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PHMSA ar-2017-gas-program-evaluation
2017 AR NG Program Evaluation - ar-2017-gas-program-evaluation (Arkansas; Natural Gas State Program Evaluation)
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AR NG Program Evaluation, 2017, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2017 Gas State Program Evaluation for ARKANSAS 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 -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 1#
AR NG Program Evaluation, 2017, page 22017 Gas State Program Evaluation -- CY 2017 Gas State Agency: Arkansas Rating: Agency Status: Date of Visit: 10/22/2018 - 10/26/2018 Agency Representative: Bobby Henry, Chief, Pipeline Safety Office PHMSA Representative: Agustin Lopez, State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: Ted Thomas, Chairman Agency: Arkansas Public Service Commission Address: 1000 Center Street City/State/Zip: Little Rock, Arkansas 72201 60105(a): Yes 60106(a): No Interstate Agent: No 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 2017 (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. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. 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 46 46 D Compliance Activities 15 15 E Incident Investigations 11 11 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 115 115 State Rating................................................................................................................................................... 100.0 DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 2#
AR NG Program Evaluation, 2017, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed PDM and APSC records to verify operators and units. There are no issues with Attachment 1. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Verified inspection days with APSC for accuracy of submitted data. There are no issues with Attachment 2. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Reviewed annual reports and APSC operator data to verify attachment 3. There is one master meter (Granite Redevelopment) operator that submitted an annual report but is no longer operating. 4 Were all federally reportable incident reports listed and information correct? - Progress 1 1 Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were two reportable incidents in 2017 that were investigated by the APSC. The APSC did not go on site but did gather enough information before making the determination to not go onsite. One was vehicular damage to a regulator station and the other was at a compressor station. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Verified compliance actions and numbers seem to be correct. There was a mistake on last years (2016) Progress Repot which showed 82 carry overs but should've been 68. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, all files are kept electronically. All inspection reports are available on the APSC website as well. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Verified training with APSC records and SABA. Qualification of inspectors seems accurate. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Adoption of rules is done biannually. In process of adopting 27-82 FR 7972, have until 2019 to adopt. 1 1 DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 3#
AR NG Program Evaluation, 2017, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, state described goals and accomplishments in detail. Worked with Black Hills to lower the amount of 3rd party damages. They had an average of 9 hits per 1,000 tickets and has been lowered to less than 1 hit per 1,000 ticket. The APSC provides training to contractors who break the one call law in Black Hills operating areas. 10 General Comments: Info Only = No Points Evaluator Notes: The Arkansas PSC is mainly complying with Part A of the Evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 4#
AR NG Program Evaluation, 2017, 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: Pipeline Safety Office Inspection Plan has standard inspection procedures (Section III) that give guidance to inspectors on performing standard inspections. Procedures include pre and post inspection activities. 2 IMP and DIMP 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: Pipeline Safety Office Inspection Plan has IMP and DIMP inspection procedures (Section VI and VII) that give guidance to inspectors on performing IMP and DIMP inspections. Procedures include pre and post inspection activities. 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: Pipeline Safety Office Inspection Plan has OQ inspection procedures (Section V) that give guidance to inspectors on performing OQ inspections. Procedures include pre and post inspection activities and OQ field verifications. 4 Damage Prevention Inspection procedures should give guidance to state inspectors that 1 1 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: Pipeline Safety Office Inspection Plan has Public Awareness/Damage Prevention inspection procedures (Section X) that give guidance to inspectors on performing Public Awareness/Damage Prevention inspections. Procedures include pre and post inspection activities. 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: On site Operator Training is conducted as needed and have procedures in place. Each training is documented in their database of inspections. There was no operator training conducted in 2017 6 Construction 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: Pipeline Safety Office Inspection Plan has construction inspection procedures (Section IX) that give guidance to inspectors on performing construction inspections. Procedures include pre and post inspection activities. Construction projects are assigned by the PSO Chief. DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 5#
