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STATE OF NEW YORK DEPARTMENT OF PUBLIC SERVICE

THREE EMPIRE STATE PLAZA, ALBANY, NY 12223-1350


PUBLIC SERVICE COMMISSION
AUDREY ZIBELMAN
Chair
PATRICIA L. ACAMPORA
GARRY A. BROWN
GREGG C. SAYRE
DIANE X. BURMAN
Commissioners
Mr. Robert A. Demarinis
Vice President Operations, NY
National Grid
175 E. Old Country Road
Hicksville, NY 11801
www .dps.ny .gov
September 5, 20 14
Re: 2014 National Grid- Gas Operations and Maintenance Audit
Dear Mr. Demarinis,
KIMBERLY A. HARRIMAN
General Counsel
KATHLEEN H. BURGESS
Secretary
Enclosed for your review are the final2014 National Grid record audit reports prepared by Staff of the New
York State Department ofPublic Service, Office of Electric, Gas, and Water. The reports are specific in outlining
instances of non-compliance where National Grid failed to adhere to the requirements of 16 NYCRR 255-
Transmission and Distribution of Gas and 16 NYCRR 261- Piping Beyond the Meter.
Staffs Syracuse office conducted the audit ofNational Grid Central territories and Staff's Albany office
conducted the audit ofNational Grid Eastern service territories. Please note that Staffs audits were based on a
sample review of operation and maintenance activities, and findings were discussed in detail with National Grid
management during compliance meetings. National Grid was afforded five business days to provide
documentation to cure record deficiencies surrounding Staffs findings presented as the subject of the compliance
meetings.
The Violations Performance Measure in Case 12-G-0202 classifies violations as either High Risk or Other
Risk. The violations found by the Syracuse and the Albany offices have been combined into two documents.
Attachment 1 contains the details of the High Risk violations. Attachment 2 contains the details of the Other Risk
violations.
With respect to the Violations Performance Measure in Case 12-G-0202, violations pertaining to
documentation or actions performed, or required to be performed, on or after April1, 2013, will constitute an
occurrence under the metric. These are noted in the two attachments by (Post 4/1/13) following each post April 1,
2013 violation. Staff has identified 179 High Risk and 263 Other Risk violations after April 1, 2013.
Please respond within 30 days of this letter detailing what actions have and/or will be taken by National
Grid to remediate noted violations and concerns, and insure future compliance. If you have any questions
regarding these or any other gas safety concerns, please do not hesitate to call Chris Stolicky at (518) 473-9994 or
Bill Wade at (518) 486-2820.
cc: Secretary
Kevin Speicher
Robyn Adair
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Sincerely,
Christopher Stolicky
Utility Supervisor (Safety)
Office of Electric, Gas, and Water
William D. Wade
Utility Supervisor
Office ofElectric, Gas, & Water

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Attachment 1
High Risk Violations
Violation Specifics


Albany

Record Audits
Nineteen violations of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261
were noted.

16 NYCRR Part 255.603(d) - General Provisions - 1 Violation, 11 Occurrences


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

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

Retention Period of Forms

National Grid Albany failed to conform to National Grid GOPB 206,
dated 2/15/11, which was the procedure in place at the time of the
violation states, Retention period of both forms is 6 years. (Post 4/1/13)

The following is an example where National Grids procedure was not
followed:

Regulator Inspection Report #215963 - 12 Red-Lane Dr, Colonie -
The Curb Valve/OS Riser portion of the 2013 Regulator Inspection
Report states, Not Ok cannot locate curb valve GRO 187134.
Staff requested a copy of the GRO on 6/25/14, but the Company
could not produce one. The Company failed to retain the GRO.

CGI Calibration Check

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


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The following are examples where National Grids procedure was not
followed:

CGI #1243-303075 - Records show a gap in calibration from
12/28/12 to 4/9/13.

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

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

Leakage Surveys Intervals

National Grid Albany failed to conform to National Grid CNST02002,
Leakage Surveys, Rev 1, dated 05/15/13, states, A leakage survey of the
gas facility in Company defined business district shall be performed once
each calendar year and at intervals not to exceed fifteen (15) months.
(Post 4/1/13)

The following is an example where National Grids procedure was not
followed:

Map 189977, Zone 12-12 (Glenmont Plaza), Glenmont - Records
show that a section of business district pipe was surveyed on
5/5/09 and not again until 6/18/13. The Company failed to survey
this business district pipe at intervals not exceeding 15 months.

Service Regulator Inspection

National Grid Albany failed to conform to National Grid CMS06001,
Inspecting High Pressure Service Regulating Equipment, Rev 2, dated
02/01/13, states, Check for proper size and location of vent terminus.
(Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

Regulator Inspection Report #227901 - 11 Cary St, Ravena -
Records from 5/10/13 indicate No for Screening/Piping in the
Service Regulator and Vent inspection box. The Company
failed to conduct and/or document a vent inspection.

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

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

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

Type 1 Leak Classification

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

The following is an example where National Grids procedure was not
followed:

GRO #194954 - 89 Delaware Ave, Albany - This Type 2A leak,
classified on 1/30/13, was a result of contractor damage to a 1 inch
drip line off of a main. The Company failed to correctly classify
this leak as a Type 1.

Leak Surveillance

National Grid Albany failed to conform to National Grid CNST02009,
Classifying Gas Leaks, Rev 1, dated 06/01/13, the current procedure,
states, Surveillance: Surveillance of a Class 2A leak shall be at intervals
not to exceed 14 days until the source of the leak has been corrected, or
reclassified. (Post 4/1/13)

The following is an example where National Grids procedure was not
followed:

GRO #231764 - 34 Genesee Ave, East Greenbush - This leak
history card shows that a Type 2A leak was surveyed on 8/21/13. It
was siphoned on 8/22/13, and was not surveyed again until
9/17/13. The Company failed to survey this leak with a frequency
not to exceed two weeks.

Leak Classification Downgrade


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National Grid Albany failed to conform to National Grid GDx 050001-
PL, Rev 0, dated 12/15/10, which was the procedure in place at the time of
the violation, states, In situations in which no repair has been affected,
the classification of a leak migration pattern may be downgraded after two
consecutive decreased readings, in the level of natural gas, at its normal
surveillance cycle.

The following is an example where National Grids procedure was not
followed:

GRO #207771 - 119 Orchard St, Delmar - This leak history card
showed Type 2A readings on 2/28/13. It was reclassified to a Type
2 Leak on 3/11/13 with no surveillances in between. There were no
repairs made until after this reclassification. The Company failed
to perform at least one additional surveillance at the normal
interval before downgrading to a lower classification.

Type 2A Leak Classification

National Grid Albany failed to conform to National Grid GDx 050001-
PL, Rev 0, dated 12/15/10, which was the procedure in place at the time of
the violation, Attachment 2: Leak Classification Guide - Massachusetts,
New York State and Rhode Island, depicts that Type 2A leaks include gas
readings greater than 20% within 20 feet of a building, inside the curb, in
an unpaved area.

The following is an example where National Grids procedure was not
followed:

GRO #202934 - 143 Woodlawn Ave, Albany - This leak was
originally classified as a Type 2 leak on 2/23/13. The leak history
card shows readings of 25% gas at 20 feet from a building, inside
the curb, in an unpaved area. The Company failed to correctly
classify this leak as a Type 2A.

Type 2 Leak Classification

National Grid Albany failed to conform to National Grid GDx 050001-
PL, Rev 0, dated 12/15/10, which was the procedure in place at the time of
the violation, Attachment 2: Leak Classification Guide - Massachusetts,
New York State and Rhode Island, the current procedure, depicts that
Type 2 leaks include gas readings greater than 30% within 50 feet of a
building, inside the curb, in an unpaved area.

The following is an example where National Grids procedure was not
followed:

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GRO #208102 55 Nathaniel Blvd, Delmar - This leak was
originally classified as a Type 3 leak on 7/9/12. The leak history
card shows readings of 67% gas within 50 feet from a building,
inside the curb, in an unpaved area. The Company failed to
correctly classify this leak as a Type 2 leak.

Replacement of Exposed Cast Iron Pipe

National Grid Albany failed to conform to National Grid GOPB 417,
Protection and Replacement of Exposed Cast Iron Pipe, dated 2/1/03, and
DAM01007, Cast Iron Encroachment Policy for Long Island and Upstate
New York, Revision 0, dated 12/15/13, requires, Any cast iron pipe eight
(8) inches or less in diameter, exposed and undermined by an excavation
36 inches or greater in width, the purpose of which is for work other than
normal gas operation and maintenance work being performed on the
exposed cast iron main, shall be replaced by steel or plastic pipe. For
crossings, the pipe replaced shall be at least the length of exposed pipe
plus twice the product of the exposed pipe length and the distance from
the top of the main to the bottom of the trench divided by the trench width.
Replacements shall extend approximately equally on both sides of said
excavations. (Post 4/1/13).

The following is an example where National Grids procedure was not
followed:

DSNY Ticket #1204314800600 - 462 1
st
St, Albany - Records
from 12/4/13 indicate that 10 feet of the 6 inch cast iron main was
exposed. Records also indicate that only 10 feet of the main was
replaced. The Company did not replace the correct length of the
main.

Replacement of Exposed Cast Iron Pipe

National Grid Albany failed to conform to National Grid GOPB 417,
Protection and Replacement of Exposed Cast Iron Pipe, dated 2/1/03
states, Un-exposed Pipe Parallels Excavation (Angle of Repose): The
length of pipe replaced shall be at least the length of pipe in the angle of
repose plus twice the distance from the top of the main to the bottom of
the trench. (Post 4/1/13).

The following is an example where National Grids procedure was not
followed:

DSNY Ticket #1022315402100 - 765 Madison Ave - Premiers
Cast Iron Report from 10/30/13 states, it was determined that the

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

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

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

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

Map 189977, Zone 12-12 (Glenmont Plaza), Glenmont - Records show that a
section of business district pipe was surveyed on 5/5/09 and not again until
6/18/13. The Company failed to survey this business district pipe at intervals
not exceeding 15 months. (Post 4/1/13)

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

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

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

DSNY Ticket #1204314800600 - 462 1
st
St, Albany - Records from 12/4/13
indicate that 10 feet of the 6 inch cast iron main was exposed and undermined.
Records also indicate that only 10 feet of the main was replaced. The
Company did not replace the correct length of the main. (Post 4/1/13)

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

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

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

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DSNY Ticket #1022315402100 - 765 Madison Ave, Albany - Premiers Cast
Iron Report from 10/30/13 states, it was determined that the 6CI gas main
will be in the angle of repose for a total length of 26ft. Staff questioned the
Company about the main and the local supervisor provided documentation
showing that only 14 feet was replaced. The Company did not replace the
correct length of the main. (Post 4/1/13)

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

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

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

CGI #1243-303075 - Records show a gap in calibration from 12/28/12 to
4/9/13. (Post 4/1/13)

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

CGI #1243-303055 - Records show a gap in calibration from 11/15/12 to
4/9/13. (Post 4/1/13)


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

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

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

GRO #194954 - 89 Delaware Ave, Albany - This Type 2A leak, classified on
1/30/13, was a result of contractor damage to a 1 drip line off of a main. The
Company failed to correctly classify this leak as a Type 1.

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


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

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

GRO #231764 - 34 Genesee Ave, East Greenbush - This Type 2A leak was
surveyed on 8/21/13. It was siphoned on 8/22/13, and was not surveyed again
until 9/17/13. The Company failed to survey this leak with a frequency not to
exceed two weeks. (Post 4/1/13)

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

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

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

GRO #202934 - 143 Woodlawn Ave, Albany - This leak was originally
classified as a Type 2 leak on 2/23/13. The leak history card shows readings
of 25% gas at 20 feet from a building, inside the curb, in an unpaved area. The
Company failed to correctly classify this leak as a Type 2A.

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

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

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

GRO #208102 55 Nathaniel Blvd, Delmar - This leak was originally
classified as a Type 3 leak on 1/23/13. The leak history card shows readings
of 67% gas within 50 feet from a building, inside the curb, in an unpaved area.
The Company failed to correctly classify this leak as a Type 2 leak.

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

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

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

156 Madison Ave, Albany - Records indicate that the heating facilities were
disconnected on 1/2/13. The Company failed to notify HEFPA.

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

One violation of 261.57(b)(3), which states, (b) Class A conditions include, but are not
limited to:(3) any venting system used to convey flue gases, that is defective,
obstructed or inoperable.

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

MWork Order #13982933 - 171 Quail St Fl 1, Albany - Records indicate that a
Class B Warning Tag was issued on 12/3/13. The Plugged or Defective Vent
section states, Yes. The Company failed to accurately classify the Warning
Tag. (Post 4/1/13)

Corporate - Capital and Northeast

Record Audits
Two violations of 16 NYCRR Part 255 and zero violations of 16 NYCRR Part 261 were
noted.

16 NYCRR Part 255.465(e) - External corrosion control: Monitoring - 1 Violation,
1 Occurrence

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


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

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

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

One violation of 255.605(i), which states, Each operator shall include, as a
minimum, the following in its operating and maintenance plan as
applicable:details of how an operator plans to comply with any requirement of
this Part that is written in non-specific language. For example 255.805(b) of this Part
states, "Each operator shall...establish a means by which it determines the appropriate
surveillance interval at leak locations under frost conditions..." the details required by
this subdivision would necessitate the operator to specify the established "means".

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

National Grid GOPB 410, Inactive Gas Services, dated 7/14/2008, states,
GROUP 2. All other Inactive service lines may remain for a period of not
more than six years, provided there is a definite plan for future use. These
services must be leakage surveyed and maintained according to all applicable
procedures. If these services are not re- activated by the end of the fifth year
of inactivity, they must be physically disconnected from the gas supply at the
main or if the main is located under pavement service line may be
disconnected in an unpaved area but no closer than 10 feet from the building
by the end of the sixth year. These partial services shall be clearly noted on
maps or records of gas distribution system.

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

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

Glens Falls

Record Audits

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Five violations of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261 were
noted.

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

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

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

Retention Period of Forms

National Grid Glens Falls failed to conform to National Grid GOPB 206,
dated 2/15/11, which was the procedure in place at the time of the
violation states, Retention period of both forms is 6 years. (Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

Regulator Inspection Report #13577533 - 162 Sherman Ave,
Queensbury - The Curb Valve/OS Riser portion of the 2013
Regulator Inspection Report states, Not Ok could not locate
turned in GRO to gas op. Staff requested a copy of the GRO on
6/25/14, but the Company could not produce one. The Company
failed to retain the GRO.

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

Service Regulator Inspection

National Grid Glens Falls failed to conform to National Grid
CMS06001, Inspecting High Pressure Service Regulating Equipment, Rev
2, dated 02/01/13, states, Check for proper size and location of vent
terminus. (Post 4/1/13)

The following is an example where National Grids procedure was not
followed:

Regulator Inspection Report #210294 - 19 J ackson Ave, South
Glens Falls - Records from 1/4/13 indicate No for
Screening/Piping in the Service Regulator and Vent inspection

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

Leak Repair Identification

National Grid Glens Falls failed to conform to National Grid GOPB 206,
Leak, Maintenance, and Repair Records, dated 2/15/11 states, A Leak
History Record card (Example on page 11) is to be used as a supplement
to the Gas Repair Order form. (Post 4/1/13)

The following is an example where National Grids procedure was not
followed:

GRO #181608 - 46 William St, Glens Falls - Repairs were made
on 7/28/13. The Company failed to document the nature of the
repair on the GRO.

Leak History Card

National Grid Glens Falls failed to conform to National Grid GOPB 206,
Leak, Maintenance, and Repair Records, dated 2/15/11 states, A Leak
History Record card (Example on page 11) is to be used as a supplement
to the Gas Repair Order form.

The following is an example where National Grids procedure was not
followed:

GRO #181847 - 86 Blvd, Queensbury - The Company identified a
leak in a curb box on 12/30/12. The Company failed to complete a
leak history card with the GRO.

Gas Repair Order Form

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


-14-
The following is an example where National Grids procedure was not
followed:

GRS #205 - Grant Ave, Glens Falls - The Company noted heavy
corrosion on the 10/2/12 gas regulator station inspection form.
Staff requested a copy of the associated GRO, but the Company
could not produce one. The Company failed to write a GRO for
the heavy corrosion noted and to make repairs within 1 year.

16 NYCRR 261.53 - HEFPA - 1 Violation, 11 Occurrence

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

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

35 Dix Ave, Glens Falls - Records indicate that heating facilities were
disconnected on 1/3/13. The Company failed to notify HEFPA.

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

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

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

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

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

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

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

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


-15-
26 W. Notre Dame St, Glens Falls - Records indicate that heating facilities
were disconnected on 11/25/13. The Company failed to notify HEFPA. (Post
4/1/13)

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

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

One violation of 261.57(b)(3), which states, (b) Class A conditions include, but are not
limited to: (3) any venting system used to convey flue gases, that is defective,
obstructed or inoperable.

