{"operation":"document","citation":"PHMSA ar-2018-gas-program-evaluation","title":"2018 AR NG Program Evaluation - ar-2018-gas-program-evaluation (Arkansas; Natural Gas State Program Evaluation)","source_type":"inspection","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-01-01","effective_on":null,"summary":"2018 PHMSA natural gas program evaluation for Arkansas.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-state-evaluation-ar-ng-program-evaluation-ar-2018-gas-program-evaluation.json","markdown":"https://regulus.evalyn.ai/document/phmsa-state-evaluation-ar-ng-program-evaluation-ar-2018-gas-program-evaluation.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-state-evaluation-ar-ng-program-evaluation-ar-2018-gas-program-evaluation","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/subdoc/4366/ar-2018-gas-program-evaluation.pdf","body":"1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2018 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 2018 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 1\n\n2018 Gas State Program Evaluation -- CY 2018 Gas State Agency: Arkansas Rating: Agency Status: Date of Visit: 06/17/2019 - 06/21/2019 Agency Representative: Robert Henry, Chief, Pipeline Safety Donna Gray, Executive Director PHMSA Representative: Glynn Blanton, US DOT/PHMSA State Evaluator Commission Chairman to whom follow up letter is to be sent: Name/Title: Ted J. 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 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 46 46 D Compliance Activities 15 15 E Incident Investigations 5 5 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 109 109 State Rating................................................................................................................................................... 100.0 DUNS: 096796201 2018 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 2\n\nPART 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 1 1 Evaluator Notes: Reviewed Arkansas Public Service Commission (AR PSC) state jurisdictional authority in SharePoint and confirmed they have safety over all intrastate natural gas distribution systems and LNG facilities. In December, 2018 Black Hills Energy abandoned their LNG facility. This item was listed in the note section and removed from attachment 3. A review found the number of master meter operators have increased from 126 to 128. No areas of concern. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Conducted a review of AR PSC Pipeline System data base and office files to confirm inspection days were correctly entered. Discussion with Program Manager on damage prevention activities, training and construction person days were reviewed and found correct. 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: Total number of operators match attachment 1 and was verified by pipeline data mart data. No areas of concern. 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 occurred 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: The number of carryover compliance actions continue to remain at the 36 number level. A review of compliances found a large portion of the violations were cited in the fourth quarter of CY2018. No carryover violations were more than a year old. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes, a review of AR PSC data base and office files found all information on the inspections were well organized. 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: Yes, reviewed information in Training & Qualification Center Blackboard data base and found the employees listed are current. All inspectors have met the requirements to be qualified Gas Inspectors. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 096796201 2018 Gas State Program Evaluation 1 1 Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 3\n\nA review of information found three amendments, 81-FR 70989, 82-FR 7972 & 82- FR 7972 have not been adopted but steps are being taken to adopt. These three federal rules were issued in CY2017. These will need to be adopted by 2020 to prevent a loss of points in future state program evaluations. 9 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: Excellent description of planned and past performance. As of December 2018, all cast iron piping has been removed from the State of Arkansas. All bare, ineffectively coated steel and Aldyl-A PE piping is scheduled to be replaced under a separate program. 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: 096796201 2018 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 4\n\nPART 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: A review of Arkansas Pipeline Safety Operation & Inspection Plan (APSO) found information on standard inspections listed on page 2. Pre-inspection activities, inspection activities and post activities are listed on pages 3-5. 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: A review of Arkansas Pipeline Safety Operation & Inspection Plan (APSO) found IMP & DIMP inspections are listed under Section VI Integrity Management (IM) Inspection Procedures pages 6-8. 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: A review of Arkansas Pipeline Safety Operation & Inspection Plan (APSO) found OQ inspections are listed under Section V. Operator Qualification (OQ) Inspection Procedures page 5. 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: A review of Arkansas Pipeline Safety Operation & Inspection Plan (APSO) found Damage Prevention, with emphasis on API 1162, procedures shall be inspected during all standardized gas pipeline inspections on page 3. 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 Arkansas Pipeline Safety Operation & Inspection Plan (APSO) found operator training listed on page 10, under XII. On-Site Operator Training. 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: A review of Arkansas Pipeline Safety Operation & Inspection Plan (APSO) found this item listed on page 8, under VIII. Construction Inspection Procedures. 7 Does inspection plan address inspection priorities of each operator, and if necessary each unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 DUNS: 096796201 2018 Gas State Program Evaluation 6 6 Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 5\n\na. 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, items a through e are listed on pages 1-2, under Planning and Scheduling of Inspection in Arkansas Pipeline Safety Operation & Inspection Plan (APSO). A separate review of inspection units confirm the units are broken down appropriately. 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: 096796201 2018 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 6\n\nPART 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): 783.00 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 783.00 / 1551.00 = 0.50 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)= 783 B.Total Inspection Person Days Charged to the program(220*Number of Inspection person years(Attachment 7)=1551 Formula:- Ratio = A/B = 783/1551 = 0.5 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 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: a. Yes, a review of records and inspection reports confirm lead inspectors are qualified. b. Yes, conducted a review of DIMP/IMP/TIMP inspections and found seven of the eight inspectors are Gas IM qualified. c. Yes, all except for one inspector have successfully attended and completed the course. The Program Manager completed the course in 2008. d. No outside training has been attended or completed by the inspector staff in CY2018 e. Yes, all eight inspectors have obtained the minimum qualification to lead a standard inspection. This was verified by reviewing the records at T&Q Training Center blackboard. . 