Inspectionhistorical
PHMSA ar2009ngprogramevaluation
2009 AR NG Program Evaluation - ar2009ngprogramevaluation (Arkansas; Natural Gas State Program Evaluation)
Current as of source date Government source
RegulusPipeline researchRegulusPipeline researchPHMSA ar2009ngprogramevaluation
AR NG Program Evaluation, 2009, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2009 Natural Gas State Program Evaluation for ARKANSAS PUBLIC SERVICE COMMISSION Document Legend PART: O -- Representative Date and Title Information A -- General Program Qualifications B -- Inspections and Compliance - Procedures/Records/Performance C -- Interstate Agent States D -- Incident Investigations E -- Damage Prevention Initiatives F -- Field Inspection G -- PHMSA Initiatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 096796201 2009 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 1#
AR NG Program Evaluation, 2009, page 22009 Natural Gas State Program Evaluation -- CY 2009 Natural Gas State Agency: Arkansas Rating: Agency Status: Date of Visit: 09/13/2010 - 09/17/2010 Agency Representative: PHMSA Representative: Patrick, Gaume Commission Chairman to whom follow up letter is to be sent: Name/Title: Paul Suskie, Chairman Agency: Arkansas Public Service Commission Address: 1000 Center St City/State/Zip: Little Rock, Arkansas 72203-0400 60105(a): Yes 60106(a): No Interstate Agent: No Robert Henry, Sr Inspector & Robert Booth, Manager, Gas & Water Utilities Section 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 2009 (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 certification/agreement attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART F): 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 F, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A General Program Qualifications 26 25 B Inspections and Compliance - Procedures/Records/Performance 24.5 24.5 C Interstate Agent States 0 0 D Incident Investigations 6.5 6.5 E Damage Prevention Initiatives 9 9 F Field Inspection 10 10 G PHMSA Initiatives - Strategic Plan 9 9 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 97 96 State Rating................................................................................................................................................... 99.0 DUNS: 096796201 2009 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 2#
AR NG Program Evaluation, 2009, page 3PART A - General Program Qualifications Points(MAX) Score 1 Did the state submit complete and accurate information on the attachments to its most current 60105(a) Certification/60106 (a) Agreement? (NOTE: PHMSA Representative to verify certification/agreement attachments by reviewing appropriate state documentation. Score a deficiency in any one area as "needs improvement". Attachment numbers appear in parenthesis) Previous Question A.1, Items a-h worth 1 point each Yes = 8 No = 0 Needs Minor Improvement = 3-7 Needs Major Improvement = 2 a. State Jurisdiction and agent status over gas facilities (1) b. Total state inspection activity (2) c. Gas facilities subject to state safety jurisdiction (3) d. Gas pipeline incidents (4) e. State compliance actions (5) f. State record maintenance and reporting (6) g. State employees directly involved in the gas pipeline safety program (7) h. State compliance with Federal requirements (8) 8 7 SLR Notes: A.1 IMPROVEMENT NEEDED 7 points. A---- Need to CHANGE- change Transmission Interstate from 'F' to 'B', & change Transmission Interstate LNG from 'F' to 'A' AR PSC has both 192 & 193; there is one LNG facility, Arkansas Western Gas, Blytheville Plant. b----all operators are seen on a two year rotation, not to exceed 3 calendar years. c----are listed on attachment 3 of the Natural Gas certification document. D----1 significant incident was not reported on Attachment 4; #20090052, NRC 899711, Arkansas Western Gas Co, 3/11/2009. 2 of the 3 significant Incidents in 2009 were reported. 2009 was an abnormal year as there was only 1 incident in '05 and 0 in '06, '07, & '08. e----59 in '05, 66 in '06, 99 in '07, 153 in '08, & 113 in 2009. All were processed per AR commission rules. f----keeping paper, spreadsheet, & d-base files. (good redundancy). g----It was noted that some of the classes that Inspectors have completed were not reported on this attachment. In August 2010, each inspector reviewed and compared his records of classes with Attachment 7 and with TQ records of his classes. The records that are used to generate Attachment 7 are fully current and complete. While some classes were omitted from Attachment 7, all classes reported have been verified as completed. All inspector TSI training & inspectors have their core training except for the new hire. h----in full compliance. 2 Did the state have an adequate mechanism to receive operator reporting of incidents to ensure state compliance with 60105(a) Certification/60106(a) Agreement requirements (fatality, injury requiring hospitalization, property damage exceeding $50,000 - Mechanism should include receiving "after hours" reports)? (Chapter 6) Previous Question A.2 Yes = 1 No = 0 1 1 SLR Notes: A.2 Yes, APSC requires the Operators to report to both the State and the Fed for federally reportable incidents. In addition the APSC has a $5000 reporting requirement, & requires a report for any injury that requires a Doctor's visit 3 Has the state held a pipeline safety TQ seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar or if state requested seminar, but T&Q could not provide, indicate date of state request for seminar. Seminars must be held at least once every 3 calendar years.) (Chapter 8.5) Previous Question A.4 Yes = 2 No = 0 SLR Notes: A.3 Yes, APSC hosted a TSI Seminar on June 20-21, 2007 and on 8/10-11/2010. The nest one will likely occur in 2013 2 2 4 Were pipeline safety program files well-organized and accessible?(NOTE: This also includes electronic files) (Chapter 5) Previous Question A.5 Yes = 1 No = 0 SLR Notes: A.4 Yes, the files are in file cabinets in three PSC offices 1 1 5 Did state records and discussions with the state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? (Chapter 4.1, Chapter 8.1) Previous Question A.6 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: A.5 Yes, Clint has a professional knowledge of the 49 CFR 190-194 regulations. 49 CFR 195 Hazardous Liquid Regulation is not handled by APSC. APSC considered but did not request authorization for Hazardous Liquid Regulation in the 2008 or 2010 Legislatures. APSC continues to consider the submission of a request for Hazardous Liquid Regulation as they have been encouraged to by PHMSA 6 Did the state respond in writing within 60 days to the requested items in the Chairman's letter following the Region's last program evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8 1 1 DUNS: 096796201 2009 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 3#
