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PHMSA az-2017-gas-program-evaluation
2017 AZ NG Program Evaluation - az-2017-gas-program-evaluation (Arizona; Natural Gas State Program Evaluation)
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AZ NG Program Evaluation, 2017, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2017 Gas State Program Evaluation for ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety 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: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 1#
AZ NG Program Evaluation, 2017, page 22017 Gas State Program Evaluation -- CY 2017 Gas State Agency: Arizona Rating: Agency Status: Date of Visit: 05/21/2018 - 05/25/2018 Agency Representative: Dennis Randolph Program Manager PHMSA Representative: Michael Thompson Transportation Specialist Commission Chairman to whom follow up letter is to be sent: Name/Title: Tom Forese, Chairman Agency: Arizona Corperation Commission Address: 1200 West Washington Street - Second Floor City/State/Zip: Phoenix, AZ 85007 60105(a): Yes 60106(a): No Interstate Agent: Yes INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2017 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 13 10.5 C Program Performance 46 46 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) 7 7 I 60106 Agreement State (If Applicable) 0 0 TOTALS 122 119.5 State Rating................................................................................................................................................... 98.0 DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 2#
AZ NG Program Evaluation, 2017, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: No Issues; Found in the Arizona constitution under Article XV, Section 2 and Arizona Revised Statutes 40-441 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No Issues; They use daily, monthly and annual activity reports for each inspector to track this data. I reviewed the records for accuracy. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No Issues; They use their annual audit/inspection schedule for each year to track this. 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, the records were reviewed and no issues found. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: accuracy. No issues; they use their daily and monthly activity reports to track this information and the records were reviewed for 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the files were available and accessible. However, some of the documentation, (operator responses and follow up were still in electronic format and not in the files) 7 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, this was very well documented on a spread sheet showing all employees and the training they have received since joining the AZCC. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 121-80FR70989 (4/14/17) Taking Steps 123-80FR7972 (3/24/17) Taking Steps 27-82FR7972 (3/24/17) Taking Steps DUNS: 141953807 2017 Gas State Program Evaluation 1 1 Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 3#
AZ NG Program Evaluation, 2017, page 4These are in the process now. The older ones from last evaluation have been adopted by the state. 9 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. In attachment 10 of the progress report, the state has provided a description of their planned annual and long term goals, along with their accomplishments. 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 4#
AZ NG Program Evaluation, 2017, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 1 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: The AZCC has made improvements to their procedures for Master Meter operators, but still needs to provide greater detail in their Standard inspection procedures for Post Inspection activities. (Needs to clarify the 30 and 90 days notifications of probable violations to the operator) 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The AZCC has updated their procedures to clarify the pre and post inspection activities, and have added a link/location to find all inspection forms. 3 OQ Inspection procedures should give guidance to state inspectors that insure 1 0.5 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The AZCC has provided greater clarification to its OQ inspection procedures in the Pre, Active and Post inspection processes. (more specific steps) 4 Damage Prevention Inspection procedures should give guidance to state inspectors that 1 0.5 insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The AZCC still needs to provide greater clarification to its Damage Prevention inspection procedures in the Pre, Active and Post inspection processes. Steps for notifying operator of probable violations found during inspection and how to do the follow up if needed. (Same as 2016 evaluation - Second notice) 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Section 5, page 3 of the inspection procedures manual. 1 1 6 Construction Inspection procedures should give guidance to state inspectors that insure 1 0.5 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The AZCC needs to provide greater clarification to its Construction inspection procedures in the Pre, Active and Post inspection processes. Steps for notifying operator of probable violations found during inspection and how to do the follow up afterwards are needed. (Second year noted) DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 5#
