# 2020 AR NG Program Evaluation - arog-2020-gas-program-evaluation (Arkansas; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA arog-2020-gas-program-evaluation
- **title:** 2020 AR NG Program Evaluation - arog-2020-gas-program-evaluation (Arkansas; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2020-01-01
- **effective on:** Not available
- **summary:** 2020 PHMSA natural gas program evaluation for Arkansas.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2022-05/arog-2020-gas-program-evaluation.pdf
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1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2020 Gas State Program Evaluation for ARKANSAS OIL AND GAS COMMISSION Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: NA 2020 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 1

2020 Gas State Program Evaluation -- CY 2020 Gas State Agency: Arkansas Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: No Date of Visit: 10/04/2021 - 10/08/2021 Agency Representative: Gary Looney, Assistant Director, Arkansas Oil and Gas Commission Bryan Brown, Sr. Petroleum Geologist, Arkansas Oil and Gas Commission PHMSA Representative: Patrick Gaume, State Liaison, PHMSA 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 INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2020 (not the status of performance at the time of the evaluation). 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 than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their 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 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 49 49 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 99 99 State Rating................................................................................................................................................... 100.0 DUNS: NA 2020 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 2

PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress Info Only Info Only report) Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: okay. Attachment 1 & 3 had typos: attach 1 - change gathering operators to show 4 of 5; change gathering Units to show 9 of 46. Attach 3 - change Fayetteville Gathering Company to show 0 gathering lines. Add note to show: Fayetteville Gathering Company derated and lowered the operating pressure of its 4 gathering lines during 2020 to make them become non- jurisdictional. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: NA 2020 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 3

PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities 5 5 for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. TIMP and DIMP Inspections (reviewing largest operator(s) plans annually) c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) g. LNG Inspections Evaluator Notes: B1 Yes. Pre, During, & Post procedures are clear. Standard Inspection procedures are contained in Section VI, VII, and VIII of the AOGC Inspection Guidelines; The AOGC has no jurisdictional operators in the LNG, IMP and DIMP programs; OQ Inspection procedures are contained in Section XI of the AOGC Inspection Guidelines; Damage Prevention Inspection procedures are contained in Section XIII of the AOGC Inspection Guidelines; On-Site Operator Training procedures are contained in Section X of the AOGC Inspection Guidelines; Construction Inspection procedures are contained in Section IX of the AOGC Inspection Guidelines. 2 Do written procedures address inspection priorities of each operator, and if necessary 4 4 each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? Evaluator Notes: B2. 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 a 3 yr. inspection cycle. Not to exceed 5 yr, which is being tracked by the AOGC. 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 3 3 taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: B3. 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. No 30/90 deadlines were missed. The procedures are contained in Section XV and XVI of the AOGC Inspection Guidelines. 4 (Incident/Accident Investigations) Does the state have written procedures to address state actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 3 3 DUNS: NA 2020 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 4

a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. Evaluator Notes: B4. Yes. The AOGC incident/accident procedures are contained in section XII of the AOGC Inspection Guidelines. The Guidelines address response and onsite investigations. No Incident in 2020. 5 General Comments: Info Only = No Points Evaluator Notes: B5. Part B scored 15 of 15 points. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: NA 2020 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 5

PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See 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 b. Completion of Required DIMP/IMP Training before conducting inspection as lead c. Completion of Required LNG Training before conducting inspection as lead d. Root Cause Training by at least one inspector/program manager e. Note any outside training completed f. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) 5 5 Evaluator Notes: C1. Yes. Gary Looney & Bryan Brown team inspect. Bryan Brown completed necessary Gas training in 2nd Qtr 2020. 2 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 = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: C2. Yes. Gary is very knowledgeable of PHMSA program and regulations 5 5 3 General Comments: Info Only = No Points Evaluator Notes: C3. Part C 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 2020 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 6

PART D - Program Performance Points(MAX) Score 1 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 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction (did state achieve 20% of total inspection person-days?) g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) 5 5 Evaluator Notes: D1. Yes. Great Lakes Chemical Corporation, Riverfront Exploration, LLC, & Merit Energy Company were reviewed. All applicable inspections are current. Both construction activities in 2020 were witnessed. The 20% Field time for Construction was not achieved (2/34 days), but all available construction was witnessed in the Field. 2 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. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) 10 10 Evaluator Notes: D2. Yes. All types of inspections were reviewed for Great Lakes Chemical Corporation, Riverfront Exploration, LLC, & Merit Energy Company. The inspections were complete. Federal forms were used. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: D3. Yes. The OQ programs are up to date. Federal Form 15 is being used. 2 2 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 a. Are the state's largest operator(s) plans being reviewed annually to ensure they are completing the full cycle of the DIMP/IMP process? b. Are states verifying with operators any plastic pipe and components that have shown a record of defects/leaks and mitigating those through DIMP plan? c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? 2 2 DUNS: NA 2020 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 7

