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2012 AR NG Program Evaluation - ar2012ngprogramevaluation (Arkansas; Natural Gas State Program Evaluation)
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AR NG Program Evaluation, 2012, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2012 Natural 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 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 1#
AR NG Program Evaluation, 2012, page 22012 Natural Gas State Program Evaluation -- CY 2012 Natural Gas State Agency: Arkansas Rating: Agency Status: Date of Visit: 06/24/2013 - 01/01/1900 Agency Representative: Bobby Henry - Chief, Pipeline Safety PHMSA Representative: Don Martin Commission Chairman to whom follow up letter is to be sent: Name/Title: Collette Honorable, Chairman Agency: Arkansas Public Service Commission Address: 1000 Center Street City/State/Zip: Little Rock, Arkansas 72203 60105(a): Yes 60106(a): No Interstate Agent: Yes INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2012 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 15 15 C Program Performance 45 45 D Compliance Activities 15 15 E Incident Investigations 3 3 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 108 108 State Rating................................................................................................................................................... 100.0 DUNS: 096796201 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 2#
AR NG Program Evaluation, 2012, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress 1 1 Report Attachment 1 (A1a) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No errors were identified for authority or operator/inspection information. The information in the APSC's electronic system supported the numbers of operators and units in Attachment 1. Unit totals matched Attachment 3 totals. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: The APSC downloads information from the inspection database into a spreadsheet that subtotals inspection person days by operator type and inspection type. The subtotals on the spreadsheet matched the entries on Attachment 2. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No errors were found when comparing Attachment 3 information to the APSC's database report. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress 1 1 Report Attachment 4 (A1d) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A review of PHMSA's reporting database did not show any reportable incidents during CY2012. The APSC reported that there were reportable incidents on Attachment 4. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The compliance statistics on Attachment 5 matched the report from the APSC's database. 1 1 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Files were easily accessed and are placed in an organized manner. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 (A1g) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The employee listing and training records matched the information contained in TnQ's SABA database. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report 1 1 Attachment 8 (A1h) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: All entries matched the information contained on State Program Division's spreadsheet. There is a question pertaining to both the APSC and Arkansas Oil and Gas Commission reporting 60105 authority for gas transmission facilities that should be researched. DUNS: 096796201 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 3#
AR NG Program Evaluation, 2012, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 (H1-3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 No issues identified with Attachment 10. 10 General Comments: Info Only = No Points Evaluator Notes: The APSC has generally complied with the requirements of Part A of this evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 096796201 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 4#
AR NG Program Evaluation, 2012, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Procedures for Standard Inspections for each operator type are contained in the Arkansas Pipeline Safety Operation and Inspection Plan. Risk analysis results can cause inspections to be planned more frequently. 2 IMP Inspections (including DIMP) (B1b) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Inspection Plan. Procedures for Gas Transmission IMP and Gas Distribution IMP are contained in the Arkansas Pipeline Safety Operation and 3 OQ Inspections (B1c) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Procedures for conducting Operator Qualification inspections including Protocol 9 inspections is contained in the Arkansas Pipeline Safety Operation and Inspection Plan. 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Damage Prevention inspections are scheduled as part of Standard Inspections. 5 On-Site Operator Training (B1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: On site operator training is scheduled as needed based upon changes in operator personnel. 1 1 6 Construction Inspections (B1f) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Construction inspections are stated in the procedures to be scheduled as construction projects are started. 1 1 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Incident investigations are stated to be conducted as needed. 8 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? (B2a-d, G1,2,4) Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection 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) DUNS: 096796201 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 5#
AR NG Program Evaluation, 2012, page 6f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: All criteria listed are considered. The length of time since the last inspection is used to place a maximum limit between inspections. A detailed risk analysis spreadsheet is also used to adjust frequencies between the maximum intervals. 9 General Comments: Info Only = No Points Evaluator Notes: The APSC has generally complied with the requirements of Part B of this evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 096796201 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 6#
