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2021 AR NG Program Evaluation - arog-2021-gas-program-evaluation (Arkansas; Natural Gas State Program Evaluation)
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AR NG Program Evaluation, 2021, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2021 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 2021 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 1#
AR NG Program Evaluation, 2021, page 22021 Gas State Program Evaluation -- CY 2021 Gas State Agency: Arkansas Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: No Date of Visit: 10/18/2022 - 10/19/2022 Agency Representative: Gary Looney, Assistant Director, Arkansas Oil and Gas Commission Bryan Brown, Sr. Petroleum Geologist, Arkansas Oil and Gas Commission PHMSA Representative: Agustin Lopez, State Evaluator Commission Chairman to whom follow up letter is to be sent: Name/Title: W. Frank Morledge, Chairman Agency: Arkansas Oil and Gas Commission Address: 205 North Washington Street City/State/Zip: Forrest City, AR 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 2021 (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 50 50 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 100 State Rating................................................................................................................................................... 100.0 DUNS: NA 2021 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 2#
AR NG Program Evaluation, 2021, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress 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: a. Verified operator data with PDM and annual reports. b. Reviewed inspection activity to verify inspection days. c. Verified operator list with PDM and operator annual reports. d. No reportable incidents in 2021. e. Reviewed compliance data to verify compliance actions on attachment 5. f. Have list of records kept in their files. g. Verified training with TQ Blackboard. h. Have adopted regulations within the 2 year interval requirement. i. Include description of accomplishments and inititiatives. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: NA 2021 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 3#
AR NG Program Evaluation, 2021, page 4PART 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: Section VI of the AOGC Pipeline Safety Program Manual has a list of all types of inspections. Section VII has inspections activities which include pre and post inspection activities. a. Section VIII has standard inspection procedures which provide guidance to inspectors. b. There are no IMP inspection procedures. Section V only states that the AOGC will reevaluate, on a timely basis, the requirements. Although there are no transmission operators with HCA's the AOGC has to conduct verification IMP inspection to assure operators are conducting HCA verifications. In addition, the operators IMP plans need to be reviewed to assure they are analyzing their pipeline for HCA accordingly. The AOGC is conducting IMP inspections but need to add to procedures. c. Section XI includes OQ inspection procedures which provide guidance to inspectors. d. Section XIII includes detailed Damage Prevention inspection procedures. e. Section X includes operator training procedures with guidance to inspectors. f. Section IX includes construction inspection procedures that provide guidance to inspectors. g. No LNG operators. 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: Section VI of the AOGC Pipeline Safety Program Manual has risk based inspection scheduling based on type of pipeline, length of last inspection, pipe material, pipe size, leak history, age of pipe, incident history. Inspection cycles are conducted on an annual or bi-annual bases. 3 (Compliance Procedures) Does the state have written procedures to identify steps to be taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 3 3 DUNS: NA 2021 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 4#
AR NG Program Evaluation, 2021, page 5a. 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: Sections XIV, XV, and XVI provide detailed procedures for actions taken if compliance issues are found during inspections. Civil Penalty options are not addressed in procedures. AOGC laws has description and laws in issuing civil penalties which will be referenced in procedures. Section XVI has follow-up procedures for corrective actions to avoid breakdowns and delays. Section XVI has closing out procedures that gives guidance on closing out cases. Section XV states that correspondence will be sent to company officials. 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 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. 3 3 Evaluator Notes: Section XII of AOGC Pipeline Safety Program Manual has Incident Investigation procedures that provide guidance to inspectors. AROGC has incident investigation procedures but need a more detailed mechanism to receive, record, and respond to incidents. Will amend procedures to provide better detail of receiving incident notifications. 5 General Comments: Info Only = No Points Evaluator Notes: The AROGC is mainly complying with Part B of the evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: NA 2021 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 5#
AR NG Program Evaluation, 2021, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines Appendix C for requirements) Chapter 4.3 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: Reviewed Blackboard to verify qualifications and to assure lead inspectors are qualified to lead each type of inspection. 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Gary Looney has been with pipeline safety for many years He is very knowledgeable of the pipeline safety program. 3 General Comments: Info Only = No Points Evaluator Notes: The AROGC is mainly complying with Part C of the evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: NA 2021 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 6#
AR NG Program Evaluation, 2021, page 7PART 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: Reviewed randomly selected inspection reports to verify inspection cycles. Inspect units within the required 5 year interval. 2 Did inspection form(s) cover all applicable code requirements addressed on Federal 10 10 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) Evaluator Notes: Yes, use PHMSA forms to document inspections. Reviewed randomly selected inspection reports to verity completeness and verify that any issues identified are documented properly. Inspection reports are on website which can be reviewed by the public. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 2 2 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: Yes, reviewed randomly selected OQ inspection reports. The AROGC conducts OQ inspections to assure operators are in compliance. 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 Subparts O and P Yes = 2 No = 0 Needs Improvement = 1 a. Are the implementation plans of the state's large/largest operators(s) being reviewed annually to ensure they are completing full cycle of the 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 2021 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 7#
AR NG Program Evaluation, 2021, page 8Evaluator Notes: Yes, reviewed Protocol A IMP inspection reports to review HCA verifications. 5 Did the state review the following (these items are NTSB recommendations to PHMSA 2 2 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: AOGC utilizes Addendum to Inspection Form which include NTSB and ADB questions to ask the operator during inspections. 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: AOGC utilizes Addendum to Inspection Form which include NTSB and ADB questions to ask the operator during inspections. 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 2021 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 8#