AR NG Program Evaluation, 2017, page 67 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 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 areas, 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, the inspection plan addresses each of the following element: a. length of time since previous inspection. b. operating history of operator or change of ownership/personnel c. construction activities or significant activities d. History of operator and leakage or high unaccounted gas lost locations e. risk based analysis f. yes, units are broken down accordingly. 8 General Comments: Info Only = No Points Evaluator Notes: The APSC is mainly complying with Part B of the Evaluation. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 6#
AR NG Program Evaluation, 2017, 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 A. Total Inspection Person Days (Attachment 2): 851.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 7.05 = 1551.00 Ratio: A / B 851.00 / 1551.00 = 0.55 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: The APSC met the required total inspection person days to total person days ratio. 5 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 DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program 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: Yes, all lead inspectors are qualified to lead each type of inspection. a. yes, Verified that lead inspectors were qualified to conduct inspections. b. Yes, reviewed IMP inspection reports to verify lead inspectors were qualified. c. Yes, at least one inspector has taken the Root Cause Course. d. No outside training in 2017. e. Reviewed inspection reports to verify lead inspectors were qualified. 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 Evaluator Notes: Yes, Mr. Bobby Henry is very knowledgeable of the pipeline safety program and regulations. 2 2 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 Evaluator Notes: There was no response necessary in 2017. 2 NA 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: Yes, co-host seminar with Louisiana in 2017. 1 1 DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 7#
AR NG Program Evaluation, 2017, page 86 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 Evaluator Notes: Yes reviewed inspection reports to verify inspection cycles. Inspection intervals is every five years. 5 5 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 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, reviewed inspection reports for completion and found no issues. 2 2 8 Did the state review operator procedures for determining if exposed cast iron pipe was 1 1 examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: The last of cast iron pipe was removed in 2018. Centerpoint had about 4 miles of cast iron left in state but has been removed. 9 Did the state review operator procedures for surveillance of cast iron pipelines, including 1 1 appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes, the APSC verified operator procedures for survelliance of cast iron. Centerpoint was the only operator with cast iron pipe in the state but has been all been replaced in 2018. 10 Did the state review operator emergency response procedures for leaks caused by 1 1 excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes, the APSC reviews operator emergency response procedures which includes multiple leaks caused by excavation damages. 11 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 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, operator records of incidents/accidents are reviewed to ensure procedures are being followed as required by 192.617. 12 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 Evaluator Notes: Yes the review of annual reports is on the APSC website and is analyzed for trends. 2 2 13 DUNS: 096796201 2017 Gas State Program Evaluation Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 1 1 Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 8#
AR NG Program Evaluation, 2017, page 9Evaluator Notes: Yes, review NPMS data during inspections 14 Is the state verifying operators are conducting drug and alcohol tests as required by 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: 2 2 Yes, the APSC conducts drug and alcohol program inspections to assure operators are complying with 49 CRF 199. 15 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 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the APSC conducts OQ Plan and field inspections to assure operators are in compliance with CFR192 Part N. 16 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 up to date? This should include a previous review of IMP 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-13)). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the APSC conducts IMP inspections on operators to assure they are in compliance. IMP Inspections are conducted at intervals not to exceed 5 years. 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 2 This should include a review of DIMP plans, along with monitoring progress. 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?). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the APSC conducts DIMP inspections on operators to assure they are in compliance with the regulations. All operators have had a DIMP inspection and are conducted on intervals not to exceed 5 years. 18 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 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the APSC completed all PAPEI inspections in 2013 and review Public Awareness activities during standard inspections. PAPEI program inspections are conducted at intervals not to exceed 5 years. 19 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 the APSC website has information available to the public. Inspection reports can be viewed by the public at any time and is very transparent. DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 9#
