Columbia would earn a rate of return in excess of that authorized to
19 calculate the fixed costs under the DSIC. All of these customer safeguards comply
20 with the requirements of Act 11 and the Commission's model DSIC tariff.
21 Q. Did Columbia file a Long Term Infrastructure Improvement Plan ("LTIIP")?
NancyJ. D. Krajovic Statement No. 6
Page 8 of 14
1 A. Yes. Section 1352 of 66 Pa. C.S. requires that in order to qualify for DSIC
2 recovery, a utility must file a LTIIP for Commission approval. Columbia's filed its
3 LTIIP with the Commission on December 7, 2012 at P-2012-2338282.
4 Q. Has the Commission taken action on that filing?
5 A. No, not at this time.
6 Q. Please describe the contents of Columbia's LTIIP.
7 A. Columbia's filing included the six specific elements listed in the statute: 1) types
8 and age of eligible property; 2) schedule for its planned repair and replacement; 3)
9 location of the eligible property; 4) reasonable estimate of the quantity of property
10 to be improved; 5) projected annual expenditures and measures to ensure that plan
11 is cost effective; and 6) manner in which replacement of aging infrastructure will be
12 accelerated and how repair, improvement or replacement will maintain safe and
13 reliable service. In addition, Columbia's LTIIP includes a description of the
14 Company's workforce management and training plan designed to ensure that the
15 utility will have access to a qualified workforce to perform the work in a cost-
16 effective, safe and reliable manner, as required by the Commission's Final
17 Implementation Order referenced earlier. The filing also described the history of
18 Columbia's accelerated pipeline replacement program, increased leak repair efforts,
19 quantities of priority pipe already retired and improvements in O&M metrics
20 already achieved. A copy of Columbia's LTIIP is included as Exhibit NJDK-2 to my
21 testimony.
NancyJ. D. Krajovic Statement No. 6
Page 9 of 14
I Q. Are there any specific items of property in the DSIC you would like to explain?
2 A. Yes. I would like to explain Columbia's claim for investment in customer-owned
3 gas service lines. In the western portion of Columbia's system, by virtue of 66 Pa.
4 C.S. § 1510 and Columbia's tariff, customers own their service lines from the curb
5 line or curb box to the meter. In many instances, these services are constructed of
6 bare steel or otherwise may be inadequate to connect to Columbia's main
7 replacements. The bare steel customer-owned service lines have been subject to
8 the same elements that affect the physical integrity of the Company-owned mains
9 that are being replaced across Columbia's system. While these service lines are
10 owned by the customer, for safety reasons it is just as necessary to upgrade them as
11 it is to upgrade the bare steel and cast iron mains. Columbia could not continue to
12 provide service to these customers without replacing the customer service lines,
13 because the lines are incapable of handling the new system pressures and are not
14 up to current code requirements. Replacing these lines is an integral part of the
15 Company's strategy for improving the quality of its distribution system.
16 Q. Why is Columbia's replacement of these customer-owned service lines an integral
17 part of its main replacement program?
18 A. When Columbia began its accelerated mains replacement program in 2007, the
19 Company recognized that in order to maintain the speed and efficiency of its
20 replacement strategy, it would need to undertake the replacement of customer-
21 owned service lines on its own. The Company concluded that if it had to rely on
Nancy J. D. Krajovic Statement No. 6
Page 10 of 14
I individual customers to arrange for the replacement of customer owned lines to be
2 connected to replacement mains, it would delay or alter Columbia's replacement
3 schedule. Customers may not have the necessary resources at the time the
4 Company intends to replace the main that provides them with service, or may be
5 unable to get the necessary equipment and qualified labor in a timely fashion. As a
6 result, customers could be without service for an extended period of time, and the
7 Company could not efficiently replace mains if it had to wait to connect new
8 services to the main. Columbia is certainly capable of making these replacements
9 in a more efficient and less costly manner, since it will already have the personnel
10 and equipment near the customers' properties. Further, utilizing Columbia's
11 resources allows the Company to make the replacements exactly when they are
12 most convenient, and does not inhibit its replacement schedule. The investment in
13 customer-owned service lines is directly and solely driven by Columbia's
14 accelerated infrastructure replacement program.
15 Q. Has the Commission made any determinations related to Columbia's replacement
16 of customer-owned service lines?
17 A. Yes, it has. In "Petition of Columbia Gas of Pennsylvania, Inc. for Limited
18 Waivers of Certain Tariff Rules Related to Customer Service Line Replacement",
19 Docket No. P-00072337 (Order entered May 19, 2008) ("Petition"), Columbia
20 specifically requested that the Commission allow the Company to waive certain
21 tariff rules regarding customer responsibility to replace customer-owned service
NancyJ. D. Krajovic Statement No. 6
Page 11 0114
I lines. In its Petition, Columbia requested that the Commission allow it to replace
2 all customer-owned service lines at the Company's cost where doing so is
3 necessitated by Columbia's main replacement and upgrade program. Columbia
4 noted that it would capitalize to the mains account the costs incurred in replacing
5 the customer-owned service lines. The Commission approved Columbia's Petition
6 without objection on May 19, 2008. In every rate case since that time, the cost of
7 replacement of customer-owned service lines has been included in the mains
8 account without objection. Columbia's inclusion of customer-owned service lines
9 as part: of the DSIC is, therefore, a logical continuation of the Commission's
10 determination in Columbia's prior cases.
11 Q. Why is it appropriate to include this investment in the DSIC?
12 A. As noted above, for accounting and ratemaking purposes, Columbia books the cost
13 of these customer-owned service line replacements to the Company's mains
14 account. This is no different from how Columbia would book the cost of other
15 customer-owned property, such as driveways, that are replaced as part of a main
16 replacement project. Furthermore, as explained above, these replacements are
17 necessary to an efficient mains replacement program. Thus, Columbia believes that
18 customer-owned service lines, which are already booked in the mains account, are
19 appropriate for inclusion in the DSIC as either cgas service lines" under
20 §1351(2)(iii) of the Act or "other related capital costs" under §1351(2)(x) of the Act.
21 Q. Has Columbia filed a base rate case within the five years prior to this filing?
NancyJ. D. Krajovic Statement No. 6
Page 12 of 14
1 A. Yes. Included as part of our DSIC filing as Exhibit NJDK-3 is a certification that
2 prior to this filing, Columbia filed a base rate case under which its current base
3 rates were established on January 14, 2011 at Docket No. R-2010-2215623.
4 Q. Will the DSIC facilitate Columbia's compliance with Section 1501 of the Public
5 Utility Code and other state and federal laws or orders related to the provision and
6 maintenance of adequate, efficient, safe, reliable and reasonable service?
7 A. Yes. As described in detail in the LTHP included as Exhibit NJDK-3, Columbia
8 determined that the most effective means to mitigate the risks associated with
9 leakage from corrosion and cracks is to accelerate the replacement of aging
10 infrastructure. Columbia now routinely exceeds required leak surveys and has used
11 the information from those surveys to dramatically reduce the number of open
12 Class 2 leaks as well as to aid in the prioritizatiori of the pipe segments to be
13 replaced. Through the removal of deteriorating portions of its system and
14 replacement with new, longer lasting and safer materials, the Company is ensuring
15 the deliverability of service at the system's Maximum Allowable Operating
16 Pressure. Utilization of the DSIC facilitates Columbia's ability to carry out its
17 infrastructure replacement program in a cost-effective and accelerated manner. As
18 evidenced by the statistics provided in the LTIIP, Columbia accelerated its
19 replacement activity in 2007. Following the passage of Act ii, investment increased
20 to greater levels. Projected capital spending over the next five years for the
Nancy J. D. Krajovic Statement No. 6
Page 13 of 14
I replacement of aging infrastructure continues at levels that greatly exceed historic
2 investment.
3 Q. Is adoption of the DSIC in the public interest?
4 A. Yes. For reasons explained above and in the LTIIP, the DSIC will enable Columbia
S to continue its accelerated facilities replacement program, which will enhance the
6 safety and reliability of Columbia's system, to the benefit of Columbia's customers
7 and the public.
8 Q. Does Columbia currently have a base rate proceeding before the Commission?
9 A. Yes. Columbia filed a for a general rate increase on September 28, 2012 at R-2012-
10 2321748.
11 Q. Does the case that Columbia filed utilize any provisions of Act ii?
Yes. Columbia filed its requested rate increase based upon a fully projected future
test year ending June 30, 2014, as permitted by new language at 66 Pa. C. S. § 315.
How will the order issued in that proceeding impact Columbia's DSIC?
The DSIC will be reset to zero upon the application of the new rates.
When could Columbia next apply for a DSIC?
Under Act 11, the DSIC may only include plant not previously reflected in rate base.
Therefore, if Columbia's rate base plant additions claimed in the case currently
before the Commission are adopted, Columbia would be able to file for a DSIC for
eligible investment made after June 2014. Therefore, the next DSIC would likely be
implemented no sooner than the fourth quarter of 2014.
12 A.
13
14 Q.
15 A.
16 Q.
17 A.
18
19
20
21
Nancy J. D. Krajovic Statement No. 6
Page 14 of 14
Q. Does this complete your testimony?
A. Yes, it does.
Exhibit NJDK-1
Exhibit NJDK-1 Page 1 of 4
Columbia Gas of Pennsylvania
Proposed Distribution Service Improvement Charge (DSIC)
To be Effective March 3, 2013
Surcharge Calculation
Description Surcharge Effective
March 3 2013
1 Additions 29109
2 Less: Depreciation 112
22997 3 Applicable Additions
4 Annual Revenue Requirement Rate 12.05%
5 Qiarterly Revenue Requirement Rate (In 4 / 4) PTRR 3.01%
6 Quarterly Capital Cost Recovery (In 3 * Ln 5) DSI X PTRR 874
7 Quarterly Depreciation Expense (Ln 2) 150
8 Quarterly Base Revenue to Be Collected PQR 53896
9 Distribution System Improvement Charge ((Ln 6 + In 7) /Ln 8) DSIC 1.90%
Capital Structure as of November 30, 2012
Weighted Average Revenue
Type Amount Capital Structure Cost Rate Cost Rate Requirement
Debt - Long term * 378390 47.34% 5.80% 275% 2.75%
Debt - Shortterm 2,577 032% 1.29% 000% 0.00%
Equity 418406 52.34% 10.40% 5.44% 9.30%
799,373 100% 8.19% 12.05% Total Capital
Anticipated Base Revenues ($000s)
Annual Revenues 215,582
Quarterly Revenue 53,896
Exhibft F'LJDK-1 Page 2 of 4
Columbia Gas of Pennsylvania
Proposed Distribution Service Improvement Charge (DSIC)
To be Effective March 3, 2013
Additions Projected Projected
Description Plant Account November-12 December-12 January-13 Total
Mains 37600 11,892,444 4,242,000 5,208,000 21,342,444
Mains CSL Replacements 37608 88,778 469,000 345,000 902,778
Services 38000 1,980,975 2,000,000 1,658,000 5,638,975
Meters 38100 306,498 69,000 45,000 420,498
Auto Meter Reading Devices 38110 368,017 65,000 101,000 534,017
Meter Installations 38200 36,289 130,000 55,000 221,289
House Regulators 1 38300 1 2,552 26,000 20,000 1 48,552
1 Total Additionsl 14,675,553 7,001,000 7,432,000 1 29,108,553
Retirements
Depreciation Expense
Projected Projected
Description Plant Account Novem bet-I 2 December-I 2 January-I 3 Total
Mains 37600 52,624 18,771 23,045 94,440
Mains CSL Replacements 37608 393 2,075 1,527 3,995
Services 38000 13,173 13,300 11,026 37,499
Meters 38100 1,701 383 250 2,334
Auto Meter Reading Devices 38110 6,790 1,199 1,863 9,853
Meter Installations 38200 178 637 270 1,084
House Regulators 1 38300 1 19 190 146 1 354
Total Depreciation 1 74,878 36,555 38,126 1 149,559
Exhibit NJDK-1 Page 3 of4
Columbia Gas of Pennsylvania
Proposed Distribution Service Improvement Charge (DSIC)
To be Effective March 3, 2013
Embedded Cost of LongTerm Debt
November 30, 2012
Amount of Note
Date of Issuance
Date of Maturity Interest Rates Debt Service Requirement Rate
$47,350,000
$18,525,000
$54,515,000
$20,000,000
$58,000,000
$22,000,000
$28,000,000
$30,000,000
$35,000,000
$65,000,000
November 28, 2005
November 28, 2005
November 28, 2005
November 1, 2006
December 14, 2007
December 18, 2008
December 16, 2010
March 28, 2012
March 28, 2012
November 28, 2012
November 28, 2015
November 28, 2016
November 28, 2025
November 1, 2021
December 14, 2027
December 18, 2013
December 16, 2030
March 26, 2032
March 26, 2042
November 28, 2042
5.41%
5.45%
5.92%
6.015%
6.865%
5.460%
6.020%
5.355%
5.890%
5.26%
2,561,635
1,009,613
3,227,288
1,203,000
3,981,700
1,201,200
1,685,600
1,606,500
2,061,500
3,419,000
$378,390,000 21,957,036 5.80%
Exhibit NJDK-1 Page 4 of 4
Columbia Gas of Pennsylvania
Proposed Distribution Service Improvement Charge (DSIC)
To be Effective March 3, 2013
Base Revenue By Rate Class
For the 12 Months Ending February 28, 2014
Customer 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2014 2014
Class March April May June July August September October November December January February Total*
Reshdential 19,113609 14,521,846 9,607,477 7,279920 7372,080 7,321,318 7255,153 3,132,003 11,434,420 16,466,274 22,025,625 21,568,547 152,797976
Commercial 6,255,982 4,952,764 2,688,374 2,088,616 1,799,243 1,709,256 1,737,837 2,249,478 3,433,628 5,357682 7,433,979 7,434,559 46,896,397
lrichjstrial 1.430,441 1,337,942 1,240,959 1,228,721 1,215,543 1,259,123 1,273404 1,314,953 1,309,195 1355,316 1,441,270 1,430,831 15,887,695
26,800,032 20,412,552 13,536,810 11,197,257 10,386,863 10,289,397 10,366,399 11,696,433 16,227,243 23,179,272 30,955,274 30,533,932 215,522,069
quarterly Revenues 53,895,517
* Represents annual revenues consistent with those filed in Columbia Gas of Pennsylvania's most recent base rate case, Case 2012-232-1748.
Exhibit NJDK-2
Columbia Gas of Pennsylvania, Inc.
Long-Term Infrastructure Improvement Plan
(2013-2017)
Columbia Gas of Pennsylvania, Inc. ("Columbia" or "the Company) submits its Long
Term Infrastructure Improvement Plan ("LTllP") in compliance with the requirements of
66 Pa. C.S. § 1352(a) and the Pennsylvania Public Utility Commission's ("Commission") Final
Implementation Order in Docket M-2012-2293611 (August 2, 2011). This LTIIP is being
submitted in order to qualify the investment in that infrastructure for Distribution System
Improvement Charge ("DSIC") recovery under 66 Pa. C.S. §1350 et seq, referred herein as the
"Act" or the "DSIC Statute".
After the following brief introduction which provides background information on the
Company and the history of its distribution system, the Company provides information
responsive to the seven issues that the Commission directed to be included in the LT1IP in its
Final Implementation Order.
Background
Columbia was incorporated in 1962. Prior to that time, Columbia's distribution
operations in Pennsylvania had been operated as part of the Columbia Gas System's Pittsburgh
operating group, whose principal operating company was Manufacturers Light & Heat
Company. Manufacturers Light & Heat Company was comprised of many companies which
were combined and consolidated over many years, starting with the 1885 chartering of
Manufacturers Natural Gas Company. In 1966, Columbia acquired the properties of the Central
Pennsylvania Gas Company, serving the area in and around State College. ln 1969, Columbia
acquired the York County Gas Company, which had originally been chartered in 1849.
Currently, Columbia serves approximately 415,000 residential, commercial, and industrial
customers in portions of 26 Counties throughout its greater York and Western Pennsylvania
service territories. Columbia provides that service through approximately 7,350 miles of mains
arid 400,000 services that it owns, operates, and maintains. (Please note that in compliance
with Pennsylvania statutory law, in Western Pennsylvania the Company does not own the
service lines all the way to the building, but terminates its ownership at the curb valve, typically
found at or near the property line. If there is no curb valve on the service line, the Company
terminates its ownership at the property line itself. For these customer-owned services, the
customer then installs and maintains the remainder of the service line to the building.) These
facilities (as of January 1, 2012 and as stated in Columbia's DOT Annual Report) include
approximately 1,751 miles of unprotected bare steel mains, 46 miles of cast iron mains, 113
miles of wrought iron mains and 66,781 bare steel services 1 . The balance of the system is
comprised of coated cathodically protected steel, or plastic (polyethylene) mains and services
and 81 miles classified as "other." Columbia's distribution infrastructure constitutes the final
step in the delivery of natural gas to customers from the producing regions of the Southern
United States, Western Canada, and in-state, Penn sylvan ia-prod u ced supplies.
1) Types and age of eligible property
Mains
Columbia's system comprises many different types of pipe, fittings and appurtenances.
From the 1850s to the early 1900s, Columbia's predecessor companies installed cast iron
pipe throughout the early distribution systems. Cast iron, wrought iron and wood were among
the first materials available, and cast iron had the advantage in that it was relatively strong and
was easy to install. However, it was vulnerable to breakage from ground movement.
I This number does not fake into account customer-owned services. Because Columbia does not own and did not originally install customer-owned services, Columbia does not have certain records by pipe material.
When the pipe was buried to typical depths of between two and five feet, if the soil beneath
the pipe or to its side was disturbed and pressure exerted on the pipe, it could crack.
Further, each pipe section was not easily joined, so joints were prone to leaks. Finally, it was
determined that cast iron pipe was unsuitable for long- distance transportation of gas because it
was unable to withstand high pressures.
By the early 1900s, the industry had adopted steel and wrought iron piping for mains.
These were deemed to be stronger than cast iron and able to withstand greater pressure.
During this time, bare steel and wrought iron began replacing cast iron pipe as the
material of choice when building a natural gas distribution system. During the pre- and
post-World War II construction boom, gas utilities like Columbia, along with developers and
customers, installed a significant amount of bare steel mains and services. Bare steel is steel
pipe that has no exterior coating and has no cathodic protection installed on the pipe. The
use of bare steel and wrought iron was common until the 1950s and 1960s when the industry
began to realize that, despite its strength, bare steel was subject to corrosion, and, in order to
increase long-term safety and reliability, coating and cathodic protection should be applied to
all new piping systems. Both exterior coatings and cathodic protection were designed to
inhibit corrosion. Columbia installed its last bare steel pipe in the 1960s. By 1970, the federal
government prohibited the use of bare steel for natural gas distribution system infrastructure.
All metals corrode as a result of the natural process of chemical Interactions with their
physical environment, most commonly caused by moist soil (which creates an electrolyte)
around the pipe causing corrosion. What occurs in these circumstances is that direct electric
current flows from the metal surface into the electrolyte, and as the metal ions leave the
surface of the pipe, corrosion takes place. This current flows in the electrolyte to the site
where oxygen or water is being reduced. This site is referred to as the cathode or cathodic
site. In order to combat corrosion, LDCs began using coated steel. Unprotected coated steel
3
("UPCS" or "coated steel") refers to steel pipe with an exterior coating (intended to electrically
isolate the steel from the surrounding electrolytes in the soil).
Despite the best efforts of industry, and even though it was for a time an accepted
industry standard, unprotected coated steel corroded as well. But from the 1940s through the
1960s, as the industry assessed its options, it was one of just a few alternative piping materials
available to meet the public demand for service. By 1970, Columbia had laid its last non-
cathodically protected coated steel segment. Further, since that time Columbia has retrofitted
all of its unprotected coated steel facilities with cathodic protection systems.
During the late 1960s and early 1970s, one of the first generation plastic pipes to be
installed was Aldyl-A. Despite its classification as a medium density polyethylene material,
operating history has demonstrated that Aldyl-A is more vulnerable to stress propagation
cracking than the contemporary medium density 418 polyethylene commonly installed today.
Therefore, in the course of executing Columbia's current age and condition replacement
projects, some of these Aldyl-A facilities are being retired or replaced contemporaneously with
the Bare Steel and Cast Iron to which these facilities are adjacent. Columbia best estimate is
that there is approximately 735 miles of Aldyl pipe presently in Columbia's distribution system.
Over the five-year course of this long-term infrastructure improvement plan, Columbia's
primary focus in its accelerated main replacement program is replacing its "first generation"
bare steel and cast iron pipe, which is most susceptible to failure from corrosion, cracks and
leakage. If however, during any main replacement program other facilities are located adjacent
to the project that are prone to fail such as unprotected coated steel pipe, ineffectively coated
steel pipe, Aldyl-A, etc., those facilities will also be replaced. Collectively, all of the distribution
main that is replaced is considered 'eligible property" for the DSIC under §1351(2)(i).