AR NG Program Evaluation, 2009, page 4Yes = 1 No = 0 SLR Notes: A.6 Yes, The Chairman letter was sent within 50 days of receipt. It addressed efforts for effective civil penalties for Damage Prevention, improving the data base for tracking inspections, consideration for inspecting Hazardous Liquid lines, improved consistency between inspection reports and violation letters, using risked base analysis for choosing inspections, using data to evaluate one-call effectiveness, efforts to keep the NPMS current , and updates to the D&A questionnaire. 7 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the 1 1 previous year? Did actions correct or address deficiencies from previous year's evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8/A.9 Yes = 1 No = 0 SLR Notes: A.7 Yes, The Chairman letter was sent within 50 days of receipt. It addressed efforts for effective civil penalties for Damage Prevention, improving the data base for tracking inspections, consideration for inspecting Hazardous Liquid lines, improved consistency between inspection reports and violation letters, using risked base analysis for choosing inspections, using data to evaluate one-call effectiveness, efforts to keep the NPMS current , and updates to the D&A questionnaire. Specifically APSC has been working with Bob McArthur, CEO of AR One Call, to compare the 9 elements with the current AR Damage Prevention Law. Many elements are being addressed, but enforcement has not been effectively addressed Personnel and Qualifications 8 Has each inspector fulfilled the 3 year TQ training requirement? If No, has the state been granted a waiver regarding TQ courses by the Associate Administrator for Pipeline Safety? (NOTE: If the State has new inspectors who have not attended all TQ courses, but are in a program which will achieve the completion of all applicable courses within 3 years of taking first course (5 years to sucessfully complete), or if a waiver has been granted by the applicable Region Director for the state, please answer yes.) (Chapter 4.4) Previous Question A.10 Yes = 3 No = 0 SLR Notes: A.8 Yes, the inspectors are trained or their training is underway and is on track to meet the 'within three years' time requirement 3 3 9 Brief Description of Non-TQ training Activities: Info Only = No Points Info Only Info Only For State Personnel: State personnel- annual H2S awareness training 8 hours. One inspector maintains the 8 hour hazwoper re- certification. All staff had an 8-hr first aid course, some are CPR certified. For Operators: Operators- In '09 APSC personnel attended and supported Nat'l and Regional NAPSR, participated on the NAPSR EFV committee, hosted a Master Meter training seminar in Little Rock, also individual on-site training of Operators. For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: Non-Operator- there were no activities in 2009. Emphasis continues to be on training the new employees. SLR Notes: A.9 State personnel- annual H2S awareness training 8 hours. One inspector maintains the 8 hour hazwoper re-certification. All staff had an 8-hr first aid course, some are CPR certified. Operators- In '09 APSC personnel attended and supported Nat'l and Regional NAPSR, participated on the NAPSR EFV committee, hosted a Master Meter training seminar in Little Rock, also individual on-site training of Operators. Non-Operator- there were no activities in 2009. Emphasis continues to be on training the new employees. 10 Did the lead inspectors complete all required T&Q OQ courses and Computer Based Training (CBT) before conducting OQ Inspections? (Chapter 4.4.1) Previous Question A.12 Yes = 1 No = 0 1 1 SLR Notes: A.10 Bobby Henry was trained in Dec 2003 & Steve O'Connor was trained in Oct 2003. 4 inspectors have been trained in Course 299 (PL3OQ). All OQ inspections are done by those 3 inspectors 11 Did the lead inspectors complete all required TQ Integrity Management (IMP) Courses/Seminars and CBT before conducting IMP Inspections? (Chapter 4.4.1) Previous Question A.13 Yes = 1 No = 0 SLR Notes: A.11 Greg Loarie trained Jun 2005, & Bobby Henry trained Jun 2005 are the IMP Leads. 3 Inspectors have taken T&Q Course 297 1 1 12 DUNS: 096796201 2009 Natural Gas State Program Evaluation Was the ratio acceptable of Total inspection Person-days to Total Person-days charged to the program by state inspectors? (Region Director may modify points for just cause) (Chapter 4.3) Previous Question B.12 5 5 Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 4#
AR NG Program Evaluation, 2009, page 5Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 645.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 6.25 = 1375.00 Ratio: A / B 645.00 / 1375.00 = 0.47 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 SLR Notes: A.12- a- '09 total inspection days 659. b- person days '09 is 6.25*220=1375 days. c-score=A/B '09 score=659/1375=.479. .479 is greater than .38. Okay 13 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Info Only Info Only Question B.13 Info Only = No Points SLR Notes: A.13. ? Yes, authorized staffing levels for 2009 increased by 1 inspector in November 2009. It is now 1 supervisor, 7 inspectors, & 1 clerical. In July, 2010 Clint Stephens resigned to become a Fed. Bobby Henry is serving as 50% inspector/50% administrative duties until a new Chief is selected. Staffing for 2006, '07, & '08 were unchanged at 1 supervisor, 6 inspectors, & 1 clerical. Had resignations in August, 2008 (Ben Beaver) and July, 2010 (Clint Stephens); had new hires in April (Jason Donham) and October, 2008 (Mike Gray), and in October (Phillip Brown), 2009. Training for new hires is on pace 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: A.14 The program to replace cast iron & bare pipe continues. At this point only one operator has any significant amount of cast iron pipe. The Operator is working a 27 year plan that started in 2001 and will continue through 2027. a summary of the last few years follows: Year cast iron (miles) bare steel (miles) cost (million$) 2006 29.46 41.12 12.0 2007 31.6 55.24 17.5 2008 23.12 23.33 14.3 2009 14.0 37.4 11.3 Bare pipe with other operators has not shown to be an integrity problem. 2009 NAPSR participation included; Mr Bobby Henry being named to the NAPSR Excess Flow Valve Committee, and Clint Stephens serving on the Public Awareness Committee. Clint was also on the inactive Gathering Line NAPSR Committee. The Arkansas PSO intends to nominate additional NAPSR staff members as NAPSR committee postions become available. The Pipeline Safety Office (PSO), participates in the Arkansas Department of Emergency Management's (ADEM) comprehensive Emergency Operations Plan with emphasis on gas leak response due to natural disaster or manmade events. Natural Disaster threats are mostly tornados or ice storms with consideration for the New Madrid fault and floods. All necessary pipeline code revisions were submitted on December 10, 2008 to the 2008 Legislature and they were approved. APSC has been working with Bob McArthur, CEO of AR One Call, to compare the 9 elements with the current AR Damage Prevention Law. During 2009, APSC spent 14 man days in this effort. Many elements are being addressed, but enforcement has not been effectively addressed. A review of the 9 elements relative to Arkansas Laws and the AR One Call program shows that 8 of the elements are being met or nearly met. The exception is element 7, Enforcement. One-Call enforcements; citations, fines, letters, civil penalties; they are not happening Total points scored for this section: 25 Total possible points for this section: 26 DUNS: 096796201 2009 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 5#