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

MWork Order #12244372 - 37 Orville St, Glens Falls - Records indicate that a
Class B Warning Tag was issued on 1/12/13. The Plugged or Defective Vent
section states, Yes. The Company failed to accurately classify the Warning
Tag.


Gloversville

Record Audits
Fifteen violations of 16 NYCRR Part 255 and three violations of 16 NYCRR Part 261
were noted.

16 NYCRR 255.603(d) - General Provisions - 1 Violation, 10 Occurrences

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

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

Retention Period of Records

National Grid Gloversville failed to conform to National Grid GDx
050001-PL, Rev 0, dated 12/15/10, which was the procedure in place at
the time of the violation states, Records of leak investigations,
surveillance, and repairs shall be kept for a period of six (6) years. (Post
4/1/13)

The following are examples where National Grids procedure was not
followed:

-16-

GRO #28598 - Clizbe Ave, Amsterdam - The Company failed to
retain the leak history record, as of 6/26/14. (Perm Filed on
1/23/13. No GRO, leak history card or sketch).

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

GRO #163922 - 519 N. Perry St, J ohnstown - The Company failed
to retain the leak history record, as of 6/26/14. (Perm Filed on
6/24/13. No sketch).

GRO #163935 - 75 Newman St, Gloversville - The Company
failed to retain the leak history record, as of 6/26/14. (Perm Filed
on 1/28/13. No GRO, leak history card or sketch).

GRO #121098 - 180 Fifth Ave, Gloversville - The Company
failed to retain the leak history record, as of 6/26/14. (Perm Filed
on 5/14/13. No GRO, leak history card or sketch).

GRO #182761 - 78 Wesleyan Ave, Amsterdam - The Company
failed to retain the leak history record, as of 6/26/14. (Perm Filed
on 2/6/13. No GRO, leak history card or sketch).

GRO #14619 - Auto Palace V-347, J ohnstown - The Company
failed to retain the leak history record, as of 6/26/14. (Perm Filed
on 5/14/13. No GRO, leak history card or sketch).

Annual Regulator Inspection for Correct Pressure

National Grid Gloversville failed to conform to National Grid Regulator
Station Annual Inspection Policy 060026-PL, Rev 1, dated 4/15/12, states,
This document covers regulator station inspections and includes, pressure
regulators, relief devices, principal station valves, filters, meters, vaults,
buildings, and associated equipment. The purpose of these inspections
and tests is to determine whether the equipment is: Set to function at the
correct operating and relief pressures. (Post 4/1/13)

The following is an example where National Grids procedure was not
followed:

GRS #816 - Bush Rd, J ohnstown - The Company conducted an
annual inspection of its gas regulator station on 8/9/12. At that
time, the station was set to operate at 46 psig, but the MAOP is 45
psig. The Company failed to set at the correct pressure.


-17-
Annual Regulator Inspection

National Grid Gloversville failed to conform to National Grid Regulator
Station Annual Inspection Policy INR03002, Rev 1, dated 6/1/13, states,
In New York, all instruments used for telemeter or for recording
pressures shall be operated, inspected, and tested, at least annually in
accordance with the manufacturers recommendations. Any abnormal
pressure reading shall immediately be reported to the appropriate regional
supervisory personnel. (Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

East State EOL (End of Line) Pressure Recording Gauge - The
Company tested the recording gauge on 8/13/12 and did not test it
again until 11/27/13. The Company failed to test at intervals not
exceeding 15 months.

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

Phelps EOL (End of Line) Pressure Recording Gauge - The
Company tested the recording gauge on 8/13/12 and did not test it
again until 11/27/13. The Company failed to test at intervals not
exceeding 15 months.

Annual Regulator Inspection Vent Inspection

National Grid Gloversville failed to conform to National Grid
CMS06001, Inspecting High Pressure Service Regulating Equipment, Rev
2, dated 02/01/13, states, Check for proper size and location of vent
terminus. (Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

Regulator Inspection Report #13086653 - 22 River St, Fl 3, Fort
Plain - Records from 6/30/13 indicate No for the
Screening/Piping in the Service Regulator and Vent inspection
box. The Company failed to conduct and/or document the service
regulator associated vent inspection.

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

-18-
Screening/Piping in the Service Regulator and Vent inspection
box. The Company failed to conduct and/or document the service
regulator associated vent inspection.

Annual Regulator Inspection Corrective Action

National Grid Gloversville failed to conform to National Grid
CMS06001, Rev 2, dated 2/1/13 states, If the installation does not pass
inspection: Corrective action shall be taken, or: A follow up order shall
be given to the appropriate CMS or Operations and Construct area, or:
The appropriate Warning Tag shall be issued. (Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

Regulator Inspection Report #242935 - 208 Well St, J ohnstown -
The Curb Valve/OS Riser, Key Fit, portion of the 2013 Regulator
Inspection Report from 9/4/13 states, Not Ok filled with dirt,
could not see valve. The Company failed to take and/or
document corrective action.

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

Regulator Inspection Report #13361726 - 444 Guy Park Ave,
Amsterdam - The Curb Valve/OS Riser portion of the 2013
Regulator Inspection Report from 8/15/13 states, Not Ok cant
find. The Company failed to take and/or document corrective
action.

Regulator Inspection Report #13934028 - 11 4
th
Ave, Amsterdam
- The Curb Valve/OS Riser portion of the 2013 Regulator
Inspection Report from 11/15/13 states, Not Ok. The Company
failed to take and/or document corrective action.

Class 1 Leak Repair Recheck

National Grid Gloversville failed to conform to National Grid
CNST02009, Rev 1, dated 6/1/13 states, A recheck of a Class 1 leak shall
be performed 14 to 30 days, after repairs have been made. (Post 4/1/13)

The following are examples where National Grids procedure was not
followed:


-19-
GRO #113173 - 214 Division St, Amsterdam - Repairs were made
on 6/24/13 and a reading of 2% gas was noted at barhole 2 after the
repair. The Company failed to conduct a follow-up inspection at
least 14 days after but within 30 days.

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

Class 2A Leak Surveillance

National Grid Gloversville failed to conform to National Grid
CNST02009, Rev 1, dated 6/1/13, states, Surveillance of a Class 2A leak
shall be at intervals not to exceed 14 days until the source of the leak has
been corrected, or reclassified. (Post 4/1/13)

The following is an example where National Grids procedure was not
followed:

GRO #231739 - 324 Forest Ave, Amsterdam - The Company
identified a Type 2A leak on 8/6/13. On 8/26/13 the Company
made repairs. The Company failed to maintain the leak under
surveillance with a frequency not to exceed two weeks until repairs
were made.

Type 2A Leak Classification

National Grid Gloversville failed to conform to National Grid GDx
050001-PL, Rev 0, dated 12/15/10, which was the procedure in place at the
time of the violation, requires gas in air readings of >1% to less than 4% in
manholes, vaults, and catch basins be classified as a Type 2A leaks

The following is an example where National Grids procedure was not
followed:

GRO #189665 - 10 Eagle St, Gloversville - On 1/19/13, the
Company found 2% gas in a sewer manhole. The leak was
classified as a Type 2 that day. The Company incorrectly
classified the leak.

Gas Repair Order Form

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

-20-
required to correct conditions, other than gas leaks, on Company facilities
that cannot be made at the time of discovery. See GAS REPAIR ORDER
MAINTENANCE below, for instructions related to completion of
GRO's associated with Maintenance not related to gas leaks. When a
GRO is prepared for maintenance, it shall be prioritized for repair as
follows:WITHIN 1 YEAR - Repairs of lesser importance that still
require scheduling and completion date. This includes, but is not limited
to: E. Operable transmission line or Distribution-critical valves with non-
critical repair items (valve is still operable) including missing and/or
broken stops. (Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

GRS #817 - Homestead, Amsterdam - The Company noted broken
valve stops on the 42 valve during the 10/31/13 gas regulator
station inspection. Staff requested a copy of the associated GRO,
but the Company could not produce one. The Company failed to
write a GRO for the broken stops.

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

CGI Calibration Check

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

The following are examples where National Grids procedure was not
followed:

CGI #1243-303060 - Records show a gap in calibration from
10/28/12 to 4/9/13.

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


-21-
CGI #1243-303068 - Records show a gap in calibration from
10/28/12 to 4/9/13.

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

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

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

One violation of 255.619(a), which states, Except as provided in subdivision (c) of
this section, no person may operate a segment of steel or plastic pipeline at a pressure
that exceeds the pre-determined MAOP.

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

GRS #816 - Bush Rd, J ohnstown - The Company conducted an annual
inspection of its gas regulator station on 8/9/12. At that time, the station was
set to operate at 46 psig, but the MAOP was 45 psig. Due to the incorrect set
pressure, the station periodically operated above the pre-determined MAOP
(depending on demand and load) for several months afterwards. The
Company lowered the station pressure in April of 2013 following the
Companys implementation of its new MAOP/set pressure policy. (Post
4/1/13)

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

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

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

GRS 816 - Bush Rd, J ohnstown - The Company conducted an annual
inspection of its gas regulator station on 8/9/12. At that time, the station was
set to operate at 46 psig, but the MAOP is 45 psig. The Company failed to set
at the correct pressure. (Post 4/1/13)

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


-22-
One violation of 255.809(b), which states, Each instrument utilized for leakage
surveys and investigations must be tested against a known sample or in accordance
with the manufacturer's recommended instructions as follows: (a) after any repair or
replacement of parts other than normal maintenance; (b) once every three months for
CGI's and solid state leak detection instruments and yearly for Hydrogen Flame
Ionization (HFI) instruments; and (c) any time it is suspected that the calibration has
changed.

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

CGI #1243-303060 - Records show a gap in calibration from 10/28/12 to
4/9/13. (Post 4/1/13)

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

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

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

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

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

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

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

GRO #231739 - 324 Forest Ave, Amsterdam - The Company identified a
Type 2A leak on 8/6/13. On 8/26/13 the Company made repairs. The
Company failed to maintain the leak under surveillance with a frequency not to
exceed two weeks until repairs were made. (Post 4/1/13)

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

One violation of 255.819(a), which states, Each operator shall, upon completing a
Type 1, Type 2A or Type 2 leak repair to its underground facilities, conduct a follow-
up inspection at least 14 days after but within 30 days of the repair to validate said
repair.

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


-23-
GRO #113173 - 214 Division St, Amsterdam - Repairs were made on 6/24/13
and a reading of 2% gas was noted at barhole 2 after the repair. The Company
failed to conduct a follow-up inspection at least 14 days after but within 30
days. (Post 4/1/13)

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

16 NYCRR 261.53 - HEFPA - 1 Violation, 14 Occurrences

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

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

7 Prospect, Gloversville - Records indicate that heating facilities were
disconnected on 1/2/13. The Company failed to notify HEFPA.

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

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

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

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

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

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

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

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


-24-
12 5th, Gloversville - Records indicate that heating facilities were
disconnected on 4/2/13. The Company failed to notify HEFPA. (Post 4/1/13)

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

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

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

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

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

One violation of 261.57(b)(1), which states, (b) Class A conditions include, but are not
limited to: (1) any leaking gas piping inside the building which cannot be stopped by
temporary or permanent repair means.

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

MWork Order #13462187 - 30 Carmichael St, Amsterdam - Records indicate
that a Class B Warning Tag was issued on 8/29/13. The Leak - House Piping
section states, Yes and there is no indication of a temporary repair. The
Company failed to accurately classify the Warning Tag. (Post 4/1/13)


Hudson

Record Audits
One violation of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were
noted.

16 NYCRR 255.603(d) - General Provisions- 1 Violation, 1 Occurrence

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

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


-25-
Annual Regulator Inspection Vent Inspection

National Grid Hudson failed to conform to National Grid CMS06001,
Inspecting High Pressure Service Regulating Equipment, Rev 2, dated
02/01/13, states, Check for proper size and location of vent terminus.
(Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

Regulator Inspection Report #12287890 - 816 Warren St, Hudson
Records from 1/25/13 indicate No for Screening/Piping in the
Service Regulator and Vent inspection box. The Company
failed to conduct and/or document a vent inspection.

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

Regulator Inspection Report #12447091 - 555 State St, Hudson
Records from 3/4/13 indicate No for Screening/Piping in the
Service Regulator and Vent inspection box. The Company
failed to conduct and/or document a vent inspection.

Regulator Inspection Report #12627582 - 36 N 3
rd
St, Hudson
Records from 4/3/13 indicate No for Screening/Piping in the
Service Regulator and Vent inspection box. The Company
failed to conduct and/or document a vent inspection.

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

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

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

42 Parkwood Blvd, Hudson - Records indicate that the heating facilities were
disconnected on 3/19/13. The Company failed to notify HEFPA.


Saratoga

Record Audits

-26-
Seven violations of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261 were
noted.

16 NYCRR 255.603(d) - General Provisions - 1 Violation, 4 Occurrences

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

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

Annual Regulator Inspection Vent Inspection

National Grid Saratoga failed to conform to National Grid CMS06001,
Inspecting High Pressure Service Regulating Equipment, Rev 2, dated
02/01/13, states, Check for proper size and location of vent terminus.
(Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

Regulator Inspection Report #12783064 - 139 Nelson Ave,
Saratoga - Records from 5/8/13 indicate No for the
Screening/Piping in the Service Regulator and Vent inspection
box. The Company failed to conduct and/or document the service
regulator associated vent inspection.

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

Regulator Inspection Report #12535040 - 1 Stonebreak Rd, Malta
- Records from 3/15/13 indicate No for the Screening/Piping
in the Service Regulator and Vent inspection box. The
Company failed to conduct and/or document the service regulator
associated vent inspection.

Regulator Inspection Report #12535028 - 16 Stonebreak Rd,
Malta - Records from 3/15/13 indicate No for the
Screening/Piping in the Service Regulator and Vent inspection
box. The Company failed to conduct and/or document the service
regulator associated vent inspection.


-27-
Regulator Inspection Report #213577 - 110 Brookline Rd,
Ballston Spa - Records from 1/29/13 indicate No for the
Screening/Piping in the Service Regulator and Vent inspection
box. The Company failed to conduct and/or document the service
regulator associated vent inspection.

Regulator Inspection Report #12502767 - 11 Anyhow Ln,
Gansevoort - Records from 3/8/13 indicate No for the
Screening/Piping in the Service Regulator and Vent inspection
box. The Company failed to conduct and/or document the service
regulator associated vent inspection.

Regulator Inspection Report #12279445 - 738 Route 9,
Gansevoort - Records from 1/21/13 indicate No for the
Screening/Piping in the Service Regulator and Vent inspection
box. The Company failed to conduct and/or document the service
regulator associated vent inspection.

Regulator Inspection Report #13238482 - 60 Lake Ave, Saratoga -
Records from 7/26/13 indicate No for the Screening/Piping in
the Service Regulator and Vent inspection box. The Company
failed to conduct and/or document the service regulator associated
vent inspection.

Class 2A Leak Surveillance

National Grid Saratoga failed to conform to National Grid CNST02009,
Rev 1, dated 6/1/13 states, Surveillance of a Class 2A leak shall be at
intervals not to exceed 14 days until the source of the leak has been
corrected, or reclassified. (Post 4/1/13)

The following is an example where National Grids procedure was not
followed:

GRO #202464 - 186 Spring St, Saratoga - The Type 2A leak was
surveyed on 9/27/13 and did not get surveyed again until 10/14/13.
The Company failed to maintain the leak under surveillance with a
frequency not to exceed two weeks.

CGI Calibration Check

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

-28-
instrument manufacturer indicates that a longer calibration frequency
interval is acceptable; however, in no case shall the frequency of
calibrations exceed three (3) months. (Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

CGI #1243-303046 - Records show a gap in calibration from
10/28/12 to 4/9/13.

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

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

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

Building of Public Assembly Inspections

National Grid Saratoga failed to conform to National Grid CNST02003,
Building of Public Assembly Inspection, Rev 1, dated 2/1/13, states, If
the curb valve is not visible or accessible, a curb valve repair ticket must
be completed. The repair ticket should be addressed within 90 days.
(Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

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

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

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


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

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

DSNY Ticket #725322206000 - Front St @ Low St, Ballston Spa - Premiers
Cast Iron Report, dated 7/25/13, states, 4" cast iron gas main is 2' from the
premarked work area and is paralleling the premarked work area for a length
of 7'. Cast iron replacement. Staff questioned the Company about the main
and the local supervisor stated that it was never encroached. Staff also
requested documentation to verify the disposition, but it could not be provided
by the Company. (Post 4/1/13)

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

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

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

CGI #1243-303046 - Records show a gap in calibration from 10/28/12 to
4/9/13. (Post 4/1/13)

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

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

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

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

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

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

GRO #202464 - 186 Spring St, Saratoga - The Type 2A leak was surveyed on
9/27/13 and did not get surveyed again until 10/14/13. The Company failed to
maintain the leak under surveillance with a frequency not to exceed two weeks.
(Post 4/1/13)

16 NYCRR 261.53 - HEFPA - 1 Violation, 9 Occurrences

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

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

1 Spring St, Schuylerville - Records indicate that heating facilities were
disconnected on 1/20/13. The Company failed to notify HEFPA.