4
Gas Service Lines
Bare steel customer service lines, whether owned by the Company or its customers, are
also subject to the same elements that affect the physical integrity of Company-owned mains
that are being replaced across Columbia's system. Consequently, it is necessary to replace
bare steel customer service lines and any other customer service lines that are incapable of
handling the new system pressures or not up to current code requirements, along with
appurtenant facilities, such as excess flow valves, service regulators, meter risers, fittings, etc.,
in conjunction with Columbia's main replacement program. Since customer-owned service
lines that cannot, or potentially cannot, operate safely at the new pressures must be replaced
in conjunction with main replacements, and because it would not be practical or efficient to
require customers to arrange for replacement of customer-owned services at the time of a main
replacement, it is reasonable for Columbia to pay the cost of replacing customer-owned service
lines. The customer will continue to own and have the responsibility to maintain a customer-
owned service line after replacement. By Order entered at Docket No. P-00072337, the
Commission approved Columbia's request to replace customer-owned service lines in
conjunction with the Company's main replacement efforts. Columbia books the cost of these
customer-owned service line replacements to the Company's mains account just as it would
book the cost of other customer-owned property, such as driveways, that are replaced as part
of a main replacement project. Gas service lines and insulated and non-insulated fittings are
considered eligible property under §1 351(2)(iii) of the Act.
In the time since the Commission granted the Company's request to replace customer-
owned service lines the related investment has been included in rate base and, as such, has
been recovered through base rates. The USIC provisions of Act 11 are designed to "provide
an additional mechanism to recover the costs related to the repair, improvement and
replacement of eligible property." The investment in customer-owned service lines is directly
and solely driven by Columbia's accelerated infrastructure replacement program. It is therefore
5
appropriate that the investment in customer-owned service lines booked to the mains account
is considered eligible property as "other related capitalized costs" under §1351 (2)(vi).
Excess Flow Valves
As part of the infrastructure upgrade, Columbia is installing excess flow valves on nearly
all services connected to the replacement mains that operate over 10 pounds of pressure.
(The exception would be for those commercial and industrial customers whose consumption is
over 5,000 CFH per hour.) These valves are not replacement property in that they do not
function on a low-pressure system and therefore were not part of the property being replaced,
but are now being incorporated as a part of the medium pressure infrastructure being installed.
Excess flow valves are not capitalized as distinct units of property on the Company's books;
rather the associated costs are included in the capitalized cost of the service lines. Excess
flow valves are considered eligible property under §1 351(2)(v) of the Act.
Risers
Risers, which are the sections of pipe that connect the service flne to the meter, are
among the facilities replaced in concert with the service lines. Like excess flow valves, risers
are not reflected as distinct units of property on the Company's books. The costs associated
with risers are capitalized as part of the service lines replaced. Risers are considered eligible
property under §1351(2)(vi) of the Act.
Service Regulators
As Columbia's distribution system is upgraded to medium pressure, it is necessary to
install additional regulation on each customer's service line. Service regulators lower the
pressure of the gas at the customer's premise so that it can safely be delivered from the
distribution system into the customers' premises. Service regulators will be installed on each
service line replaced that will operate over one half pound per square inch (i.e. anything greater
than 'low pressure" delivery). The installation of regulators will therefore generally track the
number of service lines replaced. In most service line replacements, a prefabricated meter set,
consisting of the meter bar and regulator, are installed. Consequently the cost of this
equipment is included in the capitalized cost of the service lines. Since service regulators must
be installed in all modernization projects that involve increasing the pressure in the main,
service regulators are considered eligible property as "other related capitalized costs" under
§1 351(2)(vi).
Meters, Meter Bars, Valves
Columbia continually tests and replaces its stock of meters as appropriate to maintain
safe and reliable service and continue accurate customer billing. Additionally, as the
automated meter reading (AMR) system was deployed across Columbia's territory, meters that
were not compatible with the AMR device were also replaced. As services lines are being
replaced, meters are often relocated from the edge of the customer's property line often near a
road, to a location closer to the building for enhanced safety. When appropriate the meters are
also replaced. This replacement activity, while not easily projected as the customer-owned
facilities are not known, will continue to be a component of the accelerated main replacement
program 2
A meter bar is the apparatus upon which a meter sits and is sized according to the
equipment that it supports. With the replacement of low pressure infrastructure with medium
pressure infrastructure, regulators are now installed on the meter bar, requiring a change of the
meter bar, although not necessarily of the meter itself. Meter bars are not unitized, but rather
2 Industriar measuring and regulating equipment will also be subject to replacement and therefore included in
requested recovery although recorded under separate FERC accounts.
'4
are considered installation equipment and the cost of that equipment is capitalized into the
service line accounts. These costs will be incurred as service lines are replaced.
The Company routinely installs a meter inlet valve as well as a meter outlet valve on the
meter bar to control the flow of gas 3. These valves are installed on each customer service line
that is renewed as part of the Company's accelerated pipeline replacement program. Like
other appurtenances, these valves are not reflected as distinct units of property on the
Company's books. The costs associated with inlet and outlet valves are capitalized as part of
the service lines replaced.
Meter bars are deemed eligible property under §1 351 (2)(vii) of the Act. In those
instances where meters are replaced, they are considered eligible property under §1351(2)(vii)
of the Act. The inlet and outlet valves are considered eligible property under §1 351 (2)(iv) of
the Act.
2) Schedule for planned repair and replacement of eligible property
Replacement
Under the accelerated main replacement program in the next five years, Columbia will
focus on replacing existing bare steel and cast iron mains and other related facilities based on
the needs driven by the distribution system, in accordance with the basic tenets of system
engineering and planning. Given the current replacement rate and capital plans, Columbia
anticipates that the replacement of cast iron and bare steel will be completed in approximately
seventeen years, or by the end of 2029. Replacements are determined based on the
condition and age of the pipe, geographical proximity, leak history the capacity needs of the
In most renewals of customer service lines, curb valves and curb boxes are no longer used. However, in those
infrequent situations when a curb valve and/or a curb box is necessary, they are capitalized as part of the service
line renewed rather than being reflected on the Company's books as distinct units of property. To the extent that
a curb box and/or a curb valve are installed in a customer service line, those items are considered eligible property
under §1351(2)(ii), §1351(2)(iv) and §1351(2)(x) of the Act.
' After that, Columbia plans to focus on replacing other first generation distribution system components such as
Aldyl-A, ineffectively coated steel pipe, distribution regulator stations, etc.
E]
area, and expected growth in system demand requirements. Columbia employs a systemic
rather than segmental approach, reflecting the belief that the specific program approach is the
most effective way to deal with the complexities of its unprotected steel situation.
Annually, Columbia attempts to identify the highest risk segments and prioritizes those
replacements each year. Columbia utilizes Optimain DS® as a tool in the identification of the
most efficient plan to accomplish this goal. Optimain DS® is a comprehensive software
solution being used by all NiSource Gas Distribution Companies to help assess and prioritize
the risk associated with priority mains and allocate capital towards those risks. Optimain DS®
continually evaluates our priority pipe network, and directs the attention of engineers and
operators to the riskiest pipes. Columbia's approach targets larger geographic replacement
areas mixed with individual high risk segments to insure efficient utilization of capital. Trends
and performance are monitored by Columbia's Operations Center. Optimain DS® utilizes
many environmental and pipe condition factors obtained from field reports to develop and
calculate the risk factors for each segment of pipe. Some examples include:
• Pipe Size, Pressure and Pipe Material
• Leak history
• Ground Cover Type (grass, concrete, etc.)
• Service Length/Building Proximity
• Building Use (hospital, etc.)
• Population Density
• Pipe Condition and Depth
• Coating Condition
This is consistent with Columbia's Distribution Integrity Management Plan (DIMP) that
complies with 49 CFR 192.1007. In Columbia's DIMP plan, replacement programs are
referenced as one of the measures to reduce risk. Columbia's pipe replacement program
NO
impacts risk and reduces the probability of three threats identified by the DIMP Steering Team
as corrosion, natural forces damage, and material or weld failure.
Attachment A to this Plan is a list of the projects currently engineered for 2012 through
2013. The distribution system is reassessed and projects are reprioritized each year based on
the most current data available. As such, the list of projects is a dynamic roster that is subject
to modification based on emerging conditions. It will also be supplemented throughout the
calendar year to reflect the continued assessment of system conditions. These modifications
and additions account for differences between the projected annual replacement footage and
the total of projects shown on Attachment A. Additionally, mandatory replacements, non-
reparable leakage and active and atmospheric corrosion continue to drive replacement of
segments of pipe that are not reflected in this Plan and will impact the ultimate timing of the
completion of projects on the Plan.
Repair
In 2007 Columbia began an accelerated leakage survey program to inspect all bare
steel and cast iron mains at least annually, instead of the three year interval which is required
in the leakage survey requirements of CFR 49, Part 192. As a result, Columbia routinely
exceeds the requirements of existing Code of Federal Regulations, and this accelerated survey
process provides the Company the ability to discover system leakage on a much timelier basis
than if it were only meeting the minimum federal standards. Until such time that sU of the at-
risk pipe is removed from Columbia's distribution system, an aggressive leakage survey—as
Columbia employs today—will be key to maintaining the safety and reliability of the existing
infrastructure.
The following system enhancements for 2013 Columbia Gas of Pennsylvania operations
have been identified: to accelerate the repair rate of open Type-2 leaks, to increase the use of
camera-based technology to identify cross-bore conflicts, to deploy GPS technology to identify
10
the location of all new facilities, and to enhance damage prevention advertising and contractor
outreach.
The pipeline safety action enhancement agenda identified above, in conjunction with the
ongoing bare steel, cast iron, and wrought iron accelerated replacement program, is designed to
address the key risks identified in Columbia's Distribution Integrity Management Program Plan
("DIMP Plan"), and continue to reduce the pipeline safety risks inherent in the Columbia
system .
3) Location of the eligible property
Columbia's priority pipe is located throughout its service territory. As described earlier,
Columbia's service territory comprises 26 counties throughout Western and South Central
Pennsylvania as shown in the image below.
Columbia notes that to the extent these repair activities are charged to Operations and Maintenance Expense,
they will not be recovered through a DSIC.
11
Eligible property is located in each of these counties. A precise static identification of
each piece of eligible property throughout Columbia's service territory at any given time would
be impractical due to the geographic diversity of Columbia's service territory and the
distribution of eligible property throughout that service territory, and inappropriate given the
ever changing risk profile associated with individual segments of distribution facilities across
the service territory. Columbia utilizes a systemic approach to determining the property to be
replaced based on the age, condition, geographical proximity, leak history, and capacity needs
of the area as described in section 2 above. The specific projects identified are then
engineered for a calendar year beginning in the fourth quarter of the preceding year in
accordance with expected capital budgets. This systemic process ensures that the Company's
capital dollars are being optimally invested by replacing the riskiest pipe. The fact that the
process is conducted annually ensures that any segments of pipe whose risk profile has
changed from the previous analysis (e.g. more leaks, different ground cover, etc.) are
addressed appropriately.
Columbia anticipates that the Annual Asset Optimization Plan required at 66 Pa. C.S.
§1356 will be used to provide the Commission with current specific annual replacement
projects as well as address any changes that were made in the implementation of the prior
year's plan.
4) Reasonable estimate of the quantity of property to be improved
Proiected annual feet of pipe
• 2013 625,000
• 2014 625,000
• 2015 525,000
• 2016 525,000
12
• 2017 500,000
It should be noted that these replacement footages are estimates that are not based on
actual projects already designed, but approximations based on average cost-per-foot estimates
from actual construction costs experienced in 2011 and 2012. It should be expected that these
footages will vary from the estimates shown above based on a number of operational variables
that could include but are not limited to: the number of services in the various segments in any
given year, the actual pipe type installed in any given year (plastic or coated steel), the
character of the area (urban, suburban, rural, right of way) and the municipality where the work
is taking place (there are dramatically different permit fees and restoration standards required
at the municipal level across Columbia's operating territory).
Prolected annual number of services
In addition to the mains, it is estimated that CPA will replace 7000 to 9,000 service lines
per year over the next five years for a total of approximately 36,000 service lines by the end of
2017. As discussed above, excess flow valves and regulators are installed and risers and
meter bars are replaced in concert with the service line replacements but are not separately
identified. The quantities involved will be reflective of the service line replacements and the
associated costs will be included in the capitalized cost of service lines.
Proiected annual number of meters
Meter replacement will be driven by conditions found at each service location and
therefore cannot be forecasted based upon specific defined infrastructure projects. However, it
can be reasonably estimated that approximately 2000 to 4,000 meters will be replaced
annually over the next five years.
13
5) Projected annual expenditures and measures to ensure that plan is cost-effective
It is important to note that beyond 2014, the capital budgets associated with the
projected replacement activity are approved in the fourth quarter of the year preceding the
projections. Therefore, these estimates are based, among other things, upon current capital
markets, current economic conditions and Columbia's projected revenues given its current rate
structure. These estimates will also drive the projected quantity of property to be improved
stated in paragraph 4 above. Additionally, the Age and Condition capital budget includes
projects that are not DSIC eligible. These projects generally represent less than 3% of the Age
and Condition budget.
Prolected Annual Budget for Age and Condition, Upgrade and Mandatory Replacement 2013 -
2017
. 2013 $151,600,000
2014 $148,900,000
. 2015 $120,600,000
2016 $119,400,000
2017 $116,900,000
Cost-Effectiveness
As stated previously, Columbia employs a systemic rather than a segmental approach.
Efficiencies are maximized and costs minimized by addressing larger segments of the system
than had historically been undertaken, and carrying out replacements on a planned, systemic
basis. Further, contractor resources are concentrated and competitive bidding processes are
leveraged in order to drive down costs of time and materials. By identifying larger segments of
the system that require attention (through leak rates, pipe condition reports, and repair
14
percentages), Columbia can focus resources and complete full segment replacements and tie-
ins, in a systematic fashion, thus reducing the overall quantity of bare steel in the system as
quickly and efficiently as possible, with minimal disruption to the customers and municipalities
that we serve.
By including the integration of Columbia's program work with State and municipal
improvements in the systemic approach, costs are minimized. Columbia is able, through
competitive bidding, to continue to secure long-term, lower unit cost contracts with various
utility installation contractors. Columbia is also able to purchase larger quantities of
construction materials by competitive bidding, resulting in lower cost, long-term contracts. By
these means, Columbia was able to reduce costs by moving away from a segment by segment
approach.
Over the long term there is an item from an operations perspective that continues to
challenge Columbia's ability both to perform system maintenance and to replace facilities in a
cost effective manner, and that is the recent trend from some municipalities in enacting costly
excavation permit fees and extensive restoration requirements. While Columbia has been
vigilant in trying to negotiate the fees and requirements to reasonable levels, there is not
sufficient statewide legislation to support this effort in a systematic way. Permit fees and
restoration requirements can be seen as a source of easy revenue for some municipalities and
can create a burden on all rate payers through rising construction costs. Replacing aging
facilities in coordination with planned municipal paving projects is one way Columbia is
attempting to manage these rising costs, but that alone does not mitigate the entire concern.
For new and replacement mains and services, Columbia is using plastic or cathodically
protected steel throughout its system. Coated steel pipe continues to be used when higher
distribution pressures are required, but it is cathodically protected with an electric current.
Cathodically protected steel has all the advantages of steel in terms of strength and, because
of its impressed electrical current, is highly corrosion resistant. However, it is more costly to
15
purchase and install, and requires more ongoing maintenance, than the next generation pipe -
plastic. Cathodically protected steel will be used in any system that operates at high-pressure,
as well as in any above ground installation, such as a bridge attachment.
Plastic pipe has proven to be very good for distribution-level pressures. It has strength
and flexibility, and as a result, is generally immune to the stress of ground movement. Plastic
is also less costly to purchase and easier to join and install than steel pipe. Plastic does not
corrode and therefore does not require cathodic protection.
The single drawback to plastic is its relative vulnerability to third party damage
compared to cast iron or steel. Asa result, excavators who do not dig by hand (as required by
One-Call laws) in the vicinity of plastic facilities are very likely to cause pipeline damage. Cast
iron and steel piping have greater tensile strength and thus are somewhat more likely to resist
external impact.
Columbia has improved its locating performance and excavator outreach to reduce risks
to the system caused by excavator damage. In addition, Columbia has started using 'marking
balls" when installing its new plastic facilities. These marking balls are placed in the ground
above the pipe after it has been installed and enable Columbia to locate it later using electronic
technology.
The initial installation of natural gas distribution pipe requires the excavation of a trench
usually under or adjacent to a public street into which the pipe is laid. Then new or existing
customer services are connected to the new main. Installation of natural gas distribution pipe
can be a major inconvenience for residents, business owners, and municipalities. In some
circumstances where smaller diameter plastic facilities are installed to replace larger diameter
steel piping, the cost and inconvenience associated with excavating a trench can be reduced
by inserting the new pipe through the old piping. This involves smaller street cuts for the
insertion plus cuts associated with service line and intersecting main tie-ins. Even if a
16
replacement main must be laid rather than inserted, the use of smaller plastic pipe rather than
larger steel or cast iron pipe will produce a saving in material costs.
6) Manner in which replacement of aging infrastructure will be accelerated and how
repair improvement or replacement will maintain safe and reliable service.
As noted above, Columbia determined that the most effective way to mitigate the
concern associated with bare steel corrosion and cracks on cast iron on its system is the
accelerated replacement of bare steel and cast iron main and to survey that same material
on an annual basis until it can be replaced. With regard to leak survey and repairs,
Columbia routinely exceeds the requirements of the Code of Federal Regulations, doing
more leakage surveys than at any point in the Company's history and, as a result of
Columbia's comprehensive survey and leak reduction initiative, the Company has reduced
open Class 2 leaks by nearly 50% since 2007:
Year Open Class 2 Leaks
2007 3,755
2012 (as of September) 1,924
% Reduction 48.8%
With regard to the accelerated replacement of bare steel and cast iron, in 2007,
Columbia began to accelerate the replacement rate of bare steel and cast iron pipe. Columbia
has invested over $400 million since that time to replace cast iron bare steel mains and
services. Since 2006 (as demonstrated in the Annual DOT 7100 reports) Columbia has
already replaced or retired 17.3% of the total amount of cast iron and unprotected bare steel
that existed on its system five years ago, which represents a reduction of approximately 400
miles of bare steel and cast iron mains. The projected investment over the next five years is
17
expected to replace another 2,800000 feet or 530 miles, representing an additional 23.4% of
the cast iron and unprotected bare steel in the system prior to 2007.
In 2011 alone, Columbia spent approximately $92 million and replaced over 100 miles
(533,765 feet) of bare steel and cast iron, which equateg to an annual replacement of over
5.2% of Columbia's remaining first generation pipe. Another 97 miles (510,000 feet) are
anticipated to be replaced by year end 2012. At this rate, Columbia would replace its entire
remaining inventory of first generation pipe in 17 years, or by year-end 2029. 6
In recent years, Columbia has determined that there are an increasing number of leaks
in areas with a high concentration of unprotected pipe. In fact, corrosion on these first
generation mains and services represents over 85% of all the leakage that occurs annually on
mains in the Columbia distribution system, making bare steel and cast iron mains at least 16
times more likely to experience leakage than plastic or cathodically protected facilities. As a
result of this clear trend, Columbia continues to believe that it needs to replace the bare steel
and cast iron system at a more rapid rate than it did prior to 2007. Further, Columbia intends to
continue the accelerated pace of its first generation main replacement actMties.
Table I below sets forth a comparison of Columbia's replacement activity in three
periods. Period 1 includes annual footage of cast iron and bare steel (priority) pipe replaced for
the six years prior to the initiation of Columbia's accelerated replacement program. Period 2
depicts the amount of priority pipe replace by year since the accelerated program began and
Period 3 projects the annual footage of that pipe that will be replaced under the term of this
Long-Term Infrastructure improvement Plan.
This replacement rate is contingent on future access to capital over the long term. Events, such as the freezing up of capital markets experienced in 2003, can affect future capital dollar projections.
18
Table I
Priority Pipe Retired/Replaced per Year (feet)
Period 1 Period 2 Period 3 (estimate) 2002 232,320 2007 355,764 2013 625,000
2003 179,520 2008 528,567 2014 625,000
2004 201,712 2009 344,488 2015 525,000
2005 174,240 2010 322,583 2016 525,000
2006 282,518 2011 533,765 2017 500,000
2012 (projected) 510,000
Average/Year 214,062 432,528 560,000
On an average basis since 2007 Columbia has more than doubled its bare steel and cast iron
retirements/replacements to approximately 435,000 feet per year, compared to the 2002
through 2006 timeframe where approximately 214,000 feet per year was retired/replaced.
Period 3 in the Table above demonstrates that not only is the accelerated pace of replacement
projected to continue, but to increase, on average, an additional 110,000 feet per year over the
period 2013-2017.
The next table provides a similar comparison of service line replacement.
Table 2
Service Lines Replaced per Year
Period 1 Period 2 Period 3 (estimate)
2002 2,710 2007 5,222 2013 7,000-9,000
2003 2,809 2008 7,381 2014 7,000-9,000
2004 3,777 2009 4,661 2015 7,000-9,000
2005 3,743 2010 5,241 2016 7,000-9,000
2006 3,407 2011 7,603 2017 7,000-9,000
2012 7,452
Average/Year 3,289 6,260 8,000
19
Again, the accelerated pace of infrastructure replacement in evidenced in the nearly two-fold
increase in the number of service lines replaced in the historical Period 1 and current Period 2.
Period 3 shows a projected annual range of replacement as the particular location/prioritization
of projects completed each year will drive the number of service lines ultimately replaced.
In terms of capital spending, Table 3 illustrates the increased investment in DSIC
eligible property across the three periods.