AR NG Program Evaluation, 2009, page 6PART B - Inspections and Compliance - Procedures/Records/ Performance Points(MAX) Score Inspection Procedures 1 Does the State have a written inspection plan to complete the following? (all types of operators including LNG) 6.5 6.5 (Chapter 5.1) Previous Question B.1 + Chapter 5 Changes + Incorporate LNG Yes = 6.5 No = 0 Needs Improvement = 50% Deduction a Standard Inspections (Including LNG) (Max points = 2) b IMP Inspections (Including DIMP) (Max points = .5) c OQ Inspections (Max points = .5) d Damage Prevention (Max points = .5) e On-Site Operator Training (Max points = .5) f Construction Inspections (Max points = .5) g Incident/Accident Investigations (Max points = 1) h Compliance Follow-up (Max points = 1) Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement SLR Notes: B.1. a, b, c, d, e, f, g, & h, Yes, have procedures in the Arkansas Pipeline Safety Operation and Inspection Plan. Damage Prevention is part of the Std Inspections 2 Did the written Procedures for selecting operators adequately address key concerns? (Chapter 5.1) Previous 2 2 Question B.2, items a-d are worth .5 point each Yes = 2 No = 0 Needs Improvement = 50% Deduction a Length of time since last inspection Yes No Needs Improvement b History of Operator/unit and/or location (including leakage , incident and compliance history) Yes No Needs Improvement c Type of activity being undertaken by operator (construction etc) Yes No Needs Improvement d For large operators, rotation of locations inspected Yes No Needs Improvement SLR Notes: B.2 All selecting criteria are named and used, but the dominate criteria is length of time since the last inspection. The other criteria are used more for determining special and follow-up inspections Inspection Performance 3 Did the state inspect all types of operators and inspection units in accordance with time intervals established in its written procedures? (Chapter 5.1) Previous Question B.3 Yes = 2 No = 0 2 2 SLR Notes: B.3 Improvement Needed ?If improvement needed is not available then will choose Yes. YES for Standard Inspections. All Units are within a 3 year inspection cycle. Could not determine inspection frequency for OQ & IM inspections of Operators, however, as OQ & IM were performed in 2005, then 2009 is within the 5 yr re-inspection interval. Information Technology attempts to generate an Operator list that showed OQ & IM inspection frequencies was not successful during this Evaluation visit. This is an area of concern for next year's evaluation 4 Did the state inspection form cover all applicable code requirements addressed on the Federal Inspection forms? (Chapter 5.1 (3)) Previous Question B.4 Yes = 1 No = 0 1 1 SLR Notes: B.4- Arkansas uses the federal forms that have been modified in places to meet more stringent Arkansas regulations 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 1 1 Yes = 1 No = 0 SLR Notes: B.5- Yes. A spot check of OQ and Standard inspections showed the reports to be complete, with U, NA, and NC items explained, and the inspection was consistent with the NOPV letter 6 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.6 DUNS: 096796201 2009 Natural Gas State Program Evaluation .5 NA Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 6#
AR NG Program Evaluation, 2009, page 7Yes = .5 No = 0 SLR Notes: B.6- NA no SRCR in 2009 7 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) Previous Question B.7 Yes = .5 No = 0 .5 .5 SLR Notes: B.7- Yes. In early '07 it was discovered that this question was not well addressed on the current Federal inspection form. APSC modified the Federal Form to include this subject. APSC is emphasizing cast iron pipe replacement, & reviews every leak repair form to check that proper procedures were followed every time. Luckily, graphitization is a very minor cause of leaks in cast iron pipes in Arkansas, (brittle fracture is the major cause) 8 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) Previous Question B.8 Yes = .5 No = 0 .5 .5 SLR Notes: B.8- Yes. In early '07 it was discovered that this question was not well addressed on the current inspection form. APSC modified the Federal Form to include this subject. AR does inspect to Appendix G-192-18. AR policy includes a financial incentive to replace cast iron pipe & bare steel pipe 9 Did the state review operator emergency response procedures for leaks caused by 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) Previous Question B.9 Yes = .5 No = 0 .5 .5 SLR Notes: B.9- Yes. In early '07 it was discovered that this question was not well addressed on the current inspection form. APSC modified the Federal Form to include this subject. AR emphasizes review of operator responses to emergencies or leaks at or near buildings 10 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? (NTSB) Previous Question 1 1 B.10 Yes = 1 No = 0 SLR Notes: B.10 ? Yes. AR has more stringent requirements for reporting accidents. All reportable accidents are reviewed to ensure proper response Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous 1 1 Question B.14 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.11 Yes. all violations are documented and processed through the Commission rules. All information is kept in the same file; the inspection, the evidence, the violation letter, the response, the final finding? 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a 1 1 probable violation as specified in the "Guidelines for State Participating in the Pipeline Safety Program"? (Chapter 5.1) Previous Question D(1).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.12 Yes, & the Commission has its own rules for processing any probable violations noted in it's inspection program. Effective August, 2010, a peer review of NOPV reports has been initiated until a new Pipeline Chief has been found 13 Does the state have written procedures to notify an operator when a noncompliance is identified as specified in the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(4)) Previous Question D 1 1 (1).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: inspection) B.13 Yes. The Commission sends notices to the operators that have probable violations, NOA, recommendations, or no violations found (notice of DUNS: 096796201 2009 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 7#
