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PHMSA arog-2017-gas-program-evaluation
2017 AR NG Program Evaluation - arog-2017-gas-program-evaluation (Arkansas; Natural Gas State Program Evaluation)
Current as of source date Government source
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AR NG Program Evaluation, 2017, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2017 Gas State Program Evaluation for ARKANSAS OIL AND GAS 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: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 1#
AR NG Program Evaluation, 2017, page 22017 Gas State Program Evaluation -- CY 2017 Gas State Agency: Arkansas Rating: Agency Status: Date of Visit: 10/25/2018 - 10/27/2018 Agency Representative: October 4, 2018 Mr. Gary Looney Assistant Director PHMSA Representative: Mr. Clint Stephens Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. W. Frank Morledge, Chairman Agency: Arkansas Oil and Gas Commission Address: 205 N. Washington City/State/Zip: Forrest City, Arkansas 72335 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2017 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 13 13 C Program Performance 45 45 D Compliance Activities 15 15 E Incident Investigations 11 11 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 114 114 State Rating................................................................................................................................................... 100.0 DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 2#
AR NG Program Evaluation, 2017, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: The accuracy of jurisdictional authority and operator/inspection units' data in Attachment 1 seems to have no issues. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The accuracy for inspection days in Attachment 2 was reviewed and seems to have no issues. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: The accuracy of operators and operators' inspection units in Attachment 3 seemed to correct with no issues. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no reportable incidents in CY2017 as listed in Attachment 4. This was verified in the PDM. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The accuracy of compliance activities in Attachment 5 seems accurate with no issues. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Program files are well organized and accessible by filing paper copies, and electronically on the agency network drive. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 The employee listing of training seemed accurate based on Attachment 7 data and comparing information in SABA. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: State Program is up to date with Rules and Amendments. 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 3#
AR NG Program Evaluation, 2017, page 4Evaluator Notes: Planned performance in Attachment 10 is satisfactory. 10 General Comments: Info Only = No Points Evaluator Notes: There were no issues with Part A of the evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 4#
AR NG Program Evaluation, 2017, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Standard Inspection procedures are contained in Section VI, VII, and VII of the AOGC Inspection Guidelines. 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The AOGC has no jurisdictional operators in the IMP and DIMP programs. 1 1 3 OQ Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: OQ Inspection procedures are contained in Section XI of the AOGC Inspection Guidelines. 1 1 4 Damage Prevention Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Damage Prevention Inspection procedures are contained in Section XIII of the AOGC Inspection Guidelines. 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: On-Site Operator Training procedures are contained in Section X of the AOGC Inspection Guidelines. 1 1 6 Construction Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Construction Inspection procedures are contained in Section IX of the AOGC Inspection Guidelines. 1 1 DUNS: NA 2017 Gas State Program Evaluation 7 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 5#
AR NG Program Evaluation, 2017, page 6c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: AOGC has established a spreadsheet which outlines each operator and the different types and class of pipelines owned and operated by that operator. These pipelines by operator type are set up on an inspection cycle which is being tracked by the AOGC. 8 General Comments: Info Only = No Points Evaluator Notes: There were no issues in Part B of evaluation. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 6#
AR NG Program Evaluation, 2017, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 33.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 0.40 = 88.00 Ratio: A / B 33.00 / 88.00 = 0.38 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 0 Evaluator Notes: Based on Attachment - 7 of 2017 Progress Report ? Ratio: A/B = 33/220 x .40 = 33/88 = .375 >= .38. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: Yes. The state pipeline manager indicates adequate knowledge of PHMSA program and regulations. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The state pipeline manager indicates adequate knowledge of PHMSA program and regulations. 2 2 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: There was no Chairman's letter response required from the AOGC. 2 2 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: The previous seminar was held in 2016, and is scheduled for 2019. 1 1 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: 5 5 DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 7#
AR NG Program Evaluation, 2017, page 8Yes. Based on review of inspection reports, the AOGC inspected all types of operators and inspection units in accordance with time intervals outlined in the AOGC Inspection Guidelines. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The AOGC is using the PHMSA Form 1 during its inspections. 2 2 8 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: The AOGC has no jurisdictional operators with cast iron pipe. 1 NA 9 Did the state review operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: The AOGC has no jurisdictional operators with cast iron pipe. 1 NA 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 Yes = 1 No = 0 Evaluator Notes: The AOGC has added an addendum to its inspection form which includes this procedure. 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 Yes = 1 No = 0 Evaluator Notes: This item is included in the AOGC Form 1 inspection checklist. 1 1 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: The AOGC reviews operator annual reports, along with Incident/Accident reports for accuracy. These reports are also included with records files when the AOGC perform operator inspections. 13 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: This item is included in the AOGC Form 1 inspection checklist. 1 1 DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 8#
AR NG Program Evaluation, 2017, page 914 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The drug and alcohol tests are conducted as required by regulation. There were four D/A inspections preformed in 2015, and five D/A inspections in 2016. 15 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: There was two OQ inspections performed in 2017. There were three performed in 2016, and two performed in 2015. 16 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually? Are replies to Operator IM notifications addressed? (formerly part of Question C-13)). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The AOGC has no jurisdictional operators in the IMP program. After a Protocol A re-inspections in 2017, there no jurisdictional operators identified. 17 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). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The AOGC has no jurisdictional operators in the DIMP program. 2 NA 18 Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Reviewed inspection report performed in 2017 for Great Lakes with no issues. 2 2 19 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The AOGC has included inspection reports and compliance cases on its website for public access. The AOGC attends the annual APRO (Arkansas Independent Producers and Royalty Owners) meeting with oil and gas producer stakeholders to discuss issues pertaining to public outreach. 20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 9#