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

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

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

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

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

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

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

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


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

One violation of 261.57(b)(1), which states, (b) Class A conditions include, but are not
limited to: (1) any leaking gas piping inside the building which cannot be stopped by
temporary or permanent repair means.

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

MWork Order #12230501 - 2453 Saratoga-Albany Rd, Ballston Spa - Records
indicate that a Class B Warning Tag was issued on 1/9/13. The Leak - House
Piping section states, Yes and there is no indication of a temporary repair.
The Company failed to accurately classify the Warning Tag.

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

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

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

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


Schenectady

Record Audits
Four violations of 16 NYCRR Part 255 and three violations of 16 NYCRR Part 261 were
noted.

16 NYCRR 255.603(d) - General Provisions - 1 Violation, 2 Occurrences

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

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

CGI Calibration Check

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

The following are examples where National Grids procedure was not
followed:

CGI #1243-303073 - Records show a gap in calibration from
10/28/12 to 4/9/13.

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

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

Class 2A Leak Surveillance

National Grid Schenectady failed to conform to National Grid
CNST02009, Classifying Gas Leaks, Rev 1, dated 06/01/13, states,
Surveillance: Surveillance of a Class 2A leak shall be at intervals not to
exceed 14 days until the source of the leak has been corrected, or
reclassified. (Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

GRO #218096 - 104 Irving St, Schenectady - This Type 1 leak
history record shows 20% gas within 20 feet of a building, in a
paved area, in an after repair reading on 10/3/13. This leak was not
surveyed again until 10/28/13. The Company failed to survey a
leak with Type 2A readings within two weeks.

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

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

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

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

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

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

CGI #1243-303073 - Records show a gap in calibration from 10/28/12 to
4/9/13. (Post 4/1/13)

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

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

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

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

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

GRO #218096 - 104 Irving St, Schenectady - This Type 1 leak history record
shows 20% gas within 20 feet of a building, in a paved area, in an after repair
reading on 10/3/13. This leak was not surveyed again until 10/28/13. The

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

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

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

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

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

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

1066 Howard St, Schenectady - Records indicate that the heating facilities were
disconnected on 1/22/13. The Company failed to notify HEFPA.

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

One violation of 261.57(b)(3), which states, (b) Class A conditions include, but are not
limited to: (3) any venting system used to convey flue gases, that is defective,
obstructed or inoperable.

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

MWork Order #13759521 - 2316 Sheridan Ave, Schenectady - Records indicate
that a Class B Warning Tag was issued on 10/15/13. The Plugged or Defective
Vent section states, Yes, and the Remarks section states, found water heater
vent not pitched correctly. The Company failed to accurately classify the
Warning Tag. (Post 4/1/13)

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

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

One violation of 261.59(c)(2), which states, (c) Class B conditions include, but are not
limited to: (2) any gas appliance with a missing or inoperative required safety
device.

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

MWork Order #13568414 - 5 Princeton St, Schenectady - Records indicate that
a Class C Warning Tag was issued on 9/17/13. The Remarks section states,
Customer accidently broke off pilot tubing at the pilot assembly. Valve is
100% shut off. Gas off at appliance shut off. Replace tubing. The Company
failed to accurately classify the Warning Tag. (Post 4/1/13)


Syracuse

Record Audits
One violation of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261 were
noted.

16 NYCRR Part 255.603(d) - General provisions 1 Violation, 2 Occurrences

One violation of 255.603(d), which states that each operator shall satisfactorily
conform to the program submitted.

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

Building of Public Assembly Inspections

National Grid Syracuse failed to conform to National Grid Procedure
CNST02003, which states that, In New York State, BPA inspections /
leakage surveys shall be completed annually, and at intervals not to exceed
15 months. (Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

The building designated as a public building requiring an annual
inspection located at 318 E. Fayette Street, Syracuse was not
inspected as required in 2013

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

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

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

Service Regulator Inspection

National Grid Syracuse failed to conform to National Grid Procedure
CMS06001 Rev 2 section 5.1 which states that regulators shall be
inspected in conjunction with a meter turn-on where the service has been
inactive for more than two years. (Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

No service regulator inspection record could be located for the
service regulator at 103 East Way in Camillus that was reactivated
on 12/3/13 after being inactive since 10/5/11.

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

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

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

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

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

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

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No service regulator inspection record could be located for the
service regulator at 159 Meredith Ave. in Nedrow that was
reactivated on 7/18/13 after being inactive since 5/4/11.

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

A Class A warning tag was issued on 1/8/13 at 419 East Avenue in Minoa that
resulted in the customer being unable to use the heating facilities. The
Company was unable to provide a record showing that the HEFPA liaison
with local social services departments was contacted as required.

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

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

A Class A warning tag was issued on 1/27/13 at 716 J ames Street in Syracuse
that resulted in the customer being unable to use the heating facilities. The
Company was unable to provide a record showing that the HEFPA liaison
with local social services departments was contacted as required.

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

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

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

A Class A warning tag was issued on 3/18/13 at 859 Lancaster Avenue in
Syracuse that resulted in the customer being unable to use the heating
facilities. The Company was unable to provide a record showing that the
HEFPA liaison with local social services departments was contacted as
required.

A Class A warning tag was issued on 11/11/13 at 405 Sedgwich Drive in
Syracuse that resulted in the customer being unable to use the heating
facilities. The Company was unable to provide a record showing that the
HEFPA liaison with local social services departments was contacted as
required. (Post 4/1/13)

A Class B warning tag was issued on 11/11/13 at 325 DeWitt Street in
Syracuse that resulted in the customer being unable to use the heating
facilities. The Company was unable to provide a record showing that the
HEFPA liaison with local social services departments was contacted as
required. (Post 4/1/13)

A Class A warning tag was issued on 11/13/13 at 129 Sudbury Drive in
Liverpool that resulted in the customer being unable to use the heating
facilities. The Company was unable to provide a record showing that the
HEFPA liaison with local social services departments was contacted as
required. (Post 4/1/13)

A Class A warning tag was issued on 11/19/13 at 1021 Park Street in Syracuse
that resulted in the customer being unable to use the heating facilities. The
Company was unable to provide a record showing that the HEFPA liaison
with local social services departments was contacted as required. (Post
4/1/13)

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

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


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

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

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

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

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

One violation of 261.57(b)(3), which states that Class A conditions include, but are
not limited to any venting system used to convey flue gases, that is defective,
obstructed or inoperable.

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

A Class B warning tag was issued on10/25/2013 at 705 Scarboro, Dr.,
Syracuse for a Plugged chimney which is a class A condition. (Post 4/1/13)

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

A Class B warning tag was issued on 11/19/2013 at 729 N. Alvord Street,
Syracuse - for a cracked heat exchanger which is a class A condition. (Post
4/1/13)


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


Troy

Record Audits
Nine violations of 16 NYCRR Part 255 and six violations of 16 NYCRR Part 261 were
noted.

16 NYCRR 255.603(d) - General Provisions - 1 Violation, 1 Occurrence

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

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

CGI Calibration Check

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

The following are examples where National Grids procedure was not
followed:

CGI #1243-303013 - Records show a gap in calibration from
10/28/12 to 4/9/13.

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

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

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


-43-
CGI #1243-303063 - Records show a gap in calibration from
10/28/12 to 4/9/13.

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

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

Gas Repair Order Record

National Grid Troy failed to conform to National Grid GOPB 206, Leak,
Maintenance, and Repair Records, dated 2/15/11 states, Initial and ALL
subsequent repair efforts shall be identified.

The following is an example where National Grids procedure was not
followed:

GRO #134844 - 30 Hendrix-Hudson Way, Clifton Park - This leak
history record shows that a repair was made on 3/7/13. The GRO
shows no detail of the repair and there is no other documentation
showing that a repair was performed. The Company failed to
document the nature of the repair.

Type Leak 2A Classification

National Grid Troy failed to conform to National Grid GDx 050001-PL,
Rev 0, dated 12/15/10, which was the procedure in place at the time of the
violation, Attachment 2: Leak Classification Guide - Massachusetts, New
York State and Rhode Island, depicts that Type 2A leaks include gas
readings greater than 10% gas, within 30 feet of a building, in a
continuously paved area.

The following is an example where National Grids procedure was not
followed:

GRO #187135 - 13 Atlantic Ave, Wynantskill - On 2/14/13, this
leak history record shows 2% gas in a sewer at barhole 7. The leak
was classified as a Type 2 leak. The Company failed to correctly
classify the leak as a Type 2A.

Type Leak 2A Classification

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

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current procedure, depicts that Type 2A leaks include gas readings greater
than 1% to less than 4% gas in manholes.

The following is an example where National Grids procedure was not
followed:

GRO #191619 - 1224 5
th
Ave, Watervliet - On 1/18/13, this leak
history record shows 10% gas within 30 feet of a building, in a
paved area. The leak was classified as a Type 2 leak. The
Company failed to correctly classify the leak as a Type 2A.

Type Leak 2 Classification

National Grid Troy failed to conform to GDx 050001-PL, Rev 0, dated
12/15/10, which was the procedure in place at the time of the violation,
Attachment 2: Leak Classification Guide - Massachusetts, New York State
and Rhode Island, depicts that Type 2 leaks include gas readings less than
20% gas, within 20 feet of the building, in an unpaved area.

The following is an example where National Grids procedure was not
followed:

GRO #153759 - 517 3
rd
Ave, Troy - On 2/9/09, this leak history
record shows 35 LEL at 10 feet from a building, in an unpaved
area. The leak was classified as a Type 3 leak. The Company
failed to correctly classify the leak as a Type 2 leak.

Annual Regulator Inspection Vent Inspection

National Grid Troy failed to conform to National Grid CMS06001,
Inspecting High Pressure Service Regulating Equipment, Rev 2, dated
02/01/13, states, Check for proper size and location of vent terminus.
(Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

Regulator Inspection Report #244065 - 263 Bloomingrove Dr,
Troy Records from 9/12/13 indicate No for Screening/Piping
in the Service Regulator and Vent inspection box. The
Company failed to conduct and/or document a vent inspection.

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

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

Regulator Inspection Report #13981567 - 7 David Dr, Cohoes
Records from 11/16/13 indicate No for Screening/Piping in the
Service Regulator and Vent inspection box. The Company
failed to conduct and/or document a vent inspection.

Regulator Inspection Report #13787765 - 279 Old-Loudon Rd,
Latham Records from 10/18/13 indicate No for
Screening/Piping in the Service Regulator and Vent inspection
box. The Company failed to conduct and/or document a vent
inspection.

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

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

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

CGI #1243-303013 - Records show a gap in calibration from 10/28/12 to
4/9/13. (Post 4/1/13)

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

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

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

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

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

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

-46-

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

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

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

GRO #191619 - 1224 5
th
Ave, Watervliet - On 1/18/13, this leak history
record shows 10% gas within 30 feet of a building, in a continuously paved
area. The leak was classified as a Type 2 leak. The Company failed to
correctly classify the leak.

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

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

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

GRO #153759 - 517 3
rd
Ave, Troy - On 2/9/09, this leak history record shows
35 LEL at 10 feet from a building, in an unpaved area. The leak was classified
as a Type 3 leak. The Company failed to correctly classify the leak as a Type
2 leak.

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

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

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

38 Craig St, Watervliet - Records indicate that the heating facilities were
disconnected on 1/3/13. The Company failed to notify HEFPA.

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

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

-47-

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

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

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

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

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

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

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

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

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

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

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

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

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

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

One violation of 261.57(b)(1) which states, (b) Class A conditions include, but are not
limited to: (1) any leaking gas piping inside the building which cannot be stopped by
temporary or permanent repair means.

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

-48-

MWork Order #13334879 - 15 Patton Rd, Troy - Records indicate that a
Class C Warning Tag was issued on 8/19/13. This tag clearly states, Leak -
House Piping Yes, and that the cause for the tag was, red tag at house pipe
union. There are no indications on the tag that a temporary repair was made.
The Company failed to correctly classify this Warning Tag. (Post 4/1/13)

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

One violation of 261.57(b)(3) which states, (b) Class A conditions include, but are not
limited to: (3) any venting system used to convey flue gases, that is defective,
obstructed or inoperable.

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

MWork Order #13265069 - 1902 7
th
Ave Fl 1, Watervliet - Records indicate
that a Class C Warning Tag was issued on 8/2/13. This tag clearly states,
Plugged or Defective Vent Yes for the water heater, and that the cause for
the tag was, Spill at vent, not venting properly. There are no indications on
the tag that a temporary repair was made. The Company failed to correctly
classify this Warning Tag. (Post 4/1/13)

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

One violation of 261.59(c)(1), which states, (c) Class B conditions include, but are not
limited to: (1) any leaking gas appliance inside the building which cannot be stopped by
temporary or permanent repair means.

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

MWork Order #13320270 - 5 Blue-Creek Ln, Latham - Records indicate that
a Class C Warning Tag was issued on 8/7/13. This tag clearly states, Leak At
Appliance Yes for the water heater. There are no indications on the tag that a
temporary repair was made. The Company failed to correctly classify this
Warning Tag. (Post 4/1/13)

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

One violation of 261.59(c)(5), which states, (c) Class B conditions include, but are not
limited to: (5) open flame burners too close to combustibles.

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

MWork Order #12729756 - 382 3
rd
St Fl 1, Troy - Records indicate that a
Class C Warning Tag was issued on 4/24/13. This tag clearly states that the

-49-
cause for the tag was, fire at appl due to debris in and on range. There are
no indications on the tag that a temporary repair was made. The Company
failed to correctly classify this Warning Tag. (Post 4/1/13)

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

One violation of 261.59(c)(6), which states, (c) Class B conditions include, but are not
limited to: (6) any unit other than a heating or hot water appliance having visual
indications of improper combustion.

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

MWork Order #12219515 - 1519 3
rd
Ave Fl 2, Watervliet - Records indicate
that a Class C Warning Tag was issued on 1/7/13. This tag clearly states that
the cause for the tag was, oven may be a little over gassed. There are no
indications on the tag that a temporary repair was made. The Company failed
to correctly classify this Warning Tag.


Utica

Record Audits
Four violations of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were
noted.

16 NYCRR Part 255.465(a) - External corrosion control: Monitoring 1 Violation,
28 Occurrence

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

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

The isolated service located at 3466 Oneida Street (cha:oneida, TS 58) was
tested on 1/1/2001 and not again until 3/19/13. This exceeds the code allowed

-50-
maximum interval of 10 years. This service was included on the list of
isolated and protected services that was provided by the Company.

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

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

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

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

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

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

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

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

The isolated service located at 46 Parkside Circle (nym:parkside, TS 6) was
tested on 1/1/1994 and not again until 2/27/13. This exceeds the code allowed

-51-
maximum interval of 10 years. This service was included on the list of
isolated and protected services that was provided by the Company.

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

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

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

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

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

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

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

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

The isolated service located at 505 Parklane Drive (uti:parklane, TS 6) was
tested on 1/1/1989 and not again until 3/26/13. This exceeds the code allowed

-52-
maximum interval of 10 years. This service was included on the list of
isolated and protected services that was provided by the Company.

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

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

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

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

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

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

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

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

The isolated service located at 51 Meyers Avenue (yor:myers, TS 12) was
tested on 1/1/1992 and not again until 3/7/13. This exceeds the code allowed

-53-
maximum interval of 10 years. This service was included on the list of
isolated and protected services that was provided by the Company.

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

One violation of 255.603(d), which states that each operator shall satisfactorily
conform to the program submitted.

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

Record Retention

National Grid Utica failed to conform to National Grid Procedure GOPB
206, dated 12/15/10, which was the procedure in place at the time of the
violation states: Retention period of both forms is 6 years. (Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

Mwork order number 12656299: On the service regulator
inspection form for 2011 Genesee Street in Utica the Curb
Valve/OS Riser portion of the 2013 Regulator Inspection Report
states Not Ok curb box full of stones GRO 180152. Staff
requested a copy of the GRO, but the Company could not produce
one. The Company failed to retain the GRO.

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

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

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

-54-

Corrosion Inspection

National Grid Utica failed to conform to National Grid Procedure
040020 PL (rev 1)Section 5 which states that isolated service inventory
shall have at least 10 percent of these protected structures, distributed over
the entire system surveyed each calendar year, with a different 10 percent
checked each subsequent year, so that the entire system is tested in each
10-year period. (Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

The isolated service located at 3466 Oneida Street (cha:oneida, TS
58) was tested on 1/1/2001 and not again until 3/19/13. This
exceeds the code allowed maximum interval of 10 years. This
service was included on the list of isolated and protected services
that was provided by the Company.

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

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

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

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

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

-55-
service was included on the list of isolated and protected services
that was provided by the Company.

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Inactive Gas Services

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National Grid Utica failed to conform to National Grid Procedure GOPB
410 Section (B)(3)(a) which states that all other service lines, including
stubs, not under cathodic protection must be reviewed after two years of
inactivity. (Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

The inactive service located at 4360 Acme Road in the village of
Ilion became inactive on 2/19/10. No documentation was provided
showing that the service was reviewed after two years of inactivity.