AR NG Program Evaluation, 2009, page 814 Does the state have a written procedure for routinely reviewing the progress of compliance actions to prevent delays or breakdowns of the enforcement process, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(5)) Previous Question D(1).3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Inspector) B.14 Yes. The tracking system is 'the suspense file', Dbase tracking, & also a spreadsheet maintained by the Chief. (as of 8/2010 Acting Lead & Sr 15 Has the State issued compliance actions for all probable violations discovered? (Note : PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation) Previous Question D(1).4 Yes = 1 No = 0 SLR Notes: B.15 Yes, 113 in 2009. Violations are found regularly during inspections and notices are sent out 1 1 16 Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that prompt corrective actions were taken by operators, within the time frames established by the procedures and compliance correspondence, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? Previous Question D(1).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.16 Yes, AR follows its written program. Notices are followed until compliance is achieved 1 1 17 If compliance could not be established by other means, did state pipeline safety program staff request formal action, such as a "Show Cause Hearing" to correct pipeline safety violations? (check each states enforcement procedures) Previous Question D(1).6 No = 0 Yes = 1 1 1 SLR Notes: B.17 Yes. It is an available process, but is rarely needed (Show Cause Hearing). Most Operators are cooperative. Even fines are seldom necessary 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question D(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.18 Yes. Final resolutions are documented and placed in the appropriate file 1 1 19 Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question D(1).8 Yes = .5 No = 0 SLR Notes: B.19 Yes, APSC sends notices to owners or Corporate officers .5 .5 20 Did the compliance proceedings give reasonable due process to all parties? (check each states enforcement procedures) Previous Question D(1).9 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: show cause hearings B.20 Yes. It is a formalized process that is followed and explained to the Operator in the notice letter. Per the Plan, it includes notices, response times, & Compliance - 60106(a) States 21 Did the state use the current federal inspection form(s)? Previous Question D(2).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.21 ? B.26 NA. Arkansas is a 60105(a) program 1 NA 22 Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question D(2).2 Yes = 1 No = 0 Needs Improvement = .5 DUNS: 096796201 2009 Natural Gas State Program Evaluation 1 NA Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 8#
AR NG Program Evaluation, 2009, page 9SLR Notes: B.21 ? B.26 NA. Arkansas is a 60105(a) program 23 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.) Previous Question D(2).3 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: B.21 ? B.26 NA. Arkansas is a 60105(a) program 24 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(2).4 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: B.21 ? B.26 NA. Arkansas is a 60105(a) program 25 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(2).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: B.21 ? B.26 NA. Arkansas is a 60105(a) program 26 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Previous Question D(2).6 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: B.21 ? B.26 NA. Arkansas is a 60105(a) program 27 Part B: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: B.27 The Arkansas Pipeline Safety Office (PSO) continues to be well run. The new Inspection Database has now been in operation for close to two years, it has proven to be an improvement over the previous system and further improvement is promised. The PSO was allowed to increase staff by 1 inspector in October, 2009. The PSO is dedicating manpower to OQ, IMP, Damage Prevention, Public awareness, Gathering Line Regulations, Construction Inspections, & other special projects in addition to its primary focus on Standard Inspections. The Expansion of the program to include Hazardous Liquid was re-visited Total points scored for this section: 24.5 Total possible points for this section: 24.5 DUNS: 096796201 2009 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 9#
AR NG Program Evaluation, 2009, page 10PART C - Interstate Agent States Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Previous Question D(3).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: C.1 ? C.8. NA. Not an Interstate Agent 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Previous Question D(3).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: C.1 ? C.8. NA. 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? Previous Question D(3).3 Yes = 1 No = 0 SLR Notes: C.1 ? C.8. NA. Not an Interstate Agent 1 NA 4 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.) Previous Question D(3).4 Yes = 1 No = 0 1 NA SLR Notes: C.1 ? C.8. NA. Not an Interstate Agent 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(3).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: C.1 ? C.8. NA. Not an Interstate Agent 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(3).6 Yes = 1 No = 0 SLR Notes: C.1 ? C.8. NA. Not an Interstate Agent 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Previous Question D(3).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: C.1 ? C.8. NA. Not an Interstate Agent 1 NA 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: C.1 ? C.8. NA. Not an Interstate Agent Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 096796201 2009 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 10#
AR NG Program Evaluation, 2009, page 11PART D - Incident Investigations Points(MAX) Score 1 Are state personnel following the procedures for Federal/State cooperation in case of an incident? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6.1) Previous Question E.1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: D.1 Yes, 'Appendix E ? Federal/State Cooperation in Case of an Incident/Accident' is being followed 1 1 2 Are state personnel familiar with the jurisdictional authority and Memorandum of Understanding between NTSB and PHMSA? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6 ? Appendix D) Previous Question E.2 Yes = .5 No = 0 SLR Notes: D.2 Yes, the State has a good understanding of the MOU between NTSB and DOT (PHMSA) .5 .5 3 Did the state keep adequate records of incident notifications received? Previous Question E.3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: D.3 YES, All incidents are investigated and a report is made. (one incident in '05, none since) 1 1 4 If an onsite investigation of an incident was not made, did the state obtain sufficient information by other means to determine the facts and support the decision not to go on-site? Previous Question E.4 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: D.4 Yes, telephonic contact, but it is the practice of PSC to visit every federally reportable incident 1 1 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? Previous Question E.5, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Observations and Document Review 2 2 b. Contributing Factors c. Recommendations to prevent recurrences where appropriate SLR Notes: Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement D.5 Yes, Fed Form F7100.1 is required of all Federal or State reportable incidents. In the event that a site visit is made, the PHMSA Form 11 is used. In '09, there were 3 Fed reportable incidents reported. Two of the federally reportable incidents were visited on-site & the other was handled telephonically. 