AZ NG Program Evaluation, 2017, page 67 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement 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. Arizona takes all of the above items into consideration when scheduling and conducting inspections. All operators; Gas, LPG, LNG, and hazardous liquid operators with the exception of Priority 2 master meter operators are inspected every year. Priority 2 master meter operators are described in Arizona policies and procedures and are inspected once every two years. If the inspector feels that there is an increased risk based on leaks or other risk factors such as increased number of violations, the procedure allows the inspector to reclassify the inspection to a higher risk priority 1 status requiring annual inspections. 8 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: B1. -1 point The AZCC has made improvements to their procedures for Master Meter operators, but still needs to provide greater detail in their Standard inspection procedures for Post Inspection activities. (Needs to clarify the 30 and 90 days notifications of probable violations to the operator) B3 - .5 points The AZCC has provided greater clarification to its OQ inspection procedures in the Pre, Active and Post inspection processes. (more specific steps) B4 0.5 points The AZCC still needs to provide greater clarification to its Damage Prevention inspection procedures in the Pre, Active and Post inspection processes. Steps for notifying operator of probable violations found during inspection and how to do the follow up if needed. (Same as 2016 evaluation - Second notice) B6 - 0.5 points The AZCC needs to provide greater clarification to its Construction inspection procedures in the Pre, Active and Post inspection processes. Steps for notifying operator of probable violations found during inspection and how to do the follow up afterwards are needed. (Same as 2016 evaluation - Second notice) Total points scored for this section: 10.5 Total possible points for this section: 13 DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 6#
AZ NG Program Evaluation, 2017, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 5 5 A. Total Inspection Person Days (Attachment 2): 1443.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 10.43 = 2293.96 Ratio: A / B 1443.00 / 2293.96 = 0.63 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Yes the ration was acceptable. The Arizona CC had a .628 ratio for the 2017 inspection cycle. 0.17 percent of the 2017 inspections were Construction Inspections. The construction inspections increased from .08 in 2016 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, Reviewed the Arizona CC training records and SABA records to verify the information. 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 2 2 Evaluator Notes: The AZCC Program Manager has been in the position for a little over one year. He has becoming more familiar with the PHMSA state guidelines and has a pretty good handle on the state's own processes and record keeping. He has completed all TQ courses for Standard inspections and has done the HL inspection course, Breakout tanks course, fundamentals of fluid mechanics, OQ course and the Hazwoper course, he still needs only a few to cover IMP and DIMP. 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 2 2 Evaluator Notes: Yes, the AZCC Chairman's letter went out on 7/27/2017and the response letter was received on September 17, 2017. 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 seminar was held on 2/15/2015. (Need to conduct seminar by2/11/2018) They have it scheduled for June 12-13, 2018. 1 1 DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 7#
AZ NG Program Evaluation, 2017, page 86 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 5 5 Evaluator Notes: Yes, reviewed completed inspections and found no issues. Language for the procedure setting time intervals for Master Meter operators was rewritten to provide more clarity. 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, no issues were found in the review of 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: 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: 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, it is on the state inspection form under 614.(c).(6).(i) 1 1 11 Did the state review operator records of previous accidents and failures including 1 1 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 is reviewed and addressed on Arizona's inspection report. All state reportable damages track notification to company time vs gas off times. Arizona also collects and tracks pipeline damage information including number of locate tickets, damages per thousand tickets and by type of damage; no ticket, mis-marked locate, 1st 2nd and 3rd party damages. 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: The Arizona CC uses mandatory quarterly reports for leaks and accidents/damages from operators to track this information. It gives a good real time account of the information. They also review the annual reports to track new installation of pipe and services. DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 8#
AZ NG Program Evaluation, 2017, page 913 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 1 1 Evaluator Notes: Yes, this information is reviewed by inspectors prior to conducting inspections and is found in question 191.22 on their form. 14 Is the state verifying operators are conducting drug and alcohol tests as required by regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Drug and alcohol plans are reviewed at the same time the standard inspection is being conducted. 2 2 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, this is verified during all annual inspections, incident/accident inspection and verified while in the field. 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, this completed during annual inspections and can be found in box 1 of audit procedures for intrastate transmission standard. Once every three years a specialized inspection is conducted to cover plan activities and is done in addition to the annual inspection. (Gas. LNG or Liquid) 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 2 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: Yes, the DIMP plans are being reviewed every three years, and the activities are being looked at during the annual standard inspections using a recap sheet. 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, the PA inspections are conducted at the same time the operator is having a Standard Inspection. 2 2 19 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 9#