Service Regulator Inspection

National Grid Utica failed to conform to National Grid Procedure
CMS06001 Rev 2 section 5.1 which states that regulators shall be
inspected in conjunction with a meter turn-on where the service has been
inactive for more than two years. (Post 4/1/13)


The following are examples where National Grids procedure was not
followed:

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

No service regulator inspection record could be located for the
service regulator at 112 Bruno Road in Canastota that was
reactivated on 11/22/13 after being inactive since 10/5/11.

No service regulator inspection record could be located for the
service regulator at 123 Seneca Street in Utica that was
reactivated on 10/29/13 after being inactive since 3/24/11.

No service regulator inspection record could be located for the
service regulator at 1305 Maple Street in Utica that was
reactivated on 10/2/13 after being inactive since 9/12/11.

No service regulator inspection record could be located for the
service regulator at 144 Bono Boulevard in Frankfort that was
reactivated on 10/28/13 after being inactive since 10/24/11.


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

No service regulator inspection record could be located for the
service regulator at 2043 Genesee Street in Utica that was
reactivated on 10/8/13 after being inactive since 8/15/11.

No service regulator inspection record could be located for the
service regulator at 2903 RT 12B in Deansboro that was
reactivated on 6/25/13 after being inactive since 6/9/11.

No service regulator inspection record could be located for the
service regulator at 416 Race Street in Chittenango that was
reactivated on 9/24/13 after being inactive since 6/27/11.

No service regulator inspection record could be located for the
service regulator at 423 West Dominick Street in Rome that was
reactivated on 9/19/13 after being inactive since 2/17/09.

No service regulator inspection record could be located for the
service regulator at 507 Floyd Avenue in Rome that was
reactivated on 11/26/13 after being inactive since 5/25/11.

No service regulator inspection record could be located for the
service regulator at 5870 Columbus Drive in Marcy that was
reactivated on 12/18/13 after being inactive since 4/19/10.

No service regulator inspection record could be located for the
service regulator at 613 2
nd
Avenue in Frankfort that was
reactivated on 11/25/13 after being inactive since 7/18/11.

No service regulator inspection record could be located for the
service regulator at 75 Bedford Drive in Whitesboro that was
reactivated on 11/5/13 after being inactive since 5/12/11.

No service regulator inspection record could be located for the
service regulator at 9647 River Drive in Marcy that was
reactivated on 9/17/13 after being inactive since 8/25/11.

Outside Leak Report Diagram

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

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The following are examples where National Grids procedure was not
followed:

GRO #228678 was issued on 5/28/13 at 601 J ay St., Utica for a
leaking cap on a service tee. The operator found 11 LEL 12 feet
from a building, during a recheck made on 6/12/13. The leak was
re-classified as a Type 3 leak on this date. This was not classified
properly; it should have been reclassified to a Type 2 leak because
the 11 LEL was within 20 feet a building.

GRO #216843 was issued on 8/22/12 at 4046 Bristol Rd., Kirkland
for an 8 STL dresser that was leaking. The initial investigation
found 25% gas at barhole #3 at 40 feet from the building. During
the surveillance on 7/23/13 a reading of 36% gas was found at
barhole #3. This reading would have required the leak to be
reclassified to a Type 2. There was no indication on the record that
the leak was ever re-classified.

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

One violation of 255.815(d)(2), which states that any reading less than 20 percent
gas-in-air in any unpaved area which is more than five feet (1.5 meters) from but
within 20 feet (6.1 meters) of a building and inside the curbline or shoulder of the
road.

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

GRO #228678 was issued on 5/28/13 at 601 J ay St., Utica for a leaking cap on
a service tee. The operator found 11 LEL 12 feet from a building, during a
recheck made on 6/12/13. The leak was re-classified as a Type 3 leak on this
date. This was not classified properly; it should have re classified to a Type 2
leak because the 11 LEL was within 20 feet a building. (Post 4/1/13)

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

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

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

GRO #216843 was issued on 8/22/12 at 4046 Bristol Rd., Kirkland for an 8
STL dresser that was leaking. The initial investigation found 25% gas at

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

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

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

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

A Class A warning tag was issued on 3/1/2013 at 228 West Main Street in
Frankfort that resulted in the customer being unable to use the heating
facilities. The Company was unable to provide a record showing that the
HEFPA liaison with local social services departments was contacted as
required.

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

A Class A warning tag was issued on 11/5/2013 at 18 Fulmer Street in
Mohawk that resulted in the customer being unable to use the heating
facilities. The Company was unable to provide a record showing that the
HEFPA liaison with local social services departments was contacted as
required. (Post 4/1/13)

A Class A warning tag was issued on 1/4/2013 at 401 South J ames Street in
Rome that resulted in the customer being unable to use the heating facilities.
The Company was unable to provide a record showing that the HEFPA liaison
with local social services departments was contacted as required.

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

A Class A warning tag was issued on 12/18/2013 at 7105 Herkimer Avenue in
Rome that resulted in the customer being unable to use the heating facilities.
The Company was unable to provide a record showing that the HEFPA liaison

-62-
with local social services departments was contacted as required. (Post
4/1/13)

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

A Class A warning tag was issued on 2/18/2013 at 2 Beechwood Road in New
Hartford that resulted in the customer being unable to use the heating
facilities. The Company was unable to provide a record showing that the
HEFPA liaison with local social services departments was contacted as
required.

A Class A warning tag was issued on 4/3/2013 at 8516 Westmoreland Road in
Whitesboro that resulted in the customer being unable to use the heating
facilities. The Company was unable to provide a record showing that the
HEFPA liaison with local social services departments was contacted as
required. (Post 4/1/13)

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

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

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

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

A Class A warning tag was issued on 11/5/2013 at 721 Plant Street in Utica
that resulted in the customer being unable to use the heating facilities. The

-63-
Company was unable to provide a record showing that the HEFPA liaison
with local social services departments was contacted as required. (Post
4/1/13)

A Class A warning tag was issued on 11/7/2013 at 511 Eagle Street in Utica
that resulted in the customer being unable to use the heating facilities. The
Company was unable to provide a record showing that the HEFPA liaison
with local social services departments was contacted as required. (Post
4/1/13)

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

A Class A warning tag was issued on 11/12/2013 at 153 J ames Street in Utica
that resulted in the customer being unable to use the heating facilities. The
Company was unable to provide a record showing that the HEFPA liaison
with local social services departments was contacted as required. (Post
4/1/13)

A Class B warning tag was issued on 11/12/2013 at 1002 Blandina Street in
Utica that resulted in the customer being unable to use the heating facilities.
The Company was unable to provide a record showing that the HEFPA liaison
with local social services departments was contacted as required. (Post
4/1/13)

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

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

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


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

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

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

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

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

A Class B warning tag was issued on 12/31/2013 at 510 Albany Street in
Utica that resulted in the customer being unable to use the heating facilities.
The Company was unable to provide a record showing that the HEFPA liaison
with local social services departments was contacted as required. (Post
4/1/13)


Volney

Record Audits
One violation of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were
noted.

16 NYCRR Part 255.603(d) - General provisions - 1 Violation, 4 Occurrences


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One violation of 255.603(d), which states that each operator shall satisfactorily
conform to the program submitted.

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

Record Retention

National Grid Utica failed to conform to National Grid Procedure GOPB
206, dated 12/15/10, which was the procedure in place at the time of the
violation states: Retention period of both forms is 6 years. (Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

GRO #165747 was issued for a Type 1 Leak on 7/24/13 at 28 Ellen
St. in Oswego. A Gas Repair Order and Leak History Record
could not be produced for Staff review. Therefore, all details
pertaining to this leak and follow-up are not adequately
documented and unable to be reviewed. The Company failed to
retain the GRO.

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

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

Service Regulator Inspection

National Grid Fulton failed to conform to National Grid Procedure
CMS06001 Rev 2 section 5.1 which states that regulators shall be
inspected at the time of a meter change and in conjunction with a meter
turn-on where the service has been inactive for more than two years.
(Post 4/1/13)

The following are examples where National Grids procedure was not
followed:


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

The meter at 220 Seneca St. in Fulton was a scheduled meter
change on 6/28/2013. No service regulator inspection record could
be located

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

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

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

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

Service Valve Inspection

National Grid Fulton failed to conform to National Grid Procedure
CMS06001 Rev 2 section 5.1 which states that the curb valves on high
pressure services shall be inspected at the time of the regulator inspection.
(Post 4/1/13)

The following is an example where National Grids procedure was not
followed:

The meter at 463 W. 4th St. S in Fulton was a scheduled meter
change on 10/302013. An MWork Regulator Inspection Report
was produced for the service regulator, vent and valve inspections
to be performed at the time of meter change, however it is
indicated that no inspection was done on the curb valve as the
valve could not be located.

Service Valve Inspection

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

-67-
corrective action shall be taken, or a follow up order shall be given to the
appropriate CMS or Operations and Construct area. (Post 4/1/13)

The following is an example where National Grids procedure was not
followed:

The meter at 463 W. 4th St. S in Fulton was a scheduled meter
change on 10/302013. An MWork Regulator Inspection Report
was produced for the service regulator, vent and valve inspections
to be performed at the time of meter change, however it is
indicated that no inspection was done on the curb valve as the
valve could not be located. It was not indicated on the inspection
record that a follow up order was given to the appropriate CMS or
Operations and Construct area.

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

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

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

A Class A warning tag (MWork Order Number 12317193) was issued on
1/29/2013 at 83 Ridgeway-Sites Ave. in Oswego. The warning tag was issued
for a plugged heat exchanger and the appliance was isolated. The Company
was unable to provide a record showing that the HEFPA liaison with local
social services departments was contacted as required.

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

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

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

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

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


Watertown

Record Audits
Two violations of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261 were
noted.

16 NYCRR Part 255.603(d) - General provisions - 1 Violation, 4 Occurrences

One violation of 255.603(d), which states that each operator shall satisfactorily
conform to the program submitted.

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

Service Regulator Inspection

National Grid Watertown failed to conform to National Grid Procedure
CMS06001 Rev 2 section 5.1 which states that regulators shall be
inspected at the time of a meter change and in conjunction with a meter
turn-on where the service has been inactive for more than two years.
(Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

The meter at 139 Cedar St. in Watertown was a scheduled meter
change on 4/12/2013. No service regulator inspection record could
be located

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

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


-69-
The meter at 508 New York Ave. in Watertown was a scheduled
meter change on 10/28/2013. No service regulator inspection
record could be located.

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

Service Valve Inspection

National Grid Watertown failed to conform to National Grid Procedure
CMS06001 Rev 2 section 5.1 which states that the curb valves on high
pressure services shall be inspected at the time of the regulator inspection.
(Post 4/1/13)

The following are examples where National Grids procedure was not
followed:

The meter at 161 Paddock St. in Watertown was a scheduled meter
change on 3/12/2013. An MWork Regulator Inspection Report
was produced for the service regulator, vent and valve inspections
to be performed at the time of meter change, however it is
indicated that no inspection was done on the curb valve as the
valve could not be located.

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

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

Service Valve Inspection

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


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The following are examples where National Grids procedure was not
followed:

The meter at 161 Paddock St. in Watertown was a scheduled meter
change on 3/12/2013. An MWork Regulator Inspection Report
was produced for the service regulator, vent and valve inspections
to be performed at the time of meter change, however it is
indicated that no inspection was done on the curb valve as the
valve could not be located. It was not indicated on the inspection
record that a follow up order was given to the appropriate CMS or
Operations and Construct area.

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

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

Leak, Maintenance, and Repair Records

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

The following is an example where National Grids procedure was not
followed:

GRO#138674 is for a Type 1 leak on 11/4/13 at Creekwood Dr. in
Watertown. There is no reading to the North of bar hole #1 to
determine the extent of hazardous gas migration.

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

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

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

GRO#138674 is for a Type 1 leak on 11/4/13 at Creekwood Dr. in
Watertown. There is no reading to the North of bar hole #1 to determine the
extent of hazardous gas migration. (Post 4/1/13)

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

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

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

A Class A warning tag (MWork Order Number 12536309) was issued on
3/15/2013 at 409 Flower Ave E. in Watertown. The warning tag was issued
for a possible pinhole in the furnace heat exchanger with excessive CO and
the appliance was isolated. The Company was unable to provide a record
showing that the HEFPA liaison with local social services departments was
contacted as required.

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

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


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

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

One violation of 261.57(b)(4) which states that Class A conditions include, but are
not limited to: heat exchangers which are corroded or cracked beyond repair or
blocked and which cause products of combustion to enter the warm air distribution
system.

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

A Class B warning tag (MWork Order Number 13879153) was issued on
11/4/13 at 214 Schley Dr. in Watertown. The warning tag was issued for a
cracked heat exchanger on the furnace. This is not a class B condition,
however, and a Class A warning tag should have been issued. (Post 4/1/13)


-1-
Attachment 2
Other Risk
Violation Specifics


Albany

Record Audits
Four violations of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were
noted.

16 NYCRR Part 255.17(a) - Preservation of records - 1 Violation, 1 Occurrence

One violation of 255.17(a), which states, Notwithstanding the requirements of Part
293 or Part 733 of this Title, the minimum period of retention of records required by
this Part shall be at least 3 years.

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

Regulator Inspection Report #215963 - 12 Red-Lane Dr, Colonie - The Curb
Valve/OS Riser portion of the 2013 Regulator Inspection Report states, Not
Ok cannot locate curb valve GRO 187134. Staff requested a copy of the
GRO on 6/25/14, but the Company could not produce one. The Company
failed to retain the GRO. (Post 4/1/13)

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

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

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

481 3
rd
St, Albany (meter #1262131) - The Company failed to conduct and/or
document a future use survey during the third year of inactivity, as of 6/26/14.
Last Final Read Date was 3/15/10. (Post 4/1/13)

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

-2-

36 Sparkill Ave, Albany (meter #3165974 and meter #1173619) - The
Company failed to conduct and/or document a future use survey during the
third year of inactivity, as of 6/26/14. Last Final Read Date was 1/18/10 and
1/7/10, respectively. (Post 4/1/13)

69 Beverly Ave, Albany (meter #1970070) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 12/18/09. (Post 4/1/13)

537 1
st
St, Albany (meter #0P593074) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 11/3/09. (Post 4/1/13)

2 Central Ave, Albany (meter #0Z290890) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 7/19/09. (Post 4/1/13)

24 S Pine Ave, Albany (meter #0H545006) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 7/9/09. (Post 4/1/13)

268 3
rd
St, Albany (meter #14381021) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 7/7/09. (Post 4/1/13)

139 3
rd
Ave, Albany (meter #9568968) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 6/10/09. (Post 4/1/13)

132 Central Ave, Albany (meter #267601) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 6/8/09. (Post 4/1/13)

452 Hamilton St, Albany (meter #3301965) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 5/27/09. (Post 4/1/13)

410 Clinton Ave, Albany (meter #0L622172) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 5/5/09. (Post 4/1/13)

45 Prospect Ave, Albany (meter #9928234) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 4/14/09. (Post 4/1/13)


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

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

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

Regulator Inspection Report #227901 - 11 Cary St, Ravena - Records from
5/10/13 indicate No for Screening/Piping in the Service Regulator and
Vent inspection box. The Company failed to conduct and/or document a
vent inspection. (Post 4/1/13)

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

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

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

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

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

GRO #207771 - 119 Orchard St, Delmar - This leak was a Type 2A leak on
2/28/13. It was reclassified to a Type 2 leak on 3/11/13 with no surveillances
in between. There were no repairs made until after the reclassification. The
Company failed to perform at least one additional surveillance at the normal
interval before downgrading to a lower classification.

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


-4-
One violation of 261.63(a)(1), which states, When a Class A condition is discovered,
the operator shall lock off the gas supply at the meter, unless the affected piping or gas
fired appliance can be effectively isolated and secured from the rest of the system, and
issue a Warning Tag. If the operator is not advised by the customer within 10 calendar
days that the condition has been corrected and service is ready to be reinstituted, the
operator shall contact the customer no later than the end of the first business day after
the 10-day period to determine the status of service. Following are examples where
this requirement was not met:

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

MWork Order #12470463 - 6 Taylor Dr, East Greenbush - Records indicate
that a Class A Warning Tag was issued on 3/3/13. The customer did not
advise the Company that the condition was corrected within 10 calendar days
and the Company failed to contact the customer by the end of the first
business day after the 10-day period.