Table 3
Age and Condition, Betterment, Mandatory Replacement Investment ($)
Period 1 Period 2 Period 3 (estimate)
2002 9,996,000 2007 51,235,000 2013 $151,600,000
2003 14,191,000 2008 71,772,000 2014 148,900,000
2004 21,327,000 2009 57,333,000 2015 120,600,000
2005 29,541,000 2010 56,595,000 2016 119,400,000
2006 32,089,000 2011 106,696,000 2017 116,900,000
2012 126,400,000
Total $107,144,000 $470,031,000 $657,400,000
Average/Year $21,428,800 $78,338,500 $131,480,000
% over prior period 338.69% 39.86%
In sum, Columbia has made significant progress since 2006 in delivering and
maintaining a safe and reliable distribution system for our customers. However, the system
data is clear that as first generation bare steel and cast iron pipe continues to age, its condition
will deteriorate at an increasing rate, and Columbia will have to continue to focus on the
accelerated replacement of bare steel and cast iron to address the problems associated with
aging infrastructure.
Further, because first generation AldyI-A plastic is also failing at a rate much faster that
the newer polyethylene materials, Columbia intends to replace these facilities identified though
Ra
leak investigations, or when they are present within the scope of projects planned in the
course of the bare steel and cast iron replacement program.
Columbia is replacing the segmented, 19th and early 201h century designs of its system
with a more integrated, 21 century system design. This integrated, higher pressure (up to a
maximum of 99 pounds) system will enable Columbia to substantially reduce the current need
for pressure regulators that are presently located throughout its system, thereby making the
system safer, easier and more reliable to operate. A distribution system operating at these
higher pressures also will enable Columbia to install new safety devices in areas to be
upgraded. As part of the upgrade, Columbia is installing excess flow valves on nearly all
services connected to the replacement mains that operate over 10 pounds of pressure. (The
exception would be for those commercial and industrial customers whose consumption is over
5,000 CFH per hour.) These excess flow valves will shut off gas to a residence or business in
the event of a large pressure differential which is typically indicative of a major gas leak or a
service damaged by excavation. This results over time in a system where services are much
less vulnerable to safety risks from third-party damage.
Given that 85% of the Company's current main leakage is corrosion related, it is unlikely
that decreases in operating and maintenance expenses related to leak repairs will be evident in
the near term. However, as the percentage of bare steel and cast iron pipe is materially
diminished, it is reasonable to expect a reduction in such expenses over the long term.
Columbia is removing deteriorating portions of its system and enhancing the safety of
its system by ensuring replacement of facilities with new, longer lasting and safer materials. Its
system will continue to be able to provide deliverability at its Maximum Allowable Operating
Pressure ("MAOP"). The public will receive better service, with fewer interruptions.
21
7) Workforce Management and Training
Columbia Gas of Pennsylvania Workforce
Since 2008, Columbia Gas has been developing and monitoring a strategy to address
future workforce planning issues because of our workforce demographics as well as the
increasing infrastructure replacement activities. In 2009, the Company hired a full time
workforce planning coordinator to help develop a comprehensive, long term strategy to address
the challenges of an aging workforce.
The initial focus of our strategy was to do an analysis of the current workforce, the
potential exodus of employees over the next 5 to 10 years and a determination of the
competencies and skill sets that we would require in the future, as well as staff complement.
Initially, we have enhanced our recruiting efforts to address the volume of hiring as well as
advocate a more diverse workforce to mirror the communities we serve. This effort involves
reaching out to local minority groups, military sites as well as community and technical schools
to alert them to opportunities that Columbia is offering. We strive to bring new employees to
our organization that have a positive attitude and are willing to learn and develop quickly, thus
being able to assume more responsibility as employees are promoted or retire.
Concurrent with the recruiting efforts, the decision was made to bring the pipeline
locating function back in-house. By doing this, we were able to hire new employees into the
organization and put them into roles that allow them to learn our system, develop new skills
and eventually promote into jobs that are vacated by promotions or retirements. A significant
factor in this decision was Columbia's ongoing effort to reduce the number of third party
damages to our facilities.
Another important part of our strategy was the creation and use of multi-skilled
positions. The creation of these positions over the past few years has allowed employees to
develop a wider range of skills and to promote the transfer of knowledge from those employees
that will be leaving the company. These positions also offer the flexibility to utilize workers
22
based on the peak needs of the business. These multi-skilled employees provide the flexibility
to better respond to our customers and thereby enhance our cost effectiveness.
Contractors
Early in 2011, Columbia's affiliated service entity, NiSource Corporate Services
Company, began discussions around the impact of the escalating capital replacement program
on the supply of construction contractors. As the program had grown in the prior few years and
with a forecasted significant growth in the future years, a risk to successful execution was
having sufficient quality contractor crews.
Subsequently a decision was made to proceed with a Contractor Acquisition Strategy to
build longer term relationships with current blanket contractors. The objective was to establish
new contracts that include language enabling Columbia to become the "preferred customer" of
these contractors and entice the contractors to grow their business to support Columbia's
replacement program. A specific goal of this initiative was to position Columbia to have access
to sufficient qualified and experienced contract resources.
From early to mid-2012, meetings were held with incumbent blanket contractors to
share Columbia's capital future and begin the dialogue around proposed enhancements to the
blanket construction contracts. Columbia successfully reached agreements with those
contractors. Highlights of the new contracts are shown below.
New contracts established as of July 1, 2012.
• Extended the term until December 31, 2015.
• Alignment of the contract year with the calendar year beginning in 2013.
• Broadened geographic coverage enabling contractors to work across
operating center boundaries.
23
Expanded the contract scope to include projects involving polyethylene
pipe up to $5,000,000 in contract spend.
Added mechanisms for quarterly adjustments to baseline indexed values
for gasoline and asphalt plus accounted for unexpected costs to complete
contractual requirements.
Included an annual contract adjustment that is tied to a national Laborer's
contract for the Mid-Atlantic Region, Local 1058, Allegheny Zone 2,
Pennsylvania Contract.
• Aligned the responsibility for hard surface restoration to the construction
contractor that generated the work.
Each one of these changes was designed to enhance Columbia's ability to continue to
execute efficiently on its large scale capital program by providing certainty, clarity and flexibility
in the relationship between Columbia and its pipeline contractors. The new contracts establish
a long term, cost effective means of replacing Columbia's cast iron and bare steel pipe.
Operator Qualification
The NiSource Gas Distribution companies maintain a written Operator Qualification
Plan applicable to all Company employees, contractors and mutual aid individuals who perform
covered tasks on behalf of Columbia. The plan encompasses all aspects of ensuring a
qualified workforce and that its operations comply with relevant Federal Pipeline Safety
Regulations. A copy of the plan is included as Attachment B.
Additionally, all DSIC eligible capital projects are subject to inspection by Columbia Gas
of Pennsylvania employees.
24
Summary
in 2007 Columbia embarked on a longterm initiative to replace aging infrastructure in
its distribution system to ensure the provision of safe and reliable service throughout its
territory. Our planning and prioritization methods are dynamic and continually updated to
deploy resources in such a way that the safety of our customers, our employees and the
communities in which our faciUties are located is always the foremost consideration. As such,
each Annual Asset Optimization Plan to be filed subsequent to this Long Term Infrastructure
Improvement Plan will provide the Commission with refreshed projections and details of work
completed.
25
Appendix A
Atlahment A Page 1 of 35
CPA - 2012 Infrastructure Project Replacement Summary
12/7/2012
Project Name Install Footage
D-1581 Country Club Drive Area 3,125
Fairland Phase II 4,000
Pickwick Area - Bethel Park 3,000
College and Lincoln 8,700
D-4 Phase II 9,000
D-1 Phase 1 1,300
Winshire Area - Pittsburgh Norlh Side AMRP Phase 11 3,600
D-82 Cranberry Township 20,000
Kenyon Avenue Area 4,400
Delaware Avenue Phase Il 7,500
Willowbrook Road 8,800
D-5181 Allegheny River Crossing 1,200
Emlenton AMRP 6,000
D-8500 Duck Hollow 3,500
Cedar St, Jeannette 12,000
Atlahment A Pia,, 2 rf 35
• Project Name Install Footage
D-1254, Somerset 10340
Edgewood Rd, York 4000
E. Princess St, York 12,639
N. Main/Susquehanna Trail 3,500
Tn-Hill, York 4,100
S. MainlSunset, Shrewsbury 5,800
E Main, Dallastown 6,000
0-91 7688
Eliwood Avenue from College to Smiley 5,227
Amity Ridge RoadIS.R. 19 5,138
Brookwood Road and E. McMurray 4,515
Fairdale Avenue, Rice to Highland 4,360
Virginia Avenue, Madison to Park (0-84 and LP) 3,800
D-81, Logan Road to Northbrook Drive 3,748
Ninevah Road, Ron McHenry to Line Rd (9-30-1 3) 3,635
Willet 3,524
Linden Road, Thomas to EOL 3,254
Attahment A PnPj 3 0f35
Project Name Install Footage
Second Street, Watson to Water 3,120
Juirich, between Oakhurst and Maple 3,010
North Ohio Street, Girard to Marie 2,884
D-2756 between Van Neal and Old Scales 2,815
D-5263 (SR 0038 to SR 2005) (3-31-13) 2,581
Thornwood Drive, Greenridge to Milton 2,570
Hazel Avenue. Walnut to Dead End 2,436
Thornycroft/Shady
Mason Drive, Evelyn to Dead End
D-147 (Townwood Rd.)
2,431
2,335
2,254
E. Poland Av. 2,250
Beaver Road, 8th to 13th 2,200
Bell Road, D-5252 to S.R. 3009
SR 208 (R. McHenry to Nickleville) (11-30-12)
2,109
2,107
Redrock MP 2,089
D-63 Highland Road, Bethel Park
W. Corydon, (South to E.O.L) 11-30-12
2,064'
2,043
ALlahment A Pane 4 nI 3
• Project Name Install Footage
Rebecca St. 1,943
Blossom Hill Road, Middleboro to Gene 1,940
Wilson Drive, Penhurst to New Gate 1,905
D-81, Arthur Drive, Rinaman to Grubbs Road 1,887
Simplon and Varney Streets 1,844
Locust Street, 3rd to 4th 1,824
Hamilton Road 1,794
Meredith Steet 1,780
Devils Den Road, Pleasantview and Johns 1,742
D-81, Crows Run to Conway Walirose Road 1,720
McClane Farm RoadID-504 1,624
Pennsylvania, Water and Market (3-31-13) 1,609
Jefferson between Norman and Hewitt 1,591
EhIe, Oval to Coraopolis 1589
Pine Avenue, Case to Dead End 1,567
Noblestown Road 1,553
Lincoln Road, Forest to Coolidge 1,466
Attahment A Pie 5 nf3!i
Project Name Install Footage
S.R. 980 between Ohare and Vista drive 1,443
SR 0008 (B Street to Boyers Road) (1-31-13) 1,401
Daly Avenue, Phillips to Dorthea 1,400
LineAv. 1,397
Middle Street, Newport to Dead End 1,373
Spring Valley Road 1,365
Bellingham Avenue, Potomac and Durham 1,360
SR. 8, McCandless toCStreet (11-30-12) 1,341
Arlington 2400 Block 1,316
D-1, R-3321 to Route 51 1,300
Briercliff Road, S.R. 588 to Hillcrest 1238
Eccles 1,237
D-53, between Warrick and Phillips 1,226
SR 2003 (6-30-13) 1,208
River Rd 1,206
Second Avenue, East End Avenue to Beaver Street 1,200
S.R. 308 at Slippery Rock Creek 1,150
Allah ment A PriA F3 üf 35
Project Name Install Footage
Woodland Drive, Green to Dead End 1,119
SR2005 1,115
Walker Avenue, Mechanic to Kennedy 1,058
Industry 1,012
Main Street, Center to Walnut 11-30-13 1,012
Pilgrim Drive, Forty 'to end of line (7-31-13) 1,001
Lewis Avenue LP, S.R. 51 to Hays 1,000
Lambeth, Old Washington to S.R. 19 993
Forest Road, Glenmore Road to Edgewood Road 983
Barr Run Road, between Koci and Adamson 977
Burnside (Boyer to Welch) 966
Lavina Avenue, Church Place to Dead End 925'
Meadow between Pleasant and McNary 922
Wilmington Rd Crossing at Kenneth 900
Orchard Place 597
McMurray Road - medium pressure 891
Greenridge Road, Thornwood to Vermont 886
Attahmerit A P ~;np 7 nf v;
Project Name Install Footage
Rosewood Avenue, Briarcliff to Rania 824
Oxford Drive, Essex to Dead End 816
0-84 Johnson Avenue, Bechtel to Elm 810
Cedar Road/Right-of-Way 805
Springfield, between Murray and Rosewood 787
Clokey/Bowerhill 773
Pleasaritview Rd. 771
17th Street, between 3rd and 4th Avenues 767
McNary, between First and Poplar 753
Sugar Run (Emerald Longwall Mining Mitigation) 738
Patterson Avenue 715
0-86 Water Street 713
Highland, Route 19to Oxford 700
Green Drive 686
Nobles Lane 650
Columbia Drive, S.R. 980 to Arlington 625
Cottage Street, between Ross Avenue and 18th 610
Attahment A P;np R nf5
Project Name Install Footage
Chewton-Wurtemburg Road 607
Mecklem to Virginia (LP) 600
S.R. 980 bewteen Noblestown and North Branch 590
Kohlersburg Rd (LP) 576
Water Street (Mayport) 540
Meadow Lane, Valley to Planter 525
Sankey Court, Churchviewto Dead End 521
SR 2003 (11-30-13) 512
SR 551 at Beaver Creek 511
Merle Street 500
Jefferson (College/Pike) 500
Mercer Road 498
Peters Road, Gables to Orchard 492
Barbour (Bridge to Whitney) 470
Murphys Cut 453
Henderson bewteen High and Monterrey 450
Rosemary Drive, Franklin Park (D-81) 448
Atlahment A Poe 9 ofR5
Project Name Install Footage
AveIla 445
Baptist Road 440
D-81 Brandt School Road 440
Kirsopp Avenue 428
D-3764, between Rawson and Lynn Portal 418
Laurel Ridge 404
D-41 Park Avenue 400
Oak Alley, Wood to Main 398
Nevin Avenue, Hill to Hopkins 390
Heathville Road (1-31-1 3) 3
Grey Lane, Old Stuebenville to Dead End 375
Walker Flat/B Street 372
Chatsworth Street, Erdner to Sedalia 360
Station, Lewis Avenue to Elizabeth Street 352
Curry Hollow 342
Hilltop Acres 340
Lambeth 320
Atthhment A pnnp In nf
Project Name Install Footage
D-504 between Allison Hollow and Kings 316
Lawrence 310
33rd Street, 4th to 5th MR 310
Yale Drive, Queenston to Sinton 305
Sunnyland 300
Gosser 300
Ron McHenry 300
Hazeldell, Brownsville to Lutz 296
East Second Av 282
Brook Street, Interstate Parkway to Bonair 281
Noblestown Road 279
Leon 272
E Street aka Highland Av 271
Pine Hollow, Deweyville and W 11th 242
Pine Hollow, 13th and 14th 240
Trost 240
Knolls Drive - Jackson Knolls 226
Attahmerit A Paue 11 of 35
Project Name Install Footage
Grand Avenue LP 219
Shady, between Henderson and Southpointe 215
GStreet 213
Trost Street 206
Gallion 200
Gass Road 200
Woodlawn, Park to Madison 181
Replace Valve C-35 at Leon Street 149
Chestnut (insert 1 1/4" P) 144
Thompson and Kane 142
Valley St between Home and Peggy 138
Maryland Av - Alley from Winslow to Maryland 130
Homehurst 120
Seneca 120
Kendall (5-31-12) 112
Vineland, Jacob to Huff 105
Replace Valve C-30 at Boylston Street 100
Atfahrnent A Paue 12 of 35
Project Name Install Footage
Estella 95
Hasting Miii 92
Curry Hollow 88
Perry Highway, Manor to Wallace 84
Birmingham Avenue, California to Duff Alley 80
14th Street, 4th Avenue to 5th Avenue 80
Miliview and Summit 75
Ruthwood 70
Park Avenue, Josephine to School 70
Ruthwood 67
Clive Street, Mckinley to dead end 60
Lawnview Av 60
Millers Run, between Grant and Sherman 59
Tanager 52
S.R. 136, Eastpointe to Floral Hill 50
Grandview Dr 50
Pine Street 50
Attahment A Poo 13 of 3f
ProjectName Install Footage
Camfield 41
Princeton 40
Washington Street 40
Montgomery Av 30
Castle 28
D-4, between Washington and McCarrell 20
Pulaski Rd. - Neshannock - Corrosion Date 20
642 S Ray St ( Emergency Job Order) 20
Rail Car Road (6-30-13) 18
D-47, between Home Run and Hillsboro 15
McElree between McGowan and Elwood 10
D-217, between Duff and Linda Vista 10
Lathrop St - Cut out CPLG 10
Thorn Av. / Eliwood City Corrosion Date 6
Ohio River Boulevard 5
6621 Ohio River Boulevard 5
8" Wyatt Park(Wyatt Circle 7171) 8971
AttahmentA Pn 14 rf35
Project Name Install Footage
W Jackson Street (7301) 3912
Baltimore Pike (White Ch & Low Dutch) 3550
Poplars 3500
S Main - Mill to Ore (Active Corrosion) 3450
Mont Alto 2850
Scarboro (AC) 2809
Table Rock (LK) 2753
N Oak Ln (LK/OP) 2450
Pinchtown Road (OP) 2300
Basehoar School Road (Carry-over) 2210
Hillside Ave (LK) 2200
Somerset (AOP) 2080
Glendale (AOP) 1902
Corl St(AOP) 1900
N Belvidere: Madison - Lincoln (AOP) 1882
3rd Street (Optimain/AOP) 1745
E Main, Windsor (Carry-Over) 1646
Attahment A Page 15 of 35
Project Name Install Footage
Brockie/Wyndam Hills (AOP) 1592
E Aaron Dr ( AOP) 1527
West California (
LK) 1400
Hay Street 1377
Linden (AOP) 1327
Norway St 1293
Table Rock Ph 2 (LK) 1267
Maryland (AOP) 1215
Tn-Hill 1180
MtRose 1166
Pattison 1142
Alta Vista 1133
Meadowbrook (AC) 1062
Ogontz 1061
S Albemarle 1040' - 4" PMMP 1040
Linden Avenue (West to Hawthorne) 1000
2" Poplar (Wyatt Cirice) 989
Altaliment A P2ae 16af35
Project Name Install Footage
E South St 965
Wiltshire (AOP) 907
S. Howard 898
Simpson St 910' - 2" PMMP 888
McKee Street (AOP) 840
Stanton 810
Highland / K Alley ( OP) 806
Lee St 744
Lexington 686
Peyton Road 680
E Calder (LK) 675
Park 658
Topper/Harrison (Leak Driven) 599
S Yale & Ogontz (MT Rose & Spawn) 583
S Charles Street 581
Susquehanna Trail Leak (OP) 580
Baltimore SR 0016 548
Attahment A Page 17of35
Project Name Install Footage
E Jackson (Part of Pine St Large Project 7155) 541
Washington St 540
Water St 531
Warren St 525
Frederick Ct 654' - 2" PMMP 515
Carlisle Road (Harmony & George) 515
Cleveland 498
Maryland (Hartley-Elm - AOP) 490
Girard 450
S Sherman 441
Local Way, York 401
Bennett 400
Delta 370
Echo Ln 360
Shannon Ln (LK) 350
6 Mason 350
1'1 George 350
Allahrnent A Paae Th of 35
Project Name install Footage
N Washington 331
Eberts Lane 329
Cleveland 8" Critical Valve 308
Maple St 300
Pennsylvania (AOP) 278
Third St 202
W High & Howard (AOP) 192
Wilson Alley 132
E Princess St 65
Druck Valley 13
Clover 10
2" Palomino (Wyatt Circle) 10
Old National Pike 5366
D-7007 Mellinger 2500
Meadow Av 2487
W Garrett & R St 2320
Depot St 2137
Attahment A Pari IQ nfc
Project Name Install Footage
D-1254 Garrett Short 2086
*N7th bet Harrison & Pit* 1922
D-8664 1870
D-7011 Lowber Rd 1800
SR88 1800
D-7101 1766
D-7128 Kelly Run 1756
Chestnut Str 1653
Crawford 1441
NSecondSt 1340
Federal St liso
NJefferson Str 1175
CowanAve 1127
D-7024 PA Av 1075
Park Ave 1041
SRB8 1021
WBlakeAv 926
Attahrnent A Page 20 of 35
Project Name Install Footage
Scott Ave 916
White St 851
N Fourth St 850
Altman 847
"C" Rd (off SR 166) 831
D7007/D7024 825
PA Ave 809
Laurel Crest 803
St Clair 800
ShadyAv 755
Center Str 711
LewisAv 660
Mountain View 606
Bethel Rd 594
Greene St 577
Leisenring Ave 573
Eighth St 558
Attahment A P1A21 nf
Project Name Install Footage
D-8547 @ Lake Str 555
Grant St 530
2nd Ave 520
Scenery Str 470
Old Trail 386
Meadow Str 382
Second Str 326
Lincoln Ave 315
"R" St 279
LewisAv 275
Willow St 260
Pittsburgh St 234
SR 40, National Pike 207
ml of Oak & E Alley 200
D-7090 Energy Drive 190
7thStr 166
"AF" Alley/Be rkey Ln 157
Attahment A Paoe 22 of 35
Project Name Install Footage
Varsity Rd 121
Ash Street 118
W. George Street 76
EMainSt 74
Conrad Ave & 5th 57
D-8528 @ R-3033 36
Boulevard Str 30
Lewis Str 20
D-7090 Fox Stop Rd 7
D-7553 5
Center Str 5
Attahment A Page 23 of 35
CPA - 2013 Infrastructure Project Replacement Summary
12/7/2012
Project Name Install Footage
VanKirk 2,200
Kirsopp 3,000
EhIe 4,000
Freeland 2,400
Gearing 1,850
Lodge 1,200
Broadmoor Avenue 4,000
lroquios Drive 5,400
Fruithurst Drive 4,600
Cliff Mine Road 2,100
Glencoe 1250
Orchard/Parkway 3,400
Fairland Phase III 9,200
Tropical/Crane 8,500
D-1581 4,000
Atlahment A Pno 24 of 35
Project Name Install Footage
D-1 0183 10,000
Lincoln Avenue in McDonald 1,200
Wolfsdale 5000
CaIdwell Avenue 9,000
Franklin Avenue 1,500
Bucktown 8,400
Dutch Hill 4,800
East National Parkway 6,200
Shenango Road - Active Corrosion 3,100
W ittmer Street 1,160
4th Street - Active Corrosion 1 ,1 20
Ambridge Avenue - Active Corrosion 2,530
D-74 - Coraopolis 5,200
D-84 - Monaca 1,200
Sewickley Cast Iron - AMRP 3960
D-88 River Crossing 1,200
D-1 Phase 11 at Groveton 2,800
Attaliment A Pene 25 nf::5
Project Name Install Footage
Ray Street 3,800
Pershing Street 5,200
Emlenton MP Phase ii 3,400