6 Did the state initiate enforcement action for violations found during any incident investigation(s)? Previous Question E.6 Variation Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: D.6 Yes, there were 3 Fed reportable incidents and there were probable violations found on 2 of those incidents 1 1 7 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate annual report data from operators concerning incidents/accidents and investigate discrepancies) (Chapter 6) Previous Question E.7/E.8 Yes = .5 No = 0 SLR Notes: D.7 NA, there were no Federal follow up actions in '09. All historical intrastate incidents have been closed .5 NA 8 Part D: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: D.8 Yes, NRC reports are received, telephonic reports are filed, and site visits are made for federally reportable incidents. Form F7100.1 reports will be reviewed & checked to ensure a final report has been submitted. How a significant Federally reportable incident missed being reported on the 2010 Natural Gas Certification will be investigatedDUNS: 096796201 Arkansas 2009 Natural Gas State Program Evaluation ARKANSAS PUBLIC SERVICE COMMISSION, Page: 11#
AR NG Program Evaluation, 2009, page 12Total points scored for this section: 6.5 Total possible points for this section: 6.5 DUNS: 096796201 2009 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 12#
AR NG Program Evaluation, 2009, page 13PART E - Damage Prevention Initiatives 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? Previous Question B.11 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: E.1 In early '07 it was discovered that this question was not well addressed on the current Federal Standard Inspection form. APSC modified the Federal Form to include this subject. APSC reviews operator's directional drilling procedures during their inspections, and requires 'pot-holing' to insure the bored pipe is located correctly 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? New 2008 Yes = 2 No = 0 2 2 SLR Notes: E.2 Yes, it is in the Std Insp Form, under Damage Prevention 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to 2 2 its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.7 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: E.3 Yes, APSC has a One-Call link on its web site. It is addressed in the every 3rd year TSI Seminars. It is reviewed during every Standard Inspection. In '09 APSC helped to establish an Arkansas CGA Regional Partnership. Specifically APSC has been working with Bob McArthur, CEO of AR One Call, to compare the 9 elements with the current AR Damage Prevention Law. Many elements are being addressed, but enforcement has not been effectively addressed. One-call membership is mandatory of all underground utilities including Gas Operators. AR Law 14-271 requires One-Call notifications with exceptions per 14-271-109 (hand tools, some routine road work, farming, graves, pre-engineered projects, & some emergency responses), and allows for Civil penalties per 14-271-104. In '06-participated in a legislative initiative to require mandatory one-call membership for any company with underground facilities. Senate Bill 82. In '05-participated with an RP 1162 compliance seminar. PSC regulates the One-call center 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? New 2008 Yes = 1 No = 0 1 1 SLR Notes: E.4 ARKUPS, the pipe locating service of AR One-Call tracks the number of locates per damage. It was 1/2832 in 2009 and 1/3012 in 2010 year to date 5 Did the state review operators' records of accidents and failures due to excavation damage to ensure causes of failure are addressed to minimize the possibility of recurrence as required by 192.617? Yes = 2 No = 0 SLR Notes: E.5 Yes, for federally reportable and State reportable incidents 2 2 6 Part E: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only E.6 APSC continues to work on achieving the 9 elements of the 2006 PIPES ACT. The AR CGA was created in 2009 Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 096796201 2009 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 13#
AR NG Program Evaluation, 2009, page 14PART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Center Point Energy Arkansas Gas Co, opid 603 Name of State Inspector(s) Observed: Risa Parker Location of Inspection: Oppello, Perry, and Perryville, AR Date of Inspection: September 15, 2010 Name of PHMSA Representative: Patrick Gaume SLR Notes: F.1 Center Point Energy Arkansas Gas Co, opid 603 Risa Parker Oppello, Perry, and Perryville, AR September 15, 2010 Patrick Gaume Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? New 2008 Yes = 1 No = 0 SLR Notes: F.2 Yes, the Operator was notified in advance and they had up to 4 personnel participating in the inspection 1 1 3 Did the inspector use an acceptable inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Previous Question F.2 Yes = 2 No = 0 SLR Notes: F.3 Yes, Form 2, Standard Inspection Report of Gas Distribution Operator, Rev 03/28/10 2 2 4 Did the inspector thoroughly document results of the inspection? Previous Question F.3 Yes = 2 No = 0 2 NA SLR Notes: F.4 NA, A full day field inspection was observed, the field notes were through, but filling out the Form was not the targeted objective on the day I observed. I have full confidence the Form will be filled out based on the field notes 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps, pyrometer, soap spray, CGI, etc.) New 2008 Yes = 1 No = 0 1 1 SLR Notes: F.5 Yes, multi-meter, CGI unit, Operator CP list, half cell, hand tools, paint, brushes, mastic coating, replacement meters, signs, stickers, etc 6 What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) New 2008 Info Only = No Points Info Only Info Only SLR Notes: F.6 Standard Inspection of a Distribution Unit, specifically a field inspection of 35 cp points with, associated meters, valves, regulators, exposed pipe, etc 7 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) New 2008, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records DUNS: 096796201 2009 Natural Gas State Program Evaluation 2 2 Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 14#