MWork Order #12971184 - 465 Hamilton St Fl 1, Albany - Records indicate
that a Class A Warning Tag was issued on 6/7/13. The customer did not
advise the Company that the condition was corrected within 10 calendar days
and the Company failed to contact the customer by the end of the first
business day after the 10-day period. (Post 4/1/13)

MWork Order #13105534 - 638 Park Ave, Albany - Records indicate that a
Class A Warning Tag was issued on 7/2/13. The customer did not advise the
Company that the condition was corrected within 10 calendar days and the
Company failed to contact the customer by the end of the first business day
after the 10-day period. (Post 4/1/13)

MWork Order #13733398 - 107 Park St Apt 2, Altamont - Records indicate
that a Class A Warning Tag was issued on 10/14/13. The customer did not
advise the Company that the condition was corrected within 10 calendar days
and the Company failed to contact the customer by the end of the first
business day after the 10-day period. (Post 4/1/13)

MWork Order #13705149 - 37 The Crossway, Delmar - Records indicate that
a Class A Warning Tag was issued on 10/7/13. The customer did not advise
the Company that the condition was corrected within 10 calendar days and the
Company failed to contact the customer by the end of the first business day
after the 10-day period. (Post 4/1/13).

MWork Order #14119600 - 552 Route 9W, Glenmont - Records indicate that
a Class A Warning Tag was issued on 12/31/13. The customer did not advise
the Company that the condition was corrected within 10 calendar days and the
Company failed to contact the customer by the end of the first business day
after the 10-day period. (Post 4/1/13)


-5-
MWork Order #13968547 - 224 Washington Ave Fl 3, Albany - Records
indicate that a Class A Warning Tag was issued on 11/27/13. The customer
did not advise the Company that the condition was corrected within 10
calendar days and the Company failed to contact the customer by the end of
the first business day after the 10-day period. (Post 4/1/13)


Corporate - Capital and Northeast

Record Audits
Zero violations of 16 NYCRR Part 255 and zero violations of 16 NYCRR Part 261 were
noted.


Glens Falls

Record Audits
Four violations of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261 were
noted.

16 NYCRR Part 255.17(a) - Preservation of records - 1 Violation, 2 Occurrences

One violation of 255.17(a), which states, Notwithstanding the requirements of Part
293 or Part 733 of this Title, the minimum period of retention of records required by
this Part shall be at least 3 years.

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

Regulator Inspection Report #13577533 - 162 Sherman Ave, Queensbury -
The Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report
states, Not Ok could not locate turned in GRO to gas op. Staff requested a
copy of the GRO on 6/25/14, but the Company could not produce one. The
Company failed to retain the GRO. (Post 4/1/13)

Regulator Inspection Report #13948176 - 2 Angel Lane, Queensbury - The
Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report states,
Not Ok GRO for gas op. Staff requested a copy of the GRO on 6/25/14, but
the Company could not produce one. The Company failed to retain the GRO.
(Post 4/1/13)

16 NYCRR Part 255.726(a) Inactive service lines 1 Violation, 1 Occurrence

One violation of 255.726(a), which states All inactive service lines, including stubs,
must be inspected, leakage surveyed and maintained according to the applicable
provisions of this Part. Inactive steel service lines not under cathodic protection,
including stubs, may remain under the conditions established by subdivision

-6-
255.727(d) for a period of not more than six years subject to the following conditions.
During the third year of inactivity, the operator must conduct a survey for potential
future use and, if there is no definite plan for future use, disconnect the service at the
main or in compliance with subdivision 255.726(d), purge the service and seal the
open end.

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

18 Mccrea, Fort Edward (meter #13298657) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity. Last
Final Read Date was 8/13/09. (Post 4/1/13)

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

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

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

Regulator Inspection Report #210294 - 19 J ackson Ave, South Glens Falls -
Records indicate No for Screening/Piping in the Service Regulator and
Vent inspection box. The Company failed to conduct and/or document a
vent inspection. (Post 4/1/13)

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

One violation of 255.807(b), which states, The record shall contain information as to
the nature of the repair and follow-up results.

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

GRO #181608 - 46 William St, Glens Falls - Repairs were made on 7/28/13.
The Company failed to document the nature of the repair on the GRO. (Post
4/1/13)

16 NYCRR 261.63(a)(1) - Warning Tag: Action and Follow-up - 1 Violation, 3
Occurrences

One violation of 261.63(a)(1), which states, When a Class A condition is discovered,
the operator shall lock off the gas supply at the meter, unless the affected piping or gas

-7-
fired appliance can be effectively isolated and secured from the rest of the system, and
issue a Warning Tag. If the operator is not advised by the customer within 10 calendar
days that the condition has been corrected and service is ready to be reinstituted, the
operator shall contact the customer no later than the end of the first business day after
the 10-day period to determine the status of service.

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

MWork Order #13299920 - 5 Bonner Dr, Queensbury - Records indicate that
a Class A Warning Tag was issued on 8/5/13. The customer did not advise
the Company that the condition was corrected within 10 calendar days and the
Company failed to contact the customer by the end of the first business day
after the 10-day period. (Post 4/1/13)

MWork Order #14088980 - 6 Pearl St, Apt 3, Hudson Falls - Records
indicate that two Class A Warning Tags were issued on 12/21/13. The
customer did not advise the Company that the condition was corrected within
10 calendar days and the Company failed to contact the customer by the end
of the first business day after the 10-day period. (Post 4/1/13)

MWork Order #14004069 - 17 Baker Ave, South Glens Falls - Records
indicate that a Class A Warning Tag was issued on 11/29/13. The customer
did not advise the Company that the condition was corrected within 10
calendar days and the Company failed to contact the customer by the end of
the first business day after the 10-day period. (Post 4/1/13)

16 NYCRR 261.63(f) - Warning Tag: Action and Follow-up - 1 Violation, 3
Occurrences

One violation of 261.63(f), which states, In the case of Class A or B conditions in
apartment buildings, the operator shall post a notice in a conspicuous place at or within
the dwelling stating that a Warning Tag has been issued and including a description of
the condition.

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

MWork Order #12262795 - 105 Bay St, Glens Falls - A Class A Warning
Tag was issued on 1/16/13. The record indicates that notice was posted at the
leak. The Company failed to post notice in a conspicuous place.

MWork Order #13128619 - 453 Glen St, Apt 5, Glens Falls - A Class A
Warning Tag was issued on 7/12/13. The record indicates that notice was
posted with the tenant. The Company failed to post notice in a conspicuous
place. (Post 4/1/13)


-8-
MWork Order #14024991 - 22 Pine St, Apt A, Hudson Falls - A Class B
Warning Tag was issued on 12/4/13. The record indicates that notice was
posted at the hot water heater. The Company failed to post notice in a
conspicuous place. (Post 4/1/13)


Gloversville

Record Audits
Five violations of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were
noted.

16 NYCRR Part 255.17(a) - Preservation of records - 1 Violation, 7 Occurrences

One violation of 255.17(a), which states, Notwithstanding the requirements of Part
293 or Part 733 of this Title, the minimum period of retention of records required by
this Part shall be at least 3 years.

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

GRO #28598 - Clizbe Ave, Amsterdam - The Company failed to retain the
leak history record, as of 6/26/14. (Perm Filed on 1/23/13. No GRO, leak
history card or sketch). (Post 4/1/13)

GRO #79806 - 73 Barclay Rd, Canajoharie - The Company failed to retain
the leak history record, as of 6/26/14. (Perm Filed on 1/18/13. No leak
history card or sketch). (Post 4/1/13)

GRO #163922 - 519 N. Perry St, J ohnstown - The Company failed to retain
the leak history record, as of 6/26/14. (Perm Filed on 6/24/13. No sketch).
(Post 4/1/13)

GRO #163935 - 75 Newman St, Gloversville - The Company failed to retain
the leak history record, as of 6/26/14. (Perm Filed on 1/28/13. No GRO,
leak history card or sketch). (Post 4/1/13)

GRO #121098 - 180 Fifth Ave, Gloversville - The Company failed to retain
the leak history record, as of 6/26/14. (Perm Filed on 5/14/13. No GRO,
leak history card or sketch). (Post 4/1/13)

GRO #182761 - 78 Wesleyan Ave, Amsterdam - The Company failed to
retain the leak history record, as of 6/26/14. (Perm Filed on 2/6/13. No
GRO, leak history card or sketch). (Post 4/1/13)


-9-
GRO #14619 - Auto Palace V-347, J ohnstown - The Company failed to retain
the leak history record, as of 6/26/14. (Perm Filed on 5/14/13. No GRO,
leak history card or sketch). (Post 4/1/13)

16 NYCRR 255.726(a) - Inactive service lines - 1 Violation, 8 Occurrences

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

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

172 Forbes St, Amsterdam (meter #0C804427) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 3/10/10. (Post 4/1/13)

40 Union St, Amsterdam (meter number #0Y156597) - The Company failed
to conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 9/28/09. (Post 4/1/13)

20 Academy, Amsterdam (meter #T4815606) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 6/19/09. (Post 4/1/13)

11 Willow, Amsterdam (meter #00816584) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 5/13/09. (Post 4/1/13)

31 Storrie St, Amsterdam (meter #0Z290133) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 4/14/09. (Post 4/1/13)

8 Carman Ct, Palentine Bridge (meter #0K901610) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 4/23/09. (Post 4/1/13)

296 N. Main, Gloversville (meter #0L315397) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 12/2/09. (Post 4/1/13)


-10-
3 Wells St, Gloversville (meter #0K202553) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 8/26/09. (Post 4/1/13)

16 NYCRR 255.741(d) - Pressure limiting and regulating stations: Telemetering or
recording gauges - 1 Violation, 3 Occurrences

One violation of 255.741(d), which states, (a) Each distribution system supplied by
more than one district pressure regulating station must be equipped with telemetering or
recording pressure gauges to indicate the gas pressure in the district (d) The accuracy
of each recording pressure gauge provided and maintained by each operator at the
locations required herein shall be tested at intervals not exceeding 15 months, but at least
once each calendar year. The results of the tests shall be recorded.

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

East State EOL (End of Line) Pressure Recording Gauge - The Company tested
the recording gauge on 8/13/12 and did not test it again until 11/27/13. The
Company failed to test at intervals not exceeding 15 months. (Post 4/1/13)

Lafayette EOL (End of Line) Pressure Recording Gauge - The Company tested
the recording gauge on 7/16/12 and did not test it again until 11/26/13. The
Company failed to test at intervals not exceeding 15 months. (Post 4/1/13)

Phelps EOL (End of Line) Pressure Recording Gauge - The Company tested the
recording gauge on 8/13/12 and did not test it again until 11/27/13. The
Company failed to test at intervals not exceeding 15 months. (Post 4/1/13)

16 NYCRR 255.744(e) - Service Regulators and Vents: Inspection - 1 Violation, 2
Occurrences

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

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

Regulator Inspection Report #13086653 - 22 River St, Fl 3, Fort Plain -
Records from 6/30/13 indicate No for the Screening/Piping in the
Service Regulator and Vent inspection box. The Company failed to conduct
and/or document the service regulator associated vent inspection. (Post
4/1/13)


-11-
Regulator Inspection Report #14080411 - 281 Market St, Amsterdam -
Records from 12/18/13 indicate No for the Screening/Piping in the
Service Regulator and Vent inspection box. The Company failed to conduct
and/or document the service regulator associated vent inspection. (Post
4/1/13)

16 NYCRR 255.748(c) - Valve maintenance: Service line valves - 1 Violation, 4
Occurrences

One violation of 255.748(c), which states, (a) Except as provided in subdivision
255.748(b), buried high pressure service line valves or exposed exterior high pressure
service line valves shall be inspected in conjunction with the service regulator
inspection required under section 255.744. (c) Each buried service line valve
inspection shall determine accessibility, key alignment and tests for external leakage.
Each exposed exterior service line valve shall be inspected for accessibility and
external leakage.

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

Regulator Inspection Report #242935 - 208 Well St, J ohnstown - The Curb
Valve/OS Riser, Key Fit, portion of the 2013 Regulator Inspection Report
from 9/4/13 states, Not Ok filled with dirt, could not see valve. The
Company failed to verify accessibility and key alignment. (Post 4/1/13)

Regulator Inspection Report #245193 - 465 Guy Park Ave, Amsterdam - The
Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report from
9/19/13 states, Not Ok could not locate. The Company failed to verify
accessibility, key alignment and leakage. (Post 4/1/13)

Regulator Inspection Report #13361726 - 444 Guy Park Ave, Amsterdam -
The Curb Valve/OS Riser portion of the 2013 Regulator Inspection Report
from 8/15/13 states, Not Ok cant find. The Company failed to verify
accessibility, key alignment and leakage. (Post 4/1/13)

Regulator Inspection Report #13934028 - 11 4
th
Ave, Amsterdam - The Curb
Valve/OS Riser portion of the 2013 Regulator Inspection Report from
11/15/13 states, Not Ok. The Company failed to verify accessibility and
key alignment. (Post 4/1/13)

16 NYCRR 261.63(a)(1) - Warning Tag: Action and Follow-up - 1 Violation, 5
Occurrences

One violation of 261.63(a)(1), which states, When a Class A condition is discovered,
the operator shall lock off the gas supply at the meter, unless the affected piping or gas
fired appliance can be effectively isolated and secured from the rest of the system, and
issue a Warning Tag. If the operator is not advised by the customer within 10 calendar

-12-
days that the condition has been corrected and service is ready to be reinstituted, the
operator shall contact the customer no later than the end of the first business day after
the 10-day period to determine the status of service.

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

MWork Order #233701 - 177 Spring St, Gloversville - Records indicate that a
Class A Warning Tag was issued on 6/20/13. The customer did not advise the
Company that the condition was corrected within 10 calendar days and the
Company failed to contact the customer by the end of the first business day
after the 10-day period. (Post 4/1/13)

MWork Order #240519 - 125 S. Main St, Gloversville - Records indicate that
a Class A Warning Tag was issued on 8/17/13. The customer did not advise
the Company that the condition was corrected within 10 calendar days and the
Company failed to contact the customer by the end of the first business day
after the 10-day period. (Post 4/1/13)

MWork Order #14103032 - 70 3
rd
St, Gloversville - Records indicate that a
Class A Warning Tag was issued on 12/26/13. The customer did not advise
the Company that the condition was corrected within 10 calendar days and the
Company failed to contact the customer by the end of the first business day
after the 10-day period. (Post 4/1/13)

MWork Order #14096669 - 102 Prospect St, J ohnstown - Records indicate
that a Class A Warning Tag was issued on 12/23/13. The customer did not
advise the Company that the condition was corrected within 10 calendar days
and the Company failed to contact the customer by the end of the first
business day after the 10-day period. (Post 4/1/13)

MWork Order #13496050 - 40 Mcclellan Ave, Amsterdam - Records indicate
that a Class A Warning Tag was issued on 9/5/13. The customer did not
advise the Company that the condition was corrected within 10 calendar days
and the Company failed to contact the customer by the end of the first
business day after the 10-day period. (Post 4/1/13)

16 NYCRR 261.63(f) - Warning Tag: Action and Follow-up - 1 Violation, 1
Occurrence

One violation of 261.63(f), which states, In the case of Class A or B conditions in
apartment buildings, the operator shall post a notice in a conspicuous place at or within
the dwelling stating that a Warning Tag has been issued and including a description of
the condition.

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


-13-
MWork Order #12438809 - 144 S Main St, Gloversville - A Class A Warning
Tag was issued on 2/25/13. The record indicates that no notice was posted.
The Company failed to post notice in a conspicuous place.


Hudson

Record Audits
One violation of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were
noted.

16 NYCRR 255.744(e) - Service Regulators and Vents: Inspection - 1 Violation, 4
Occurrences

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

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

Regulator Inspection Report #12287890 - 816 Warren St, Hudson - Records
from 1/25/13 indicate No for Screening/Piping in the Service Regulator
and Vent inspection box. The Company failed to conduct and/or document a
vent inspection. (Post 4/1/13)

Regulator Inspection Report #12343222 - 345 Union St, Hudson - Records
from 2/28/13 indicate No for Screening/Piping in the Service Regulator
and Vent inspection box. The Company failed to conduct and/or document a
vent inspection. (Post 4/1/13)

Regulator Inspection Report #12447091 - 555 State St, Hudson - Records
from 3/4/13 indicate No for Screening/Piping in the Service Regulator
and Vent inspection box. The Company failed to conduct and/or document a
vent inspection. (Post 4/1/13)

Regulator Inspection Report #12627582 - 36 N 3
rd
St, Hudson - Records from
4/3/13 indicate No for Screening/Piping in the Service Regulator and
Vent inspection box. The Company failed to conduct and/or document a
vent inspection. (Post 4/1/13)

16 NYCRR 261.63(a)(1) - Warning Tag: Action and Follow-up - 1 Violation, 3
Occurrences

-14-

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

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

MWork Order #12205880 - 128 N 2
nd
St, Hudson - Records indicate that a
Class A Warning Tag was issued on 1/3/13. The customer did not advise the
Company that the condition was corrected within 10 calendar days and the
Company failed to contact the customer by the end of the first business day
after the 10-day period.