D5181 Pickard Valley 4,500
D-4227 Phase I 3,800
Pleasant Drive 2,500
D-1254 Lichty School Rd 5,200
Franklin, Somerset AMRP 9,000
D-7024 Gregg Dr 2,500
D-7128 Craftmore Rd 4,970
Cedar St AMRP 12,200
Water Street, California AMRP 3,700
Ridge Av. (Juergens) 3,700
Penn St. (Juergens) 15,000
Company St. (Juergens) 2,600
Sycamore Rd (Wagaman) 2665 & 1000
11th Ave (Wagaman) 3763 & 4016
Attahment A Paae 26 of 35
Project Name Install Footage
Bridgeton Rd (Wagaman) 2,195
Lincoln Avenue (Martin) 3,100
Gettysburg Crossing HP (Martin) 3,420
College Ave AMRP ( Clark / Gill) 3,560
West Jackson Street ( Clark) 13,347
D-54 9,500
Ken Forest Drive 7,000
Connor Road 4,500
Joseph 3,000
Bowerh iii 2,727
Kingwood Street 2,578
Rt 51/ Rt 88 Interchange 2,400
Eccles 1,600
Beryl 1,350
Country Club 1,200
Groveland Street 900
Sylvania Avenue 900
Allahmenl A Pnnp 27 of r;
Project Name install Footage
Beaufort 772
Russellwood 507
Brig htwood Road 500
Brookline Blvd 400
Shaw Avenue 300
Dell Rose (Overbrook to Parkfield-ish) (2264-2292) 250
Gallion 200
LocustMP 10
Elberta 4,300
Bucktown 4,000
D-503 3,300
East National Pike 2,700
Midway 2,700
Lawrence 2,300
Franklin Avenue 2,000
D-48 1,860
Brown Alley 1,600
Altahment A Page 28 of 3
Project Name Install Footage
Burnside Road 1,400
Dunn Station Road 1,000
D-1810 Exposed Pipe 1,000
Noblestown Road 931
Burnside Road 800
Beeson 700
Spring Valley 650
O'Hare Road 600
12 Wells Drive 560
Chartiers Street 500
Johns Drive (Burgettstown) 500
Third Street 340
Fawcett Church Road 300
Mount View 20
4th Avenue (SR. 18), 32nd to 47th (SB No. 7341) 6,831
Diebold Road, Robert to Francis 2,611
D-75 Duss Avenue, Legionville to Harmony 2,344
Atlahment A Paae 290135
Project Name Install Footage
N. Baiph Avenue, Forest to United States 2,289
Shenango Road, Holly Drive to Park 2,094
3rd Street, Insurance to Market 2,015
Grand Avenue, Phillips to 1st Street 2,010
Economy Street, Keystone to Pioneer (SB 7371) 1,730
Hopkins Church Road, Law to Camp Meeting Road 1,700
Wexford Bayne Road, Lloydmont to Limerick 1,621
Roosevelt Avenue, Meade to Starr 1,522
Fern Hollow Road, Meta to Westholm 1,453
Viruth Street, McClure to Benton 1,300
D-81, From Concord Church to 989 1190
Cleveland Avenue, Florence to S.R. 65 1,000
8th Street, Glenwood to Melrose 943
Orchard Avenue, S.R. 65 to Center 933
Blockhouse Run Road 932
Forest Avenue, Ravenswood to Maryland 912
Rosemary Drive, Brandt School to Dead End (MP) 912
Attahment A Prn' M nf r;
Project Name Install Footage
Gringo Clinton Road--Supply from POD 890
Woodland Road, Bradford to Lake 747
21stAvenue, 18thto19thStreet 680
Naugle Lane, Blackhawk Road to Pine Street 673
Beaver Road, Lantern to Sycamore 497
3rd Avenue, 5th to 6th Street 479
Rosemary Drive, Franklin Park (D-81) 448
Centennial, Pine to Canterbury 415
8th Avenue, 4th St to 5th St in Patterson Hgts 400
Wapello Avenue, Davis 'to Pemberton 322
Backbone Road 40
Delaware Phase 4 (SB 7323) 10900
Creekview Drive (SB 7361) 5,900
D-22 - Branchton to Keister 5,100
Miller Road Phase IV 5,000
D-80, SR 258 to Fergus 3,134
Miller Road Phase 111 2,600
Ada hment A pr,.q1
Project Name Install Footage
Kay St. Clyde to Water - Wampum 2.414
Stanton and Rose Av 2,200
Beaver Street - New Galilee 1,800
Eliwood Road (Rt. 65) 1,535
Argonne 1,400
Chapel Dr 901
Fire St Eliwood City 800
Rhodes Place 600
West Poland Av - Bessemer 500
Eastbrook Rd Relocation 400
Edgewater Rd - New Galilee 241
10 W. Sharp Street, S. Jefferson to End of Line 150
Moorehead Av Between Jefferson and Hanna St 100
Summit St. 2nd to 4th 25
Nickelville Road (SR 4007) Driveway Conflict 1,000
Summit in Foxburg 800
E. Church Street (W. Sunbury) 733
Attahment A Fade 32 of 35
Project Name Install Footage
SR 4012 (8-31-13) 619
SR 38/208 PA DOT Project 512
SR 308 400
D-5245 in Clintonville (4-30-14) 20
S.R.2009 1638
Huber Road, Curllsville Road to end of line 1140
S.R.66 800
S.R. 2003 (Olean Road) 295
Seaward Avenue, Tuna Cross Roads to Riley 5148
D-4002, S. R. 219 to Minard Run Road 1318
E. Main Street MP, R-4167 to SR 346 703
High Street, Minard Run Road to end of main 619
Nancy Lane, B Road to BJ Road 550
Lake Circle Drive, Lambert to Webster 332
River (Elm to end of line) 260
Future Way RR Bridge X-ing at Kendall Ck (5-31-14) 122
Birch Street 100
Attahment A Paue 33 of 35
Project Name Install Footage
D-4005 at Beaver Pond (4-1-13) 4031'
Prospect Street, Divison to Conewango 3,882
Liberty Street and Third Ave 1,658
D4005 near CP 1469 (5-31-13) 1,500
4TH Avenue, Public to Chestnut (12-31-13) 20
SR 0030 5,800
Route 30 4,000
Margaret/Catherine (LK) 2,300
Lincoln Avenue - Gettysburg College 2,300
Rocky Mountain - Corrosion project 1,000
Carroll Rd (leakage) 733
W Main St - Corrosion 600
Bucha non Valley Rd - AOP 400
D-8542 4200
D-7055 3005
Clover 2,673
ALLEN & 4TH 2,530
Attahment A Ptie 34 c,f 35
Project Name Install Footage
Waddell St 2,436
D-7169 - Warfel Road 2,432
Ben Lomond 2,269
FoundryAv 1,916
D-1254 1,600
D-7169 - Laureldale Road 1,562
D-7169 - New Hill Road 1335
Brashear Ave 1,326
D-7191 1,258
Wendel Rd 1,190
State St 1,045
Felgar Rd @ Franklin 1,030
MapleLn 1010
Clawson 979
Allen (1st-3rd) 775
Main SIr 759
Fiscus 718
Atlahnient A
Project Name Install Footage
D-7128Barneys Run 670
Flinn St 626
Blue Jay Drive 583
V Alley 479
S. Rosina Ave 411
Fifth St 373
D721 5/Fifth St 250
D-7009 80
Appendix B
Attachment B Page 1 of 67
IM ixu
Columbia Gas Distribution Companies 1 Kentucky, Maryland, Ohio, Pennsylvania and Virginia
DOT OPERATOR QUALIFICATION PLAN 49 CFR PART 192, SUBPART N
Revised 04-01-2012
c• Written qualification programs were established for all of the Columbia Gas companies on or before April 27, 2001
•:. Written qualification programs were established for all of the Columbia Gas companies identifying covered tasks performed on Columbia's facilities on or before April 27, 2001.
•:• Written qualification programs were established for all of the Columbia Gas companies identifying initial qualification methods for the evaluation of individuals performing covered tasks prior to October 28, 2002.
•:. All individuals performing covered tasks as of October 28, 2002, and not otheiwise directed and observed by a qualified individual, were qualified prior to October 28, 2002.
1 The Columbia Gas Distribution Companies (Columbia Gas) are: Columbia Gas of Kentucky Columbia Gas of Maryland Columbia Gas of Ohio Columbia Gas of Pennsylvania Columbia Gas of Virginia
Attachment B Page 2 of 67
Table of Contents
Federal OQ Rule . 3
Introduction..........................................................................................................6
Scope & Program Performance and Improvement .........................................................7
Definitions............................................................................................................8
Section A CoveredTasks ............................................................................................12
Section B Evaluation of Qualification ..............................................................................14
Section C Non-qualified Individuals ...............................................................................16
Section 0 Performance contributing to an incident ............................................................17
Section E Reasonable Cause to Verify Qualification .........................................................18
Section F Communicate Change ..................................................................................19
Section G Qualification Evaluation and Intervals ..............................................................20
Section H Training.....................................................................................................22
Section 1 Significant Modification Communication ...........................................................24
Section J RecordKeeping ..........................................................................................25
Section K Mutual Aid, Mergers and Acquisitions ............................................................26
Section L Management of Change (MOC)..............................................................27
Exhibit A TaskList ....................................................................................................30
Exhibit B Subsequent Qualification Intervals & Interval Matrix ......................................44
Exhibit C Methods for Verifying Qualification of Contract Personnel ....................................49
ExhibitD Protocol for Evaluating Operator/Contractor OQ Plan ........................................54
Exhibit E Failureto Qualify .........................................................................................63
Exhibit F Notification of Change Form ..........................................................................65
Exhibit G MOC Proposed Change Form ........................................................................67
2
Atlachment B Page 30167
The Rule:
49 CFR 192 Subpart N- Qualification of Pipeline Personnel.
Subpart N—Qualification of Pipeline Personnel
§ 192.801 Scope.
(a) This subpart prescribes the minimum requirements of operator qualification of
individuals performing covered tasks on a pipeline facility.
(b) For the purpose of this subpart, a covered task is an activity, identified by the
operator, that:
(1) Is performed on a pipeline facility;
(2) Is an operations or maintenance task;
(3) Is performed as a requirement of this part; and
(4) Affects the operation or integrity of the pipeline.
Amdt 192-86 64 FR 46853, Aug 27, 1999
§ 192.803 Definitions.
Abnormal operating condition means a condition identified by the operator that may
indicate a malfunction of a component or deviation from normal operations that may:
(a) Indicate a condition exceeding design limits; or
(b) Result in a hazard(s) to persons, property, or the environment.
Evaluation means a process established and documented by the operator, to determine
an individual's ability to perform a covered task by any of the following:
(a) Written examination;
(b) Oral examination;
(c) Work performance history review; after October 28, 2002 may not be used as
the sole method of evaluation. (d) Observation during; after December 16, 2004 may not be the used as the sole
method of evaluation
(1) Performance on the job.
(2) On the job training.
(3) Simulations; or
(e) Other forms of assessment.
Qualified means that an individual has been evaluated and can:
(1) Perform assigned covered tasks; and
(2) Recognize and react to abnormal operating conditions.
JAmdt 192-86 64 FR 46853, Aug 27, 1999 as amended by Amdt. 192-86A, 66 FR 43523, Aug. 20,
2001]
3
Attachment B Page 4 of 67
§ 192.805 qualification Program.
Each operator shall have and follow a written qualification program. The program shall
include provisions to:
(a) Identify covered tasks;
(b) Ensure through evaluation that individuals performing covered tasks are qualified;
(c) Allow individuals that are not qualified pursuant to this subpart to perform a
covered task if directed and observed by an individual that is qualified;
(d) Evaluate an individual if the operator has reason to believe that the individual's
performance of a covered task contributed to an incident as defined in part 191 of
this chapter;
(e) Evaluate an individual if the operator has reason to believe that the individual is
no longer qualified to perform a covered task;
(f) Communicate changes that affect covered tasks to individuals performing those
tasks.
(g) Identify those covered tasks and the intervals at which evaluation of the
individual's qualifications are needed;
(h) After December 16, 2004, provide training as appropriate, to ensure that
individuals performing covered tasks have the necessary knowledge and skills to
perform the tasks in a manner that ensures the safe operation of the pipeline
facilities; and
(i) After December 16, 2004, notify the Administrator or State agency participating
under 49 U.S.C. Charter 601 if the operator significantly modifies the program
after the Administrator or State agency has verified that it complies with this
section.
rAmdt 192-86 64 FR 46853, Aug 27, 1999; as amended by Amdt 192-100, 70 FR 10332 Feb 25,
2005;
§ 192.807 Record keeping.
Each operator shall maintain records that demonstrate compliance with this subpart.
(a) Qualification records shall include:
(1) Identification of qualified individual(s);
(2) Identification of the covered tasks the individual is qualified to perform;
(3) Date(s) of current qualification;
(4) Qualification method(s).
(b) Records supporting an individual's current qualification shall be maintained while
the individual Is performing the covered task. Records of prior qualification and
records of individuals no longer performing covered tasks shall be retained for a
period of five years.
Amdt 192-86 64 FR 46853, Aug 27, 1999
§ 192.809 General.
(a) Operators must have a written qualification program by April 27, 2001. The
program must be available for review by the Administrator or by a state agency
participating under 49 U.S.C. 601 if the program is under the authority of the state
agency.
4
AttachmeriL B Page 5 of 67
(b) Operators must complete the qualification of individuals performing covered tasks
by October 28, 2002.
(c) Work performance history review may be used as a sole evaluation method for
individuals who were performing covered task prior to October 26, 1999.
(d) After October 28, 2002, work performance history may not be used as the sole
evaluation method. -
(e) After December 16, 2004, observation of on-the-job performance may not be
used as the sole method of evaluation.
[Amdt 192-86 64 FR 46853, Aug 27, 1999; Amdt. 192-90, 66 FR 43523, Aug. 20, 2001; Amdt 192-
100, 70 FR 10332 Feb 25, 2005]
5
Attachment B Page 6 of 67
Introduction
Columbia Gas in tends to improve pipeline safety by ensuring a qualified workforce and that its operations comply with relevant Federal Pipeline Safety Regulations.
In accordance with pipeline safety regulations defined in 49 CFR part 192, Subpart N, the
U.S. Department of Transportation, through its Research and Special Programs
Administration (RSPA) [now known as Pipeline and Hazardous Materials Safety
Administration (PHMSA)], adopted regulations requiring that all individuals who operate
and maintain pipeline facilities "be qualified to operate and maintain the pipeline facilities" and have "the ability to recognize and react appropriately to abnormal operating conditions that may indicate a dangerous situation or a condition exceeding
design limits". To ensure its compliance with these regulations, Columbia Gas has adopted this DOT Operator Qualification (OQ) Plan (the Plan). Columbia Gas intends to
make its employees, and other individuals who may perform tasks covered under the
regulations setforth in Subpart Non behalf of Columbia Gas, aware of the regulatory
requirements and the contents of this Plan.
This Plan and its Exhibits provide guidance for
• Identifying relevant operating and maintenance tasks (Covered Tasks);
• Achieving and maintaining compliance with the requirements of Subpart N and;
• Establishing and maintaining qualifications to perform Covered Tasks
on a Columbia Gas pipeline facility.
Atlachment B Page 7 of 67
Scope
This written Operator Qualification plan applies to all Columbia Gas employees,
contractors and mutual aid individuals who perform covered tasks on behalf of Columbia. It is adopted to comply with 49 CFR Part 192, Subpart N. This plan replaces in its entirety, any prior written operator qualification plans established for Columbia Gas
of Kentucky, Columbia Gas of Maryland, Columbia Gas of Ohio2, Columbia Gas of Pennsylvania and Columbia Gas of Virginia.
This written Operator Qualification plan shall become effective Apr11 28, 2004; the initial
Columbia Gas state-specific written Operator Qualification plans shall be archived for a
period of not less than five years from the effective date of this plan. The initial,
established written Operator Qualification plans shall be available upon request until
April 29, 2009. The effective dote of this plan for Columbia Gas of Virginia is February
01, 2005. The initial Virginia established written Operator Qualification plan shall be
available upon request until February 02, 2010.
Program Performance and Improvement Columbia Gas continues to seek program performance improvements through participation in Federal and State OQ seminars, public meetings, presentations and
special OQ committee involvement. Compliance and Technology (C&T) and Technical
Training remains actively engaged in meetings and presentations with Columbia Gas and
Contractor individuals. The meetings and presentations are made up of management,
supervision and field employees, from both Columbia Gas and contract companies. Columbia Gas has established a validated qualification curriculum. Part of the validation
of this process is allowing affected individuals the opportunity to offer suggestions and
comments.
Columbia Gas envisions its Operator Qualification program as a living document. We
are dedicated to perpetually seeldag, and adopting as appropriate, program
performance improvements.
2 The date of the original Columbia Gas of Ohio OQ plan was 4-27-2001 7
Attachment B Page 8 of 67
Definitions
Ability- means the capacity to do or act, physically and/or mentally.
Abnormal Operating Condition (AOC)- means a condition identified by Columbia Gas that may
indicate a malfunction of a component or a deviation from normal operations that may: (a) indicate an
operating condition exceeding design limits; or (b) result in hazard(s) to persons, property, or the
environment.
Activity- A specific deed, action, function, or sphere of action.
Affects the Operation or Integrity of the Pipeline- Any activity, or omission of an activity, that could
directly or indirectly result in a hazard to persons, property or the environment. As used in the safety
context of the OQ rule, the phrase indicates activities that could result in an AOC that in turn could
result in an unsafe operating condition.
Alarm - an audible or visible means of indicating to the controller that equipment or processes are
outside operator defined, safety-related parameters.
Alerts - an audible or visible means of indicating to the controller that equipment or processes are
outside normal operating parameters
Communicate- To convey information about; make known; to reveal clearly.
Compliance- Activity(ies) in accordance with the rule.
Contributed- Determined to be a factor.
Contributed to- A judgment by designated Columbia Gas personnel, that the action or inaction of an
individual(s) was a factor in the occurrence of an incident/accident.
Control Room - an operations center staffed by personnel charged with the responsibility for remotely
monitoring and controlling a pipeline facility.
Controller—a qualified individual who remotely monitors and controls the safety-related operations of
a pipeline facility via a SCADA system from a control room, and who has operational authority and
accountability for the remote operational functions of the pipeline facility.
Covered Task- is an activity, identified by Columbia Gas, that: (1) is performed on a Columbia Gas
pipeline facility; (2) is an operations or maintenance task, (3) is performed as a requirement of this part
(Part 192); and (4) affects the operation and integrity of the pipeline
Criterion- A standard upon which a judgment is based.
Current- Belonging to the present time; now in progress.
Demonstrate- Provide tangible evidence.
Determine- To conclude after consideration, investigation, or calculation.
Direct- To take authoritative charge of or supervise; to control, order or command.
Direct Observation- Observation of an unqualified individual(s) during the performance of a covered
task by a qualified person,(in that task). Such qualified person must be able to take immediate and
effective corrective action if incorrect procedures or AOCs are observed.
Document- Retrievable record.
Evaluator- Persons performing evaluations should possess the required knowledge (1) to ascertain an
individual's ability to perform the covered task(s), and (2) to substantiate an individual's ability to
N.
Attachment B Page 9 of 67
recognize and react to AOCs that might surface while performing those activities. This does not mean
that the person performing the evaluations should be physically able to perform the covered task(s)
themselves.
Evaluation- means the process set forth in this Plan to assess and document an Individual's ability to
perform a Covered Task(s) by any or all, as appropriate, of the following;
u Written examination,
u Oral examination,
• Work performance history review - shall not be the sole method of evaluation,
• Observation during:
1. Performance on-the-job (shall not be the sole method of evaluation)
2. On-the-job training
3. Simulations; or
ci Other forms of assessment.