AZ NG Program Evaluation, 2017, page 10Yes, Arizona maintains a public website and maintains a working relationship and meets with the Arizona Utility Group. Arizona is a member of; the AZ National Utility Contractors Association, One call ticket resolution committee, Arizona Emergency Response Committee Advisory Board, the Arizona and National Common Ground Alliance. Arizona participates as a sponsoring member of the AZ 811 Alliance. Arizona meets quarterly with their largest LDC, Southwest Gas Corporation to discuss possible safety issues, ongoing maintenance, operational issues and vintage pipe replacement projects or other issues relevant to the safe operation of pipelines in Arizona. They are also working with the Pipeline Safety Trust to update their website to have better out reach. 20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, no issues found 1 1 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, they did a survey of all their operators in 2014 and have disallowed the use of certain plastic pipe through rule making. They have added this as a question to their inspection form to follow up with each operator. This is also one of the issues covered during their quarterly meetings with their major operators. (Reviewed meeting agendas) 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, they provided records of their response to NAPSR surveys. 1 1 23 If the State has issued any waivers/special permits for any operator, has the state verified 1 1 conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: The AZCC has made efforts to improve this by verifying the condition of their waivers. There are at least 8 waivers that exist and they have been provided to the operators to review for applicability. They expect to have answers for all by the 3rd quarter of 2018. 24 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes, Dennis, (program Manager) and Pam West, (Supervisor) attended the annual meeting. 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: The states excavation damages have lowered steadily from 2013 to 2016 from 1.7 to 1.2 damages per 1000 locate requests. Inspection days for gas pipelines has decreased from 2013 and 2014 at 13 days per 1000 miles to 9 days in 2016. Leaks repaired per 1,000 miles of distribution went up by almost 100, stayed approximately the same for HL, and outstanding DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 10#
AZ NG Program Evaluation, 2017, page 11leaks. Enforcement for Gas has come up from 2013 to 100 percent then same as in 2012 and2011. Enforcement for Hazardous Liquids has dropped from 100 percent in 2012 right at 88 percent in 2014 and 2015. Incident Investigation is steady at 100 percent for both Gas and HL. Inspection days for MMO/LPG also dropped from a high of 1.1 days in 2013 to .8 in 2014 and .820 in 2015 now is 0.8 in 2016. Hazardous Liquid inspection days are up from 60 days in 2013 and 65 in 2014, to almost 8 in 2016. The percentages for Inspector qualifications has stayed basically the same for both Gas and Hazardous Liquids in 2014 and 2015, then went up in % core training and 5-year retention in 2016. 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: Had a discussion with PM on the numbers as they stood for 2017. The SICT had 2361 days and the progress report showed 1443 inspection days. The program had some issues with three of it's senior inspectors that caused them to not be able to do inspections. All three senior inspectors left the commission by summer. The PM feels like they could do the numbers with a full staff, but will resubmit new numbers for 2019. 27 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 1 NA Evaluator Notes: 28 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 46 Total possible points for this section: 46 DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 11#
AZ NG Program Evaluation, 2017, page 12PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: Yes, Section 5, Page 1 for Compliance Officer and Section 5, Page 5 for Compliance Actions in their policy and procedures manual. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: Yes, all compliance actions reviewed showed that the AZCC did follow their compliance procedures and were adequately documented. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, 448 compliance actions were initiated in 2017 and the records were reviewed to verify the count. 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, No issues 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were 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: 2 2 Yes, Dennis (Program Manager) has familiarized himself with the states process for imposing civil penalties. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 12#
AZ NG Program Evaluation, 2017, page 13Yes, the last civil penalty issued was in 2016 and collected in 2017. The program is in the process of setting up a system and procedure with clear and concise language to insure consistency. 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 13#
AZ NG Program Evaluation, 2017, page 14PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ 2 2 accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, They can be found in Section 10 of their policies and procedures manual, and in their training manual. During 2017 the AZCC made contact with all operators to refresh what their expectations are and to update contact names and numbers. 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, they have a dedicated phone number (602-252-4449) that is forwarded to the on call inspector after hour for response. AZCC should make contact with all operators to refresh what their expectations are and update contact names and numbers. 3 If onsite investigation was not made, did state obtain sufficient information from the 1 1 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, they do onsite investigations of almost 90 percent of all reportable incidents and collect documentation to verify decision to not go on site. 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, Reviewed all reportable incidents. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: Yes, on an El Paso interstate line reported 1/10/2017. 1 1 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking 1 1 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, the AZCC works with the Accident Investigation Division to ensure the reports are accurate and finals have been received. 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) DUNS: 141953807 2017 Gas State Program Evaluation 1 1 Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 14#