MWork Order #13606410 - 63 N 5
th
St Fl 1, Hudson - Records indicate that a
Class A Warning Tag was issued on 9/23/13. The customer did not advise the
Company that the condition was corrected within 10 calendar days and the
Company failed to contact the customer by the end of the first business day
after the 10-day period. (Post 4/1/13)

MWork Order #13693432 - 42 Parkwood Blvd Fl 1, Hudson - Records
indicate that a Class A Warning Tag was issued on 10/3/13. The customer did
not advise the Company that the condition was corrected within 10 calendar
days and the Company failed to contact the customer by the end of the first
business day after the 10-day period. (Post 4/1/13)


Saratoga

Record Audits
Two violations of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were
noted.

16 NYCRR 255.17(a) - Preservation of records - 1 Violation, 3 Occurrences

One violation of 255.17(a), which states, Notwithstanding the requirements of Part
293 or Part 733 of this Title, the minimum period of retention of records required by
this Part shall be at least 3 years.

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

GRO #157854 - 390/392 Broadway, Saratoga - Public building valve
inspection records indicate that a GRO was written on 4/11/13. Staff

-15-
requested a copy of the GRO, but the Company could not produce one, as of
6/25/14. The Company failed to retain the GRO. (Post 4/1/13)

GRO #157863 - 390/392 Broadway, Saratoga - Public building valve
inspection records indicate that a GRO was written on 2/24/12. Staff
requested a copy of the GRO, but the Company could not produce one, as of
6/25/14. The Company failed to retain the GRO. (Post 4/1/13)

GRO #157848 - 358 Broadway, Saratoga - Public building valve inspection
records indicate that a GRO was written on 3/4/13. Staff requested a copy of
the GRO, but the Company could not produce one, as of 6/25/14. The
Company failed to retain the GRO. Note: Its unknown why GRO #157848
was documented for this address. GRO #157848 was actually written for 22
Whitney Place. (Post 4/1/13)

16 NYCRR 255.744(e) - Service Regulators and Vents: Inspection - 1 Violation, 8
Occurrences

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

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

Regulator Inspection Report #12783064 - 139 Nelson Ave, Saratoga -
Records from 5/8/13 indicate No for the Screening/Piping in the Service
Regulator and Vent inspection box. The Company failed to conduct and/or
document the service regulator associated vent inspection. (Post 4/1/13)

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

Regulator Inspection Report #12535040 - 1 Stonebreak Rd, Malta - Records
from 3/15/13 indicate No for the Screening/Piping in the Service
Regulator and Vent inspection box. The Company failed to conduct and/or
document the service regulator associated vent inspection. (Post 4/1/13)

Regulator Inspection Report #12535028 - 16 Stonebreak Rd, Malta - Records
from 3/15/13 indicate No for the Screening/Piping in the Service
Regulator and Vent inspection box. The Company failed to conduct and/or
document the service regulator associated vent inspection. (Post 4/1/13)

-16-

Regulator Inspection Report #213577 - 110 Brookline Rd, Ballston Spa -
Records from 1/29/13 indicate No for the Screening/Piping in the
Service Regulator and Vent inspection box. The Company failed to conduct
and/or document the service regulator associated vent inspection. (Post
4/1/13)

Regulator Inspection Report #12502767 - 11 Anyhow Ln, Gansevoort -
Records from 3/8/13 indicate No for the Screening/Piping in the Service
Regulator and Vent inspection box. The Company failed to conduct and/or
document the service regulator associated vent inspection. (Post 4/1/13)

Regulator Inspection Report #12279445 - 738 Route 9, Gansevoort - Records
from 1/21/13 indicate No for the Screening/Piping in the Service
Regulator and Vent inspection box. The Company failed to conduct and/or
document the service regulator associated vent inspection. (Post 4/1/13)

Regulator Inspection Report #13238482 - 60 Lake Ave, Saratoga - Records
from 7/26/13 indicate No for the Screening/Piping in the Service
Regulator and Vent inspection box. The Company failed to conduct and/or
document the service regulator associated vent inspection. (Post 4/1/13)

16 NYCRR 261.63(a)(1) - Warning Tag: Action and Follow-up - 1 Violation, 3
Occurrences

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

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

MWork Order #12414727 - 1234 Trouble St, Saratoga - Records indicate that
two Class A Warning Tags were issued on 2/19/13. The customer did not
advise the Company that the condition was corrected within 10 calendar days
and the Company failed to contact the customer by the end of the first
business day after the 10-day period.

MWork Order #14078051 - 10 Reservation Ave, Saratoga - Records indicate
that a Class A Warning Tag was issued on 12/18/13. The customer did not
advise the Company that the condition was corrected within 10 calendar days
and the Company failed to contact the customer by the end of the first
business day after the 10-day period. (Post 4/1/13)


-17-
MWork Order #14089742 - 527 Leahy Ln, Ballston Spa - Records indicate
that a Class A Warning Tag was issued on 12/21/13. The customer did not
advise the Company that the condition was corrected within 10 calendar days
and the Company failed to contact the customer by the end of the first
business day after the 10-day period. (Post 4/1/13)


Schenectady

Record Audits
Two violations of 16 NYCRR Part 255 and four violations of 16 NYCRR Part 261 were
noted.

16 NYCRR 255.17(a) - Preservation of records - 1 Violation, 6 Occurrences

One violation of 255.17(a), which states, Notwithstanding the requirements of Part
293 or Part 733 of this Title, the minimum period of retention of records required by
this Part shall be at least 3 years.

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

CGI #0024-050966 - Staff requested documentation showing when this CGI
was calibrated in 2013. The Company could not provide any records, as of
6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI #0128-051879 - Staff requested documentation showing when this CGI
was calibrated in 2013. The Company could not provide any records, as of
6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI #0128-051878 - Staff requested documentation showing when this CGI
was calibrated in 2013. The Company could not provide any records, as of
6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI #9328-002256 - Staff requested documentation showing when this CGI
was calibrated in 2013. The Company could not provide any records, as of
6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI #9430-003550 - Staff requested documentation showing when this CGI
was calibrated in 2013. The Company could not provide any records, as of
6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI #9450-004262 - Staff requested documentation showing when this CGI
was calibrated in 2013. The Company could not provide any records, as of
6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

16 NYCRR 255.726(a) - Inactive service lines - 1 Violation, 23 Occurrences


-18-
One violation of 255.726(a), which states, All inactive service lines, including stubs,
must be inspected, leakage surveyed and maintained according to the applicable
provisions of this Part. Inactive steel service lines not under cathodic protection,
including stubs, may remain under the conditions established by subdivision
255.727(d) for a period of not more than six years subject to the following conditions.
During the third year of inactivity, the operator must conduct a survey for potential
future use and, if there is no definite plan for future use, disconnect the service at the
main or in compliance with subdivision 255.726(d), purge the service and seal the
open end.

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

3032 Cox Ave, Schenectady (meter #02705715) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 9/8/09. (Post 4/1/13)

2617 Hamburg St, Schenectady (meter #00816595) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 3/10/10. (Post 4/1/13)

2334 Campbell Ave, Schenectady (meter #08678058) - The Company failed
to conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 10/15/09. (Post 4/1/13)

1009 Hegeman St, Schenectady (meter #0Z109982) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 6/3/09. (Post 4/1/13)

19 Close St, Schenectady (meter #0E744688) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 5/20/09. (Post 4/1/13)

294 Altamont Ave, Schenectady (meter #01653998) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 7/22/09. (Post 4/1/13)

933 Congress St, Schenectady (meter #03333836) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 11/6/09. (Post 4/1/13)

0 Duanesburg Rd, Schenectady (meter #T4861038) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 9/18/09. (Post 4/1/13)

392 Shannon St, Schenectady (meter #02264178) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 2/17/10. (Post 4/1/13)

-19-

62 Wylie St, Schenectady (meter #0K003978) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 3/11/10. (Post 4/1/13)

1128 7
th
Ave, Schenectady (meter #0R683386) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 10/21/09. (Post 4/1/13)

86 Western Pkwy, Schenectady (meter #0V489444) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 6/24/09. (Post 4/1/13)

1111 McClyman St, Schenectady (meter #0W658698) - The Company failed
to conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 8/11/09. (Post 4/1/13)

43 McClellan St, Schenectady (meter #0H685646) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 2/3/10. (Post 4/1/13)

550 Summit Ave, Schenectady (meter #00972415) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 11/16/09. (Post 4/1/13)

41 McClellan St, Schenectady (meter #03219003) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 12/18/09. (Post 4/1/13)

175 J ay St, Schenectady (meter #0F601871) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 2/16/10. (Post 4/1/13)

3040 Wellington Ave, Schenectady (meter #0A320403) - The Company
failed to conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 12/11/09. (Post 4/1/13)

943 Maple Ave, Schenectady (meter #0Y391086) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 11/9/09. (Post 4/1/13)

1228 8
th
Ave, Schenectady (meter #0J 606385) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 9/5/09. (Post 4/1/13)

206 5
th
St, Schenectady (meter #0V521794) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 7/2/09. (Post 4/1/13)

-20-

1040 Webster St, Schenectady (meter #0B406349) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 4/27/09. (Post 4/1/13)

219 Linden St, Schenectady (meter #0R059312) - The Company failed to
conduct and/or document a future use survey during the third year of
inactivity, as of 6/26/14. Last Final Read Date was 4/20/09. (Post 4/1/13)

16 NYCRR 261.63(a)(1) - Warning Tag: Action and Follow-up - 1 Violation, 6
Occurrences

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

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

MWork Order #12605158 - 61 Ingersoll Ave Fl 3, Schenectady - Records
indicate that a Class A Warning Tag was issued on 4/3/13. The customer did
not advise the Company that the condition was corrected within 10 calendar
days and the Company failed to contact the customer by the end of the first
business day after the 10-day period. (Post 4/1/13)

MWork Order #13713230 - 941 Crane St, Schenectady - Records indicate
that a Class A Warning Tag was issued on 10/7/13. The customer did not
advise the Company that the condition was corrected within 10 calendar days
and the Company failed to contact the customer by the end of the first
business day after the 10-day period. (Post 4/1/13)

MWork Order #14116391 - 1039 Webster St Fl 2, Schenectady - Records
indicate that a Class A Warning Tag was issued on 12/31/13. The customer
did not advise the Company that the condition was corrected within 10
calendar days and the Company failed to contact the customer by the end of
the first business day after the 10-day period. (Post 4/1/13)

MWork Order #13987276 - 990 OBrien Ave, Schenectady - Records
indicate that a Class A Warning Tag was issued on 11/25/13. The customer
did not advise the Company that the condition was corrected within 10
calendar days and the Company failed to contact the customer by the end of
the first business day after the 10-day period. (Post 4/1/13)


-21-
MWork Order #13775931 - 513 Seneca St Fl 1, Schenectady - Records
indicate that a Class A Warning Tag was issued on 10/17/13. The customer
did not advise the Company that the condition was corrected within 10
calendar days and the Company failed to contact the customer by the end of
the first business day after the 10-day period. (Post 4/1/13)

MWork Order #13516247 - 39 Beechwood Dr, Clifton Park - Records
indicate that a Class A Warning Tag was issued on 9/9/13. The customer did
not advise the Company that the condition was corrected within 10 calendar
days and the Company failed to contact the customer by the end of the first
business day after the 10-day period. (Post 4/1/13)

16 NYCRR 261.63(d)(1) - Warning Tag: Action and Follow-up - 1 Violation, 1
Occurrence

One violation of 261.63(d)(1), which states, (d) Whenever a Warning Tag is issued,
regardless of the class of the condition, the operator shall attempt to notify the customer
and obtain a signature acknowledging receipt of such notice. (1) In apartment
buildings, the operator shall notify the property owner or agent (such as superintendent,
custodian or maintenance worker) of the condition and state the corrections that are
required.

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

MWork Order #14062742 - 2 Fuller St Apt 12, Schenectady - Records
indicate that a Class B Warning Tag was issued on 12/14/13. The tag clearly
states, Apartment Building Yes, and Landlord/Agent Notified No. The
Company failed to notify the landlord/agent of this Warning Tag. (Post
4/1/13)

16 NYCRR 261.63(d)(2) - Warning Tag: Action and Follow-up - 1 Violation, 1
Occurrence

One violation of 261.63(d)(2), which states, (d) Whenever a Warning Tag is issued,
regardless of the class of the condition, the operator shall attempt to notify the customer
and obtain a signature acknowledging receipt of such notice. (2) If the operator can
not obtain a signature, an additional notice shall be provided to the customer stating that
a notice of hazardous condition tag has been issued and the corrective actions that are
required.

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

MWork Order #13514002 - 1233 6
th
Ave, Schenectady - Records indicate
that a Class C Warning Tag was issued on 9/9/13. No Signature was obtained
and there are no records of any notice being provided to the customer. The
Company failed to notify the customer of this Warning Tag. (Post 4/1/13)

-22-

16 NYCRR 261.63(f) - Warning Tag: Action and Follow-up - 1 Violation, 1
Occurrence

One violation of 261.63(f), which states, (f) In the case of Class A or B conditions in
apartment buildings, the operator shall post a notice in a conspicuous place at or
within the dwelling stating that a Warning Tag has been issued and including a
description of the condition.

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

MWork Order #14062742 - 2 Fuller St Apt 12, Schenectady - Records
indicate that a Class B Warning Tag was issued on 12/14/13. The tag clearly
states, Apartment Building Yes, and Notice Posted No. The Company
failed to post a notice at the apartment building for this Warning Tag. (Post
4/1/13)


Syracuse

Record Audits
Three violations of 16 NYCRR Part 255 and one violation of 16 NYCRR Part 261 were
noted.

16 NYCRR Part 255.744(a) Service regulators and vents: Inspection - 1 Violation,
20 Occurrences

One violation of 255.744(a) which states that, Each operator shall inspect each
service regulator at the time which a service which has been inactive for a period of
two years or more is reactivated to service.

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

No service regulator inspection record could be located for the service
regulator at 103 East Way in Camillus that was reactivated on 12/3/13 after
being inactive since 10/5/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 107 Center St. in Solvay that was reactivated on 12/5/13 after
being inactive since 12/14/07. (Post 4/1/13)

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


-23-
No service regulator inspection record could be located for the service
regulator at 110 Elk St. in Syracuse that was reactivated on 3/16/13 after being
inactive since 2/27/04.

No service regulator inspection record could be located for the service
regulator at 111 Pond Ln. in Syracuse that was reactivated on 12/5/13 after
being inactive since 8/17/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 116 Churchill Ave. in Syracuse that was reactivated on 10/11/13
after being inactive since 10/6/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 144 Greenland Dr. in Syracuse that was reactivated on 8/22/13
after being inactive since 5/10/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 159 Meredith Ave. in Nedrow that was reactivated on 7/18/13
after being inactive since 5/4/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 1912 Teall Ave. in Syracuse that was reactivated on 12/16/13
after being inactive since 9/29/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 198 Longview Ave. in Syracuse that was reactivated on 10/16/13
after being inactive since 3/22/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 200 Mc Kenney Ave. in Syracuse that was reactivated on 7/11/13
after being inactive since 8/12/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 210 Morton St. in Syracuse that was reactivated on 12/9/13 after
being inactive since 10/3/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 212 Dorwin Ave. in Syracuse that was reactivated on 6/13/13
after being inactive since 3/31/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 2798 Cold Springs Rd. in Baldwinsville that was reactivated on
9/17/13 after being inactive since 4/6/11. (Post 4/1/13)


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No service regulator inspection record could be located for the service
regulator at 312 Hall Ave. in Solvay that was reactivated on 12/27/13 after
being inactive since 11/3/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 313 Bailey Rd. in North Syracuse that was reactivated on
12/18/13 after being inactive since 7/11/07. (Post 4/1/13)

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

No service regulator inspection record could be located for the service
regulator at 5529 Chateau Ln. in Clay that was reactivated on 6/10/13 after
being inactive since 5/5/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 612 Wright Ave. in Syracuse that was reactivated on 10/3/13 after
being inactive since 7/2/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 7 Oriole Path in Liverpool that was reactivated on 12/20/13 after
being inactive since 8/8/11. (Post 4/1/13)

16 NYCRR Part 255.748(a) - Valve maintenance: Service line valves - 1 Violation,
20 Occurrences

One violation of 255.748(a), which states that except as provided in subdivision
255.748(b), buried high pressure service line valves or exposed exterior high pressure
service line valves shall be inspected in conjunction with the service regulator
inspection required under section 255.744.