Excavation within a Pipeline Facility- Qualification for this covered task does not require Columbia
Gas employee(s) or contractor employee(s) to be proficient in the operation of excavation equipment.
Covered tasks requiring qualification shall include: *Verification of line location and depth, *On e Call
and underground facility owner/operator notifications, *Sloping / Shoring, *Water removal, and *l ns pection. Third party excavations that take place on Columbia Gas pipeline facilities shall be handled
in accordance with Columbia Gas's damage prevention program requirements.
Identify- To establish the identity of; to ascertain the origin, nature, or definitive characteristics of.
Immediate Corrective Action- Taking steps to correct mistakes or abnormal or hazardous conditions
without delay.
Individual- means an employee of Columbia Gas or an employee of an affiliated or unaffiliated entity
who, on behalf of Columbia Gas, performs one or more Covered Tasks on a Columbia Gas pipeline
facility.
Integrity- The ability of a pipeline to operate safely and to withstand the stresses imposed during
operations.
Interval- The amount of time between two specified instants, or events.
Knowledge- Understanding gained through experience or study.
Knowledge, Skills, and Abilities (KSA)- An appropriate combination of information, craftsmanship,
and proficiency that allows an individual to perform covered task(s) in a competent manner.
Maintain- To keep in a condition of good repair or efficiency.
Maintenance- The act of maintaining orthe state of being maintained; the work of keeping something
in proper condition; upkeep.
Observe- The act of watching; to watch or perceive. For purposes of conducting qualification
evaluations using on-the-job (OJT) performance, observations must include the interaction of the
evaluator and qualification candidate to ensure that the candidate's knowledge of the procedures (and
the reasons for the key steps therein) is adequate to ensure the continued safe performance of the task.
Written documentation of the evaluation materials, i.e. task requirement key steps and AOCs are
utilized during observation to ensure consistent evaluations are administered across Columbia Gas
Operate- Starting, stopping and/or monitoring a device or system.
Altachnient B Page 10 of 67
Operation- Actions taken to facilitate storage or movement of product through a regulated pipeline.
Operator- As defined in 192.3 and 195.2, means a person who engages in the transportation of gas.
May also be referred to as Owner when used within NiSource contracts.
Perform- To begin and carry through to completion; to demonstrate in accordance with the
requirements of; to accomplish (a covered task) in the proper, customary or established manner.
Person- A5 defined in 192.3 and 195.2, means any individual, firm, joint venture, partnership,
corporation, association, State, municipality, cooperative association, or joint stock association, and
includes and trustee, receiver, assignee, or personal representative thereof.
Pipeline-As defined in 192.3 and 195.2, means all parts of those physical facilities through which gas
moves in transportation, including pipe, valves, and other appurtenance attached to pipe, compressor
units, metering stations, regulator stations, delivery stations, holders, and fabricated assemblies.
Pipeline facility- means new and existing pipelines, rights-of-way, and any equipment, facility or
building owned by Columbia Gas and directly connected to and used in the transportation of gas or in
the treatment of gas during the course of transportation.
Prior- Preceding in time or order.
Process- A systematic series of actions directed to some end.
Program- A written description of processes to be followed; a clear delineation of authorities and
responsibilities there under and the specific results expected to be achieved for the implementing
organization.
Protocol- A standard methodology used to conduct inspections of regulated entities to determine
conformance to specific requirements prescribed by regulation.
Provision- The written description of the element(s) or approach employed by Columbia Gas to satisfy
the requirements of the OQ rule in 49 CFR Part 192 Sub-Part N.
Pursuant- In accordance with or as a follow-up.
Qualified Individual- means an Individual who has been evaluated and can (a) perform assignec
covered tasks, observe & direct non-qualified individuals and (b) recognize and react to Abnormal
Operating Conditions.
Records- Recorded information or data on a particular subject (OQ), collected and preserved to
demonstrate compliance with the OU rule.
Retain- To keep possession of, in a retrievable and useable condition.
Skill - A demonstrable competency to perform a given task well, arising from talent, training or practice.
Subject Matter Expert (SME) - An individual recognized by Columbia Gas as having a special skill or
specialized knowledge of a process in a particular field, or of a piece of equipment.
Supervisory Control and Data Acquisition (SCADA) - means a computer based system or systems
used by a controller in a control room that collects and displays information about a pipeline facility and
may have the ability to send commands back to the pipeline facility.
Standard- A written document, which is commonly used and accepted as a basis for judging
acceptability of performance in the areas addressed.
Task - A piece of work assigned to or expected of an individual(s).
10
Attachment B Page 11 of67
Training - An educational or instructional process (e.g., classroom, computer-based, or on-the-job) by
which an individual's KSA level is improved. While not currently required by the 00 rule, training is
nonetheless fundamental to implementing many of the 00 Rule's requirements.
Written - To set down in writing many of various ways.
11
AUacliment B Page 12 of 67
Covered Tasks (192.805 (a))
Columbia Gas conducts job task analysis of activities performed on its Pipeline facilities. It then applies the following four-part test (as set
forth in 49 CFR 192.801) to each of the identified activities to
determine which activities are Covered Tasks:
1. Is the task performed on a pipeline facility;
2. Is the task an operations or maintenance task;
3. is the task performed as a requirement of 49 CFR Part 192; and
4. Does the task affect the operation or integrity of the pipeline.
Columbia Gas analyzes data gathered during the four-part test and job task analysis to develop a
covered task list customized to match Columbia Gas, operating standards.
Process for analyzing data while establishing and maintaining Columbia Gas's
identified Covered Task list.
Process to establish Columbia Gas's identified Covered Task list.
C&T personnel, Technical Training, Engineering, Commercial Operations, and Operations Subject Matter
Experts (SMEs) gather and analyze data while applying the four-part test as set forth in 192.801. The
data analyzed is gathered from Federal, State and local regulatory requirements, Columbia Gas operating standards, and manufacturer and vendor instructions. C&T, along with Technical Training,
utilize the findings from this data analysis when determining and justifying the Columbia Gas identified
Covered Task list.
Process to maintain Columbia Gas's Identified Covered Task list
C&T and Technical Training are responsible for identifying:
• New State and/or Federal regulatory requirements affecting Columbia Gas's operating
standards and/or identified covered tasks.
• Revised State and/or Federal regulatory requirements affecting Columbia Gas's operating
standards and/or identified covered tasks.
• New or revised gas standards (policy and procedures) affecting identified covered task(s).
• Approved and adopted new equipment and/or technology affecting Columbia Gas's operating
standards and/or identified covered tasks.
• New or revised information from equipment or product manufactures affecting Columbia Gas's
operating standards and/or identified covered tasks.
12
Attachment B Page 13 0167
Process for disseminating and reviewing new and/or revised information
. C&T will identify the Columbia Gas operating standard(s) affected by the change.
• C&T will send out an electronic advisory detailing the new or revised information to Technical
Training and Operations SMEs for review and comment.
• C&T will analyze the affect the change(s) will have on existing identified Covered Task(s) or
determine if a new identified Covered Task(s) is required. If C&T determines the change affects
a covered task(s), Section F of this plan will be followed.
C&T working with Technical Training, Commercial Operations, and Operations SMEs will facilitate the
necessary changes to Columbia Gas's operating standards to reflect the new or revised information.
Technical Training will assess the effect the changes will have on the task(s) and make adjustments to
the evaluation and qualification process as necessary.
Attached to this Plan, as Exhibit A, is the list of identified Covered Tasks.
13
Attachriient B Page 14of67
Evaluation of Qualifications (192.805 (b))
An Individual's qualification to perform a Covered Task will be evaluated using appropriate evaluation methods identified in this Plan.
Evaluator Criteria Persons with responsibility for evaluating an Individual's qualifications to perform Covered Tasks will
have the required knowledge, through training or experience, to ascertain that Individual's ability:
(1) To perform Covered Tasks
(2) To recognize and react to Abnormal Operating Conditions that might arise or be observed
while performing identified tasks.
Evaluation Methods Evaluation methods and qualification criteria applied to a Covered Task will vary from task to task. The
evaluation method(s) chosen for any specific Covered Task will include one or more of the following, as
appropriate:
. Written examination
• Oral examination
• Work performance history review (shall not be the sole method of evaluation; 192,809 c, d)
• Observation during:
a. Performance on the job (shall not be the sole method of evaluation; 192.809 e.)
b. On-the-job training (OJT), (shall not be the sole method of evaluation; ADB-09-03) or
c. Simulation;
. Other forms of assessment.
Evaluation Categories
Transitional qualification - The qualification of Individuals: (1) who performed one or more Covered
Tasks on a regular basis prior to August 27, 1999 and (2) who qualify to perform those same Covered
Tasks, according to this Plan, priorto October 28, 2002. It is only during the transitional period of qualification that Columbia Gas may use work history
performance review as the sole evaluation method.
Initial qualification - The qualification of Individuals who did not perform a particular Covered Task on
a regular basis prior to August 27, 1999.
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Attachment 13 Page 15 of 67
Subsequent qualification - The evaluation of an Individual's qualification to perform one or more Covered Tasks, after the Individual's transitional or initial qualification to perform the same Covered Tasks, at intervals established by Columbia Gas. The subsequent qualification process may utilize different evaluation criteria than were used for transitional or initial qualification, and subsequent qualification in no event must occur until after October 28, 2002.
The following criteria will be applied to each Covered Task to determine the appropriate
evaluation methodology applied to that task:
1. Frequency of performance
2. Critical nature of the covered task with respect to operation
3. Complexity! Difficulty
4. Existence of checks and balances, such as, Reviews and/or audits
5. Statutory requirements
15
Attachment B Page 16 0167
Non-Qualified Individuals (192.805 (c))
Columbia Gas permits non-qualified Individuals to perform Covered Tasks under certain
circumstances, including but not limited to, the non-qualified Individual's participation in
on-the-job training or when working as part of a crew. l4owever, under all drcumstances when using non-qualified individuals, the following conditions shall be met:
In compliance with statutory requirements, non-qualified individuals shall not under
any circumstances perform the following identified covered tasks:
El Welding Pipelines
E2 Performing nondestructive Testing on Steel Pipelines & Welds
Fl Joining Plastic Pipe - Manual & Hydraulic
Fla Joining Plastic Pipe - Manual Only
Li Tapping & Stopping Pipelines - all Sizes & Pressures
ha Tapping & Stopping Pipelines -4" & smaller tap holes; 60 PSIG & less)
lib Tapping & Stopping Pipelines Self Punch Tees / LP Tapping and Bagging
Lic Tapping & Stopping Pipelines - Self Punch Tees
Non-qualified individuals may perform other covered task(s) if all of the following
conditions exist:
• A qualified Individual is assigned to direct and observe non-qualified individual(s) during the
performance of a Covered Task.
• A qualified Individual is able to communicate effectively with the non-qualified individual and
take immediate corrective actions when necessary.
• The qualified individual is responsible for the performance of the Covered Task.
• The ratio of non-qualified individuals to a qualified Individual is kept to a safe and controllable
minimum.
16
Attachment B Page 17of67
Performance Contributing to an Incident (192 .805 (d))
If there is reason to believe that an Individual's performance of a Covered Task contributed to an incident, as defined under 49 CFR Part 191, as amended, Columbia Gas will initiate an evaluation of that Individual's qualification to perform that Covered Task.
Process to determine whether an Individual needs to be evaluated
In the event of an incident that occurred as a result of, or possibly due in part to, the performance of a
Covered Task(s), an investigation performed by the appropriate departments (Field Operations
Management, Senior Management, Legal, C&T, and Technical Training, Commercial Operations) will be completed to determine cause and effect. Subject matter experts may be called upon to assist with the
Investigation, as appropriate.
• During the investigation the individual(s) shall not further perform the Identified Covered
Task(s) that may have contributed to the incident. If, in the course of that investigation,
Columbia Gas concludes that there is reason to believe that the Individual's performance of the
Covered Task(s) contributed to the incident, that Individual's qualification to perform that
Covered Task(s) shall be evaluated.
• The individual shall not perform the Covered Task(s) unsupervised until the evaluation is
completed and any necessary re-qualification(s) steps have been completed.
• The evaluator(s) will evaluate the Individual in accordance with this Plan.
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Attachment B Page 180167
Reasonable Cause to Verify Qualification (192.805 (e))
Columbia Gas will evaluate an Individual if there is reason to believe that the Individual is no longer qualified to perform a Covered Task. Concerns regarding an Individual's ability to perform a Covered Task may be prompted by a number of circumstances and reported
to Columbia Gas by any person.
Possible reasons to verify an Individual's qualification(s) include, but are not limited
to:
• Absenteeism.
• Obvious loss of motor skills, vision impairment, etc.
• Statements made by the individual as to the Covered Task(s) or the individual's own
qualification to perform the Covered Task(s).
• Prolonged period of non-performance of Covered Task(s).
• Unsatisfactory performance.
• Columbia Gas has received concerns, negative comments or complaints regarding the
individual's performance of a covered task(s).
If reasonable cause is determined to exist, the following process to determine
whether an Individual needs to be evaluated will be followed.
1. C&T and Technical Training, working with Field Operations Management and/or Commercial
Operations, will initiate an investigation to determine if reasonable cause exists to evaluate an
Individual's qualification to perform the Covered Task(s) in question.
If there is reason to believe that the Individual is no longer qualified to perform a Covered
Task(s), that Individual's qualification to perform that task(s) shall be revoked. The individual's
performance of that Covered Task(s) will be evaluated.
3. The evaluator(s) will evaluate the Individual in accordance with this Plan.
18
ALlachment B Page 19of67
Communicate Changes (192.805 (f))
Columbia Gas will communkatesignjficantthanges that affect a Co vered Task to the Individuals who pe,jbmi that Co vered Task A thange maybe signjficant enough to require changes to the qua! jIlcation
process or additional evaluc,tions.
These changes may include but are not limited to:
• Significant modifications to company policies or procedures.
• Significant changes in state or federal regulations.
• Use of new equipment and/or technology that significantly affects Covered Tasks.
• New information from equipment or product manufacturers that significantly affects Covered Tasks.
Responsibility for Communication of Changes affecting Covered Tasks
C&T, Commercial Operations and Technical Training is responsible for identifying substantive changes affecting an identified task(s).
Technical Training is responsible for revising the evaluation process to include the impact of such changes. C&T will make a determination as to the level of communication regarding the change that is required.
C&T will disseminate the information utilizing the Notification of Change Form (Exhibit F) to all appropriate Managers and Supervisors.
Managers and Supervisors will follow the directions identified on the Notification of Change Form. Depending on the level of change, when required, Managers and Supervisors shall conduct an informational meeting providing the information to all affected employees.
Contractors affected by the change shall be required to conduct employee meetings utilizing the Notification of Change Form. The contractor will be required to submit a copy of the Form back to Columbia Gas with employees' signatures.
19
Attachment B Page 20 of 67
Action for Communication of change
• C&T, Commercial Operations and Technical Training will evaluate information regarding changes
that may affect an identified covered task(s).
• When appropriate, C&T will establish a team of subject matter experts to evaluate if the
Covered Task(s) in question is significantly affected by internal or external changes.
Technical Training and/or Commercial Operations will assess the effect the changes will have on
the task(s) and make adjustments to the evaluation and qualification process as necessary.
These adjustments could involve anything from informing qualified individuals of the changes to
requiring complete re-evaluation.
Determining the need to communicate
The need to communicate will vary dependent upon the impact of the change on the Covered Task.
Columbia Gas has established a 3-tiered system for identifying and communicating change.
Level (1) - Limited to no impact on the Covered Task and requires no communication or further
action.
Level (2) - Moderate impact on the Covered Task and requires only communication of the change.
Level (3) - Significant impact on the Covered Task and requires communication and modification of
the qualification process. Requires training/qualification, as appropriate, for affected
Columbia Gas employees and contractor personnel.
Attached to this Plan, as Exhibit F, is the Notification of Change Form.
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Attachment B Page 21 0167
Subsequent Qualification Intervals (192.805 (g))
Information gathered from attending Federal and State regulatory Operator Qualification seminars, OQ presentations and OQ public meetings combined with participation in industry recognized gas associations is reviewed to identify Covered Task qualification intervals. Columbia Gas utilizes the information compiled from these sources and considers them while establishing covered task qualification intervals.
An individual's qualifications shall remain valid until the end of the calendaryear in which the subsequent
qualification is required. Statutory qualification requirements will take precedent and be adhered to by
Columbia Gas.
The following criteria will be applied to each Covered Task to determine the appropriate subsequent
qualification interval applied to that task:
1. Frequency of performance
2. Critical nature of the covered task with respectto operations
3. Complexity / Difficulty
4. Existence of checks and balances, such as: Reviews and/or audits
S. Statutory requirements
Attached to this plan, as Exhibit B, is a list of subsequent qualification intervals and the
Justification Matrix.
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Allacli merit B Page 22 of 67
Training: Knowledge, Skills and Abilities (192.805 (h))
Columbia Gas ensures that training is administered for each individual performing Covered Tasks. Appropriate training will be administered to ensure the safe operation of Columbia Gas pipeline facilities. Columbia Gas ensures training includes the knowledge, skills and abilities to safely perform the Covered Task(s).
Training for Operator Qualification requirements
Examples requiring training include but are not limited to:
1. New hires (OJT and classroom)
2. Individuals taking on new Covered Task(s) (New position or Expanded responsibilities)
3. Individuals who fail one or more qualification evaluations (Ref. Exhibit E)
4. Level (3) Change to a Covered Task(s) (Ref. Section F)
Process for administering training
Process for Newly hired individuals
Newly hired individuals will have a Core Developmental Covered Task List assigned to their Development
Plan (Dev Plan) based on the assignment profile for the position they are filling. New hires will
work/train within the requirements of Non-Qualified Individuals (Section C of this plan) while
completing their OJT.
New hires completing OJT will also receive classroom training developed specifically for each Covered
Task identified in the new hire's Core Developmental Covered Task List. New hire individuals will
attempt to successfully complete certification in OQ task(s) as administered by Technical Training. Technical Training will decide if individuals possess the knowledge, skills and abilities to safely perform
the identified Covered Task(s).
Process for individuals taking on new Covered Task(s)
Individuals taking on new Covered Task(s) will have their Dev Plan reviewed and updated by Technical
Training to reflect the addition of the new Covered Task(s). These Individuals will follow the process for
newly hired individuals for any new Covered Task(s).
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Attachment Page 23 0167
Process for Individuals who fail to qualify/re-qualify
A minimum score of 80% is considered a passing score for all covered task evaluations. Individuals who
fail one or more qualification evaluation will receive training as appropriate as outlined in Exhibit E of
this plan.
Process for Individuals affected by change
Level3 change(s) are when a significant change(s) has occurred affecting a Covered Task(s), which
requires communication, training and qualification as appropriate. The need for training will be
determined as outlined in Section F, Action for Communication of Change and Determining the Need
to Communicate. C&T and Technical Training will assess the effect the change(s) will have on the task(s)
and make adjustments to the evaluation and qualification process as necessary. Technical Training will
update the existing training program(s) affected to reflect the change(s). Individuals qualified in Covered
Task(s) affected by the change(s) will receive training as appropriate to ensure they possess the
knowledge, skills and abilities to perform the task(s) in a safe manner.
Records
Records are maintained in the NiSource Learning Management System (LMS).
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Attachment B Page 24 of 67
Modification to Operator Qualification Plan (192.805 (i))
Columbia Gas will notify the Administrator or State agencies of significant modification to Columbia Gas's Operator Qualification program.
Process for determining significant modifications
C&T will administrator the Columbia Gas Operator Qualification program. As modifications to the Columbia Gas program are required C&T will be responsible for assessing the significance of the
modification. C&T will assemble a team made up of individuals from each state in which Columbia Gas
has distribution facilities. The team will analyze the modification to the program and determine if it is
significant in nature warranting communication to State and/or Federal agencies that have audited the
program.
Process for communicating significant modifications
When a modification to the program is determined to be significant C&T will complete a Notification of
Change Form (Exhibit F) outlining the modification. Compliance Specialists from C&T will communicate
the modification to each state agency utilizing the Notification of Change process.
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Attachment B Page 25 of 67
Record Keeping Methods (192.807)
Columbia Gas will ensure that the record of an Individual's qualification to perform a Covered Task will be maintained at a central location, or at multiple locations, in one or more of the following formats:
• Electronically
• Paper copies
• Other formats as appropriate and available
Columbia.Gas and contractor qualification records will include the following information.
(1) Identification of the Covered Task(s).
(2) Identification of the evaluator.
(3) Evaluation method(s) used.
(4) Identification of the Individual being qualified.
(5) Date on which qualification was completed & date on which qualification will expire.
Qualification records will be maintained throughout the period of time that an Individual is qualified to
perform a Covered Task(s). Records of an Individual's prior Covered Task qualifications and the
qualification records of Individuals who are no longer performing specific Covered Task(s) will be
maintained for a period of at least five (5) years from the date a task was last performed. . Employee
records will be maintained in the NiSource LMS system. Contractors performing covered task(s) on
Columbia Gas facilities shall be required to comply with record keeping methods in a manner that
complies with 192.807 and in a manner acceptable to Columbia.
Individuals responsible for project oversight involving the performance of any covered task(s) by a
contractor shall assure contract em ployee OQ records are current for the task(s) to be performed.