AR NG Program Evaluation, 2009, page 15c. Field Activities/Facilities d. Other (Please Comment) SLR Notes: F.7 Yes, This was a Field portion of a full standard inspection and was focused on field activities 8 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Liaison will document reasons if unacceptable) Previous Question F.8 Yes = 2 No = 0 SLR Notes: F.8. Yes, Risa showed adequate knowledge of the pipeline safety program goals and regulations 2 2 9 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) Previous Question F.10 Yes = 1 No = 0 SLR Notes: F.9. Yes, it was an 'end-of-day' review 1 1 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous 1 1 Question F.11 Yes = 1 No = 0 SLR Notes: F.10. Yes, The 2 low CP sites will be PV, the rest are within regulations. The day's work included stops at 35 sites. Found 2 low CP sites, smelled gas at 5 locations and witnessed the on-site repair of 4 of them, replaced 2 meters, repaired a meter site that had been hit, visited 3 exposed mains and witnessed the on-site repair of the coating of one exposed main, will plan to monitor work orders to erect a barrier where a meter had been hit, and to remove a fallen tree that is a threat to an exposed main; and to do follow-up field verification of them 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector Info Only Info Only performed) Info Only = No Points SLR Notes: F.11 atmospheric corrosion, pipeline integrity, marker condition, blind plate flanges, exposed mains, meter supports, tags, leak tests and repairs, valves, regulators, signs, CP, CGI tests, locks, chains, and fences, meter ground clearance 12 Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only Info Only = No Points SLR Notes: F.12 Spend time in the Field! You ALWAYS find items needing attention Info Only 13 Field Observation Areas Observed (check all that apply) 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 DUNS: 096796201 2009 Natural Gas State Program Evaluation Info Only Info Only Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 15#
AR NG Program Evaluation, 2009, page 16p. 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 C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other SLR Notes: F.13 atmospheric corrosion, pipeline integrity, marker condition, blind plate flanges, exposed mains, meter supports, tags, leak tests and repairs, valves, regulators, signs, CP, CGI tests, locks, chains, and fences, meter ground clearance. Checked items; a, f, g, i, j, k, l, m, o, q, u, v, y, A, B, D, I 14 Part F: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: F.14 On September 15, 2010, Ms. Risa Parker performed a Field portion of a Standard Inspection of a gas distribution Unit Operated by Center Point Energy Arkansas Gas Co at Oppello, Perry, and Perryville, AR. The Evaluation was to observe Ms. Parker while she performed a day of Field Inspection of the gas distribution Unit. The Operator was very cooperative and Ms. Parker conducted herself in a courteous, competent, and professional manner Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 096796201 2009 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 16#
AR NG Program Evaluation, 2009, page 17PART G - PHMSA Initiatives - Strategic Plan Points(MAX) Score Risk base Inspections - Targeting High Risk Areas 1 Does state have process to identify high risk inspection units? Yes = 1.5 No = 0 1.5 1.5 Risk Factors (criteria) to consider may include: Miles of HCA's, Geographic area, Population Density Length of time since last inspection History of Individual Operator units (leakage, incident and compliance history, etc.) Threats - (Excavation Damage, Corrosion, Natural Forces, Other Outside Forces, Material or Welds, Equipment, Operations, Other) SLR Notes: G.1 Mostly; The Arkansas PSO has identified the majority of the various risk factors and they have been written into the O&I Plan for Standard, OQ, & IMP. The specific information has been broken out and loaded into four Master Spreadsheets. The weighted answers help to identify the 'Problem Operators'. The spreadsheet is focused on Operators and not Units. APSC is satisfied that a risk review by operator is sufficient. The applicability of the spreadsheets are reviewed every time they are used and all staff feel free to recommend tweaks to the spreadsheets 2 Are inspection units broken down appropriately? (see definitions in Guidelines) Yes = .5 No = 0 SLR Notes: G.2 Yes, Units are created by Operator, pipe location, Operator management unit, etc .5 0.5 3 Consideration of operators DIMP Plan? (if available and pending rulemaking) Info Only = No Points Info Only Info Only SLR Notes: G.3 Yes, APSC is aware of the pending DIMP Rule and will implement the DIMP inspections per the federal guidelines. Four staff are registered for DeWitt's March, 2011 DIMP Class 4 Does state inspection process target high risk areas? Yes = .5 No = 0 SLR Notes: G.4 Yes, the O&I Plan names several high risk factors to consider, and units are selected for inspection in accordance with the O&I .5 0.5 Use of Data to Help Drive Program Priority and Inspections 5 Does state use data to analyze effectiveness of damage prevention efforts in the state? (DIRT or other data, etc) .5 0.5 Yes = .5 No = 0 SLR Notes: G.5 Yes, have # calls and # damages in AR but disaggregated into more specific information is a work in progress. DIRT started being used in 2009, and is addressed during every Std Inspection 6 Has state reviewed data on Operator Annual reports for accuracy? Yes = .5 No = 0 .5 0.5 SLR Notes: G.6 Yes, the APSC Pipeline Chief personally reviews current annual reports against prior year reports and contacts the Operators when there are questions over the data. Also, pipeline mileage is used for assessing user fees so it is closely monitored. Since August, 2010, the Acting Chief and Sr. Inspector each do this duty until a new Chief is found 7 Has state analyzed annual report data for trends and operator issues? Yes = .5 No = 0 .5 0.5 SLR Notes: years G.7. APSC reviews the Form for completeness, miles of pipe, cast iron, bare steel, leak causes, & lost and unaccounted for gas and trends it relative to prior 8 Has state reviewed data on Incident/Accident reports for accuracy? Yes = .5 No = 0 DUNS: 096796201 2009 Natural Gas State Program Evaluation .5 0.5 Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 17#
AR NG Program Evaluation, 2009, page 18SLR Notes: G.8. Yes, incident reports are reviewed for completeness, probable cause, final report, timeliness, & necessary procedural changes. It is part of the determination to identify the Root cause, probable violations, and possible fines 9 Does state do evaluation of effectiveness of program based on data? (i.e. performance measures, trends, etc.) .5 0.5 Yes = .5 No = 0 SLR Notes: G.9 Yes, Program effectiveness is measured relative to State & Federal reportable incidents, miles of cast iron and bare steel replaced, number of violations & number of violations corrected, the scheduling of inspections in a timely manner and then further prioritized relative to probable violations, how the PV were resolved, & incidents if any 10 Did the State input all operator qualification inspection results into web based database provided by PHMSA in a timely manner upon completion of OQ inspections? Previous Question B.15 Yes = .5 No = 0 .5 0.5 SLR Notes: G.10 Yes, In 2009, APSC focused on OQ Protocol 9 inspections, and performed at least one Protocol 9 inspection for every Operator inspected. They were all uploaded into the OQ database by year end. In 2009 full OQ re-inspections commenced 11 Did the State submit their replies into the Integrity Management Database (IMDB) in response to the Operators notifications for their integrity management program? Previous Question B.16 Yes = .5 No = 0 SLR Notes: G.11 