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, Bobby Henry started as an inspector with AR PSC in 1983 and became the program manager in May 2010. He is very knowledge with the pipeline safety regulations and enforcement authority. 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: No response was required from the Chairman on the CY2017 State Program Evaluation. 2 2 DUNS: 096796201 2018 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 7\n\n5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 1 1 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: Yes, in CY2018, AR PSC conducted an in-state master meter/small operator seminar. The seminar was held at the Commission offices. The number of attendees was 100. 6 Did state inspect all types of operators and inspection units in accordance with time 5 5 intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Yes, time intervals for all inspections are no more than five years. Reviewed AR PSC Data base and confirmed this is being done. 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, they use PHMSA forms on all inspections. 2 2 8 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: All cast iron pipe was removed from operation in the State of Arkansas in December, 2018. 1 NA 9 Did the state review operator procedures for surveillance of cast iron pipelines, including 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: No cast iron pipe in the State of Arkansas. 1 NA 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, this is performed during the standard inspection audit and listed on the inspection form as a question to the operator. This item is listed on page 5 of 29 on AR PSC form. 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: Yes, this is reviewed prior to and during the standard inspection. 1 1 12 DUNS: 096796201 2018 Gas State Program Evaluation Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? 2 2 Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 8\n\nYes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, each inspector is required to conduct a review of the operator's annual report and perform an analysis of the data entered by the operator prior to the standard inspection. 13 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 Evaluator Notes: Inspection Report form. Yes, the inspector reviews this information prior to and during the inspection. This item is also listed on AR PSC Standard 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: Yes, a review of files found this item is checked on the AR PSC Standard Inspection Report form. 2 2 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, a review of files found this item is checked on the AR PSC Standard Inspection Report form. Additionally, if the operator changes its O&M Plan it must file the changes to the PSC within 20 days after the change(s) have occurred. 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, a review of files found this item is checked on the AR PSC Standard Inspection Report form question 13. All three larger operator programs are reviewed annually by inspector staff. 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, AR PSC reviews the operator's DIMP plans and any updates during the standard or DIMP inspection. All of the three larger operators DIMP programs are reviewed annually. 18 Is state verifying operators Public Awareness programs are up to date and being 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: 2 2 Yes, AR PSC is checking the operator's Public Awareness programs during the standard inspections conducted during the DUNS: 096796201 2018 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 9\n\nyear. In CY2018, seven public awareness reviews were conducted during the standard inspection on the private operators and three on the municipal operators. 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, AR PSC website provides information available to the public about their inspection reports, names of inspectors and telephone numbers, links to PHMSA and other safety organizations. 20 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 were submitted in CY2018. 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: AR PSC has a replacement program with operators that require them to submit what action they will be taking to replace and verify plastic pipe with know defects. 22 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: concern. Yes, a review of emails from Robert Clarillos to Bobby Henry confirmed participation in surveys from NAPSR. No areas of 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: No waivers or special permits have been issued to any operator. 1 1 24 Did the state attend the NAPSR National Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes, Bobby Henry attended the NAPSR National Meeting in Santa Fe, NM. 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: Conducted a review with Bobby Henry on the state program performance metric located on PHMSA website. Leaks continue to trend downward due to the operator's efforts in replacement of bare steel and removal of cast iron pipelines. A majority of the leaks reported by operators continue to be class 3 leaks. Accelerated action is being taken by AR PSC inspectors by monitoring the status of these leaks during their inspections. DUNS: 096796201 2018 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 10\n\n26 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 the process of entering information into the SICT with Program Manager. No issues in entering the information into the program. 27 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: No flow reversals in the State of Arkansas. However, AR PSC has this question listed on their standard inspection form to ask the operator during the audit. 28 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: 46 Total possible points for this section: 46 DUNS: 096796201 2018 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 11\n\nPART 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 Arkansas Pipeline Safety Operation and Inspection Plan, Section Procedures, page 4. b. This information is listed under Section IV. Follow-up Inspection Procedures, page 5. Additionally, they created a suspension file and track the progress of the violation being cleared. c. This is listed in the plan section on page 4. Operators are given 60 days to respond with corrective actions. The program manager and inspector review respond from the operator and make a decisions to accept or ask for more information prior to closing the violation. 