Columbia Gas will keep copies of contractor records at designated state business units
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ABachment Page 26 0167
Contractors, Mutual Aid, Mergers and Acquisitions
Contractors
Verifying Qualification of Contractor Personnel
Prior to commencement of any work on a Columbia Gas pipeline facility, contractors whose
employees perform any identified covered task must initially submit their 00 plan to Columbia
Gas for review and approval and then continually update any changes in their 00 program or
qualification status of their employees to Columbia Gas.
Exhibit C explains the requirements that contractors are required to meet. Exhibit D can be used
to assist in conducting the analysis to verify qualifications for contractor personnel.
Mutual Aid Agreements
Verifying Qualification of Other Operator Personnel
Prior to commencement of any work on a Columbia Gas pipeline facility, non-Columbia Gas
operators whose employees or subcontractors perform any identified covered task must initially
submit their 00 program to Columbia Gas for review and approval and then continually update
any changes in their 00 program or qualification status of their employees and subcontractors
to Columbia Gas. The operator's OQ Plan must meet or exceed the requirements of Columbia
Gas' 00 Plan for those covered tasks performed by the operator on Columbia Gas' facilities
Emergencies and/or Major Natural Disasters
The occurrence of major natural disasters or other emergencies may necessitate the mutual aid
assistance of individuals other than, or in addition to, Columbia Gas employees, contractors and
other operator personnel. Specifically, Columbia Gas may require emergency assistance in the
performance of covered tasks from employees or subcontractors of another operator or
contract company whose qualifications have not previously been reviewed, under circumstances
that do not permit a thorough review of the 00 program or qualification status of such operator
or contract company prior to the commencement of the emergency assistance.
In order to facilitate such mutual aid assistance in a timely manner without violating 49 CFR 192,
Subpart N, as well as applicable state regulations.
Columbia Gas shall verbally confirm that: (1) the operator or contract company has appropriate
OQ certifications for the scope of work to be performed; and (2) individuals to be assigned to
perform such work have appropriate 00 certifications for the scope of work to be performed.
26
AUachment B Page 27 of 67
Such verbal confirmation shall be obtained at the time that the emergency mutual aid assistance
i5 requested when mutual aid agreements have not previously been established. Columbia Gas
will perform a thorough review and confirm the qualifications of such operator or contract
company as well as associated individuals assigned to perform such work as soon as practical
following the commencement of such emergency mutual aid assistance.
Mergers and Acquisitions
In the event the Columbia Distribution Companies are involved in a merger or acquisition, C&T personnel, Technical Training, Engineering and Commercial Operations, working collaboratively, will conduct a review to ensure compliance of the rule as well as the specifications set forth in this plan.
Exhibit D can be used to assist in conducting the analysis of OQ tasks for mutual aid, mergers and
acquisitions.
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Attachment 8 Pane 28 of 67
Management of Change This plan undergoes an annual review. This section of the plan captures the changes, if any, that are made during that review or any time throughout the year. The MOC Proposed Change Form (Exhibit G) is to be used to submit suggested
changes/revisions.
Summary of changes Date of
Reason Location Description change
2007 Annual review Entire
document December Annual review
Entire Changed font and cleaned up formatting 2008 document throughout document
Entire Minor editorial changes - Updated RCT
document references to the department(s) responsible for those roles today. Added provisions for non-qualified
Section C individual(s) who speak and comprehend languages other than English.
Section K & New addition the CDC Plan July 2009 Annual review Exhibit G
Expounded on the description of some of Exhibit A the tasks so a broader audience would
understand what the task contains.
Exhibit C Streamlines the table on page 43 and flowchart on page 44.
June 2010 Update Exhibit A, B & C Updated to include the new G2 & G3 covered tasks
Entire Incorporated Energy Supply Services were document applicable
Moved management of change from
Section K Section K to L and made Section K
2010 Annual Contractors, Mutual Aid, Mergers & review and ______________ Acquisitions (previously Exhibit D)
March 2011 Legacy P/P
Section L conversion to Management of change section
Exhibit A Updated to include new Gas Standards new gas standards
Exhibit C Updated to reflect new CGV contractor requirements.
Exhibit 0 Updated the gap analysis form and moved it from Exhibit C to Exhibit D. Updated ESS to Commercial Operations
June 2011 Update Entire and Columbia Energy Distribution Group to Document Columbia Gas.
28
Attachment B Page 29 of 67
ee en.
Update Exhibit C Reinstated the exemption in Exhibit C that was removed on the 4-1-11 update.
June 2011 ____________ Update Section K
Additional explanation to better facilitate the use of mutual aid.
Section C Updated tasks and descriptions not
August 2011 Update permitted under direct observation
Exhibit A, B, D Updated covered task list and descriptions including new tasks.
Sections H & J Updated to include references around record keeping.
Exhibit A, B, 0 Added new tasks Dl and E3 November Annual
Exhibit C Updated 31d party provider listing. 2011 Review
Exhibit F Updated Form to reflect current practice.
Update Scope Inserted Ohio plan date footnote.
January 2012 Update Section H Added language around passing score for 00 evaluations.
Update Exhibit A & B Updated interval language.
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Attachment B Page 30 of 67
Exhibit A Columbia Gas Covered Task List Qualification methods:K=Knowdge only
K/S = Knowledge & Skill Qualification
Method DOT Legacy PIP Sub-
Task Description References Interval Gas Standard (GS) references Initial sequent
Al Operating/Maintaining Propane Air Facilities NFPA58& 59 Statut:ry
GS 1708.050, GS 2950.900, 651-12, 680-1, K/s K/S
Ala Operating Propane Air Facilities NFPA5B& 59 Statut:ry
GS 1708.050, GS 2950.900, 651-12, 680-1, K/S K/s
Compressor Stations Dl This isa piace holder only; Columbia 5as of Pennsylvania owns the
BLackhawk Compressor Station whith is operated end maintained by NiSource GasTrausmiasion & Storage (NGT&S)
Welding Pipelines API-1104
Statutory Welding Manual 535-4, 641-2,
El —~ TO BE PERFORMED BY QUALIFIED INDIVIDUAL
192.225 6 mo arc Welding Manual (VA)
641-3 641-4
ONLY — DIRECT OBSERVATION NOT 192235
1 year GS 1430.320, 65 1730.010, 641 5 641 6
- ' -
K S K S
PERMITTED! 2 years GS 2420.010, 641-7
192:245
Ela Visual Inspection of Welds 192.241 3 years 641-6 K/S K/S Welding ual
Perform Nondestructive Tests on steel Pipelines E2 192.243 3 years 1210.010 641-6 K/S K/S
192.309 E3 Repair of Steel Pipelines by Grinding 192.713 1 year GS 1730.010, GS 3010.010 K K
192.715
640-3, 643-3, Joining Plastic Pipe - Manual & Hydraulic 192.273 JM 1301, JM 1302 6434, 643-5,
Fl —+ TO BE PERFORMED BY QUALIFIED INDIVIDUAL 192.281 1 year5
JM 1304, JM 1306 643-10, 643-12, K S K S
ONLY— DIRECT OBSERVATION NOT 192.285 JM 1308, JM 1310 644-2, 644-3, PERMITTED! 192.287 JM 1320 644-4, 644-9,
644-12,
Twelve (12) months date specific for Columbia Gas of Virginia, Columbia Gas of Kentucky, Columbia Gas of Maryland, and Columbia Gas ofPennsylvania. Twelve (12) months not to exceed fifleen (15) months for Columbia Gas of Ohio.
30
Attachment B Page 31 of 67
Exhibit A Columbia Gas Covered Task List Qualification methods: K=Knowdge only
K!S = Knowledge & Skill Qualification
Method DOT Legacy P/P Sub-
Task Description References Interval Gas Standard (GS) references Initial sequent 640-3, 643-3,
Joining Plastic Pipe - Manual Only 192.285 JM 1301, JM 1302 643-4, 643-5,
a —p TO BE PERFORMED BY QUALIFIED INDIVIDUAL 192.281 JM1304, JM 1306 643-10, 643-12, ONLY - DiRECT OBSERVATION NOT 192.287 1 year4 JM 1308, JM 1310 644-2, 644-3,
K S K S
PERMITTEDI 192.273 JM 1320 644-4, 644-9, 644-12,
192.273 192.281 640-3, 643-3,
F2 Joining Pipe with Mechanical Fittings 192.285
1 year5 .IM 1320, 643-4 643-5, K/S K/S
192.287 1
- ' - 192.273 640-3, 643-3,
F3 Joining and Repairing Polyvinyl Chloride Pipe 1 year6 JM 1320, GS 1714.020 K/S K/S 643-10,64342,
192.287 651-6, 192.614 GS 1100.010, GS 3010040, 192.317 GS 3010.050, GS 3010.080, 535-4, 640-1,
Gi Excavation and Backfilling 192.319 3 years GS 3010.090, GS 3010.100, .640-2, 659-2, K K 192.325 65 3010.102, 653010.104, 445-3, 192.327 65 3010.106, HSE 4100.040
4 Twelve (12) months date specific for Columbia Gas of Virginia, Columbia Gas of Kentucky, Columbia Gas of Maryland, and Columbia Gas of Pennsylvania. Twelve (12) months not to exceed fifteen (15) months for Columbia Gas of Ohio.
Twelve (12) months date specific for Columbia Gas of Virginia, Columbia Gas of Kentucky, Columbia Gas of Maiyland, and Columbia Gas of Pennsylvania. Twelve (12) months not to exceed fifteen (15) months for Columbia Gas of Ohio. 6 Twelve (12) months date specific for Columbia Gas of Virginia, Columbia Gas of Kentucky, Columbia Gas of Maryland, and Columbia Gas of Pennsylvania. Twelve (12) months not to exceed fifteen (15) months for Columbia Gas of Ohio.
31
Attachment B Page 32 of 67
Exhibit A Qualification methods: K = Knowledge only Columbia Gas Covered Task List = Skill only
KIS = Knowledge & Skill . . . . . . . Qualification.
Method DOT . Legacy P/P . Sub-
Task Description References Interval Gas Standard (GS) references Initial sequent 192.307 192.317 192321 GS 1100.050, GS 3010.080.
G2 Horizontal Directional Drilling 192.325 3 years CS 3010.090, GS 3010.100, 640-1, 640-2 K K 192.327 CS 3010.102, GS 3010.104, 192.361 192.614 192.307 192.317 192.321 192. 323
G5 1100050 GS 3010.080, G3 Other Boring Methods
192.325 3 years GS 3010.090, CS 3010.100, 640-1, 640-2 K K
192.327 GS 3010.104, CS 3010.106,
192.361 192.614 192.353 192.355
Installing / Replacing / Repairing Meter & 192.357 CS 1420.5 30, CS 3020.020, 640-2, 653-4, 700-3, 724-5, Hi
Regulator Sets 192.359 3 years CS 3020.090, GS 6400.420,
724-42, 724-44, K/S K/S
192.363 GS 6400.440 192.365 192.467
32
Attachment B Page 33 of 67
Exhibit A Qualification methods: K = Knowledge only Columbia Gas Covered Task List = Skill only
K/S= Knowledge & Skill Qualification
Method DOT Legacy P/P Sub-
Task Description References Intervat Gas Standard (GS) references Initial sequent
GS 1100.050, GS 1420.4 10, 192.287 GS 1680.020, GS 1680.040, 192.307 GS 1680.050, GS 1714.020, 192.321 GS 1730.010, GS 3000.020, 192.361 GS 3010.010, GS 3010.020,
Installing / Replacing / Repairing Gas Service 192. 365
3 years GS 3010.040, GS 3010.050,
535-4, 640-1, 640-2, 640-3, HZ
lines 192.367 GS 301.0.060, GS 3010.070, K/s K/S 192.369 GS 3010.080, GS 3010.090,
640-10, 651-6,
192.375 GS 3010.100, GS 3010.102, 445-3
192.379 GS 3010.104, GS 3010.106, 192.381 GS 3020.0 10, GS 3020.020, 192.703 GS 3020.030, GS 3020.050,
GS 3020.090,
192.287 192.307 GS 1100.050, GS 1420.410, 192.317 GS 1680.020, GS 1680.050 192.319 GS 1714.020, GS 1720.010 192.325 GS 3000.020, GS 3010.010, 192.327 GS 3010.020, GS 3010.040,
H2a Visual Inspection of Gas Lines 192.353 3 years GS 3010.050, GS 3010.060, 535-5, 640-1, 640-2, 640-3, K/S K/S 192.355 GS 3010.070, GS 3010.080,
192.361 GS 3010.090, GS 3010.100, 651-6, 445-3
192.365 GS 3010.102, GS 3010.104, 192.367 GS 3010.106, GS 3020.010, 192.369 GS 3020.020, GS 3020.030, 192.461 GS 3020.050, GS 302 0.090, 192.611
33
Attachment B Page 34 of 67
Exhibit A Columbia Gas Covered Task List Qualification methods;K=Knowdge only
KIS = Knowledge & Skill Qualification
Method DOT Legacy P/P Sub-
Task Description References Interval Gas, Standard (GS) references Initial sequent 192.455 GS 1410.010, GS 1420.020, 192.457 GS 1420.030, GS 1420.035, 192.459 GS 1420.040, GS 1420.050, 192.461 GS 1420.070, GS 1420.080, 192.453 GS 1420.090, GS 1420.095, 192.465 GS 1420.100, G5 1420.105, 192.467 GS 1420.410, GS 1420.420, 535-4, 535-5, 192.469 G5 1420.430, GS 1420.440, 535-8, 640-1, 192.471 GS 1420.510, GS 1420.520, 640-2, 640-12 192.473 GS 1420.530, GS 1420.540, 643-4, 645-1
Application and Maintenance of Corrosion 192.475 G5 1420.550, GS 1420.580, 651-10, 653-2, Control Systems 192.477
3 years GS 1430.030, GS 1430.110, 653-3, 653-4,
K/s K/s Example: Corrosion Tech 192.479 GS 1430.120, GS 1430.130, 653-6, 653-7, 192.481 GS 1430.140, GS 1430.210, 653-8, 654-4, 192.483 GS 1430.220, GS 1430.230, 656-1, 563-1, 192.485 GS 1430.240, GS 1430.250, 721-2, 725-19 192.487 GS 1430.310, GS 1430.320,
192.489192.490 G5 1430.322, GS 1430.330, 192.609 GS 1430.410, GS 1440.010, 192.611 GS 1440.020, GS 1450.010, 192.613 GS 1460.010, GS 1450.020, 192.705 GS 1640.020, GS 1702.010, 192.706 G5 1704.010, GS 1708040,
1 192.721 1 GS 1730.010, GS 6500.190
34
Attachment B Page 35 of 67
Exhibit A Columbia Gas Covered Task List Qualification methods: K = Knowledge only
S = Skill only KIS= Knowledge & Skill
Qualification Method
DOT Legacy PIP Sub- Task Description References Interval Gas Standard (GS) references Initial sequent
192.455 192.457 192.459 192.461 192.463
GS 1410.010, GS 1420.035,
192.465 GS 1420.040, GS 1420.050,
192.467 GS 1420.410, GS 1420.510, 535-4, 535-5,
192.469 GS 1420.520, GS 1420.530, 535-8, 640-1,
192.471 GS 1420.540, GS 1420.580, 640-2,, 640-12,
Evaluation and Application of Corrosion Control 192.473 G5 1430.030, GS 1430.110, 643-4, 651-10, ha
Examp'e: Field Tech (plant) 192.475 3 years GS 1430.250, GS 1440.010, 653-2, 653-4, K/S K/S
192.477 GS 1450.010, GS 1460.010, 653-6, 653-8,
192.479 GS 1460.020, GS 1702.010, 654-4, 656-1,
192.481 GS 1704.010, GS 1708.040, 663-1, 721-2,
192.483 GS 2200.020, 725-19, JM 1320
192.485 192.487 192.489 192.705 192.721
35
Attachment B Page 36 of 67
Exhibit A Qualification methods: K Knowledge only Columbia Gas Covered Task List = Skill only
KIS = Knowledge & Skill Qualification
Method DOT Legacy P/P Sub-
Task Description References Interval Gas Standard (GS) references Initial sequent 192,459 192.461 192.465 192.469
Reading Test Stations & Evaluation and 192.471 GS 1420.410, 535-8, 640-1,
lib Application of Above Ground Corrosion Control 192 473 GS 1430 030 GS 1430 110 645-1 653-2
K/s K/S ExampIe Test station reader
192:475 GS 1440.010, GS 1450.010, 653-4, 654-4 192.477 GS 1702.010, GS 1704.010 653-8, 656-1, 192.479 192.481 192.705 192.721
192.465 Evaluation and Application of Above Ground 192.479 535-8, 645-1,
lic Corrosion Control 192.481 3 years GS 1440 010 GS 1450 010
653-4, 653-6, K/S K/S Example: Service tech 192.705
GS 1702 010 GS 1704 010 654-4, 656-1,
192.721
Monitor Corrosion Control Methods / Patrolling 192.465
lid & Surveillance 192.481 3 years
GS 1450.010, GS 1702.010, N/A K/S L</S
Example: meter reader 192.705 GS 1704.010 192.721
Tapping & Stopping Pipelines - all Sizes & Pressures
GS 1680 010 GS 1680 040 640-1,640-2,
LI. - TO BE PERFORMED BY QUALIFIED INDIVIDUAL 192.627 3 years GS 1680.050,
' 640-7, 640-10 K/S K/s ONLY - DIRECT OBSERVATION NOT PERMITTED!
Tapping & Stopping Pipelines - 4" & smaller tap
hole size; 60 PSIG & less 640-1, 640-2, Lia - TO BE PERFORMED BY QUALIFIED INDIVIDUAL 192.627 3 years
GS 1680 010 GS 1680 040 640-7, 640-10 K/s K/S
ONLY - DIRECT OBSERVATION NOT Gs 1680.050,
PERMITTED!
36
Attachment B Page 37 of 67
Exhibit A Columbia Gas Covered Task List Qualification methods:KKnowdge only
K!S = Knowledge & Skill Qualification
- Method DOT Legacy PIP Sub-
Task Description References Interval Gas Standard (GS) references Initial sequent Tapping & Stopping Pipelines - Self Punch Tees
/ LP Tapping and Bagging L1.b - TO BE PERFORMED BY QUALIFiED iNDIVIDUAL 192.627 3 years
- GS 1680 010 GS 1680 040 640-1 640-2
' K/S K/S GS 1680.050 640-7
ONLY— DIRECT OBSERVATLON NOT PERMITTED!