NA, no replies have been required from APSC .5 NA 12 Have the IMP Federal Protocol forms been uploaded to the IMDB? Previous Question B.17 Yes = .5 No = 0 SLR Notes: G.12 NA, there were no IMP inspections .5 NA 13 Did the State ask Operators to identify any plastic pipe and components that has shown a record of defects/leaks and what those operators are doing to mitigate the safety concerns? Previous Question B.18 Yes = .5 No = 0 .5 0.5 SLR Notes: G.13 Yes, APSC has strongly recommended to all distribution companies with plastic pipe to participate and provide data to the PLASTIC PIPE DATA BASE COMMITTEE. (PPDC) with the AGA providing umbrella support. The Aldyl-A plastic pipe advisory has been distributed to all the Distribution Companies. AR is the test site for the new PA-11 project which is the first project to use 4" pipe. A waiver has been provided to go to 200 psig MAOP. AR may be a test site for PA-12 in 2011 14 Has state confirmed transmission operators have submitted information into National Pipeline Mapping System (NPMS) database along with any changes made after original submission? Yes = .5 No = 0 .5 0.5 SLR Notes: G.14 Yes APSC noted the requirement and effective 7/22/09 added this requirement to the Standard Inspection Form Addendum Sheet Accident/Incident Investigation Learning and Sharing Lessons Learned 15 Has state shared lessons learned from incidents/accidents? (i.e. NAPSR meetings and communications) .5 0.5 Yes = .5 No = 0 SLR Notes: G.15 Yes, LDNR makes a report during the SW Region NAPSR Meeting, and responds as appropriate to email correspondence. There were 3 noteworthy accidents/incidents in 2009 and lessons learned will be shared at SW Region NAPSR 16 Does the State support data gathering efforts concerning accidents? (Frequency/Consequence/etc) .5 0.5 Yes = .5 No = 0 SLR Notes: G.16. Yes, reports are received, followup is made, paperwork is checked, lessons learned are derived, Accident causes and regulatory compliance are determined, and site visits are usually made. Operators are encouraged to share lessons learned. Inspector duties are strongly outlined in the O&I Plan 17 DUNS: 096796201 2009 Natural Gas State Program Evaluation Does state have incident/accident criteria for conducting root cause analysis? Info Only Info Only Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 18#
AR NG Program Evaluation, 2009, page 19Info Only = No Points SLR Notes: G.17 APSC does not have a criteria for a formal Root Cause Analysis at this time. One inspector took the Root Cause class in 2008, and another inspector took the class in 2010. Will place all pipeline inspectors on the Root Cause class wait list at the next opportunity. They do search for probable cause and compliance with the regulations at this time. APSC has been made aware of the DIRT Form, and use of the DIRT Form started in 2009 18 Does state conduct root cause analysis on incidents/accidents in state? Info Only = No Points Info Only Info Only SLR Notes: G.18 APSC does not have a criteria for a formal Root Cause Analysis at this time. One inspector took the Root Cause class in 2008, and another inspector took the class in 2010. Will place all pipeline inspectors on the Root Cause class wait list at the next opportunity. They do search for probable cause and compliance with the regulations at this time. APSC has been made aware of the DIRT Form, and use of the DIRT Form started in 2009 19 Has state participated on root cause analysis training? (can also be on wait list) Yes = .5 No = 0 SLR Notes: G.19 Yes, Two inspectors have taken the course to date. They will place all inspectors on the Root Cause class wait list .5 0.5 Transparency - Communication with Stakeholders 20 Other than pipeline safety seminar does State communicate with stakeholders? (Communicate program data, .5 0.5 pub awareness, etc.) Yes = .5 No = 0 SLR Notes: G.20 APSC has a web site which offers emergency contact numbers, natural gas hazards, annual reports for all operators in Arkansas, links to related sites including PHMSA, & Safety tips for the Public 21 Does state share enforcement data with public? (Website, newsletters, docket access, etc.) .5 0.5 Yes = .5 No = 0 SLR Notes: G.21 Yes, all Operators have docket access. Currently the Public has rights to request and receive paper and electronic records. APSC has been made aware that other States are posting finalized Inspection results on their web sites and is considering doing the same 22 Part G: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: G.22 APSC participates within NAPSR to share lessons learned from incident investigations. APSC is developing an outreach program to better communicate with Operators and the public. An item for consideration is increased use of the website to post finalized inspections. The risk ranking spreadsheets started being used in 2009. DIRT started being used in 2009. Two inspectors have received Root Cause Analysis training. More inspectors are scheduled for Root Cause Analysis Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 096796201 2009 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 19#
AR NG Program Evaluation, 2009, page 20PART H - Miscellaneous Points(MAX) Score 1 What were the major accomplishments for the year being evaluated? (Describe the accomplishments, NAPSR Activities and Participation, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: H.1 Have been able to hire 2 new employees in 2008 and one in 2009 which increased full Inspector staff complement from 6 to 7. Successfully worked with AR One-Call to develop and create the AR CGA. Have been able to determine that 8 of the 9 elements for Damage Prevention in the 2006 PIPES Act have been mostly met. Have identified and inspected a Regulated Gas Gathering Company operating in the Fayetteville Shale Play. The new Inspection Database has now been in use for two years. The program to replace cast iron & bare pipe continues 2 What legislative or program initiatives are taking place/planned in the state, past, present, and future? (Describe initiatives (i.e. damage prevention, jurisdiction/authority, compliance/administrative, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: H.2 The PSO enforces current Federal Regulations and provides technical information to the AR Legislature to make changes as needed in State Laws. The necessary changes were approved by the 2008 Legislature. Effective enforcement of the State One-call rule is still needed. The PSO was approved to increase staff by one Inspector 3 Any Risk Reduction Accomplishments/Projects? (i.e. Cast iron replacement projects,bare steel,third-party damage reductions, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: H.3 The program to replace cast iron & bare pipe continues. Most of the 9 elements have been achieved 4 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 1 1 SLR Notes: H.4 Yes, APSC works with NAPSR, T&Q, NTSB, & PHMSA, and responds to all surveys 5 Sharing Best Practices with Other States - (General Program) Yes = .5 No = 0 SLR Notes: H.5 Yes, through SW Region NAPSR & correspondence with other States .5 0.5 6 Part H: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: H.6 Have been able to hire 2 new employees in 2008 and one in 2009 which increased full Inspector staff complement from 6 to 7. Successfully worked with AR One-Call to develop and create the AR CGA. Have been able to determine that 8 of the 9 elements for Damage Prevention in the 2006 PIPES Act have been mostly met. Have identified and inspected a Regulated Gas Gathering Company operating in the Fayetteville Shale Play. The new Inspection Database has now been in use for two years. The program to replace cast iron & bare pipe continues Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 096796201 2009 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 20#