AR NG Program Evaluation, 2012, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 (A12) Yes = 5 No = 0 5 5 A. Total Inspection Person Days (Attachment 2): 598.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 5.50 = 1210.00 Ratio: A / B 598.00 / 1210.00 = 0.49 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: The APSC had inspection person day totals that resulted in a ratio of 0.49 which exceeded the minimum ratio of 0.38. 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines for requirements) Chapter 4.4 (A8-A11, G19) 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 Evaluator Notes: The APSC has several recently hired employees that will need to complete TnQ training classes. At this time all of the employees listed on Attachment 7 are meeting the timeframes for completing the core classes. No inspections were identified where a lead inspector had not completed the required training. 3 Did state records and discussions with state pipeline safety program manager indicate 2 2 adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues were found with the Program Manager's knowledge of PHMSA Pipeline Safety Program or regulations. The Program Manager has approximately 30 years of experience in pipeline safety. 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 (A6-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The APSC responded on the 60th day from the day it received the Chairman's letter. 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) Yes = 2 No = 0 2 2 Evaluator Notes: September, 2010 and June, 2013. Operators are also invited to a multi-state seminar in New Orleans each year. 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 (B3) Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: The APSC database has dates embedded for each operator type and inspection type that allows the reporting of required DUNS: 096796201 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 7#
AR NG Program Evaluation, 2012, page 8inspections to meet the inspection plan frequency procedures. A review of the report at year end 2012 showed that all operator units or inspection types had met the time requirement. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 (B4-5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Federal forms are used. Upon a review of randomly selected inspection reports all portions of the forms were completed. 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 (B7) Yes = 1 No = 0 Evaluator Notes: This issue is covered on question 3 of the inspection form's addendum. 1 1 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 (B8) Yes = 1 No = 0 Evaluator Notes: This issue is covered on question 4 of the inspection form's addendum. 1 1 10 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) Chapter 5.1 (B9) Yes = 1 No = 0 Evaluator Notes: This issue is covered on question 5 of the inspection form's addendum. 1 1 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 (B10,E5) Yes = 1 No = 0 Evaluator Notes: This issue is covered on question 2 of the inspection form's addendum. 1 1 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for 2 2 accuracy and analyzed data for trends and operator issues? Data Initiative (G6-9,G16) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The APSC reviews current annual reports against prior year reports and contacts the Operators when there are questions over the data. Pipeline mileage is used for assessing user fees for special revenue. The information is also analyzed to help assess the effectiveness of operator's Damage Prevention Plans. Data such as Miles of pipe, cast iron, bare steel, leak causes, & lost and unaccounted for gas are trended relative to prior years. Incident reports are reviewed for timeliness, completeness, probable cause, and completion of final report. 13 Did state input all applicable OQ, IMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 (G10-12) DUNS: 096796201 2012 Natural Gas State Program Evaluation 2 2 Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 8#
AR NG Program Evaluation, 2012, page 9Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No inspections were found which were not entered into the databases. 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? (G14) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: The Addendum page of the inspection form covers the submittal of information to the NPMS. The APSC has reviewed the NPMS and has not identified any information that was omitted by transmission operators in Arkansas. 15 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 (I1-3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes. This question is included on the addendum of the APSC's standard disribution and transmission inspection form. 16 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 (I4-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The APSC are meeting expectations related to OQ programs. The APSC's procedures address the issue of OQ programs. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 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). 49 CFR 192 Subpart 0 (I8-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The APSC is meeting the expectations for operators' gas transmission IMP programs. 2 2 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 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). 49 CFR 192 Subpart P DIMP ? First round of program inspections should be complete by December 2014 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The APSC has completed 50% of DIMP inspections required and will be close to 70% by the end of CY2013. 19 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. 49 CFR 192.616 (I13-16) PAPEI Effectiveness Inspections should be complete by December 2013 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: All of the original Public Awareness Plan reviews were conducted uitlizing the Clearinghouse. Operators were notified of amendments needed as a result of the Clearinghouse review. DUNS: 096796201 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 9#