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

No service valve inspection record could be located for the service valve at
103 East Way in Camillus that was reactivated on 12/3/13 after being inactive
since 10/5/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
107 Center St. in Solvay that was reactivated on 12/5/13 after being inactive
since 12/14/07. (Post 4/1/13)

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


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

No service valve inspection record could be located for the service valve at
111 Pond Ln. in Syracuse that was reactivated on 12/5/13 after being inactive
since 8/17/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
116 Churchill Ave. in Syracuse that was reactivated on 10/11/13 after being
inactive since 10/6/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
144 Greenland Dr. in Syracuse that was reactivated on 8/22/13 after being
inactive since 5/10/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
159 Meredith Ave. in Nedrow that was reactivated on 7/18/13 after being
inactive since 5/4/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
1912 Teall Ave. in Syracuse that was reactivated on 12/16/13 after being
inactive since 9/29/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
198 Longview Ave. in Syracuse that was reactivated on 10/16/13 after being
inactive since 3/22/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
200 Mc Kenney Ave. in Syracuse that was reactivated on 7/11/13 after being
inactive since 8/12/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
210 Morton St. in Syracuse that was reactivated on 12/9/13 after being
inactive since 10/3/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
212 Dorwin Ave. in Syracuse that was reactivated on 6/13/13 after being
inactive since 3/31/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
2798 Cold Springs Rd. in Baldwinsville that was reactivated on 9/17/13 after
being inactive since 4/6/11. (Post 4/1/13)


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No service valve inspection record could be located for the service valve at
312 Hall Ave. in Solvay that was reactivated on 12/27/13 after being inactive
since 11/3/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
313 Bailey Rd. in North Syracuse that was reactivated on 12/18/13 after being
inactive since 7/11/07. (Post 4/1/13)

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

No service valve inspection record could be located for the service valve at
5529 Chateau Ln. in Clay that was reactivated on 6/10/13 after being inactive
since 5/5/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
612 Wright Ave. in Syracuse that was reactivated on 10/3/13 after being
inactive since 7/2/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 7
Oriole Path in Liverpool that was reactivated on 12/20/13 after being inactive
since 8/8/11. (Post 4/1/13)

16 NYCRR Part 255.748(b) Valve maintenance: Service line valves - 1 Violation, 3
Occurrences

One violation of 255.748(b) which states that, buried service line valves used for
compliance with section 255.365(b)(2) of this Part, shall be inspected at intervals not
exceeding 15 months, but at least once each calendar year, for accessibility, key
alignment and external leakage.

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

The building designated as a public building requiring an annual inspection
located at 318 E. Fayette Street, Syracuse was not inspected as required in
2013. (Post 4/1/13)

The building designated as a public building requiring an annual inspection
located at 1228 Teall Street Syracuse failed the requirements for annual
inspection by having the 2012 inspection conducted on 2/28/2012 and the
2013 inspection conducted on 6/17/2013 which is a period of 69 weeks. (Post
4/1/13)

The building designated as a public building requiring an annual inspection
located at 65 Albany Street, Cazenovia failed the requirements for annual

-27-
inspection by having eh 2012 inspection conducted on 3/27/2012 and the 2013
inspection conducted on 7/15/2013 which is a period of 68 weeks. (Post
4/1/13)

16 NYCRR Part 261.63(a)(1) - Warning tag: Action and follow-up
1 Violation, 2 Occurrences

One violation of 261.63(a)(1), which states that if the operator is not advised by the
customer within 10 calendar days that the condition has been corrected and service is
ready to be reinstituted, the operator shall contact the customer no later than the end
of the first business day after the 10-day period to determine the status of service.

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

A Class A warning tag was issued on1/14/2013 and the follow-up on
2/5/2013; exceeding the requirement by 20 days.

A Class A warning tag was issued on 7/24/2013 at 6076 Bay-Hill Circle,
J amesville NY no follow-up contact effort could be documented. (Post
4/1/13)


Utica

Record Audits
Five violations of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261 were
noted.

16 NYCRR 255.17(a) Preservation of records - 1 Violation, 4 Occurrences

One violation of 255.17(a), which states Notwithstanding the requirements of Part
293 or Part 733 of this Title, the minimum period of retention of records required by
this Part shall be at least 3 years.

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

Mwork order number 12656299: On the service regulator inspection form for
2011 Genesee Street in Utica the Curb Valve/OS Riser portion of the 2013
Regulator Inspection Report states Not Ok curb box full of stones GRO
180152. Staff requested a copy of the GRO, but the Company could not
produce one. The Company failed to retain the GRO. (Post 4/1/13)

Mwork order number 12722963: On the service regulator inspection form for
25 Tindall Manor in Clinton the Curb Valve/OS Riser portion of the 2013
Regulator Inspection Report states Not Ok curb box under driveway GRO

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180137. Staff requested a copy of the GRO, but the Company could not
produce one. The Company failed to retain the GRO. (Post 4/1/13)

Mwork order number 12723653: On the service regulator inspection form for
419 Richmond Road in Utica the Curb Valve/OS Riser portion of the 2013
Regulator Inspection Report states Not Ok full of dirt,, wrote up GRO.
Staff requested a copy of the GRO, but the Company could not produce one.
The Company failed to retain the GRO. (Post 4/1/13)

Mwork order number 12723517: On the service regulator inspection form for
9 Edna Terrace in New Hartford the Curb Valve/OS Riser portion of the 2013
Regulator Inspection Report states Not Ok cb under driveway GRO 180144.
Staff requested a copy of the GRO, but the Company could not produce one.
The Company failed to retain the GRO. (Post 4/1/13)

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

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

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

The inactive service located at 4360 Acme Road in the village of Ilion became
inactive on 2/19/10. No documentation was provided showing that a three
year future use survey was conducted for this inactive service. (Post 4/1/13)

16 NYCRR Part 255.744(a) - Service regulators and vents - 1 Violation, 15
Occurrences

One violation of 255.744(a), which states that each operator shall inspect each service
regulator when it is installed, at the time of periodic meter change, and at the time a
service which has been inactive for a period of two years or more is reactivated to
service.

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

No service regulator inspection record could be located for the service
regulator at 108 Onondaga Avenue in Canastota that was reactivated on
8/23/13 after being inactive since 7/29/11. (Post 4/1/13)

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No service regulator inspection record could be located for the service
regulator at 112 Bruno Road in Canastota that was reactivated on 11/22/13
after being inactive since 10/5/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 123 Seneca Street in Utica that was reactivated on 10/29/13 after
being inactive since 3/24/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 1305 Maple Street in Utica that was reactivated on 10/2/13 after
being inactive since 9/12/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 144 Bono Boulevard in Frankfort that was reactivated on 10/28/13
after being inactive since 10/24/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 203 Roberts Street in Canastota that was reactivated on 11/7/13
after being inactive since 7/5/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 2043 Genesee Street in Utica that was reactivated on 10/8/13 after
being inactive since 8/15/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 2903 RT 12B in Deansboro that was reactivated on 6/25/13 after
being inactive since 6/9/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 416 Race Street in Chittenango that was reactivated on 9/24/13
after being inactive since 6/27/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 423 West Dominick Street in Rome that was reactivated on
9/19/13 after being inactive since 2/17/09. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 507 Floyd Avenue in Rome that was reactivated on 11/26/13
after being inactive since 5/25/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 5870 Columbus Drive in Marcy that was reactivated on 12/18/13
after being inactive since 4/19/10. (Post 4/1/13)


-30-
No service regulator inspection record could be located for the service
regulator at 613 2
nd
Avenue in Frankfort that was reactivated on 11/25/13 after
being inactive since 7/18/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 75 Bedford Drive in Whitesboro that was reactivated on 11/5/13
after being inactive since 5/12/11. (Post 4/1/13)

No service regulator inspection record could be located for the service
regulator at 9647 River Drive in Marcy that was reactivated on 9/17/13 after
being inactive since 8/25/11. (Post 4/1/13)

16 NYCRR Part 255.748(a) - Valve maintenance: Service line valves - 1 Violation,
15 Occurrences

One violation of 255.748(a), which states that except as provided in subdivision
255.748(b), buried high pressure service line valves or exposed exterior high pressure
service line valves shall be inspected in conjunction with the service regulator
inspection required under section 255.744.

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

No service valve inspection record could be located for the service valve at
108 Onondaga Avenue in Canastota that was reactivated on 8/23/13 after
being inactive since 7/29/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
112 Bruno Road in Canastota that was reactivated on 11/22/13 after being
inactive since 10/5/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
123 Seneca Street in Utica that was reactivated on 10/29/13 after being
inactive since 3/24/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
1305 Maple Street in Utica that was reactivated on 10/2/13 after being
inactive since 9/12/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
144 Bono Boulevard in Frankfort that was reactivated on 10/28/13 after being
inactive since 10/24/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
203 Roberts Street in Canastota that was reactivated on 11/7/13 after being
inactive since 7/5/11. (Post 4/1/13)


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No service valve inspection record could be located for the service valve at
2043 Genesee Street in Utica that was reactivated on 10/8/13 after being
inactive since 8/15/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
2903 RT 12B in Deansboro that was reactivated on 6/25/13 after being
inactive since 6/9/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
416 Race Street in Chittenango that was reactivated on 9/24/13 after being
inactive since 6/27/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
423 West Dominick Street in Rome that was reactivated on 9/19/13 after
being inactive since 2/17/09. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
507 Floyd Avenue in Rome that was reactivated on 11/26/13 after being
inactive since 5/25/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
5870 Columbus Drive in Marcy that was reactivated on 12/18/13 after being
inactive since 4/19/10. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
613 2
nd
Avenue in Frankfort that was reactivated on 11/25/13 after being
inactive since 7/18/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at 75
Bedford Drive in Whitesboro that was reactivated on 11/5/13 after being
inactive since 5/12/11. (Post 4/1/13)

No service valve inspection record could be located for the service valve at
9647 River Drive in Marcy that was reactivated on 9/17/13 after being
inactive since 8/25/11. (Post 4/1/13)

16 NYCRR Part 255.825(b) - Logging and analysis of gas emergency reports - 1
Violation, 3 Occurrences

One violation of 16 NYCRR Part 255.825(b), which states that a daily log shall be
kept and maintained on file recording the receipt and handling of each such report and
shall contain the following information:

(1) cross-reference to the related service record number;
(2) location of leak or emergency;
(3) time report first received by operator;

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(4) description or code designation as to type of leak or emergency;
(5) time crew first dispatched to designated location; and
(6) time of arrival of such personnel at location.

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

GRO 195637 (4/6/13) was a type 1 leak located at 1541-1543 St. Vincent
Street in Utica and was not on the Daily Leak Log. (Post 4/1/13)

GRO 216561 (9/18/13) was a type 1 leak located at 18 Faxton Street in Utica
and was not on the Daily Leak Log. (Post 4/1/13)

GRO 172060 (6/20/13) was a type 1 leak located at 1926 Oneida Street in
Utica and was not on the Daily Leak Log. (Post 4/1/13)

16 NYCRR Part 261.63(a)(1) Warning tags: Action and follow-up - 1 Violation, 5
Occurrences

One violation of 261.63(a)(1), which states that when a Class A condition is
discovered, the operator shall lock off the gas supply at the meter, unless the affected
piping or gas fired appliance can be effectively isolated and secured from the rest of
the system, and issue a warning tag.
(1) If the operator is not advised by the customer within 10 calendar days that
the condition has been corrected and service is ready to be reinstituted, the
operator shall contact the customer no later than the end of the first business
day after the 10-day period to determine the status of service.

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

A Class A warning tag (MWork Order Number 13115629) was issued
7/5/2013 at 25 Devendorf Street in Mohawk. The warning tag was issued for
the furnace and water heater being flooded; the appliances were isolated. The
operator did not contact the customer until 7/17/2013 which is the second
business day after the 10-day period. (Post 4/1/13)

A Class A warning tag (MWork Order Number 13101794) was issued
7/2/2013 at 327 Williams Street in Herkimer. The warning tag was issued for
the furnace and water heater being flooded; the appliances were isolated.
There were no records provided that indicated the required 10-day follow-
up by the operator (required by 7/15/2013) occurred. (Post 4/1/13)

A Class A warning tag (MWork Order Number 13105592) was issued
7/2/2013 at 243 Williams Street in Herkimer. The warning tag was issued for
the furnace and water heater being flooded; the meter was locked off. There
were no records provided that indicated the required 10-day follow-up by
the operator (required by 7/15/2013) occurred. (Post 4/1/13)

-33-

A Class A warning tag (MWork Order Number 13165679) was issued
7/13/2013 at 510 Devereaux Street in Oneida. The warning tag was issued for
the furnace being flooded; the appliance was isolated. There were no records
provided that indicated the required 10-day follow-up by the operator
(required by 7/24/2013) occurred. (Post 4/1/13)

A Class A warning tag (MWork Order Number 13102473) was issued
7/2/2013 at 154 Sanford Avenue in Clinton. The warning tag was issued for
the furnace being flooded; the appliance was isolated. There were no records
provided that indicated the required 10-day follow-up by the operator
(required by 7/15/2013) occurred. (Post 4/1/13)

16 NYCRR Part 261.63(d)(1) - Warning tag: Action and follow-up - 1 Violation, 2
Occurrences

One violation of 261.63(d)(1), which states that in apartment buildings, the operator shall
notify the property owner or agent (such as superintendent, custodian or maintenance
worker) of the condition and state the corrections that are required.

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

A Class B warning tag (MWork Order Number 12977348) was issued on
6/10/2013 at 821 Oswego Street (FL 1) in Utica. The warning tag was issued
for a cracked whip hose to range, the appliance was shut off. The warning tag
record from MWork indicates that this address is an apartment build and that
the landlord/agent was not notified. (Post 4/1/13)

A Class B warning tag (MWork Order Number 13086920) was issued on
7/1/2013 at 218 N Caroline Street (FL 1) in Herkimer. The warning tag was
issued for a corroded pilot orifice on the water heater, the appliance was shut
off. The warning tag record from MWork indicates that this address is an
apartment build and that the landlord/agent was not notified. (Post 4/1/13)


Troy

Record Audits
Four violations of 16 NYCRR Part 255 and two violations of 16 NYCRR Part 261 were
noted.

16 NYCRR 255.17(a) - Preservation of records - 1 Violation, 6 Occurrences

One violation of 255.17(a), which states, Notwithstanding the requirements of Part
293 or Part 733 of this Title, the minimum period of retention of records required by
this Part shall be at least 3 years.

-34-

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

CGI #9850-004261 - Staff requested documentation showing when this CGI
was calibrated in 2013. The Company could not provide any records, as of
6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI #9430-003539 - Staff requested documentation showing when this CGI
was calibrated in 2013. The Company could not provide any records, as of
6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI #9429-003522 - Staff requested documentation showing when this CGI
was calibrated in 2013. The Company could not provide any records, as of
6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI #9450-004257 - Staff requested documentation showing when this CGI
was calibrated in 2013. The Company could not provide any records, as of
6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

CGI #9429-003520 - Staff requested documentation showing when this CGI
was calibrated in 2013. The Company could not provide any records, as of
6/26/14. The Company failed to retain these calibration records. (Post 4/1/13)

GRO #134818 - 34 114
th
St, Troy - Staff requested documentation for a leak
repair on the Public Building Valve on 6/25/14. The Company failed to retain
this GRO. (Post 4/1/13)

16 NYCRR 255.726(a) - Inactive service lines - 1 Violation, 5 Occurrences

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

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

559 2
nd
Ave, Troy (meter #14380753) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 5/14/09. (Post 4/1/13)


-35-
450 8
th
Ave, Troy (meter #14380935) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 2/19/10. (Post 4/1/13)

509 2
nd
Ave, Troy (meter #0M161725) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 2/12/10. (Post 4/1/13)

31 State St, Troy (meter #0X652897) - The Company failed to conduct and/or
document a future use survey during the third year of inactivity, as of 6/26/14.
Last Final Read Date was 5/6/09. (Post 4/1/13)

1606 3
rd
Ave, Watervliet (meter #1660548) - The Company failed to conduct
and/or document a future use survey during the third year of inactivity, as of
6/26/14. Last Final Read Date was 10/20/09. (Post 4/1/13)

16 NYCRR 255.744(e) - Service Regulators and Vents: Inspection - 1 Violation, 4
Occurrences

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

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

Regulator Inspection Report #244065 - 263 Bloomingrove Dr, Troy -
Records from 9/1/13 indicate No for Screening/Piping in the Service
Regulator and Vent inspection box. The Company failed to conduct and/or
document a vent inspection. (Post 4/1/13)

Regulator Inspection Report #241917 - 30 Church Hill Rd, Waterford -
Records from 8/27/13 indicate No for Screening/Piping in the Service
Regulator and Vent inspection box. The Company failed to conduct and/or
document a vent inspection. (Post 4/1/13)

Regulator Inspection Report #13981567 - 7 David Dr, Cohoes - Records from
11/16/13 indicate No for Screening/Piping in the Service Regulator and
Vent inspection box. The Company failed to conduct and/or document a
vent inspection. (Post 4/1/13)

Regulator Inspection Report #13787765 - 279 Old-Loudon Rd, Latham -
Records from 10/18/13 indicate No for Screening/Piping in the Service

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Regulator and Vent inspection box. The Company failed to conduct and/or
document a vent inspection. (Post 4/1/13)

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

One violation of 255.807(b) which states, The record shall contain information as to
the nature of the repair and follow-up results.

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

GRO #134844 - 30 Hendrix-Hudson Way, Clifton Park - This leak history
record shows that a repair was made on 3/7/13. The GRO shows no detail of
the repair and there is no other documentation showing that a repair was
performed. The Company failed to document the nature of the repair.