AR NG Program Evaluation, 2017, page 10Evaluator Notes: There are no open SRCRs for the AOGC in 2017. 21 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? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: This question relates to gas distribution systems, and the AOGC has no gas distribution operators. 1 1 22 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. The AOGC responds to all surveys and request for information from NAPSR and/or NAPSR. 1 1 23 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: The AOGC has not issued any waivers or special permits to any operators. 1 1 24 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes. The AOGC attended the National NAPSR meeting in Columbus, OH in 2017. 1 1 25 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: All performance metrics were trending in the positive direction. 26 Discussion with State on accuracy of inspection day information submitted into State 1 1 Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: Discussed the SICT data with the AOGC, and the SICT tool was calculated at 27; Attachment 2 of Progress Report for 2017 was 33 inspection days. No issue. 27 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: There were no flow reversals, product changes, or conversion of services in 2017. 1 1 28 General Comments: Info Only = No Points Evaluator Notes: DUNS: NA 2017 Gas State Program Evaluation Info Only Info Only Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 10#
AR NG Program Evaluation, 2017, page 11There were no issues in Part C of evaluation. Total points scored for this section: 45 Total possible points for this section: 45 DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 11#
AR NG Program Evaluation, 2017, page 12PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: Yes. The procedures are contained in Section XV and XVI of the AOGC Inspection Guidelines. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: Yes. The AOGC followed compliance procedures from discovery to resolution, and adequately documented all probable violations. The AOGCs Rule A-5 requires a written letter be sent 30 days upon conclusion of inspection. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The AOGC issued one compliance action in 2017. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes. The operator was given due process which is contained within the Commission Rule A-5. 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The program manager is familiar with the state process for imposing civil penalties. However, there were no civil penalties for repeat violations or violations resulting in incidents or accidents. 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: DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 12#
AR NG Program Evaluation, 2017, page 13Yes. The AOGC did assess a civil penalty of $25,000 in 2017 for a pipeline violation. The civil penalty was collected in 2018. 7 General Comments: Info Only = No Points Evaluator Notes: There were no issues in Part D of evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 13#
AR NG Program Evaluation, 2017, page 14PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ 2 2 accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The AOGC incident/accident procedures are contained section XII of the AOGC Inspection Guidelines. 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: Yes. There is a 24 hour call in number for pipeline incidents which are routed to staff. The agreement to work with NTSB and PHMSA is included in section XII of the AOGC Inspection Guidelines. 3 If onsite investigation was not made, did state obtain sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no reportable incidents in 2017. 1 1 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: There were no reportable incidents in 2017. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: There were no reportable incidents in 2017. 1 1 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no reportable incidents in 2017. 1 1 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: DUNS: NA 2017 Gas State Program Evaluation 1 1 Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 14#
AR NG Program Evaluation, 2017, page 15There were no reportable incidents in 2017. 8 General Comments: Info Only = No Points Evaluator Notes: There were no issues in Part E of evaluation. DUNS: NA 2017 Gas State Program Evaluation Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 15#
AR NG Program Evaluation, 2017, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This question is included in the addendum to the inspection form. There were no issues. 2 2 2 Did the state inspector verify pipeline operators are following their written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes. The question is included in the inspection form Part 192.614 ? Damage Prevention Procedures. There were no issues. 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. All operators jurisdictional to the AOGC are member of one-call. On the AOGC website there is a link to Arkansas One-call, the 811 call before you dig logo, and information to contact 811. There were no issues. 4 Has the agency or another organization within the state collected data and evaluated 2 2 trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. AOGC jurisdictional operators are asked information pertaining to pipeline excavation damage per locate request. There has not been any pipeline locate damages per > 9000 locate request in 2017. There were no issues. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues in Part F of evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 16#
AR NG Program Evaluation, 2017, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: XTO Energy Inc. Name of State Inspector(s) Observed: Mr. Michael Gray Location of Inspection: Clarksville, AR Date of Inspection: September 27, 2018 Name of PHMSA Representative: Mr. Clint Stephens Evaluator Notes: The inspection performed by the AOGC was a standard gas pipeline field inspection. Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 1 1 Evaluator Notes: Yes. The operator's representative was notified and given the opportunity to be present during the inspection. 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist 2 2 used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The inspector used the appropriate inspection form during the inspection, and it was used as guide for the inspection process. 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The inspector documented the results of the inspection. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: The inspector used a pipe wrench to operate pipeline valves; and copper-copper half cell to check cathodic protection during the inspection. 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: Only a field inspection was performed during the inspection. 2 2 DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 17#
AR NG Program Evaluation, 2017, page 187 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The inspector had adequate knowledge of the pipeline safety program and 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) Yes = 1 No = 0 Evaluator Notes: Yes. The inspector conducted an exit interview. 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Yes, the inspector did an exit interview, but know probable violations were found during the inspection. 1 1 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance Info Only Info Only DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 18#
AR NG Program Evaluation, 2017, page 19E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: The following areas were observed during the inspection: cathodic protection, line markers, overpressure protection, valve maintenance, and atmospheric corrosion. There were no issues identified. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 19#
AR NG Program Evaluation, 2017, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: AOGC is not an interstate agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: AOGC is not an interstate agent. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: AOGC is not an interstate agent. 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: AOGC is not an interstate agent. 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: AOGC is not an interstate agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: AOGC is not an interstate agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: AOGC is not an interstate agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: AOGC is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 20#
AR NG Program Evaluation, 2017, page 21PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: AOGC has no 60106 Agreement. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: AOGC has no 60106 Agreement. 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: AOGC has no 60106 Agreement. 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: AOGC has no 60106 Agreement. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: AOGC has no 60106 Agreement. 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: AOGC has no 60106 Agreement. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: AOGC has no 60106 Agreement. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: NA 2017 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 21#
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