Evaluator Notes: D4. Yes. The plans are verified and are up to date. AOGC has a 'Not Applicable' exposure to the concerns cited in 4b & 4c. The operators in their jurisdiction don't deal with those issues. 5 Did the state review the following (these items are NTSB recommendations to PHMSA that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. 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); c. 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; d. 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; e. 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; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? Evaluator Notes: D5. Yes. All items are addressed with an addendum sheet to the Standard Inspection. 2 2 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued 1 1 since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: D6. Yes. Advisory Notices are forwarded to Operators via email, typically on the same date that they are received from PHMSA. 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns 10 10 DUNS: NA 2020 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 8

j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) Evaluator Notes: D7. Yes. All items, a-j, are addressed within the Pipeline Procedures, and A5 of the Commission Rules. 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did 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? i. Does state share any lessons learned from incidents/accidents? Evaluator Notes: D8. Yes. Items a-i are in the Procedures, there were no incidents in 2020. 10 10 9 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 = 1 No = 0 Needs Improvement = .5 Evaluator Notes: D9. Yes. Notice letter was on 10/27/2020. The response was 11.23.2020. Okay. 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Evaluator Notes: D10. Yes. The most recent date was in August 2019. Info Only Info Only 11 Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only = No Points Evaluator Notes: D11. Yes. This is asked during every Standard Inspection. Info Only Info Only 12 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: D12. Yes. AOGC has a user-friendly website, sends out group emails, and the staff is accessible by email and phone. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 1 1 DUNS: NA 2020 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 9

Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: D13. Yes. Procedures are in place. No SRC in 2020 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? Evaluator Notes: D14. Yes. Responds quickly to both subjects. 1 1 15 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. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: D15. NA. AOGC has not issued waivers or special permits. 1 NA 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: D16. Yes. Most records are electronic and readily accessible. Info Only Info Only 17 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 Evaluator Notes: D17. Yes. The SICT is not a good fit for extremely small programs. SCIT is updated. 3 3 18 Discussion on State Program Performance Metrics found on Stakeholder Communication Info Only Info Only site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: D18. Yes. All performance metrics were trending in an acceptable manner. Excavation Damages per 1000 locate tickets show none that are 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 has dropped off of 100% because Michael retired, and Bryan has been delayed in his TQ classes due to COVID 19. 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%. 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Info Only Info Only Evaluator Notes: D19. Yes. AOGC has contacted every operator in their jurisdiction about this and forwarded information to them via email. 20 General Comments: Info Only = No Points Evaluator Notes: D20. Part D scored 49 of 49 points. D15 was NA. DUNS: NA 2020 Gas State Program Evaluation Info Only Info Only Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 10

Total points scored for this section: 49 Total possible points for this section: 49 DUNS: NA 2020 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 11

PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the Info Only Info Only comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Evaluator Notes: E1. Riverfront Exploration, LLC, opid 39696, Bryan Brown, near Ft. Smith, AR & virtual, 10/6-7/2021, Patrick Gaume. A - OQ inspection & Special - records and field on three pipelines. B - OQ 8/15/2018, Special 8/15/2018. 3rd line is newly acquired. C - Yes, 3 operator personnel participated in the inspection. D - Yes, Bryan is finishing his 3rd year working in the PL Safety Partnership. He has about 10 years with AOGC. 2 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: E2. Yes. Form 14 & 15 for the OQ; and Form 1 Records & Field questions for the PL records & field inspection. (Pg. 18, 20-23). 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: E3. Yes. This inspection was a Full OQ, both office and field, and a Field inspection of 3 short pipelines. It was a detailed review and adequate time was spent. 4 From your observation did the inspector have adequate knowledge of the pipeline safety 2 2 program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: E4. Yes. Bryan conducted this inspection in a professional manner and demonstrated professional knowledge, skills, and abilities. 5 Did the inspector conduct an exit interview, including identifying probable violations? (If 1 1 inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: E5. Yes. The exit interview was conducted. A few items were found that were more likely items of advice and perhaps items of concern. Items included improved records management, so information is more readily available. The pressure relief valve release calculation had not been done this year but was done during the inspection; the relief valve is more than adequate. They need a checklist or other mechanism for their periodic reviews so they can document each item that is required for review. Advice for the OQ inspection addressed methods to coordinate with Veri-Force for the periodic review of covered tasks of contract personnel and to make sure that their contractors are selected for review not to exceed every 5 years. DUNS: NA 2020 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 12

6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Info Only Info Only Evaluator Notes: E6. Inspection was performed in a safe manner. PPE was worn. Items inspected included, fencing, site security, site cleanliness, atmospheric corrosion, signs, markers, valve security, valve actuation, OQ of a rectifier, rectifier check, CP readings, ROW condition. Competent practices were observed, but no new best practices. 7 General Comments: Info Only = No Points Evaluator Notes: E7. Part E scored 15 of 15 points. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: NA 2020 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 13

PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 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: F1. Yes. There have been no incidents, SRC, or line hits for pipelines jurisdictional to the AOGC. Operators have been made aware of 811, Damage prevention, and general pipeline safety. The Annual Reports are showing null for incidents, SRC, or line hits. 2 Has the state verified that the operators analyze excavation damages for the purpose of determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: F2. Yes. AOGC reviews operator procedures for damages etc. There have been no excavation damages. 2 2 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation 4 4 Damage? Yes = 4 No = 0 Needs Improvement = 1-3 a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: F3. Yes. Annual reports have been reviewed; these items are discussed with operators during inspections. There have been no jurisdictional damages. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? Evaluator Notes: DUNS: NA 2020 Gas State Program Evaluation 2 2 Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 14

F4. Yes. These items are addressed by Arkansas One Call, with the participation of AR PSC and AOGC. 5 General Comments: Info Only = No Points Evaluator Notes: F5. Part F 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 2020 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 15

PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections? Info Only = No Points Evaluator Notes: G1-6. NA. not an Interstate Agreement Program. Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days? Info Only = No Points Evaluator Notes: G1-6. NA. not an Interstate Agreement Program. 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: G1-6. NA. not an Interstate Agreement Program. Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: G1-6. NA. not an Interstate Agreement Program. Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: G1-6. NA. not an Interstate Agreement Program. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: G1-6. NA. not an Interstate Agreement Program. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: NA 2020 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 16
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