AR NG Program Evaluation, 2009, page 21PART I - Program Initiatives Points(MAX) Score Drug and Alcohol Testing (49 CFR Part 199) 1 Has the state verified that operators have drug and alcohol testing programs? Yes = 1 No = 0 SLR Notes: I.1 Yes, since the inception of the D&A Program, and verifies with all new Operators 1 1 2 Is the state verifying that operators are conducting the drug and alcohol tests required by the operators program (random, post-incident, etc.) Yes = .5 No = 0 SLR Notes: I.2 Yes, in 2009 APSC conducted several D&A short & long forms. They D&A inspected 15 Operators in 2009 .5 0.5 3 Is the state verifying that any positive tests are responded to in accordance with the operator's program? Yes = .5 No = 0 SLR Notes: I.3 Yes, This question was added to the Standard inspection Addendum Sheet on 7/22/09 .5 0.5 Qualification of Pipeline Personnel (49 CFR Part 192 Subpart N) 4 Has the state verified that operators have a written qualification program? Yes = 1 No = 0 SLR Notes: I.4 Yes. All Operators have been OQ inspected and re-inspected. Several Protocol 9 inspections are done every year 1 1 5 Has the state reviewed operator qualification programs for compliance with PHMSA rules and protocols? .5 Yes = .5 No = 0 SLR Notes: I.5 Yes, All OQ inspections were done using Federal Forms and according to Federal guidelines. All Operators came into compliance 0.5 6 Is the state verifying that persons who perform covered tasks for the operator are qualified in accordance with the operator's program? Yes = .5 No = 0 SLR Notes: I.6 Yes, it is covered in the OQ inspections. Also Protocol 9 reviews are done every year .5 0.5 7 Is the state verifying that persons who perform covered task for the operator are requalified at the intervals specified in the operator's program? Yes = .5 No = 0 SLR Notes: I.7 Yes, OQ records are checked during every OQ inspection and every Protocol 9 inspection .5 0.5 Gas Transmission Pipeline Integrity Management (49 CFR Part 192 Subpart O) 8 Has the state verified that all operators with transmission pipelines have either adopted an integrity management program (IMP), or have properly determined that one is not required? Yes = 1 No = 0 1 1 SLR Notes: I.8 Yes, all Gas Operators have been contacted. All Gas Operators have either declared they have prepared a GIMP program or declared they have no HCAs. Every Gas Operator with an identified HCA have received a full GIMP Inspection. The inspections have been uploaded into the fed database. All Gas Operator Protocol A have been reviewed 9 Has the state verified that in determining whether a plan is required, the operator correctly calculated the potential impact radii and properly applied the definition of a high consequence area? Yes = .5 No = 0 SLR Notes: DUNS: 096796201 2009 Natural Gas State Program Evaluation .5 0.5 Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 21#
AR NG Program Evaluation, 2009, page 22I.9 Yes, the impact radii calculations and the HCA determinations have been verified during every GIMP review 10 Has the state reviewed operator IMPs for compliance with Subpart O? (In accordance with State Inspection .5 0.5 plan) Yes = .5 No = 0 SLR Notes: I.10 Yes, all initial GIMP have been done and compliance with subpart O has been checked. GIMP re-inspections are scheduled to start in October, 2010 11 Is the state monitoring operator progress on the inspections, tests and remedial actions required by the operator's IMP, including that they are being done in the manner and schedule called for in its IMP? Yes = .5 No = 0 SLR Notes: I.11 Yes, tests and remedial actions are being checked for compliance with their plan .5 0.5 12 Is the state verifying that operators are periodically examining their transmission line routes for the appearance .5 0.5 of new HCAs? Yes = .5 No = 0 SLR Notes: I.12 Yes, all Gas Transmission Operators have had their first GIMP inspection, and any new HCA will be reviewed during the next GIMP inspection. GIMP re-inspections are scheduled to start in October, 2010 Public Awareness (49 CFR Section 192.616) 13 Has the state verified that each operator has developed a continuing public awareness program? (due date was .5 0.5 6/20/06 for most operators, 6/20/07 for certain very small operators,6/13/08 for master meters) Yes = .5 No = 0 SLR Notes: I.13 Yes, First compared the AR Operator list with the Clearing House plan submission list and verified all had submitted. Then reviewed and resolved with the Operators all the Clearing House and CATS exceptions. Master Meters have received directions from APSC on how to create their Public Awareness Programs. The Master Meter Programs are currently being reviewed 14 Has the state reviewed the content of these programs for compliance with 192.616 (by participating in the Clearinghouse or by other means)? Yes = .5 No = 0 .5 0.5 SLR Notes: I.14 Yes, and have also reviewed and resolved with the Operator all the Clearing House and CATS exceptions. The Master Meter Programs are in progress 15 Is the state verifying that operators are conducting the public awareness activities called for in its program? Yes = .5 No = 0 SLR Notes: I.15 Yes, through records review during Standard Inspections .5 0.5 16 Is the state verifying that operators have evaluated their Public Awareness programs for effectiveness as described in RP1162? Info Only = No Points Info Only Info Only SLR Notes: I.16 This was not an area of emphasis during 2009, implementation of the program was. Many operators are asking for guidance in how to self assess their Damage prevention Program. Clint was assigned to go to the Houston workshop but he resigned to go to work for the Feds the week before it happened. There is hope this will be addressed during Nat'l NAPSR 17 Part I: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: start I.17 APSC has an active D&A inspection program, is performing OQ Protocol 9 inspections, has performed all the initial GIMP inspections, and has done the Public Awareness reviews. Master Meter Public Awareness reviews is a work in progress. OQ and GIMP re-inspections have started or are about to DUNS: 096796201 2009 Natural Gas State Program Evaluation Total points scored for this section: 9 Total possible points for this section: 9 Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 22#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.