AR NG Program Evaluation, 2021, page 9j. 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: Reviewed randomly selected compliance letters to assure compliance procedure are being followed. The AROGC documents and issues compliance letters within their requirements in their procedures. There are no breakdowns in issuing compliance actions in a timely manner. 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly 10 10 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: There were no reportable incidents in 2021. The AROGC does have procedures which they follow in case there are any reportable incidents. 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: A response was not required. 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: Had last seminar in 2019 in Arkansas. Co-hosted seminar in LA with 100% participation in 2022. 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: Yes question is part of the inspection forms. 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: AOGC website has a lot of pipeline safety information including inspection reports. Very transparent and informative. DUNS: NA 2021 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 9#
AR NG Program Evaluation, 2021, page 1013 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No SRCR in 2021. 1 1 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: Yes, respond to NAPSR surveys and PHMSA requests. Complete tasks on WMS when assigned. 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: No waivers or special permits issued by the AROGC 1 1 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes, files were sent electronically with no issues. 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 3 3 Evaluator Notes: every year. Discussed the SICT with AROGC and no issues or concerns are foreseen. SICT is reviewed and updated by the AROGC 18 Discussion on State Program Performance Metrics found on Stakeholder Communication site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Discussed performance metrics with the AROGC and there are no negative trends identified. Info Only Info Only 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 Evaluator Notes: Yes, added a question to Addedum referncing PSMS. Also discussed during the seminar in LA. Info Only Info Only 20 General Comments: Info Only = No Points Evaluator Notes: The AROGC is mainly complying with Part D of the evaluation. Info Only Info Only DUNS: NA 2021 Gas State Program Evaluation Total points scored for this section: 50 Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 10#
AR NG Program Evaluation, 2021, page 11Total possible points for this section: 50 DUNS: NA 2021 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 11#
AR NG Program Evaluation, 2021, page 12PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the 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: Desoto Gathering Company Bryan Brown-Lead Inspector Damascas, AR September 7, 2022 Agustin Lopez-PHMSA Evaluator a. Conduct a standard inspection which involves records review and field inspection. b. Last inspection 2020. c. Yes, operator representatives were present during the inspection. d. There are two inspectors so try to rotate evaluation of inspectors. Info Only Info Only 2 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 2 2 Evaluator Notes: Yes, an inspection form with all applicable regulations was utilized as a guide and to document the results of the inspection. 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: a. O&M Manual is reviewed during a different type of inspection. b. Yes, records were reviewed with great detail during the inspection. c. Yes, a field inspection of facilities was performed. d. no other type of inspection was conducted. e. Yes the length of the inspection was adequate to perform a thorough inspection. 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: Yes, Mr. Bryan Brown demonstrated knowledge of the pipeline safety program and regulations. He has been in the industry for many years. 5 Did the inspector conduct an exit interview, including identifying probable violations? (If inspection is not totally completed the interview should be based on areas covered during time of field evaluation) 1 1 DUNS: NA 2021 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 12#
AR NG Program Evaluation, 2021, page 13Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, an exit briefing was conducted at the end of the inspection. There were no issues identified. 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 Evaluator Notes: Yes, the inspection was performed in a safe and positive manner. Info Only Info Only 7 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Mr. Bryan Brown conducted a records review and field inspection of Desoto Gathering Company. Records were reviewed with great detail. Mr. Brown demonstrated knowledge of the pipeline safety regulations and performed a very detailed inspection. Total points scored for this section: 15 Total possible points for this section: 15 DUNS: NA 2021 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 13#
AR NG Program Evaluation, 2021, page 14PART 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: Review Annual Reports as operators also submit to state. Check for accuracy and assure acquisitions miles are correct. No incidents/accidents reported in 2021. 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: There has not been excavation damages on jurisdictional pipelines recently. 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: Transmission and gathering operator annual reports do not include Part D pertaining to damages. They do analyze incidents whenever they occur on jurisdictional operators. 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? 2 2 Evaluator Notes: DUNS: NA 2021 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 14#
AR NG Program Evaluation, 2021, page 15Review damages pre 1,000 locates for jurisdictional operators to see any trends. No damages reported under the AOGC jurisdictional piping. 5 General Comments: Info Only = No Points Evaluator Notes: The AROGC is mainly complying with Part F of the evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: NA 2021 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 15#
AR NG Program Evaluation, 2021, page 16PART 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: The AROGC is not an Interstate Agent nor has a 60106 Certification. 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: The AROGC is not an Interstate Agent nor has a 60106 Certification. 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: The AROGC is not an Interstate Agent nor has a 60106 Certification. 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: The AROGC is not an Interstate Agent nor has a 60106 Certification. 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: The AROGC is not an Interstate Agent nor has a 60106 Certification. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: The AROGC is not an Interstate Agent nor has a 60106 Certification. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: NA 2021 Gas State Program Evaluation Arkansas ARKANSAS OIL AND GAS COMMISSION, Page: 16#
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