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 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: Conducted a review of all 2018 inspection reports via the AR PSC website and spreadsheet maintained by Program Manager. a. Yes, a review of inspections confirm letters were sent to company officers or board member of municipal system. b. All probable violations were well documented. c. Probable violations were resolved based on a written response from the operator and a decision between the program manager and inspector. d. They routinely review all violations within a 60 day time schedule. e. They conduct an exit interview with the operator after the inspection in the field and providing information in a letter to the operator within 60 days of the inspection. f. The final inspection report is mailed 60 days after the inspection. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, a review of files and data base confirmed 136 violations were issued in CY2018. 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, AR PSC provides the operator due process in resolving all violations or areas of concern. The operator can request a formal hearing if they are unable to resolve the violation with the program manager. DUNS: 096796201 2018 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 12\n\n5 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 Needs Improvement = 1 Evaluator Notes: Yes, Bobby Henry is familiar with imposing civil penalties for non-compliance. The last civil penalty assessed was in CY 2014. 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, AR PSC took enforcement action and issued a civil penalty against an operator in CY 2014. 1 1 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: 096796201 2018 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 13\n\nPART 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: Investigation. Yes, this procedure is listed in Arkansas Pipeline Safety Operation and Inspection Plan on page 8, under Section IX. Incident 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, AR PSC adopted the federal pipeline safety regulations Part 191 that requires the operator to notify them of all incidents. The notification requires telephonic notice including after-hour reporting. a. AR PSC is aware of the MOU between the NTSB and PHMSA and has included this information in their Operation & Inspection Plan. b. They follow the federal/state cooperation agreement in all cases of an incidents. 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 NA No incidents occurred but they evaluate all reportable incidents and document the information from the operator to determine to response or not to go on site to investigate. Information on the reason to not go is provided on the incident reportable form. 4 Were all incidents investigated, thoroughly documented, and with conclusions and recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review 3 NA Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: No incidents 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 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 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: 1 NA There were no incidents that occurred in CY2018 but they have assistance PHMSA AID team when requested. DUNS: 096796201 2018 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 14\n\n7 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, the Program Manager shares information on incidents when they occur in the effective year at the annual SW NAPSR Regional 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: 5 Total possible points for this section: 5 DUNS: 096796201 2018 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 15\n\nPART 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? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, a question pertaining to directional drilling/boring procedures was added to the standard inspection form. This question is asked and checked with the operator during the inspection. 2 Did the state inspector verify pipeline operators are following their written procedures 2 2 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, the inspector is verifying this requirement in a review of the operator's procedures and checking the marking of the pipeline during the field inspection. 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, AR PSC continue to promote the use and adoption of CGA Best Practices at meetings or training seminars. 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, they continue to tabulate data on damages and review the trends in the PDM. In CY2018 the number of hits per 1,000 tickets has dropped from 7.0 to 6.8. 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: 096796201 2018 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 16\n\nPART 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: Center Point Energy - Arkansas Name of State Inspector(s) Observed: Jerry Harris, PSO Pipeline Safety Coordinator Location of Inspection: Jacksonville, AR Date of Inspection: June 19, 2019 Name of PHMSA Representative: Glynn Blanton, PHMSA State Evaluator Evaluator Notes: This was a standard inspection that included a review of regulator stations and odorization readings at the end of the distribution system. The following individuals from Center Point Energy were present during the inspection; Ms. Sharon Utley, Jimmy Utley, Robert Schafer & Steven Crook. The field inspection included the Jacksonville & Cabot areas. 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: Ye, Jerry Harris contacted company officials two weeks prior to the inspection. 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 2 2 Evaluator Notes: Yes, Jerry Harris used the federal inspection form to record the results of the regulator station relief settings and type of regulators at each station location. 4 Did the inspector thoroughly document results of the inspection? 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, it was observed Jerry Harris was writing down the results of the testing of the relief devices when checked and recording the types of regulators each location. 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, Jerry Harris verified with the operator the type of tools and gauges necessary to test the relief settings prior to testing the devices. 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, the inspector, Jerry Harris, conducted a review of the settings of each relief device and regulator station settings in the DUNS: 096796201 2018 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 17\n\nJacksonville and Cabot areas. Each of the five regulator stations were reviewed and two odorization readings were taken to assure the odor level was in compliance with the MFSS. 7 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, Jerry Harris, has completed all the requirements for the Gas Inspector certification program and has over seven years of experience in pipeline safety. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: Yes, a brief exit interview was conducted in the field with the operator. The final exit interview was scheduled to be completed on Friday afternoon. 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Yes, one potential violation or area of concern was found pertaining to the operator's right of way. 1 1 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 Info Only Info Only DUNS: 096796201 2018 Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 18\n\nA. Repairs B. Signs C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Jerry Harris performed an excellent pipeline safety inspection and conducted himself in a professiona","truncated":true,"body_characters":43542}