RegulusPipeline researchPHMSA al-2018-hazardous-liquid-program-evaluation
AL HL Program Evaluation, 2018, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2018 Hazardous Liquid State Program Evaluation for Alabama Public Service Commission Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Accident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (if applicable) I -- 60106 Agreement State (if applicable) DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 1#
AL HL Program Evaluation, 2018, page 22018 Hazardous Liquid State Program Evaluation -- CY 2018 Hazardous Liquid State Agency: Alabama Rating: Agency Status: Date of Visit: 04/22/2019 - 05/24/2019 Agency Representative: Wallace Jones - Director, Gas Pipeline Safety Division PHMSA Representative: Glynn Blanton, US DOT/PHMSA State Evaluator Commission Chairman to whom follow up letter is to be sent: Name/Title: Twinkle Andress Cavanaugh, President Agency: Alabama Public Service Commission Address: 100 N. Union St., Suite 800 City/State/Zip: Montgomery, Alabama 36104 60105(a): Yes 60106(a): No Interstate Agent: Yes INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2018 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 13 13 C Program Performance 42 42 D Compliance Activities 15 15 E Accident Investigations 6 6 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (if applicable) 0 0 I 60106 Agreement State (if applicable) 0 0 TOTALS 106 106 State Rating................................................................................................................................................... 100.0 DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 2#
AL HL Program Evaluation, 2018, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress 1 1 Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Conducted a review of Attachment 1 - Stats on Operators and found the information correct and all inspection units were inspected in CY2018. One operator Denbury Onshore abandoned their CO2 line in CY2018. Therefore, the operator was removed from the inspection program. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: No issues with Attachment 2. Due to error in SICT the number of required inspection person days should have been 20. They performed 34 which excesses the number required. Six drug inspections were performed on the seven operators listed on attachment 2. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Attachment 3 is correct and matches attachment 1 with the number of operators. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No incidents were reported in CY2018. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Attachment 5 was reviewed. Violations carried over from previous year, violations found during current year and violations corrected were all zero. No compliance action or civil penalties were assessed. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, inspection reports, letters, forms and other pipeline safety information is located on the agency's main server I drive. All forms used by inspectors are listed in Appendix C in the Pipeline Safety Procedure Manual. 7 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A review of Blackboard at TQ determined two of the three inspectors listed on Attachment 7 are qualified. One inspector is not the lead inspector and acts as assistant to the other two inspectors until he completes all required courses. 8 Verification of Part 195,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: The agency has automatic adoption of federal rules and regulations. Civil penalty amounts are $200,000/$2 M. No issues. DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 3#
AL HL Program Evaluation, 2018, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Description of planned and past performance was provided in attachment 10. No issues of concern. 10 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 4#
AL HL Program Evaluation, 2018, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 2 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this information is located in Alabama Pipeline Safety Program Operations Plan pages 12-15, Section V. Conducting Inspections: Sub-Sections A-G. 2 IMP Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: This information is located in Alabama Pipeline Safety Program Operations Plan pages 18-19, Section V. Conducting Inspections: Sub-Sections N & P. 3 OQ Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: This information is located in Alabama Pipeline Safety Program Operations Plan on pages 17, Section I. Training & Operator Qualifications. 4 Damage Prevention Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: This information is located on pages 18, Section M Damage Prevention Activities. 1 1 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A review of Alabama Pipeline Safety Program Operations Plan found this item listed on pages 18, Operator Training. 6 Construction Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: This item is listed in Alabama Pipeline Safety Program Operations Plan on pages 15-17, Section V, Subsection H. AL PSC uses their own state form for all construction. The operator is required to file a construction notification to the agency prior to construction work being performed. This is a commission rule. 7 Does inspection plan address inspection priorities of each operator, and if necessary each unit, based on the following elements? DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation 6 6 Alabama Alabama Public Service Commission, Page: 5#
AL HL Program Evaluation, 2018, page 6Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic area, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: Yes, Alabama Pipeline Safety Program Operations Plan found the above items listed above in Appendix D, Risk Management Assessments. The elements of risk were listed separately and ranked on pages 35 & 36. No issues of concern. 8 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 6#
