RegulusPipeline researchPHMSA indnr-2020-underground-natural-gas-storage-program-evaluation
IN UNGS Program Evaluation, 2020, page 1Official PDFPHMSA UNDERGROUND NATURAL GAS STORAGE (UNGS) INDIANA DNR PROGRAM EVALUATION – CY2020 CONDUCTED 9/13-16/2021 A – PROGRESS REPORT AND PROGRAM DOCUMENTATION REVIEW 8 of 9 B – PROGRAM INSPECTION PROCEDURES 14 of 14 C – PROGRAM PERFORMANCE 23 of 27 (34) D – COMPLIANCE ACTIVITIES 8 of 8 (21) E – INCIDENT INVESTIGATIONS 9 of 9 (13) F – DAMAGE PREVENTION 0 of 0 (4) G – FIELD INSPECTIONS 10 of 10 (12) H - 60106 AGREEMENT STATE (if applicable) 0 of 0 (6) TOTAL PROGRAM EVALUATION POINTS 72 OF 77 (113)#
IN UNGS Program Evaluation, 2020, page 2PHMSA UNGS STATE PROGRAM EVALUATION – CY2020 A – PROGRESS REPORT AND PROGRAM DOCUMENTATION REVIEW THIS SECTION ANALYZES ACCURACY AND COMPLETENESS OF ANNUAL PROGRESS REPORT SCORE 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data – Progress Report Attachment 1 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes, Attachment 1 agrees with Attachment 3 and internal records. 1 2 Review of Inspection Days for accuracy – Progress Report Attachment 2 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: NI .5 of 1 points. Corrected Attachment 2 was submitted. 590 hours reported agrees with internal records. Attachment 2 needs to show time in days and fractions of days, not hours. .5 3 Accuracy verification of Operators and Operators Inspection Units in State – Progress Report Attachment 3 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. Attachment 3 agrees with Attachment 1 and internal records. 1 4 Accuracy verification of Compliance Activities – Progress Report Attachment 5 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. Program performed wellhead inspections in 2019 & 2020. No violations found. 1 5 Were UNGS program files well-organized and accessible? - Progress Report Attachment 6 (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. The files are electronic and readily available. 2 6 Was employee listing and completed training accurate and complete? – Progress Report Attachment 7 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: NI, 0.5 of 1 point. Corrected Attachment 7 was submitted. The employee list was accurate but time in the program needed revision. .5 7 Verification of Part 192 and 199 Rules and Amendments – Progress Report Attachment 8 (Yes= 1 point, No= 0 Points) Comments: Yes. Credit given, is a 60106 Program. Report is accurate. Discussed steps needed to become a 60105 Certification Partner. 1 8 List of Planned Performance - Did State describe accomplishments on Progress Report in detail – Progress Report Attachment 10 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. It describes accomplishments and goals for the future. 1 9 General Comments: Part A scored 8 of 9 points. Attachments 2 & 7 need correction; see Questions 2 & 6. Daniel W. Bortner, Director, Department of Natural Resources, 402 W. Washington St., Rm. W256, Indianapolis, IN 46204; Russell Retherford, Assistant Director, Division of Reclamation; Patrick Gaume PHMSA, UNGS PROGRESS REPORT REVIEW score is 40 of 50, is a 60106 Partner (-6), Highest percentage of inspectors are in categories I, II. III (-4): No incidents were reported in UNGS for 2020. 8#
IN UNGS Program Evaluation, 2020, page 3B – PROGRAM INSPECTION PROCEDURES Does State Inspection Plan include procedures that address the following elements? (See Guidelines Section 5.1) 1 Does State have written inspection procedures? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. Underground Natural Gas Storage Well Inspection and Incident Investigation Policies and Procedures 2 Standard Inspections Do Standard Inspection procedures give guidance to State inspectors that insure consistency for inspections conducted by the State? The following elements should be addressed at a minimum. (Review of Procedures, Records, or Field Items to complete a PHMSA UNGS IA Question Set (RESERVOIR or CAVERN) – 2019.12.31) • Pre-Inspection Activities • Inspection Activities • Post Inspection Activities (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. See VII. Key Inspection Activity Categories, & VIII. Standard (General Code Compliance) Inspection Procedures. 3 Integrity Management Inspections • Do Integrity Management Inspection procedures give guidance to State inspectors that insure consistency for inspections conducted by the State? The following elements should be addressed at a minimum. (Integrity Testing and Maintenance: Observing Integrity Testing (Tubing, Casing, Cement), reservoir integrity monitoring, & FLIR Camera inspections.) • Pre-Inspection Activities • Inspection Activities Post Inspection Activities (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. See VII. Key Inspection Activity Categories, & VIII. Standard (General Code Compliance) Inspection Procedures. 