AR NG Program Evaluation, 2017, page 1020 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: There were no SRCR in 2017. 1 NA 21 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC has a replacement program with operators to submit annual reports to the APSC to verify plastic pipe with know defects. 22 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, Mr. Henry responds to PHMSA and NAPSR surveys. 1 1 23 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: There are no waivers that require follow up or special conditions that need verification. 1 1 24 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes, Mr. Henry attended the National NAPSR Meeting. 1 1 25 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 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: Discussed the upward trend of leaks repaired. This is mainly due to the new leak detection technology (Picarro vehicle) being used by large operator which detects smaller leaks. This has caused an increase in leak repairs due to operator having to repair leaks which is a stipulation that the APSC had them agree to be able to use the new leak survey technology. The damages per 1,000 has seen a downward trend due to the APSC working with operators and contractors to educate and train on the one call laws. 26 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: Discussed the accuracy of data entered into the SICT with Mr. Henry and it seems to be accurate. There is no future issues in meeting the calculated inspector days. DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 10#
AR NG Program Evaluation, 2017, page 1127 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 APSC has a section on inspection form with NTSB and ADB questions to assure they are verified with operators during standard inspections. Reviewed inspection reports to assure questions are being asked by inspectors. 28 General Comments: Info Only = No Points Evaluator Notes: The APSC is mainly complying with Part C of the Evaluation. Info Only Info Only Total points scored for this section: 46 Total possible points for this section: 46 DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 11#
AR NG Program Evaluation, 2017, page 12PART 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: Yes, procedures gives guidance for the processing of probable violations. a. Yes, the operator is notified of findings during the exit interview and sent a letter which identify findings. APSC also sends letter if there were no probable violations. b. Yes, the PSC creates a suspension file and tracks the progress of cases. c. Procedures are in place to close outstanding probable violations. Operators are given 60 days to respond with corrective actions. The Chief and inspector review respond and decide whether it is sufficient to close out case. PSC can file for a hearing if operator does not respond within 60 days. 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? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member 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: Yes, reviewed inspection report and files to assure APSC is following compliance procedures and adequately documented all probable violations. a. Yes, all compliance actions are sent to operator officials. b. Yes, the PSC document all probable violations. c. Yes, reviewed compliance files to verify the resolution of probable violations. d. The APSC reviews progress of compliance cases to assure they are processed in a timely manner. e. Document date of exit interview on inspection. f. Provide written notification to the operator within 90 days of completing the inspection. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, reviewed inspection reports and compliance letters to verify all probable violations were addressed. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show 2 2 cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes, the APCS gives reasonable due process to all parties. The operator can request a hearing if they chose to contest findings. DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 12#
AR NG Program Evaluation, 2017, page 135 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes, Mr. Bobby Henry is very familiar with the APSC civil penalty process. There were no civil penalties issued in 2017. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the APSC has issued civil penalties in the past. 1 1 7 General Comments: Info Only = No Points Evaluator Notes: The Arkansas PSC is mainly complying with Part D of the Evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 13#
AR NG Program Evaluation, 2017, page 14PART E - Incident 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: Yes, Section IX of Procedures has guidance that addresses state actions in an event of an incident. It describes the investigation of non compliance and root cause. It also states the documentation of the investigation report. 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, 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 ARPSC has a mechanism for receiving incident notifications. The Arkansas Pipeline Safety Code adopted Part 191 which includes the reporting of incidents. The ARPSC added section 191.5(c) which directs the operators to call the PSC in case of an incident which includes after hours reporting. a. The ARPSC is aware of the MOU between the NTSB and PHMSA. b. The ARPSC follows the federal/state cooperation in case of an incident. 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: 1 1 Yes, the ARPSC incident inspector gathers enough information to decide if an onsite investigation is needed. 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 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 when appropriate Yes No Needs Improvement Evaluator Notes: Yes, there were two incidents in 2017 which were reported to the ARPSC and investigated. Incidents were documented and contributing factors noted. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: There were no compliance actions issued during incident/accident investigations. 1 1 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking 1 1 appropriate follow-up actions related to the operator incident 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: There was no assistance requested by the AID team in 2017 but the ARPSC is always open to help or assist with any questions or investigations. DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 14#