AL HL Program Evaluation, 2018, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 5 5 A. Total Inspection Person Days (Attachment 2): 34.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 0.09 = 19.80 Ratio: A / B 34.00 / 19.80 = 1.72 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: A.Total Inspection Person Days (Attachment 2)= 34 B.Total Inspection Person Days Charged to the program(220*Number of Inspection person years(Attachment 7)=19.8 Formula:- Ratio = A/B = 34/19.8 = 1.72 Rule:- (If Ratio >=.38 then points = 5 else Points = 0.) Thus Points = 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required IMP Training before conducting inspection as lead Yes No Needs Improvement c. Root Cause Training by at least one inspector/prgram manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: a. Two of the three inspectors assigned to the liquid program have completed the required OQ training. b. Two of the three have completed the IMP training to conduct as the lead inspector. c. Yes, three inspectors and the Program Manager have completed the root cause course. d. Yes, several inspectors have HAZWOPER Certifications. e. Yes, a review of Blackboard confirm 2 inspectors are qualified to perform a standard inspection as the lead HL inspector. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, Mr. Jones has an excellent understanding of the requirements of the pipeline safety program and completed all TQ courses within three years of employment. He has over forty one years of natural gas experience and been a Program Manager for eleven years. He is currently the Vice Chairman of the National Association of Pipeline Safety Representatives. 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, Chairman Cavanaugh response letter to Zach Barrett was received on August 9, 2018 and within the required 60-day time frame. Correction action was taken on the items listed in the letter. 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation 1 1 Alabama Alabama Public Service Commission, Page: 7#
AL HL Program Evaluation, 2018, page 8Evaluator Notes: AL PSC co-sponsors with the LA Department of Resources a Hazardous Liquid seminar for all operators in AL and LA. The seminar was held on July 30 to August 3 in New Orleans, LA. 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Yes, all seven HL operators were inspected in accordance to Alabama Pipeline Safety Program Operations Plan. A review of files and I drive confirm these inspections and 34 inspection days were charged to the program. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, they use the federal and state inspection forms to cover all applicable sections of the code. The state form is use the first two years and the federal form is used during the next inspection. A review of files and inspection reports found all portions of the forms were completed with a check mark or comment provided beside each question. 8 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 195.402(c)(5)? Yes = 1 No = 0 Evaluator Notes: Yes, this is reviewed in Alabama Liquid Field Evaluation Report form. 1 1 9 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, operator's annual reports are reviewed by Program Manager and data entered into a rank risk spreadsheet maintained by the Administrative Assistant. The information is used to determine inspection audits. 10 Has state confirmed intrastate operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, this item is covered on the Alabama Liquid Field Evaluation Report form. 1 1 11 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, they reviews the operator's drug & alcohol program along with the positive test required by the regulations during the Liquid Field Evaluation Inspection. In CY2018, seven drug & alcohol inspections were performed. 12 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 195 Part G Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, a review of files found this item is reviewed during the standard inspection. DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 8#
AL HL Program Evaluation, 2018, page 913 Is state verifying operator's hazardous liquid integrity management (L IMP) Programs are 2 2 up to date? This should include a previous review of LIMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually? Are replies to Operator IM notifications addressed? (formerly part of Question C-10)). 49 CFR 195.452 Appendix C Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, they verify the gas transmission integrity program using the Alabama Liquid Field Evaluation Inspection form. A review of LIMP plan, along with test and action taken by the operator are discussed and reviewed when completing the form with the operator. Yes, the state's largest operator program is reviewed annually. A check of files found Hunt Refining was inspected in September 18, 2018. 14 Is state verifying operators Public Awareness programs are up to date and being 2 2 followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 195.440 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, AL PSC conducted PAPEI inspections on the seven HL operators and reviewed the effectiveness of their program during the standard inspection. 15 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, they continue to communicate with all stakeholders using the Alabama Natural Gas Association and AL PSC websites. 16 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No safety related condition reports in CY2018. 1 NA 17 Did the state participate in/respond to surveys or information requests from NAPSR or 1 1 PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, a review of emails from Robert Clarillos to Wallace Jones confirmed participation in surveys from NAPSR. 18 If the State has issued any waivers/special permits for any operator, has the state verified 1 1 conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: Yes. There is an active waiver issued in 2009 to Alabama Gas Corp for un-odorized gas to be delivered to Hunt Oil Corp continues to be monitored. Also, the waiver issued in 2015 to Exxon-Mobil is also being monitored by AL PSC during their normal inspection audits. 19 Did the state attend the NAPSR National Meeting in CY being evaluated? Needs Improvement = .5 No = 0 Yes = 1 1 1 Evaluator Notes: Yes. Wallace Jones, Daniel Trapp and Greg Meadows attended the NAPSR National Meeting in Santa Fe, NM. DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 9#
