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PHMSA arog-2018-gas-program-evaluation
2018 AR NG Program Evaluation - arog-2018-gas-program-evaluation (Arkansas; Natural Gas State Program Evaluation)
Current as of source date Government source
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AR NG Program Evaluation, 2018, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2018 Gas State Program Evaluation for ARKANSAS 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 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 1#
AR NG Program Evaluation, 2018, page 22018 Gas State Program Evaluation -- CY 2018 Gas State Agency: Arkansas Rating: Agency Status: Date of Visit: 09/16/2019 - 09/20/2019 Agency Representative: Michael Gary, Inspector PHMSA Representative: Patrick Gaume Commission Chairman to whom follow up letter is to be sent: Name/Title: W. Frank Morledge, Chairman Agency: Arkansas Oil & Gas Commission Address: 205 North Washington Street 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 2018 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 12 12 C Program Performance 41 41 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 109 109 State Rating................................................................................................................................................... 100.0 DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 2#
AR NG Program Evaluation, 2018, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Attachment 1 is in agreement with Attachments 3, 8, and internal records. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Attachment 2 is in agreement with internal records. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Attachment 3 is in agreement with internal records. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Attachment 4 is in agreement with internal records. No incidents in 2018 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Attachment 5 is in agreement with internal records. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Attachment 6 is in agreement with internal records. The list is correct for current titles. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Attachment 7 is in agreement with internal records. The training records appear to be correct. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Attachment 8 is in agreement with internal records. 1 1 DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 3#
AR NG Program Evaluation, 2018, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes. Planned performance in Attachment 10 is satisfactory. 10 General Comments: Info Only = No Points Evaluator Notes: There were no issues in Part A of evaluation. This section scored 10 of 10 points. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 4#
AR NG Program Evaluation, 2018, 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 Yes. Standard Inspection procedures are contained in Section VI, VII, and VIII 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: NA. The AOGC has no jurisdictional operators in the IMP and DIMP programs. 1 NA 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: Yes. 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 Yes. 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 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. On-Site Operator Training procedures are contained in Section X of the AOGC Inspection Guidelines. 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: Yes. Construction Inspection procedures are contained in Section IX of the AOGC Inspection Guidelines. 1 1 7 Does inspection plan address inspection priorities of each operator, and if necessary each unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 6 6 DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 5#
AR NG Program Evaluation, 2018, page 6a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: Yes*6. 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. A2 was NA. 12 of 12 points were awarded. Info Only Info Only Total points scored for this section: 12 Total possible points for this section: 12 DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 6#
AR NG Program Evaluation, 2018, 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): 29.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 0.35 = 77.00 Ratio: A / B 29.00 / 77.00 = 0.38 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 0 Evaluator Notes: Yes. 0.35 inspector years, 29 field inspection days. 29/(220*0.35)=.3766, rounds to .38 Okay 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*5. The Program Manager and Lead Inspector are fully qualified. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 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: NA. No letter was required last year. 2 NA 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: Yes. The previous seminar was held in 2016, and was just completed in August of 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 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 7#
AR NG Program Evaluation, 2018, 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: NA. 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: NA. 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: Yes. 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: Yes. 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: Yes. 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: Yes. This item is included in the AOGC Form 1 inspection checklist 1 1 DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 8#
AR NG Program Evaluation, 2018, 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, five D/A inspections in 2016, and four D/A inspections in 2018. 15 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. There was three OQ inspections performed in 2018, There were 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: Yes. IM identification questions are asked during every standard Inspection. The AOGC has no jurisdictional operators in the IMP program. After Protocol A re-inspections in 2017, there were 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: NA. 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. PAPEIs are on schedule with the 8 operator PAPEEs and proving the PAP are up to date 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: Yes. 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 1 1 DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 9#
AR NG Program Evaluation, 2018, page 10Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. There are no open SRCRs for the AOGC in 2017 or 2018. Procedures are in place. 21 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. AOGC utilizes the questions form the standard inspection regarding leaks, incidents and SRC reports to drive toward any issues determined by the operator on plastic pipe and components. AOGC also has a lower threshold amount for reporting and utilizes its own Form 27 to also evaluate this matter 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 PHMSA 1 1 23 If the State has issued any waivers/special permits for any operator, has the state verified 1 NA 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: NA. The AOGC has not issued any waivers or special permits to any operators. I recommended that Waiver Procedures be developed. 24 Did the state attend the NAPSR National Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes. The AOGC attended the National NAPSR meeting in Santa Fe, NM in 2018 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: Yes. All performance metrics were trending in an acceptable manner. Excavation Damages per 1000 locate tickets show none jurisdictional to AOGC. Inspection days per 1000 miles of gas pipe has been trending down but here have been no safety issues. Inspections are being performed per annual work plans. Inspector qualification is 100% for core training. Gas Distribution system leaks are NA for AOGC. Incident investigation program is being handled appropriately. There have been no incidents since 2010. Enforcement Program Evaluation is steady at 94 - 100%. 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: Yes. Discussed the SICT data with the AOGC, and the SICT tool was calculated at 27; Attachment 2 of Progress Report for 2017 was 29 inspection days. No issue DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 10#