AZ NG Program Evaluation, 2017, page 15Yes = 1 No = 0 Evaluator Notes: Yes, the lessons learned were shared with the Western region states at their annual NAPSR WR meeting. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 15#
AZ NG Program Evaluation, 2017, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. This is found on the standard inspection form, page 2, and is also addressed during the in-house training course for master meters and with major operators during inspections. 2 Did the state inspector verify pipeline operators are following their written procedures 2 2 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: Yes. This is on the standard inspection check list on page 2 192.605(b)(1) 192.614 questions C1 to C5 and is reviewed during each standard inspection. 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, They conduct Damage Prevention seminars that cover Phoenix, Tucson, Prescott, Flagstaff and individual facilities as needed. The seminars reach approximately 3000 plus people per year. They participate in stakeholder meetings around the state, have information on the AZCC website and provide a learning DVD as part of their enforcement process. 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, The AZCC collects quarterly damage reports on damages from all operators (except master meter) the information provided includes the number of tickets, number of damages and the cause of damages. This information is compiled by an assigned inspector and reviewed by the Program Manager. 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only The AZCC is really starting to focus on the tolerance zone and what is being done to ensure it is being respected. Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 16#
AZ NG Program Evaluation, 2017, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: Paradise Valley Community College Name of State Inspector(s) Observed: John Caughlin, Inspector Location of Inspection: Phoenix, AZ Date of Inspection: June 14, 2018 Name of PHMSA Representative: Agustin Lopez Evaluator Notes: Evaluated Mr. John Caughlin conduct an inspection on Paradise Valley Community College pipeline facilities. He reviewed the O&M, records and performed an inspection of the pipeline facilities. 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, the operator was notified with enough notice to allow representatives to be present. 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, Mr. Caughlin utilized their state Master Meter inspection form during the inspection. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the results of the inspection were documented in the inspection form. 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: Yes, the inspector verified the operator had equipment to conduct O&M tasks. 1 1 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, the inspector reviewed the O&M Manual, reviewed inspection records and performed a field inspection. 2 2 DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 17#
AZ NG Program Evaluation, 2017, page 187 Did the inspector have adequate knowledge of the pipeline safety program and 2 2 regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Mr. Caughlin has been with the ACC Pipeline Safety Program for several years and has many years of industry experience. He is very knowledgeable of the pipeline safety program and regulations. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: Yes, the inspector concluded the inspection with an exit interview and summarized the inspection. 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Yes, the inspector needed an updated map of the system which was provided by the operator. 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 Info Only Info Only DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 18#
AZ NG Program Evaluation, 2017, page 19D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: The inspector conducted a standard inspection of the operators master meter system. He reviewed the O&M Manual, records and inspected the pipeline facilities. He performed an excellent job and is a great asset to the Arizona Corporation Commission. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 19#
AZ NG Program Evaluation, 2017, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, AZCC uses the IA process and forms to conduct inspections 1 1 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: Yes 1 1 3 Did the state submit documentation of the inspections within 60 days as stated in its latest 1 1 Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, with the IA process the documentation is completed online while doinag the inspection and is submitted as soon as the inspection is completed. 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: 1 1 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: Yes, they are identified in the IA inspection process/form and are submitted as soon as the inspection is completed. 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: Yes, this is part of the IA process. 1 1 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: yes, in IA process Yes = 1 No = 0 Needs Improvement = .5 1 1 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: Yes, the evidence and documentation is attached to the IA inspection plan/form. 1 1 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 7 Total possible points for this section: 7 DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 20#
AZ NG Program Evaluation, 2017, page 21PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: State does not have a 60106 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: State does not have a 60106 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: State does not have a 60106 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: State does not have a 60106 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: State does not have a 60106 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: State does not have a 60106 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: State does not have a 60106 Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 141953807 2017 Gas State Program Evaluation Arizona ARIZONA CORPORATION COMMISSION, Office of Pipeline Safety, Page: 21#
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