AL HL Program Evaluation, 2018, page 1020 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site ? http://primis.phmsa.dot.gov/comm/states.htm Needs Improvement = 1 No = 0 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: Reviewed with Program Manager the State Program Performance Metrics and found the total number of leaks eliminated/ repaired were trending down. Leaks scheduled for repair at end of year was 36. Number of damages per 1,000 tickets listed on the 2018 annual reports was not available during this audit. 21 Discussion with State on accuracy of inspection day information submitted into State 1 1 Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: Reviewed with program manager the accuracy of information submitted into SICT for the AL PSC HL program. During this audit we were successful in correcting the error on the HL Progress Report Review that initial showed the number of required inspection person days to be 48 instead of 20. Program Manager had made the correction to the person days in CY2018. 22 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 1 1 Evaluator Notes: The program manager is unaware of any pipeline flow reversals, product changes and conversion to service on the HL pipelines. However, this item is listed on their inspection form question number 42 and discussed with the operator. 23 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in a review of this section of the evaluation. Info Only Info Only Total points scored for this section: 42 Total possible points for this section: 42 DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 10#
AL HL Program Evaluation, 2018, page 11PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: a. This information is listed in Alabama Public Service Commission procedure manual in Section S. Notices of Probable Violations pages 19-20. b. This information is listed under section U. Notice of Probable Violation Tracking, pages 21-22 c. This information is listed under section V. Removal or Correction of a Probable Violation, pages 22-23 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? (Incident Investigations do not need to meet 30/90 day requirement) Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board director if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: a. Yes, files and inspection reports show letters were being sent to the company officer of the private companies, mayor/ superintendent of municipality systems and director/manager of housing authorities. Reviewed the contact names of the individuals on the operator's list and compared to inspection reports and found correct. b. Yes, a review of files found 181 violations against 81 operators were cited for Notice of Probable Violations. Reviewed inspection reports and found violations were documented correctly. c. Yes, violations were resolved by a follow-up inspection or additional information being filed by the operator to the agency. d. Yes, Program Manager/Administrative Assistant review on a quarterly schedule all violations. Information about the status of the information is sent to the affected inspector to perform a follow-up inspection. e. An exit interview is conducted immediately after the inspection with the operator. Information about areas of concerns or potential violations are shared with the operator's representatives. This item is described in AL PSC Procedures manual on page 17. f. All Notice of Probable Violations letters are provided to the operator about their findings within 90 days of the date of the inspection. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, a review of files and inspection reports found eighty-one NOPV's were issued in CY2018 on natural gas operators. However, no NOPV were issued on HL operators. No areas of concern. 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation 2 2 Alabama Alabama Public Service Commission, Page: 11#
AL HL Program Evaluation, 2018, page 12Yes, no show cause hearings were held in 2018 against an HL operator. Operators have agreed to correct the violations without commission action. 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Evaluator Notes: Yes, program manager is familiar with imposing civil penalties and assessed a civil penalty against operators. The last civil penalty issued against an operator was in CY2015 against Air Base Inn. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 1 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, enforcement fining authority was taken in CY2015 against Air Base Inn, a master meter operator. No enforcement action has been taken against HL operators in the history of the program. 7 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 12#
AL HL Program Evaluation, 2018, page 13PART E - Accident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ 2 2 accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Incidents. Yes, this information is located in Alabama Pipeline Safety Program Operations Plan on pages 25-29, VI. Investigation of 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 accidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: Yes, the MOU and Federal/State Cooperation agreement documents are listed in Appendix J of Alabama Pipeline Safety Program Operation Plan. Additionally, Alabama PSC's GPS Rule #9, requires the pipeline operator to give telephonic notice of all incidents by calling (334) 242-5778 to report incidents during normal business hours of 8:00 AM to 5:00 PM. After hours, the operator is required to call the Pipeline Safety Investigator assigned to or located in the operator's region of the state (North, Central or South Alabama). 3 If onsite investigation was not made, did state obtain sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No incidents on Hazardous Liquid lines occurred in CY2018. 1 NA 4 Were all accidents investigated, thoroughly documented, and with conclusions and 3 NA recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences where appropriate Yes No Needs Improvement Evaluator Notes: No incidents on Hazardous Liquid lines occurred in CY2018. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: No incidents on Hazardous Liquid lines occurred in CY2018. 1 NA 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator accident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes, Program Manager and Inspectors related information to AID and Region Office on all natural gas incident reports. DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 13#