AR NG Program Evaluation, 2017, page 157 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, any lessons learned are shared with NAPSR at the Regional meetings. 8 General Comments: Info Only = No Points Evaluator Notes: The ARPSC is mainly complying with Part E of the Evaluation. Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 15#
AR NG Program Evaluation, 2017, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the question has been added to the Appendix of the inspection forms and is asked during inspections. 2 2 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, inspectors verify procedures for excavation markings and one call systems during the inspections. 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, the APSC is very involved with damage prevention throughout the state and promoting CGA best practices. 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 APSC collects data and is reviewed and analyzed for trends and to find ways to reduce the total number of damages. Number of hits per 1,000 tickets has dropped from 8.5 to 6.9 in the last couple of years. 5 General Comments: Info Only = No Points Evaluator Notes: The Arkansas PSC is mainly complying with Part F of the Evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 16#
AR NG Program Evaluation, 2017, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: Centerpoint Energy Name of State Inspector(s) Observed: John Ray, Pipeline Safety Coordinator Location of Inspection: Russellville, AR Date of Inspection: October 25, 2018 Name of PHMSA Representative: Agustin Lopez, State Evaluator Evaluator Notes: Evaluated Mr. John Ray while conducting an inspection of Centerpoint Energy distribution system. Mr. Ray was conducting a field inspection of Centerpoint's cathodic protection on their distribution system. The records and procedures were reviewed on a different week. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 Evaluator Notes: Yes, the operator was notified with enough notice to have any representatives present. 1 1 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 Evaluator Notes: Yes, The inspector utilized the inspection form as a guide during the inspection. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the inspector was taking notes while he conducted the inspection. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: Yes, the inspector assured the technician had the appropriate equipment to conduct the tasks. The inspector verified the technicians voltmeter by comparing the readings to his own voltmeter readings. 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: The inspector conducted a field inspection of the operator's cathodic protection system around Russellville. He checked cp locations and also was vigilant of any abnormal conditions at the locations visited. DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 17#
AR NG Program Evaluation, 2017, page 187 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, Mr. John Ray has been with the ARPSC for several years and is very knowledgeable of the pipeline safety program and regulations. 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, Mr. John Ray concluded the inspection with a partial exit interview since the inspection is not complete. 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: The inspector conducted an exit interview but there were no probable violations identified during the inspection. He did mention that they need to verify if there was a leak at a location that was visited during the inspection. 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 Info Only Info Only DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 18#
AR NG Program Evaluation, 2017, page 19C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Mr. John Ray conducted an inspection of Centerpoint's cathodic protection in their distribution system. He took pipe-to-soil readings and checked the condition of the pipeline facilities. He also checked exposed crossings for coating and atmospheric corrosion. He conducted himself very professionally and did an exceptional job. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 19#
AR NG Program Evaluation, 2017, page 20PART 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: AR PSC is not an Interstate Agent. 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: AR PSC is not an Interstate Agent. 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: AR PSC is not an Interstate Agent. 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: AR PSC is not an Interstate Agent. 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: AR PSC is not an Interstate Agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: AR PSC is not an Interstate Agent. 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: AR PSC is not an Interstate Agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: AR PSC is not an Interstate Agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 20#
AR NG Program Evaluation, 2017, page 21PART 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: AR PSC does not have a 60106 Agreement. 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: AR PSC does not have a 60106 Agreement. 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: AR PSC does not have a 60106 Agreement. 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: AR PSC does not have a 60106 Agreement. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: AR PSC does not have a 60106 Agreement. 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: AR PSC does not have a 60106 Agreement. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: AR PSC does not have a 60106 Agreement. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 096796201 2017 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 21#
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