Lic Tapping & Stopping Pipelines - Self Punch Tees 192.627 3 years GS 1680.010, GS 1680.040 640-1, 640-2,
K/S K/s 135 1680.050 640-7
12 Purging Pipelines (No Restrictions) 192.629 3 years 135 1690.010, GS 1690.020 640-8 K/S K/S
1.2a Purging Pipelines (Service Lines & Meter Sets) 192.629 3 years GS 1690.010 640-8 K/S K/S
L3 Operating! Maintaining Odorization Equipment 192.625 3 years 135 1670010, GS 1670.020, 65 1-5, 660-2
K/S K/S GS 1670.030 721-6, 721-8
L3a Operating / Maintaining! Monitoring Farm Tap
192.625 3 years GS 1670.010, GS 1670020, 651-5, 660-2,
K/S K/S Odorizers & Odorant Levels 135 1670.030 721-6, 721-8
1-3b Monitoring Odorant Levels 192625 3 years 135 1670.020, GS 1670.020 K/S K/S
192.603 192.605
Gas Control - Controlling and Monitoring Gas 192.615
L4 pressure and flows; Monitoring Odorization 1 year7 GS 1660.020, 135 1754.010, K K Levels; and AOC's
192.623 192.625 192.631
' One year not to exceed 15 months per 192.631
37
Attachment B Page 38 of 67
Exhibit A Qualification methods: K KnowLedge only = Columbia Gas Covered Task List = Skill only
KIS _Knowledge & Skill Qualification
Method DOT Legacy P/P Sub-
Task Description References Interval Gas Standard ()
references Initial sequent GS 1702.010, GS 1704.010
192.613 GS 1100.020, GS 1708.010, 640-11, 642-1
192.615 GS 1708.020, GS 1708.030, 645-1, 651-2,
Perform Leak Survey, Classification & Patrolling 192. 703 GS 1708. , . , 040 GS 1708 050
651-3, 651-4,
651-5, 651-6, Ml. Example: Leak inspector
192.705 3 years GS 1708.060, GS 1708.070, 651-8, 65 1-9,
K/s K/S 192.706 GS 1708.080, GS 1714.010, 192.721 GS 1714.030, GS 1714.040,
651-12, 663-1,
192.723 GS 1714.060, GS 1780.010 721-2, 721-4,
Damage Prevention Plan 721-5, 721-7,
192.613 192.615
GS 1702.010, GS 1704.010 645-1, 659-3
192. 703 GS 1708.010, GS 1708.020, 651-2, 651-3,
Mia Leak Classification & Patrolling
. 192705 3 years GS 1708.030, GS 1708.040, 651-4, 651-5,
K/S K/s Example Field (plant) and/or Service Tech. 192.706
GS 1708.060, GS 1708.070, 6-1, 651-8, 63
192.721 GS 1708.080, GS 1714.010, 721-2, 721-4,
192.723 G5 1714.030, GS 1714.060, 721-5, 721-7,
Damage Prevention Plan
192.614 Damage Prevention Plan, 640-11, 659-1,
M2 Locate and Mark Underground Facilities 192.707
3 years GS 1100.010, GS 1100.020, 659-2, 659-3 K/S K/S GS 1100.100, REF GS 1100.010, 659-5(34)
192.503 192.505 192.507
M3 Pressure Testing Pipelines 192 .509
3 years GS 1500.010, , GS 6500.030 ,
640-1, 640-2, 640-5, 725-3, K/S K/S 192.511 GS 6500.040, G5 6500.050
192.513 725-4, 725-5
192.719 192.725
*M4 is a progression task; the subparts of M-4 are stand-a-lone tasks. There is no collateral credit contained within the subparts of M-4
38
Attachment B Page 39 of 67
Exhibit A Qualification methods: K Knowledge only Columbia Gas Covered Task List = Skill only
KIS = Knowledge & Skill Qualification
Method DOT LegacyP!P Sub-
Task Description References Interval Gas Standard (GS) references Initial sequent Inspect & Test Pressure Limit Stations, Relief Devices & Pressure Regulating Stations 192.731
192.739 GS 1750.010, GS 1750.020,
After an employee has been OQ qualified and It is 192.741 GS 1750.040, GS 1750.050,
654.3, 654-4, 4-5, 654-6,
*M4 time for subsequent re-qualification, he/she is then 192.743
3 years GS 1750.210, GS 1750.810,
654-10, 654-8, K/S K/s re- qualfled on task M-4 which contains all of the
192.749 GS 1752.010, GS 1754.010, 654-10, 724-9,
sub parts using module, GDS 6.18 ldentif,'ing 192.619 GS 1756.010, GS 1762.010,
724-U. Equipment and Practice Basic to Gas Regulation
192.621
Systems 192.623
Adjusting Pressure at Regulator Stations & Operating a By-Pass
192.739 GS 1750.010, GS 1750.020,
*M4a Training and initial qualification utilizing module, 192.619
3 years GS 1750.040, GS 1750.050 , 654-3 1 6 54-4,
654-10, K/S K/S GDS 5.2 Adjusting Pressure at Regulator St ations &
192.62 1 GS 1752.0 10, GS 1754.010,
Operating a By-Pass. Or GDS 6.4 Performing Basic 192.623 GS 1756.010
Maintenance Operation on Self-Operated Regulator Installations
192.743 Reading and Changing Charts 192.619 GS 1750.010, GS 1750.020,
654-3, 654-4, *M4b 192.621. 3 year
GS 1750.040, GS 1750.050, 654-10, K/S K/s
Training and initial qualification utilizing module, 192.741 GS 1752.010, GS 1754.010,
GDS 6.7 Reading MuftiplyRange Recording Chart 192.739 GS 175 6.010
39
Attachment B Page 40 of 67
Exhibit A Qualification methods: K = Knowledge only Columbia Gas Covered Task List = Skill only
KIS= Knowledge & Skill Qualification
Method DOT Legacy PiP Sub-
Task Description References Interval Gas Standard (GS) references Initial sequent
Operating & Maintaining Self-Operated Pressure Regulators
Training and initial qualification utilizing module, 192.619
GOS 6.10 Operating & Maintaining Self-Operated 192.749 GS 1750.010, GS 1750.020, 654-3, 654-4,
Pressure Regulators 192.621
3 years GS 1750.040, GS 1750.050, 654-5, 654-6,
KfS K/S *M4c 192.739 GS 1754.010, GS 1754.810, 654-8, 654-10,
To work on Self-Operated regulators the employee 192.741 GS 1750.210, GS 6400.090, 724-9, 724-11 192.743 GS 6400.110
must first complete modules GDS6.7 (M-4b) & GDS6.4 Performing Basic Maintenance Operation On Self-Operated Regulator Installations.
Operating & Maintaining Pilot-Operated Pressure Regulators
Training and initial qualification utilizing module, 192.743 192.619 GS 1750.010, GS 1750.040, 654-3, 654-4,
*M4d GDS 6.11 Identifying Operating Characteristics of
192.749 GS 1750.050, GS 1754.010, 654-5, 654-6, Pilot-Operated Pressure Regulators 192.621
3 years GS 1754.810, G5 1750.210(XX) 654-8, 654-10
K/S K/S
To work on Pilot Operated regulators the employee 192.739 GS 6400.090, G5 6400.110 724-9, 724-11 192.741
must complete modules GDS6.4 Performing Basic Maintenance Operation On Self-Operated Regulator Installations, GD56.7 (M-4b), GDS6.10 (M-4c), and GDS6.11 (M-4d)
40
Attachment B Page 41 of 67
Exhthit A Columbia Gas Covered Task List Qualification methods: K = Knowledge only
S = Skill only K/S= Knowledge & Skill
Qualification Method
DOT Legacy PIP Sub- Task Description References Interval Gas Standard (GS) references Initial sequent
Operating & Maintaining Instrument Controllers
Training and initial qualification utilizing module. 192.743
GDS 6.26 Identifring Fundamental Principle5 and 192.619 GS 1750.010, GS 1754.010,
654-3,654-4,
*M4e Application of Instrument Controllers 192.749 3 years GS 1754.810, GS 1750.210(XX)
654-5, 654-6, K/s K/S 192.621
GS 6400.090, GS 6400.11.0 654-8, 554-10,
To work on Instrument Controllers the employee 192.739 724-9, 724-11 must complete modules GDS6.4 Performing Basic 192.741
Maintenance Operation On Self-Operated Regulator Installations, GDS6.7 (M-4b), GDS6.10 (M-4c), and GDS6.16 (M-4e)
Operating & Maintaining Transducers and Bristol Controllers
192.743 Training and initial quahfication utilizing moduie 192.619 654-3, 654-4, GDS 6.l7ldentifring Maintenance and Operation 192.749
GS 1750.010, GS 1754.010, 654-5, 654-6, *M4f Pro cedures for Transducers and Bristol Controllers 192.621
3 years GS 1754.810, GS 1750.210(XX) 654-8, 654-10, K/S K/S
192.739 GS 6400090, GS 6400.110 724-9, 724-11
To work on Transducers and Bristol Controllers the 192.741 employee must complete modules GDS6.4 Performing Basic Maintenance Operation On Self- Operated Regulator Installations, GDS6.7 (M-4b), GDS6.10 (M-4c), and GDS6.17 (M4f)
192.179
M5 Maintenance & Repair Line Valves and Critical 192.745 GS 1760.010, GS 2400.010, Valve Inspection 192.747
3 years GS 2400.020,
652-1, 652-2(32) K/S K/s
192.181 1
41
Attachment B Page 42 of 67
Exhibit A Qualification methods: K = Knowledge only Columbia Gas Covered Task List s = Skill only
KIS _KnowLedge & Skill Qualification
Method DOT Legacy PIP Sub-
Task Description References Interval Gas Standard (GS) references Initial sequent 192745
M5a Critical Valve Inspection 192.747
3 years GS 1760.010, GS 2400.010, 652-1, 640-2,
K/s K/s 192.325 GS 2400.020 652-2(32), 445-3 192.327
GS 1150.005, GS 1150.010,
192.615 GS 1150.020, GS 1150.030,
M7 Preventing & Responding to Potentially GS 1150.050, GS 1150.060, 511-2, 511-3, Hazardous Situations
192.751 3 years GS 1150.070, GS 1150.080, 640-11, 651-5
K K 192.614
GS 1150.090, GS 1150.100, GS_1150.200,_GS_1714.0 10,
192.614 M7a Preventing Accidental Ignition 192.615 3 years GS 1150.005, GS 1150.010, K K
192.751 192.307 192.309 192.311
GS 1100.050, GS 1420.410,
192.317 GS 1460.010, GS 1680.020,
192.319 GS 1680.040, GS 1680.050,
192.321 GS 1714.020, GS 1720.010, 535-4, 539-9,
Install I Replace! Repair Mains & Transmission 192.323 GS 1730.010, GS 3000.020, 614-4, 640-1,
M8 Lines 192.325 3 years
GS 3010.010, GS 3010.020, 640-2, 640-3, K/S K/S
192.327 GS 3010.030, GS 3010.040, 640-10, 651-6,
192.605 GS 3010.050, GS 3010.060, 65 1-10,
192.703 GS 30 10.070, GS 3010.080, 445-3
192.711 GS 30 10.090, GS 3010.100,
192.713 GS 3010.102, GS 3010. 104,
192.715 GS 3010.106,
192.717 192.275 GS 1460.010, GS 1714.020,
M9 Repair / Protect Cast Iron Pipe 192.753 3 years GS 1780.010, GS 1782.010, 642-1,, 651-5,
K/S K/s 192.755 G5 3020.030,
55110
42
Attachment B Page 43 of 67
Exhibit A Columbia Gas Covered Task List Qualification methods:K=Knowdge only
KJS = Knowledge & Skill Qualification
Method DOT LegacyP/P Sub-
Task Description References interval Gas Standard (GS) references Initial sequent
MiD Abandon Gas Piping I Discontinue Service GS 1740.010GS1742.010, GS
K/s K/s
MiOa Discontinue Gas Service 192.727
3 years GS 1740.010(xx)
725-8 K/S K/S 192379 GS 1742010, GS 3020.090,
43
Atlachrnent B Page 44 of 67
Exhibit B
Subsequent Qualification Intervals
Task Description Interval
Al Operating I Maintaining Propane Air Facilities Annual
Ala Operating Propane Air Facilities Annual
D18 Compressor Stations 6 month test (arc weld)
El Welding Pipelines 1. year test (all processes)
2 year test (all processes)
Ela Visualinspection of Welds 3rd calendar year
[2 Perform Nondestructive Testing on Steel Pipelines & Welds 3 calendar year
E3 Repair of Steel Pipelines by Grinding Annual
Fl Joining Plastic Pipe Manual & Hydraulic Annual
Fla Joining Plastic Pipe - Manual Only Annual
F2 Join Pipe with Mechanical Fittings Annual
F3 Joining and Repairing Polyvinyl Chloride (PVC) Pipe Annual
Gl Excavating and Backfilling 3rd calendar year
G2 Horizontal Directional Drilling 3rd calendar year
G3 Other Boring Methods 3rd calendar year
Hi Installing / Replacing! Repairing Meter and Regulator Sets 3rd calendar year
H2 Installing / Replacing / Repairing Gas Service Lines 3Id calendar year
1-12a Visual Inspection of Gas Lines 3rd calendar year
Ii Application and Maintenance of Corrosion Control Systems 3rd calendar year
ha Evaluation and Application of Corrosion Control 3id calendar year
lib Reading Test Stations & Evaluation and Application of Above
Ground Corrosion Control
rd 3 calendar year
lic Evaluation and Application of Above Ground Corrosion Control 3(d calendar year
Ild Monitor Corrosion Control Methods / Patrolling & Surveillance 3d calendar year
Li Tapping & Stopping Pipelines - all Sizes & Pressures 3rd calendar year
Lla Tapping & Stopping Pipelines —4" and smaller tap hole / 60 PSIG
and less 3rd calendar year
Llb Tapping & Stopping Pipelines - Self Punch Tees & Low Pressure 3rd calendar year
Lic Tapping & Stopping Pipelines - Self Punch Tees 3 calendar year
L2 Purging Pipelines — No Restrictions 3rdcalendaryear
L2a Purging Pipelines - Service Lines & Meter Sets 3' calendar year
L3 Operating / Maintaining Odorization Equipment 3rd calendar year
Operating / Maintaining! Monitoring Farm Tap Odorizers & L3a 3 calendar year
Odorant Levels
L3b Monitoring Odorant Levels 3 r, calendar year
Gas Control - Controlling and Monitoring Gas pressure and flows; 14
Annual Monitoring Odorization Levels; and AOC's
Ml Perform Leak Survey, Classification & Patrolling 3 calendar year
Mia Leak Classification & Patrolling 3rd calendar year
M2 Locate and Mark Underground Facilities 3id calendar year
M3 Pressure Testing Pipelines 3" calendar year
This Is a place holder only; at this time Columbia does not operate or maintain any compressor stations.
44
Attachment B Page 45 of 67
Exhibit B
M4 Inspect and Test Pressure Limit Stations, Relief Devices and Pressure
Regulating Stations rd 3 calendaryear
M4a Adjusting Pressure at Regulating Stations and Operating a By-Pass 31C calendar year
M4b Reading and Changing Charts 3rd calendar year
M4c Operating and Maintaining Self-Operated Pressure Regulators 3d calendar year
M4d Operating and Maintaining Pilot-Operated Pressure Regulators 3rd calendar year
M4e Operating and Maintaining Instrument Controllers 3Id calendar year
M4f Operating and Maintaining Transducers and Bristol Controllers 3Id calendar year
M5 Maintenance & Repair Line Valves and Critical Valve Inspection 3Idcalendaryear
MSa Critical Valve Inspection 3rd calendar year
M7 Prevention & Responding to Potentially Hazardous Situations 3i calendar year
M7a Preventing Accidental Ignition 3rd calendar year
M8 Install / Replace / Repair Mains & Transmission Lines 3rd calendar year
M9 Repair/ Protect Cast Iron Pipe 3rd calendar year
M1O Abandon Gas Piping / Discontinue Services 3" calendar year
MlOa Discontinue Gas Service 3' calendar year
45
Attachment B Page 46 of 87
ExhibftB Subsequent Qualification Interval Matrix
Assign a value (ranging from 1 to 5) to each of the three qualifying categories. Critical nature refers to
how serious the consequences would be if the task was done improperly (1 = minor, 5 = catastrophic).
Complexity refers to how complex a task is to perform. Complex tasks have a score of 5 and simple
tasks have a score of 1. Frequency refers to how often the task is performed. Frequently performed
tasks have a score of 1, while infrequently performed have a score of 5. The total of the three columns
will identify the requalification interval.
If the total Score (X) is <6=60 Fifth calendar year
2~ 6 but <10 = Third calendar year ,?10 but<16 =12 months
Re- Columbia Covered. CRITICAL
COMPLEXITY FREQUENCY TOTAL evaluation Task and Description NATURE Interval
Al Operating / Maintaining Statutory 192.11 NFPA 58 & 59 NA Annual
Propane Air Facilities
Ala Operating Propane Air Statutory 192.11 NFPA 58 & 59 NA Annual
Facilities 9
Dl Compressor Stations 6-month arc
test
lyear all El Welding Pipelines Statutory 192.227 API 1104 NA
processes
2 year all
processes
ElaVisuallnspectionof 1 1 3 5 5years
Welds
E2 Perform Nondestructive
Testing on Steel Pipelines & 1 5 1 7 3 years
Welds E3 Repair of Steel Pipelines
4 2 5 11 Annual by Grinding
Fl Joining Plastic Pipe— Statutory 192.285 NA NA Annual
Manual &Hydraulic
Fla Joining Plastic Pipe - Statutory 192.285 NA NA Annual
Manual Only
F2 Joining Pipe with Statutory 192.285 NA NA Annual
Mechanical Fittings
F3 Joining and Repairing Statutory 192.285 NA NA Annual
Polyvinyl Chloride (PVC) Pipe
Gi Excavating and Backfilling 3 3 1 7 3 years
G2 Horizontal Directional 3 2 8 3years
Drilling
G3 Other Boring Methods 3 2 3 8 3 years
Hi Installing I Replacing / RepaIring Meter and 3 3 1 7 3 years
Regulator Sets
This is a place holder only; at this lime Columbia does not operate or maintain any compressor stations.
46
Attachment B Page 47 of 67
Exhibit B Re-
Columbia Covered CRITICAL COMPLEXITY FREQUENCY TOTAL evaluaflon
Task and Description NATURE Interval H2 Installing / Replacing / 3 3 1 7 3years Repairing Gas Service lJnes
H2a Visual Inspection of Gas 1 1 1 3 Syears
Lines
Ii Application and
Maintenance of Corrosion 3 4 1 8 3 years
Control Systems
ha Evaluation and
Application of Corrosion 3 4 1 8 3years
Control
lib Road ing Test Stations & Evaluation and Application of
3 2 2 7 3years Above Ground Corrosion
Control
lic Evaluation and
Application of Above Ground 3 2 2 7 3years
Corrosion Control
lid Monitor Corrosion
Control Methods / Patrolling 2 2 2 6 3 years
& Surveillance
Lllapping& Stopping
Pipelines—Al] Sizes & 3 3 3 9 3 years
Pressure
ha Tapping & Stopping
Pipelines —4" and smaller tap 3 3 3 9 3 years
holes! 60 PSIG & less
Lib Tapping & Stopping
Pipelines - Self Punch Tees / 3 3 2 8 3 years
Low Pressure Bagging
Lic Tapping & Stopping 3 1 1 5 Syears
Pipelines - Self Punch Tees
12 Purging Pipelines - No 5 3 1 9 3years
Restrictions
L2a Purging Pipelines - Service Lines and& Meter 3 1 - 1 5 5 years
Sets
L3 Operating / Maintaining 3 3 1 7 3years
Odorization Equipment
Ba Operating! Maintaining
/ Monitoring Farm Tap 3 2 3 8 3 years
Odorizers & Odorant Levels
L3b Monitoring Odorant 1 1 1 3 5years
Levels
14 Gas Control - Controlling
and Monitoring Gas pressure
and flows; MoLlitoring Statutory 192631 N/A N/A Annual
Odorization Levels; and
AOC's
Ml Perform Leak Survey, 3 3 1 7 3years
Classification & Patrolling _________________
47
AttachmenL B Page 48 0167
Exhibit B
Columbia Covered CRITICAL COMPLEXITY FREQUENCY TOTAL
Re- evalUation
Task and Description NATURE Interval Mia Leak Classification &
5 3 1 9 3years Patrolling
M2 Locate and Mark 3 3 1 7 3years
Underground Facilities
M3 Pressure Testing 3 3 3 9 3 years
Pipelines
M4 Inspect and Test Pressure
Limit Stations, Relief Devices 3 5 1 9 3years
and Pressure Regulating
Stations
M4a Adjusting Pressure at
Regulating Stations and 3 3 3 9 3 years
Operating a By -Pass
M4bReadingandChariging 3 3 3 9 3years
Charts
M4c Operating and
MaintainingSelf-Operated 3 3 1 7 3years
Pressure Regulators
M4d Operating and
Maintaining Pilot-Operated 3 3 3 9 3 years
Pressure Regulators
M4e Operating and
Maintaining Instrunient 3 3 3 9 3 years
Controllers
M4f Operating and
Maintaining Transducers and 3 3 3 9 3 years
Bristol Controllers
M5 Maintenance & Repair
Line Valves & Critical Valve 3 3 3 9 3 years
inspection
MSa Critical Valve Inspection 3 2 3 8 3 years
M7 Preventing & Responding
to Potentially Hazardous 5 3 1 9 3 years
Situations
M7a PreventingAccidental 3 1 9 3 years
Ignition
M8 Install! Replace / Repair 3 1 7 3 years
Mains & Transmission Lines
M9 Repair / Protect Cast Iron 3 3 9 3 years
Pipe
M10 Abandon Gas Piping! 3 3 1 7 3 years
Discontinue Service
MlOa Discontinue Gas 1 1 1 3 5years
Service _________
48
Attachment B Page 49 of 67
Exhibit C
CONTRACTOR OPERATOR QUALIFICATION REQUIREMENTS
1. Contractor shall provide and maintain, as required by Columbia Gas, a written plan identifying
Contractor's DOT Operator Qualification program. This program must meet or exceed all
requirements as outlined in 49 CFR PART 192 SUBPART N and receive Columbia Gas approval for the
written plan and any subsequent modifications to the plan.
2. Contractor shall supply to Columbia Gas an electronic copy of its written Operator Qualification plan
and any modifications or changes thereto, as well as any required employee qualification records.
This information shall be used by Columbia Gas to verify Contractor compliance with 49 CFR 192
SUBPART N as may be required by federal and state audits, or other governmental authority
requests. If the Contractor's failure to comply results in a fine and or penalty, the Contractor will be
responsible for all associated monetary cost, including reimbursement to Columbia Gas of any fines
or penalties incurred by Columbia Gas as a result of or arising out of the Contractor's Operator
Qualification plan.
3. Contractor shall be allowed to utilize Individuals who are not qualified to perform a covered task as
long as a qualified individual directly observes the performance and is able to take immediate
corrective action when necessary as outlined in Section C of this plan. Columbia reserves the right to
limit the time a person can perform a covered task before receiving the necessary qualifications.
Columbia reserves the right to limit the ratio of nonqualified to qualified employees performing
covered task(s) on Columbia Gas facilities.
4. Contractor's employees shall have with them at all times wallet cards or other acceptable means of
providing a list of their personal qualifications while performing covered task(s) on Columbia Gas
facilities.
5. Contractor shall provide Columbia, immediately, any changes that are made regarding Contractor's
written plan, or changes in an employee's qualification status to perform covered task(s) on
Columbia Gas facUlties.
6. Contractor, upon request, shall provide any information requested by Columbia Gas regarding
Contractor's compliance with Operator Qualification requirements.
7. Contractor's method used to evaluate an employee's ability to perform a covered task(s) on
Columbia Gas facilities must receive Columbia Gas approval prior to Contractor performing any
services under any agreement (3rd party qualifying, Contractor evaluation program, or other).
Columbia Gas does not accept work performance history as an acceptable evaluation method by the
Contractor. Columbia Gas does not accept computer-based/video qualification testing as the sole
method of qualification. Columbia Gas will only accept qualification methods utilizing an Operator
approved validated curriculum, administered by individuals that have successfully completed an
Operator approved qualifier program. Contractor's employees must achieve a minimum score of
80% to be qualified for each Covered Task.