AL HL Program Evaluation, 2018, page 147 Does state share lessons learned from incidents/accidents? (sharing information, such as: 1 1 at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: Yes, information on the two incidents was shared at the State-to-State Presentation during the NAPSR Southern Region meeting. 8 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 6 Total possible points for this section: 6 DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 14#
AL HL Program Evaluation, 2018, page 15PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, during an onsite construction inspection this item is reviewed with the operator and his construction supervisor. It is checked during the standard inspection review of the operator's O & M Plan. This item is question 20 on the construction inspection checklist form. 2 Did the state inspector verify pipeline operators are following their written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is item 31 on the construction inspection checklist form. 2 2 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Program Manager continues to participate in the Alabama Damage Prevention Alliance, Alabama Damage Prevention Summit and support the 811-promulgation signed by the Governor in April. 4 Has the agency or another organization within the state collected data and evaluated 2 2 trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the program manager continues to collect damage data and evaluates the trends on the number of pipeline damages per 1,000 locate request each year. This information is presented yearly at the NAPSR Southern region meeting. 5 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 15#
AL HL Program Evaluation, 2018, page 16PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Palmer Petroleum Inc. Name of State Inspector(s) Observed: Jonathan Kimbril (Lead) Gas Pipeline Safety Investigator, & Michael McVay Gas Pipeline Safety Investigator Location of Inspection: Monroeville, AL Date of Inspection: May 7, 2019 Name of PHMSA Representative: Glynn Blanton, PHMSA State Liaision Evaluator Notes: Info Only Info Only This was a standard inspection conducted at the offices of Palmer Petroleum satellite office in Monroeville, AL. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 1 1 Evaluator Notes: Yes, Shawn Emmons, Plant Operator was notified by Jonathan Kimbril AL PSC several weeks in advance of the site visit. 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, the investigator was using the AL PSC standard inspection form. 4 Did the inspector thoroughly document results of the inspection? 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Excellent documentation of items reviewed and notes of areas of concern were entered into laptop computer by the AL PSC Investigators. 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,valve keys, half cells, etc) Yes = 1 No = 0 Evaluator Notes: Yes, the investigators reviewed the operators equipment prior to conducting the field inspection. 1 1 2 2 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: Yes, company records and procedures were reviewed in the office. A field inspection was performed on the plant's facilities. DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 16#
AL HL Program Evaluation, 2018, page 177 Did the inspector have adequate knowledge of the pipeline safety program and 2 2 regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes Jonathan Kimbril has completed all TQ courses pertaining to HL & NG. Michael McVay Gas Pipeline Safety Investigator assisted in the inspection but has not completed all required courses for HL & NG. He is scheduled to attend courses at TQ in the coming months. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes an exit interview was conducted and information about areas of concern and violations were explained to the operator. 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Yes, three violations were found and three recommendations pertaining to improvements were provided to the operator. The three violations were: 195.403 (b)(c), 195.442 (c)(2) & 195.581 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Info Only Info Only Alabama Alabama Public Service Commission, Page: 17#
AL HL Program Evaluation, 2018, page 18C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Field inspection was conducted at the site area. DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Total points scored for this section: 12 Total possible points for this section: 12 Alabama Alabama Public Service Commission, Page: 18#
AL HL Program Evaluation, 2018, page 19PART H - Interstate Agent State (if applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: NA Yes = 1 No = 0 Needs Improvement = .5 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: NA Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 19#
AL HL Program Evaluation, 2018, page 20PART I - 60106 Agreement State (if applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: NA Yes = 1 No = 0 Needs Improvement = .5 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NA 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: NA Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 961833431 2018 Hazardous Liquid State Program Evaluation Alabama Alabama Public Service Commission, Page: 20#
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