AR NG Program Evaluation, 2018, page 1127 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 1 NA Evaluator Notes: NA. There were no flow reversals, product changes, or conversion of services in 2017 or 2018. 28 General Comments: Info Only = No Points Evaluator Notes: NA on C4,C8,C9,C17,C23, & C27. Section scored 41 of 41. Info Only Info Only Total points scored for this section: 41 Total possible points for this section: 41 DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 11#
AR NG Program Evaluation, 2018, 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? (Incident Investigations do not need to meet 30/90 day requirement) Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: Yes*6. 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. No 30/90 deadlines were missed. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Procedures are in place. The AOGC issued 0 compliance actions in 2018. 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 is 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 in 2018. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 12#
AR NG Program Evaluation, 2018, page 13Evaluator Notes: 2018. Yes. The AOGC did assess a civil penalty of $25,000 in 2017 for a pipeline violation. The civil penalty was collected in 7 General Comments: Info Only = No Points Evaluator Notes: No issues were found. 15 of 15 points were awarded Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 13#
AR NG Program Evaluation, 2018, 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 in 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: Yes. There were no reportable incidents in 2018. Procedures are in place. 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: Yes. Procedures are in place. No incidents in 2018. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: Yes. Procedures are in place. No incidents in 2018. 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: Yes. Procedures are in place. No incidents from PHMSA in 2018. 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 2018 Gas State Program Evaluation 1 1 Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 14#
AR NG Program Evaluation, 2018, page 15Yes. It is Policy to Share incident lessons during Regional NAPSR Meetings. There were no incidents in 2018 8 General Comments: Info Only = No Points Evaluator Notes: No issues Found. 11 of 11 points were awarded. Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 15#
AR NG Program Evaluation, 2018, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 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 members 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 2018. There were no issues. 5 General Comments: Info Only = No Points Evaluator Notes: No issues in this section. 8 of 8 points were awarded. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 16#
AR NG Program Evaluation, 2018, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Stephens Production Co. opid 32268 Name of State Inspector(s) Observed: Michael Gray Location of Inspection: at a field site in Ft. Smith, AR Date of Inspection: 09/19/2019 Name of PHMSA Representative: Patrick Gaume Evaluator Notes: Additional AOGC personnel were Bryan Brown and Gary Looney. 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 Evaluator Notes: Yes. AOGC scheduled the inspection and four operator personnel were present at the inspection. 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The federal gas inspection form was used for this field inspection. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The field inspection portion of the form was completely filled out. 2 2 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.) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes. Operator provided all equipment necessary for this field inspection including keys, tools, half cell and multimeter. 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: Yes. Field inspection at 3 sites were thoroughly reviewed. 2 2 7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) 2 2 DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 17#
AR NG Program Evaluation, 2018, page 18Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, all 3 AOGC inspectors are thoroughly trained and professional in the way they conduct inspections. 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. All items inspected were reviewed with the operator and no violations were found. 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. All items inspected were reviewed with the operator and no violations were found. 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 E. Vault Maintenance Info Only Info Only DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 18#
AR NG Program Evaluation, 2018, page 19F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: All points were awarded in this section. 12 of 12 points were awareded. DUNS: NA 2018 Gas State Program Evaluation Total points scored for this section: 12 Total possible points for this section: 12 Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 19#
AR NG Program Evaluation, 2018, 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: H 1-8. NA-not an interstate agent program. 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: H 1-8. NA-not an interstate agent program. 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: H 1-8. NA-not an interstate agent program. 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: H 1-8. NA-not an interstate agent program. 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: H 1-8. NA-not an interstate agent program. 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: H 1-8. NA-not an interstate agent program. 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: H 1-8. NA-not an interstate agent program. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: H 1-8. NA-not an interstate agent program. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 20#
AR NG Program Evaluation, 2018, 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: I 1-7. NA. Not a 60106 agreement program 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: I 1-7. NA. Not a 60106 agreement program 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: I 1-7. NA. Not a 60106 agreement program 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: I 1-7. NA. Not a 60106 agreement program 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: I 1-7. NA. Not a 60106 agreement program 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: I 1-7. NA. Not a 60106 agreement program 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: I 1-7. NA. Not a 60106 agreement program Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: NA 2018 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 21#
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