8. Contractor shall maintain adequate records, including an employee's qualification records, as
prescribed in 49 CFR 192.807 and Sec. J of this plan. Columbia Gas shall be granted access to
Contractor's records, including the written plan and employee records. This access shall be for as
long as Contractor's employee continues to perform covered tasks on Columbia Gas facilities, and
for a period of at least five (5) years after an employee no longer performs covered task(s) on
Columbia Gas facilities. Monthly submission of contractor employees OQ records is required.
9. Contractor's employee's qualification records shall include: Identification of the qualified individual;
Identification of the covered task(s) the individual is qualified to perform; Date(s) of current
49
Allachment B Page 50 of 67
Exhibit C qualification; Qualification method(s); and must identify to company, individual or
31(1 party that
performed the evaluation.
10. Qualification records supporting an individual's current qualification shall be maintained as
prescribed in section 192.807 - Record keeping (five years from the date an individual last
performed any identified covered task). Contractors will make monthly submission of qualification
records to Compliance Specialists specific to the state in which work is being performed.
11. Sub-Contractors - If a contractor requires the services of a sub-contractor to perform an identified
covered task(s) the contractor must first obtain approval from Columbia Gas's OQ Administrator, through communication with the state specific Compliance Specialist. The sub-contractor will be
required to meet or exceed all Federal, State and Columbia Gas OQ requirements prior to the
performance of any identified covered task(s) on Columbia's facilities. Non-qualified individuals
working for a sub-contractor will be allowed to perform identified covered task(s) under the direct
observation and responsibility of a qualified individual in accordance with Section C of this plan.
CONTRA CTOR EVALUATION REQUIREMENTS
> Contractors (including sub-contractors) performing work on Columbia Gas of Virginia, Inc. (CGV) facilities are required to have all OQ evaluations performed and/or proctored by an approved third
party OQ provider using only NiSource Gas Distribution materials. 10
> For Columbia Gas work outside of Virginia; qualifications can be administered by an approved third
party provider or the Contractor may administer qualifications. Self-administered qualifications are
valid only with prior approval from Columbia and only when using a NiSource approved
proctor/evaluator and OQ program. Self-administered qualification will not be valid for work on
CGV facilities.
Approved Third Party OQ Evaluation Providers
CDC has established the following companies as current approved OQ Providers for DOT 192 subpart N,
evaluations:
Avalanche and T, Inc. ARC Randolph Associates
Al Welker Donna Nedelk
276 Berry Hill Rd, 4017 Washington Road, Suite 175
Orange, VA 2216OPhone (540) 661-7308/ Fax McMurray, PA 15317 (540) 832-0077 Phone (412) 580-8668
Bluegrass Instructional Services Bowman Consulting (formerly CTS1)
Chris Sligh 9813 c5odwin Drive
3438 McClure Road Manassas, VA 20110
Winchester, KY 40391 Phone (703) 530-8093 ext. 3029 / Cell (703) 400-1360
Phone (859) 494-3173 / Fax (859) 744-9974 Professional Utility Resources (PUR) R. L. Wingate & Associates, Inc.
P.O. Box 31794 1112 North Cleveland RD.
independence) Ohio 44131 Lexington, Kentucky 40509
Phone (216) 870-2707 Phone (859) 543-0224
Utility Technologies International Corporation (UTI)
4700 Homer Ohio Lane. Groveport, Ohio 43125 Phone (614) 482-8080/ Fax (614) 482-8070
10 Exceptions to this option can be made in accordance to 'Approved Oct Programs and Material' section located below.
50
Attachment B Page 51 of 67
Exhibit C
Approved OQ Programs and Material
CDC has established the following Programs as current approved for DOT 192 subpart N, evaluations:
NiSource Gas Distribution, Midwest Energy Association (MEA), Industrial Training Services (ITS) and Northeast Gas Association (NGA). CGV will only accept qualifications performed and certified by
approved third party 00 providers utilizing NiSource Gas Distribution modules.
Exceptions to these options may be approved on a case-by-case basis and will require written
authorization by the NiSource OQAdministrator prior to any identified covered task(s) being performed
on Columbia Gas facilities including facilities in CGV. Examples under consideration for exception are,
but not limited to, underwater pipeline operations, specialized pipe lining operations, nondestructive
testing of steel welds and manufacturer training and evaluation.
51
Attachment B Page 52 0167
ExhibIt C
Contractor OQ Review/Approval Process Prior to Contract Bid
1 Group letting contract determines the covered tasks that will be performed by
the contractor (rely on input from the 00 Administrator for input on covered
task(s) based on scope of work for the contract being bid.)
2 Exhibit C and additional 00 guidance material are packaged for distribution to
contractors for the pre-bid meeting
Prior to Contract Award
Contractor submits 00 plan for Company review and approval
u 00 Administrator reviews contractor's written 00 Plan language as
submitted
ci Columbia 00 Plan language applied to contractor's plan
ci Deficiencies identified and addressed
ci Contractor's Plan reviewed for potential restrictions placed on
Colu mbia.
ci Ensure contractor's plan addresses validation methods for Evaluators
and Evaluations
• Columbia's task list is identified within contractor's plan
• Protocol applied to ensure plan meets Columbia Gas needs and
regulatory requirements
2 Plan returned to the contractor with changes (if any)
3 00 Administrator addresses any contractor questions/concerns pertaining to
00 plan approval
Notification of Affected Parties
1 00 Administrator receives revised contractor OQ plan for final review/approval
and notifies contractor of acceptance
2 Responsible Columbia Gas group notified of acceptance of the contractor 00
plan
3 Contractor and responsible Columbia Gas group advised that the contractor's
evaluation materials, record keeping and field operations, will be audited to
ensure compliance.
52
Attachment B Page 53 of 67
Exhibit C
Contractor OQ Review/Approval Process
Prior to Contract Bid
Group letting contract determines the covered tasks that will be performed by the contractor (rely on input from the 00 Administrator for input on covered task(s) based on scope of work for the contract beinci bid.)
Prior to Contractor Award Description
1. Contractor submits 00 plan for Columbia Gas review and approval
D 00 Administrator reviews Contractor's written 00 Plan language as submitted.
U Columbia Gas 00 Plan language applied to contractor's plan.
U Deficiencies identified and addressed. u Contractor's Plan reviewed for potential restrictions
placed on Columbia Gas. U Ensure contractors plan addresses validation
methods for Evaluators and Evaluations. U Columbia Gas specific task list is identified within
contractor's plan. u Protocol applied to ensure plan meets Columbia's
needs. 2. Plan returned to the contractor with changes (if any). 3. 00 Administrator addresses any contractor question/concerns pertaining to OQ plan approval.
he Contractor
I. The contractor makes necessary changes to its 00 plan as identified by 00 Administrator.
2. The contractor will resubmit their 00 plan as many times as
necessary to obtain approval.
Notification of Affected Parties
1. OQ Administrator receives revised contractor 00 plan for final review/approval and notifies contractor of acceptance.
2. Responsible Company group notified of acceptance of the contractor 00 plan.
3. Contractor and responsible Company group advised that the contractor's evaluation materials, record keeping and field operations will be audited to ensure compliance.
53
Attachment B Page 54 of 67
Exhibit D
Protocol for Evaluating Operator/Contractor OQ Plan Written Plan —49 CFR 192, Subpart N
Name of Operator/Contractor: Date Submitted:
Representative responsible for the plan: Plan reviewed and accepted by S&C:
Name: Date:
Havethe following categories been addressed YES NO COMMENTS
WRITTEN PLAN Is there a written plan in place?
COVERED TASKS
Have they identified covered tasks using the
following criteria?
• Performed on a pipeline
• Operation or maintenance task
• Affects operation/integrity of the
pipeline
• Required under 49 CFR 192
EVALUATION PROCESS
Have they ensured, through evaluations, that
individuals performing the covered tasks are
qualified.
• Written exam
• Oralexam
• Observation of performance on the job
• On the job training
• Simulations
• Otherformsofassessnient
EVALUATION PROCESS
Have they established criteria around:
• Transitional qualification —(1) who
performed covered tasks on regular
basis prior to August 27, 1999 and (2)
who is qualified to perform those same
covered tasks according to the criteria
above prior to October 28, 2002.
• Initial qualification - Did not perform
covered tasks prior to August 27. 1999.
• Subsequent qualification —after
transitional or initial qualification and
after October 28, 2002.
54
Attachment B Page 55 of 67
Exhibit D Name of Operator/Contractor: Date Submitted:
Representative responsible for the plan: Plan reviewed and accepted by S&C:
Name: Date:
Have the following categories been addressed YES NO COMMENTS
NONQUALIFIED INDIVIDUAL Have they established criteria for non-qualified
individuals to perform a covered task? Does it
meet the minimum criteria of;
• Qualified individual assigned to direct & observe during the task
• Qualified individual is able to take
immediate corrective actions
• Qualified individual is responsible for
the performance of the task
• Qualified individual can communicate
effectively with the non- qualified
individual
• Ratio of non- qualified individuals is
kept to a safe minimum
PERFORMANCE CONTRiBUTING TO AN
INCIDENT
Have they established criteria around
performance contributing to an incident,
including;
• Provision to evaluate an individual if
Columbia (the Operator) has reason to
believe the individual's performance of
a covered task contributed to an
incident.
• Process to determine whether an
individual needs to be reevaluated.
REASONABLE CAUSE TO VERIFY
QUALIE ICAT1ONS
Are there provisions to evaluate an individual if there is reason to believe he/she is no longer
qualified to perform the covered task? Reasons could include but are not limited to;
• Absenteeism
• Loss of motor skills, vision, impairment,
etc.
• Statements from the individual
• Prolonged period of non-performance
• Unsatisfactory performance
• Upon request
55
Attachment B Page 56 of 67
Exhibit D Name of Operator/Contractor: Date Submitted:
Representative responsible for the plan: Plan reviewed and accepted by S&C:
Name: Date:
Have the following categories been addressed YES NO COMMENTS
COMMUNICATE CHANGES
Are there provisions to communicate changes
that affect covered tasks to individual
performing the task? Changes could be but
are not limited to;
• Significant changes in policies or
procedures
• Changes in state or federal regulations
• Use of new equipment/technology that
affects the task.
• New information from equipment or
product manufacturers that significantly
affects the task.
The levels of communications should be based
on the severity of the changes, for instance;
• Limited impact - no communication
• Moderate impact—communication only
• Significant impact —communication & modification of the qualification process
SUBSEQUENT QUALIFICATION
INTERVALS
What method did they use to determine the
evaluation and qualification intervals for their
covered tasks?
RECORD KEEPING
Does the record system used maintain
information for the following data points and
retain that information for a minimum of five
(5) years?
• Identity of the covered tasks(s) and
related subsequent qualification
interval(s)
• Identification of the evaluator
• Evaluation method(s) used
• Identification of the individual being
qualified
• Date(s) on which the qualification was
completed
• Qualification method(s)
56
Attachment B Page 57 of 67
Exhibit D Name of Operator/Contractor: Date Submitted:
Representative responsible for the plan: Plan reviewed and accepted by S&C:
Name: Date:
Have the following categories been addressed YES NO COMMENTS
TRAINING
Does their plan have provide provision around;
• Training required for new employees
• Training for employees taking on a new
task(s)
• Training for employees who fail an
evaluation(s)
• Training as required for new
technology, equipment, materials,
statutory requirements, etc.
57
Attachment B Pa9e 58 of 67
Exhibit D
Gap Analysis for Evaluating Operator/Contractor OQ Covered Tasks
OPERATOR/CONTRACTOR INFORMATION
Name of Operator/Contractor:
Operator/Contractor Representative's Name:
Phone:
E-mail:
OQ Program used (i.e. MEA, ITS, etc)
I Evaluator(s) qualified by (i.e., SGA Evaluator training, MEA, ITS, etc.):
Materials Validated: Yes or No Year:
Validation company name:
EVALUATORS:
Name:
Task(s)
1. 1.
2. 2.
3. 3.
4. 4.
S. 5.
6. -... 6.
58
Attachment B Page 59 of 67
Exhibit D
Task Description. Operator I Contractor Equivalent Task(s)
WPHR used
Qualification Method used
V N InitIal •Re-qual
Al Operating! Maintaining Propane Air Facilities
Ala Operating Propane Air Facilities
Dl Compressor Stations
El Welding Pipelines
Ela Visual Inspection of Welds
E2 Perform Nondestructive Testing on Steel
Pipelines & Welds
E3 Repair of Steel Pipelines by Grinding
El Joining Plastic Pipe - Manual & Hydraulic
Fla Joining Plastic Pipe - Manual Only
F2 Joining Pipe with Mechanical Fittings
F3 Joining and Repairing Polyvinyl Chloride (PVC)
Pipe
Gi Excavating and Backfilling
GZ Horizontal Directional Drilling
G3 Other Boring Methods
Hi installing / Replacing! Repairing Meter and
Regulator Sets
H2 Installing / Replacing / Repairing Gas Service
Lines
H2a Visual Inspection of Gas Lines
Il Application and Maintenance of Corrosion
Control Systems
Exceptions to this option can be made in accordance to Approved OQ Programs and MateilaL" section located below.
59
Attachment B Page 60 of 67
Exhibit D WPHR Qualification Method used used
V N. Initial Re-qual Task Description Operator! Contractor Equivalent Task(s)
a Evaluation and Application of Corrosion Control
Reading Test Stations & Evaluation and lib Application of Above Ground Corrosion
Control
Evaluation and Application of Above Ground lic
Corrosion Control
Monitor Corrosion Control Methods / lid Patrolling & Surveillance
Tapping & Stopping Pipelines —All Sizes & Li
Pressures
Lia Tapping & Stopping Pipelines —4" and smaller
tap hole; 60 PSIG and less
Lib Tapping & Stopping Pipelines - Self Punch Tees
& Low Pressure Bagging
Lic Tapping & Stopping Pipelines - Self Punch Tees
L2 Purging Pipelines - No Restrictions
ila Purging Pipelines - Service Lines and Meter
Sets
Operating / Maintaining Odorization
Equipment
Operating / Maintaining! Monitoring Farm L3a
Tap Odorizers & Odorant Levels
L3b Monitoring Odorant Levels
Gas Control - Controlling and Monitoring Gas
L4 pressure and flows; Monitoring Odorization
Levels; and AOC's
Mi Leak Survey, Classification & Patrolling
Mia Leak Classification & Patrolling
Attachment B Page 61 of 67
Exhibit D • WPHR Qualification Method
used used
V N tnitial. Re -qual Task Description Operator! Contractor Equivalent Task(s)
M2 Locate and Mark Underground Facilities
M3 Pressure Testing Pipelines
Inspect and Test Pressure Limit Stations, Relief M4
Devices and Pressure Regulating Stations
Adjusting Pressure at Regulating Stations and M4a
Operating a By-Pass
M4b Reading and Changing Charts
Operating and Maintaining Self-Operated M4c
Pressure Regulators
M4d Operating and Maintaining Pilot-Operated
Pressure Regulators
Operating and Maintaining Instrument M4e
Controllers
M4f Operating and Maintaining Transducers and
Bristol Controllers
Maintenance & Repair Line Valves & Critical M5
Valve Inspection
M5a Critical Valve Inspection
Preventing & Responding to Potentially M7
Hazardous Situations
M7a I Preventing Accidental Ignition
Install I Replace / Repair Mains & Transmission MS Lines
M9 Repair/ProtectCastlron Pipe
M1O Abandon Gas Piping / Discontinue Service
MlOa Discontinue Gas Service
61
Attachment B Page 62 of 67
Exhibit D
FOR INTERNAL USE ONLY
Date received: Date completed:
Materials Validated: Yes or No When: By whom:
Comments:
Gap Analysis reviewed and completed by S&C staff member:
Name: Date:
62
Allachment B Page 63 of 67
Exhibit E
Failure to Qualify
Human Resource Guidelines on Qualification of Emp!oyees
Columbia Gas has designed a program to assist the employee in successfully completing
requirements of its DOT Operator Qualification Program. The program includes a customized training plan designed to 1) meet the needs of Columbia Gas in carrying out its legal and
regulatory obligations, and 2) assisting and supporting the individual employee in obtaining legally-required qualifications. However, Columbia Gas does not guarantee the employee will
receive qualification to perform any Covered Task and is not obligated to ensure employee
success.
The local leadership team, HR and C&Twill support and review the plan and the individual
qualification process as necessary.
If an employee fails to qualify to perform a covered task that is an essential job
function, the following action shall be taken:
1. The individual will immediately be deemed non-qualified to perform that particular task.
2. If possible, an evaluator will provide immediate feedback to the individual on his/her
performance of the covered task and noted deficiencies.
3. Where it is permissible for non-qualified employees to perform Covered Tasks, and in
accordance with the requirements of Columbia Gas's Operator Qualification plan
(Section C), the individual may, at the option of Columbia Gas, be asked to perform the task he/she did not qualify. Columbia Gas will make this determination in accordance
with its operational demands, the obligations and responsibilities of the job
classification, and pursuant to all applicable requirements of its DOT Operator
Qualification (00) plan.
4. In the immediately following *30.day period, an evaluator will evaluate the individual's
qualification to perform the covered task as required by Columbia 00 Plan. During this *30..day time period, at Columbia Gas's option, the individual may continue to work
under the direct supervision of a qualified individual and in accordance with the
requirements of the 00 Plan.
5. If an individual fails to qualify on the second attempt, he/she will go through re-training
within *30 days. During this *30day time period, the individual may continue to work
under the direct supervision of a qualified individual.
6. Within the following *30..day time period, the completion of the written training plan
and the third attempt to qualify the individual shall be conducted. If the individual fails to successfully qualify on the third attempt, Human Resource and Local Leadership will
decide upon the appropriate action taken.
*The 30-day time period may be waived at management's discretion*.
63
Attachment B Page 64 0167
Exhibit F CDOQNOC[GS standard]
[GS standard - title] Issued: [date]
NiSource Gas Distribution - Columbia Gas Companies Operator Qualification Plan
Notification of Change Form
The following Procedure(s) or Task(s) has been modified or changed
Procedures:
Tasks:
Indicate type of change: Modification to company policies or procedures Use of new equipment and/or technology Change in State or Federal regulations New information from equipment or product manufacturer Other, explain
WMS job number the meeting was charged to
The modification or change is described as follows.
This is a Level 2 Impact to the Company's OQ Cover Tasks. This Communication of Change is effective [date], with a target implementation date of [date]. This information is required to be communicated to all individuals (induding contractors) qualified for tasks [tasks]. The changes have a [impact] impact, and are [ex. for moderate: communication only and does not effect the skill and ability of performance].
The following document numbers or descriptions indicate revisions or modifications to written procedures. j
[standard no.], "[title]" [tasks affected] a. Narrative description of change.
64
Affachment B Page 65 of 67
Exhibit F
LMS Item: CDOIOCIGS standrdJ EGS standid- 111101
Is5ud: tda1
I hEmbyackrxWedgeMl TIaYe recekednoOkaDmorchange acwedbk pfredby4 CFR 192I05I) or n1Ucaftn tgWange ba oornpan titrdg. and1havereMweg Inechange aT knFatb U1lV(1L
I Linderibm that nnnaftaIlDmIalponclarrand pwceIIHenmabe reqit0d. asco0UhcnE waITarL id(ftaI undersLand CcereaTanthanQe anti agioa loal me iequlrnmenla cnolaeefleiali.
TWlUWMg rnodlnah flOf tharjga.
lkt1 -.riiI-
Nolirted by: Pane I of 2
65
Attachment B Page 66 o167
Exhibit F LMS Item: CDOQNQCLGS standardj
[G5 standard- IWeJ Issued: (date]
I e rsnoeiadgai1attase raceterI rocatIw oId1ana cia v xeed by4Y CrR 12tO5(I) a naWcatJan o(CIiin9e to company 9wandr, anrIsaVe meetoe dlange!or tiipt ionio& I undErdandlhtmoflcaflnna to palcies and pmooei1ire maybe rmd. ancoadillonawarrart alidirrati underelaliiltrie Ccierealaakcflangeaua agmen Ion! the mecpi1iemnena contained herein.
The ronamrg Ilean beEn riolillad ctthe abosrrrocrUcahon OF charge
— '
•f; i
Notified by: Page 1 of 2
66
Attachment B Page 67 0167
Exhibit G
I OQ Plan Proposed Change Form
Date: Reason for Proposed Change
D Annual Review U Change in code LI Other
Type of change: LI Editorial U Technical LI Other
Brief Description of Change:
Existing text:
Proposed text:
I. Name . of Individual ProposingChange
Printed Name:
Signature:
67
Exhibit NJDK-3
lxhibit NJKD-3
Certification Regarding Base Rate Proceeding
I, Nancy J. D. Krajovie, pursuant to 66 Pa. C.S. § 1353(b)(4), hereby certify that Columbia Gas of Pennsylvania, Inc has filed a base iate pioceeding within five years ptior to January 2, 2013, which is the date of its inthal petition to establish a Distribution System Impiovernent Charge authorized by 66 Pa C S §1353 Specifically, columbia Gas of Pennsylvania, Inc.'s current base rates were established in Docket No. R-2o10-2215623, which was a base rate case filed on January 14, 2011.
Dated: Janaiy 2, 2013 qO Nancy J. A Krajovic Director, Rates and Regulatory Affairs Columbia Gas of Pennsylvania, Inc.