AR NG Program Evaluation, 2012, page 10The APSC began effectiveness reviews in 2012. The APSC is on track to complete the effectiveness reviews by the end of CY2013. 20 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). (G20-21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC has a Pipeline Safety section on its website. The APSC uses the website to communicate important notifications for operators and information for all stakeholders. The website also contains copies of all inspection reports that be accessed by all stakeholders including the general public. 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 (B6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no safety related condition reports filed by operators in 2012. 1 NA 22 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? (G13) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC has had written communications addressed to operators and has also verbally communicated about the importance of identifying plastic pipe and participating in AGA's plastic pipe database project. 23 Did the state participate in/respond to surveys or information requests from NAPSR or 1 1 PHMSA? (H4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There was no instances known where the APSC did not participate or respond to surveys or requests. Bobby Henry is vice chair of southwest region, efv committee, meaningful metrics. Spencer Merrell was on API 1104 Welding Standards Sub Committee. 24 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only The APSC has generally complied with the requirements of Part C of this evaluation. Bobby Henry is Vice Chair of NAPSR's Southwest Region, EFV committee, Meaningful Metrics Team. Spencer Merrell was on API 1104 Welding Standards Sub Committee. Only one operator has cast iron remaining in its system. There will be 100 miles remaining at the end of 2013. Total points scored for this section: 45 Total possible points for this section: 45 DUNS: 096796201 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 10#
AR NG Program Evaluation, 2012, page 11PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 (B12-14, B16, B1h) 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 Evaluator Notes: The APSC notifies an officer of a private company. Notifications to all other operator types seem appropriate. The APSC keeps a suspense file that tracks the response requirements from compliance notifications sent to operators. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 (B11,B18,B19) 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. Were probable violations documented? Yes No Needs Improvement c. Were probable violations resolved? Yes No Needs Improvement d. Was the progress of probable violations routinely reviewed? Yes No Needs Improvement Evaluator Notes: Upon a review of randomly selected inspection reports proper notifications were provided to the operators, all inspection forms documented and reports were closed upon the proper response from operators. No instances were found where the APSC did not follow up on responses. 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: on inspection forms. Upon a review of randomly selected inspection reports, compliance notifications were sent for all probable violations noted 4 Did compliance actions give reasonable due process to all parties? Including "show 2 2 cause" hearing if necessary. (B17, B20) Yes = 2 No = 0 Evaluator Notes: The APSC provides 60 days for operators to respond to compliance notifications. The operators are allowed to provide information that disputes the allegations or provide information that verifies corrective action has taken place. Operators are given to opportunity to request a commission hearing if issues can't be resolved. 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) (B27) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The program manager stated the considerations for seeking civil penalties. The two key considerations are the severity of the probable violations (and their results such as injury or fatality) and whether or not the probable violation was repeated after a previous compliance action involving the same probable violation. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 1 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC has used its fining authority in the past. Most recently, a $10,000 penalty was assessed to an operator for failing to report an incident that met state reporting requirements.DUNS: 096796201 Arkansas 2012 Natural Gas State Program Evaluation ARKANSAS PUBLIC SERVICE COMMISSION, Page: 11#
AR NG Program Evaluation, 2012, page 127 General Comments: Info Only = No Points Evaluator Notes: The APSC has generally complied with the requirements of Part D of this evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 096796201 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 12#
AR NG Program Evaluation, 2012, page 13PART E - Incident Investigations Points(MAX) Score 1 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 (A2,D1-3) 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: The program manager stated his understanding of the MOU between the NTSB and PHMSA. His understanding is consistent with the language contained in the MOU. He also understands the cooperation between PHMSA and a state program in investigating incidents as outlined in the appendices of the Guidelines. 2 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 (D4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no incidents meeting federal reporting requirements during CY2012. 1 NA 3 Were all incidents investigated, thoroughly documented, and with conclusions and 3 NA recommendations? (D5) Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: There were no incidents meeting federal reporting requirements during CY2012. 4 Did the state initiate compliance action for violations found during any incident/accident investigation? (D6) Yes = 1 No = 0 Evaluator Notes: There were no incidents meeting federal reporting requirements during CY2012. 1 NA 5 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 report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 (D7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no incidents meeting federal reporting requirements during CY2012. 1 NA 6 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) (G15) Yes = 1 No = 0 Evaluator Notes: 1 1 The APSC shared incidents meeting state reporting requirements at the NAPSR Southwest Region in 2012. 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 096796201 2012 Natural Gas State Program Evaluation Info Only Info Only Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 13#
AR NG Program Evaluation, 2012, page 14The APSC has generally complied with the requirements of Part E of this evaluation. It should be noted that there were no reportable incidents (federal) during 2012. Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 096796201 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 14#