16 NYCRR 261.63(a)(1) - Warning Tag: Action and Follow-up - 1 Violation, 10
Occurrences

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

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

MWork Order #12748619 - 25 Deer-Run Hollow, Clifton Park - Records
indicate that a Class A Warning Tag was issued on 4/29/13. The customer did
not advise the Company that the condition was corrected within 10 calendar
days and the Company failed to contact the customer by the end of the first
business day after the 10-day period. (Post 4/1/13)

MWork Order #12449144 - 29 Roosevelt Blvd, Cohoes - Records indicate
that a Class A Warning Tag was issued on 2/26/13. The customer did not
advise the Company that the condition was corrected within 10 calendar days
and the Company failed to contact the customer by the end of the first
business day after the 10-day period.

MWork Order #12501215 - 33 George St Fl 1, Green Island - Records
indicate that a Class A Warning Tag was issued on 3/13/13. The customer did
not advise the Company that the condition was corrected within 10 calendar
days and the Company failed to contact the customer by the end of the first
business day after the 10-day period.


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MWork Order #12449150 - 1624 6
th
Ave Fl 1, Watervliet - Records indicate
that a Class A Warning Tag was issued on 2/26/13. The customer did not
advise the Company that the condition was corrected within 10 calendar days
and the Company failed to contact the customer by the end of the first
business day after the 10-day period.

MWork Order #13053109 - 64 Moreland Dr, Clifton Park - Records indicate
that a Class A Warning Tag was issued on 6/23/13. The customer did not
advise the Company that the condition was corrected within 10 calendar days
and the Company failed to contact the customer by the end of the first
business day after the 10-day period. (Post 4/1/13)

MWork Order #14062033 - 156 2
nd
St Fl 2, Troy - Records indicate that a
Class A Warning Tag was issued on 12/13/13. The customer did not advise
the Company that the condition was corrected within 10 calendar days and the
Company failed to contact the customer by the end of the first business day
after the 10-day period. (Post 4/1/13)

MWork Order #14096662 - 19 Linden Ave, Troy - Records indicate that a
Class A Warning Tag was issued on 12/23/13. The customer did not advise
the Company that the condition was corrected within 10 calendar days and the
Company failed to contact the customer by the end of the first business day
after the 10-day period. (Post 4/1/13)

MWork Order #13516496 - 13 Elm St, Cohoes - Records indicate that a Class
A Warning Tag was issued on 9/9/13. The customer did not advise the
Company that the condition was corrected within 10 calendar days and the
Company failed to contact the customer by the end of the first business day
after the 10-day period. (Post 4/1/13)

MWork Order #13606263 - 220 Grenadier Ct, Clifton Park - Records indicate
that a Class A Warning Tag was issued on 9/23/13. The customer did not
advise the Company that the condition was corrected within 10 calendar days
and the Company failed to contact the customer by the end of the first
business day after the 10-day period. (Post 4/1/13)

MWork Order #14013388 - 58 Remsen St, Cohoes - Records indicate that a
Class A Warning Tag was issued on 12/2/13. The customer did not advise the
Company that the condition was corrected within 10 calendar days and the
Company failed to contact the customer by the end of the first business day
after the 10-day period. (Post 4/1/13)

16 NYCRR 261.63(f) - Warning Tag: Action and Follow-up - 1 Violation, 1
Occurrence

One violation of 261.63(f), which states, (f) In the case of Class A or B conditions in
apartment buildings, the operator shall post a notice in a conspicuous place at or

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within the dwelling stating that a Warning Tag has been issued and including a
description of the condition.

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

MWork Order #13311614 - 2100 6
th
Ave, Troy - Records indicate that a
Class A Warning Tag was issued on 8/6/13. The tag clearly states, Apartment
Building Yes, Notice Posted Yes, and Location At Appliance. The
Company failed to post notice at the apartment building in a conspicuous
place for this Warning Tag. (Post 4/1/13)


Volney

Record Audits
Four violations of 16 NYCRR Part 255 and three violations of 16 NYCRR Part 261 were
noted.

16 NYCRR 255.17(a) Preservation of records - 1 Violation, 3 Occurrences

One violation of 255.17(a), which states Notwithstanding the requirements of Part
293 or Part 733 of this Title, the minimum period of retention of records required by
this Part shall be at least 3 years.

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

GRO #165747 was issued for a Type 1 Leak on 7/24/13 at 28 Ellen St. in
Oswego. A Gas Repair Order and Leak History Record could not be
produced for Staff review. Therefore, all details pertaining to this leak and
follow-up are not adequately documented and unable to be reviewed. The
Company failed to retain the GRO. (Post 4/1/13)

GRO#165748 was issued for a Type 1 Leak on 8/27/13 at 10 Prospect St. in
Oswego. A Gas Repair Order and Leak History Record could not be
produced for Staff review. Therefore, all details pertaining to this leak and
follow-up are not adequately documented and unable to be reviewed. The
Company failed to retain the GRO. (Post 4/1/13)

GRO#184659 was issued for a Type 2 Leak on 6/11/13 at 72 Park in Pulaski.
A Gas Repair Order and Leak History Record could not be produced for Staff
review. Therefore, all details pertaining to this leak and follow-up are not
adequately documented and unable to be reviewed. The Company failed to
retain the GRO. (Post 4/1/13)


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16 NYCRR Part 255.744(a) - Service regulators and vents - 1 Violation, 6
Occurrences

One violation of 255.744(a), which states that each operator shall inspect each service
regulator when it is installed, at the time of periodic meter change, and at the time a
service which has been inactive for a period of two years or more is reactivated to
service.

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

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

The meter at 220 Seneca St. in Fulton was a scheduled meter change on
6/28/2013. No service regulator inspection record could be located. (Post
4/1/13)

The meter at 156 S. 3rd St. in Fulton was a scheduled meter change on
12/3/2013. No service regulator inspection record could be located. (Post
4/1/13)

The meter at 223 W. Seneca St. in Fulton was a scheduled meter change on
9/16/2013. No service regulator inspection record could be located. (Post
4/1/13)

No service regulator inspection record could be located for the service at 422
S. 3rd St. in Fulton that was reactivated on 9/23/13 after two years of
inactivity (service terminated on 4/27/11). (Post 4/1/13)

No service regulator inspection record could be located for the service at 9477
Oswego Rd. in Phoenix that was reactivated on 10/2/13 after two years of
inactivity (service terminated on 6/27/11). (Post 4/1/13)

16 NYCRR Part 255.748(a) Valve maintenance: Service line valves 1 Violation, 7
Occurrence

One violation of 255.748(a), which states that except as provided in subdivision
255.748(b), buried high pressure service line valves or exposed exterior high
pressure service line valves shall be inspected in conjunction with the service
regulator inspection required under section 255.744.

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

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


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The meter at 220 Seneca St. in Fulton was a scheduled meter change on
6/28/2013. No service regulator inspection record could be located. (Post
4/1/13)

The meter at 156 S. 3rd St. in Fulton was a scheduled meter change on
12/3/2013. No service regulator inspection record could be located. (Post
4/1/13)

The meter at 223 W. Seneca St. in Fulton was a scheduled meter change on
9/16/2013. No service regulator inspection record could be located. (Post
4/1/13)

No service regulator inspection record could be located for the service at 422
S. 3rd St. in Fulton that was reactivated on 9/23/13 after two years of
inactivity (service terminated on 4/27/11). (Post 4/1/13)

No service regulator inspection record could be located for the service at 9477
Oswego Rd. in Phoenix that was reactivated on 10/2/13 after two years of
inactivity (service terminated on 6/27/11). (Post 4/1/13)

The meter at 463 W. 4th St. S in Fulton was a scheduled meter change on
10/30/2013. An MWork Regulator Inspection Report was produced for the
service regulator, vent and valve inspections to be performed at the time of
meter change, however it is indicated that no inspection was done on the curb
valve as the valve could not be located. (Post 4/1/13)

16 NYCRR Part 255.825(b) - Logging and analysis of gas emergency reports - 1
Violation, 3 Occurrences

One violation of 16 NYCRR Part 255.825(b), which states that a daily log shall be
kept and maintained on file recording the receipt and handling of each such report and
shall contain the following information:

(1) cross-reference to the related service record number;
(2) location of leak or emergency;
(3) time report first received by operator;
(4) description or code designation as to type of leak or emergency;
(5) time crew first dispatched to designated location; and
(6) time of arrival of such personnel at location.

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

GRO#184673 (11/1/13) was a type 1 leak located at 106 S. 5th St. in Fulton
and was not on the Daily Leak Log. (Post 4/1/13)


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GRO#184675 (11/4/13) was a type 1 leak located at 756 State Rt. 48 in
Granby and was not on the Daily Leak Log. (Post 4/1/13)

GRO#184665(8/7/13) was a type 1 leak located at 159 City Line in Scriba and
was not on the Daily Leak Log. (Post 4/1/13)

16 NYCRR Part 261.63(a)(1) - Warning tag: Action and follow-up - 1 Violation, 1
Occurrence

One violation of 261.63(a)(1) which states that when a Class A condition is
discovered, the operator shall lock off the gas supply at the meter, unless the affected
piping or gas fired appliance can be effectively isolated and secured from the rest of
the system, and issue a warning tag. If the operator is not advised by the customer
within 10 calendar days that the condition has been corrected and service is ready to
be reinstituted, the operator shall contact the customer no later than the end of the first
business day after the 10-day period to determine the status of service.

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

A Class A warning tag (MWork Order Number 12261521) was issued on
1/6/13 at 152 County-Route-24 in Minetto. The warning tag was issued for a
plugged boiler and the appliance was isolated. There was no record produced
to show that this warning tag was followed up on within the required time
frame.

16 NYCRR Part 261.63(d)(1) Warning tag: Action and follow-up 1 Violation, 1
Occurrence

One violation of 261.63(d)(1), which states that in apartment buildings, the operator
shall notify the property owner or agent (such as superintendent, custodian or
maintenance worker) of the condition and state the corrections that are required.

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

A Class B warning tag was issued on 6/1/13 at 87 E. 5
th
St., Oswego for a gas
leak on the ovens pilot. The customer signed the warning tag, but the landlord
was never contacted. Since this is an apartment building the owner should
have been contacted letting them know what was wrong. (Post 4/1/13)

16 NYCRR Part 261.63(f) - Warning tag: Action and follow-up - 1 Violation, 1
Occurrence

One violation of 261.63(f), which states that in the case of Class A or B conditions in
apartment buildings, the operator shall post a notice in a conspicuous place at or
within the dwelling stating that a warning tag has been issued and including a
description of the condition.

-42-

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

A Class A warning tag (MWork Order Number 1264314) was issued on
4/7/13 at 1020 County-Route 25 Apt.1 in Oswego. The warning tag was
issued for a furnace that was not venting properly and the appliance was
isolated. The warning tag record from MWork indicates that this location is
an apartment building and that no notice was posted. (Post 4/1/13)


Watertown

Record Audits
Three violations of 16 NYCRR Part 255 and three violations of 16 NYCRR Part 261were
noted.

16 NYCRR Part 255.744(a) - Service regulators and vents - 1 Violation, 5
Occurrences

One violation of 255.744(a), which states that each operator shall inspect each service
regulator when it is installed, at the time of periodic meter change, and at the time a
service which has been inactive for a period of two years or more is reactivated to
service.

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

The meter at 139 Cedar St. in Watertown was a scheduled meter change on
4/12/2013. No service regulator inspection record could be located. (Post
4/1/13)

The meter at 955 Gotham St. in Watertown was a scheduled meter change on
9/9/2013. No service regulator inspection record could be located. (Post
4/1/13)

The meter at 148 E. Main St. in Watertown was a scheduled meter change on
9/16/2013. No service regulator inspection record could be located. (Post
4/1/13)

The meter at 508 New York Ave. in Watertown was a scheduled meter change
on 10/28/2013. No service regulator inspection record could be located.
(Post 4/1/13)

No service regulator inspection record could be located for the service at
21794 Floral Dr. in Watertown that was reactivated on 6/24/13 after two years
of inactivity (service terminated on 4/7/09). (Post 4/1/13)


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16 NYCRR Part 255.748(a) Valve maintenance: Service line valves 1 Violation, 8
Occurrences

One violation of 255.748(a), which states that except as provided in subdivision
255.748(b), buried high pressure service line valves or exposed exterior high
pressure service line valves shall be inspected in conjunction with the service
regulator inspection required under section 255.744.

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

The meter at 139 Cedar St. in Watertown was a scheduled meter change on
4/12/2013. No service valve inspection record could be located. (Post
4/1/13)

The meter at 955 Gotham St. in Watertown was a scheduled meter change on
9/9/2013. No service valve inspection record could be located. (Post 4/1/13)

The meter at 148 E. Main St. in Watertown was a scheduled meter change on
9/16/2013. No service valve inspection record could be located. (Post 4/1/13)

The meter at 508 New York Ave. in Watertown was a scheduled meter change
on 10/28/2013. No service valve inspection record could be located. (Post
4/1/13)

No service valve inspection record could be located for the service at 21794
Floral Dr. in Watertown that was reactivated on 6/24/13 after two years of
inactivity (service terminated on 4/7/09). (Post 4/1/13)

The meter at 161 Paddock St. in Watertown was a scheduled meter change on
3/12/2013. An MWork Regulator Inspection Report was produced for the
service regulator, vent and valve inspections to be performed at the time of
meter change, however it is indicated that no inspection was done on the curb
valve as the valve could not be located.

The meter at 231 Paddock St. in Watertown was a scheduled meter change on
10/9/2013. An MWork Regulator Inspection Report was produced for the
service regulator, vent and valve inspections to be performed at the time of
meter change, however it is indicated that no inspection was done on the curb
valve as the valve could not be located. (Post 4/1/13)

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


-44-
16 NYCRR Part 255.825(b) - Logging and analysis of gas emergency reports - 1
Violation, 5 Occurrences

One violation of 16 NYCRR Part 255.825(b), which states that a daily log shall be
kept and maintained on file recording the receipt and handling of each such report and
shall contain the following information:

(1) cross-reference to the related service record number;
(2) location of leak or emergency;
(3) time report first received by operator;
(4) description or code designation as to type of leak or emergency;
(5) time crew first dispatched to designated location; and
(6) time of arrival of such personnel at location.

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

GRO#138674 (11/4/13) was a type 1 leak located at Creekwood Dr. in
Watertown and was not on the Daily Leak Log. (Post 4/1/13)

GRO#215057 (8/5/13) was a type 1 leak located at 629 Factory St. in
Watertown and was not on the Daily Leak Log. (Post 4/1/13)

GRO#138515 (11/6/13) was a type 1 leak located at 610 Mohawk St. in
Watertown and was not on the Daily Leak Log. (Post 4/1/13)

GRO#189326 (5/28/13) was a type 1 leak located at 23762 Route 12 (Bradley
St.) in Watertown and was not on the Daily Leak Log. (Post 4/1/13)

GRO#138679 (9/9/13) was a type 1 leak located at 26177 State Route 3 in
Watertown and was not on the Daily Leak Log. (Post 4/1/13)

16 NYCRR Part 261.63(a)(1) - Warning tag: Action and follow-up - 1 Violation, 1
Occurrence

One violation of 261.63(a)(1) which states that when a Class A condition is
discovered, the operator shall lock off the gas supply at the meter, unless the affected
piping or gas fired appliance can be effectively isolated and secured from the rest of
the system, and issue a warning tag. If the operator is not advised by the customer
within 10 calendar days that the condition has been corrected and service is ready to
be reinstituted, the operator shall contact the customer no later than the end of the first
business day after the 10-day period to determine the status of service.

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

A Class A warning tag (MWork Order Number 12219070) was issued on
1/7/13 at 110 Maple St. in Black River. The warning tag was issued for an

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improperly venting water heater. The first attempt at contact was 2/5/13
which exceeds the 10-day period to determine the status of service.

16 NYCRR Part 261.63(d)(2) Warning tag: Action and follow-up 1 Violation, 1
Occurrence

One violation of 261.63(d)(2), which states that if the operator cannot obtain a
signature, an additional notice shall be provided to the customer stating that a notice
of hazardous condition tag has been issued and the corrective actions that are
required.

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

A Class B warning tag (MWork Order Number 14005461) was issued on
11/30/13 at 160 Breen Ave., Watertown for a delayed ignition on the
customers furnace. No signature was ever obtained when the warning tag
was issued. No additional notice was ever provided to the customer
explaining the hazardous conditions that were found. (Post 4/1/13)

16 NYCRR Part 261.63(f) - Warning tag: Action and follow-up - 1 Violation, 1
Occurrence

One violation of 261.63(f), which states that in the case of Class A or B conditions in
apartment buildings, the operator shall post a notice in a conspicuous place at or
within the dwelling stating that a warning tag has been issued and including a
description of the condition.

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

A Class A warning tag (MWork Order Number 12219070) was issued on
1/7/2013 at 110 Maple St. in Black River. The warning tag was issued for a
water heater that is too tall for the cellar and an exhaust vent that is not
venting at an uphill pitch. The warning tag record from MWork indicates that
this location is an apartment building and that no notice was posted.

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