AR NG Program Evaluation, 2012, page 15PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB (E1) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The APSC addresses the risk of trenchless excavation with operators when covering the items in its inspection form addendum. 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? (E2) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 This requirement is reviewed when the APSC inspectors cover 192.614 portion of the standard inspection form. 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.) (E3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The APSC addeed this item to the Addendum of the standard inspection. Inspectors cover the items while conducting the inspection. The completed inspection forms are provided to the operator. 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) (E4,G5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The APSC has collected data on damages and is capable of charting but at this time there is not enough data history to establish a statistical trend. 5 General Comments: Info Only = No Points Evaluator Notes: The APSC has generally complied with the requirements of Part F of this evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 096796201 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 15#
AR NG Program Evaluation, 2012, page 16PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: CenterPoint Energy Name of State Inspector(s) Observed: Keith Price Location of Inspection: Little Rock, AR Date of Inspection: 9/17-18/2013 Name of PHMSA Representative: Don Martin Evaluator Notes: The APSC inspector was conducting a standard inspection of Centerpoint Energy's Little Rock, AR inspection unit. The inspection was begun on September 16, 2013. Office records and testing of facilities in the field is scheduled for the inspection. The inspection is scheduled to last two to three weeks. 2 Was the operator or operator's representative notified and/or given the opportunity to be 1 1 present during inspection? (F2) Yes = 1 No = 0 Evaluator Notes: Yes. The APSC provided two weeks notice prior to the inspection. Keith Cragg, Area Manager, represented Centerpoint during the inspection. 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) (F3) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. The APSC inspector used PHMSA Form 2, revision date 5/6/2011. During the evaluation observation the form was used to guide the inspector through the inspection process. 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The APSC inspector entered results into the electronic version of Form 2 as the inspection progressed. 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.) (F5) Yes = 1 No = 0 Evaluator Notes: Yes. The inspector reviewed the testing equipment prior to readings being taken for the day. 1 1 2 2 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) (F7) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: The scope described by the inspector would cover records and field activities during the standard inspection. The inspection is scheduled to last over two months. DUNS: 096796201 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 16#
AR NG Program Evaluation, 2012, page 177 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) (F8) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The inspector exhibited good knowledge of the regulations. 2 2 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) (F9) Yes = 1 No = 0 Evaluator Notes: The inspector conducted an exit interview for the portion conducted during the evaluation observation. 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) (F10) Yes = 1 No = 0 Evaluator Notes: Yes. Findings during the evaluation observation were communicated. 1 1 10 General Comments: What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance DUNS: 096796201 2012 Natural Gas State Program Evaluation Info Only Info Only Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 17#
AR NG Program Evaluation, 2012, page 18E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: The items checked above will be covered by inspection by the time of its completion. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 096796201 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 18#
AR NG Program Evaluation, 2012, page 19PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (C1) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC is not an interstate agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? (C2) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC is not an interstate agent. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? (C3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC is not an interstate agent. 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) (C4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC is not an interstate agent. 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? (C5) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC is not an interstate agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? (C6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC is not an interstate agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? (C7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC is not an interstate agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: The APSC is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 096796201 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 19#
AR NG Program Evaluation, 2012, page 20PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (B21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC does not have a 60106(a) agreement with PHMSA. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? (B22) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC does not have a 60106(a) agreement with PHMSA. 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) (B23) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC does not have a 60106(a) agreement with PHMSA. 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? (B24) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC does not have a 60106(a) agreement with PHMSA. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? (B25) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC does not have a 60106(a) agreement with PHMSA. 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? (B26) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The APSC does not have a 60106(a) agreement with PHMSA. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: The APSC does not have a 60106(a) agreement with PHMSA. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 096796201 2012 Natural Gas State Program Evaluation Arkansas ARKANSAS PUBLIC SERVICE COMMISSION, Page: 20#
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