4 Design, Testing, and Construction Inspections Do Design, Testing, and Construction Inspection procedures give guidance to State inspectors that insure consistency for Inspections conducted by the State? The following elements should be addressed at a minimum. (Review of procedures, records, and field activities to complete PHMSA UNGS IA Question Set (RESERVOIR or CAVERN CONSTRUCTION) – 2019.12.31. Inspection activities for well design, drilling and completion activities, well workover, reservoir maintenance/repair activities, and abandonment (Plugging and cementing), temporary abandonment, and restoration.) • Pre-Inspection Activities • Inspection Activities • Post Inspection Activities (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. See VII. Key Inspection Activity Categories, & IX. Construction, Design & Testing Inspection Procedures. 2 2 2 1#
IN UNGS Program Evaluation, 2020, page 45 Wellhead Inspections Do Wellhead Inspection procedures give guidance to State inspectors that insure consistency for Inspections conducted by the State? The following elements should be addressed at a minimum. • Pre-Inspection Activities • Inspection Activities • Post Inspection Activities (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. See VII. Key Inspection Activity Categories, & X. Wellhead Inspections. 1 6 Drug and Alcohol Inspections Do Drug and Alcohol Inspection procedures give guidance to State inspectors that insure consistency for Inspections conducted by the State? The following elements should be addressed at a minimum. (Using AI to complete the federal Comprehensive Drug and Alcohol program (Form 3.1.11). Includes time conducting joint inspections with other agencies for this type of inspection.) • Pre-Inspection Activities • Inspection Activities • Post Inspection Activities (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. See VII. Key Inspection Activity Categories, & VIII. Standard (General Code Compliance) Inspection Procedures. 1 7 Does inspection plan address inspection priorities of each inspection unit, based on the following elements? • Length of time since last inspection (Within five-year interval per inspection unit) • Operating history of operator/unit and/or location (includes leakage, incident, Integrity Testing, and compliance activities) • Type of activity being undertaken by operators in inspection units (i.e. construction) • Locations of operator’s inspection units being inspected - (Geographic area, Population Density, etc.) • Process to identify high-risk inspection units considering integrity threats • Are inspection units broken down appropriately? (Yes= 5 points, No= 0 Points, NI=1-4 points) Comments: Yes. See XV. COMPLIANCE FOLLOW-UP PROCEDURES 5 8 General Comments: Part B scored 14 of 14. 14#
IN UNGS Program Evaluation, 2020, page 5C – PROGRAM PERFORMANCE 1 Was ratio of Total Inspection Person-Days to Total Person-Days acceptable? (Chapter 4.2) A = Total Inspection Person Days (Attachment 2) B = Total Inspection Person Days Charged to the program (220 x Number of Inspection person years from Attachment 7) Ratio = A/B If Ratio >= .38 then score = 5 points. If Ratio < .38 then score = 0 points. (Yes= 5 points, No= 0 Points) Comments: Yes. 73.5/(.2805*220)=1.19. Ratio is >.38 & near 100%. 2 Has each Inspector and Program Manager fulfilled the TQ Training Requirements? (See Guidelines Appendix C for requirements and Chapter 4.3.1) (Yes= 5 points, No= 0 Points, NI=1-4) Comments: Okay. Russell is within the 3-year training window. Russell is scheduled for the UNGS Class in April, 2022. Waiting for approval for 3 new positions and plan to place those personnel onto the waiting list ASAP after they are selected. 3 Does State use the PHMSA Inspection Assistant (IA) program to document inspections? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: NI, 1 of 2 points. No Standard UNGS inspections have been performed in this partnership. 2020 is the 2nd year of the partnership. Discussed getting the first Standard Inspection done and entered into IA. 4 Did records and discussions with Program Manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 (Yes= 2 points, No= 0 Points, NI=1 point) Comments: NI, 1 of 2 points. Training for IA, using IA, completing the UNGS Class, and getting the first round of UNGS Standard Inspections done will likely qualify for full points on this question. 5 Did State respond to PHMSA's Evaluation Letter within 60 days and correct or address any noted deficiencies? Chapter 8.1 (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. December 11, 2020 for the letter and February 1, 2021 for the response. Within 60 days. 6 Did State inspect all types of operators and inspection units in accordance with time intervals established in their written procedures? Chapter 5.1 (Yes= 5 points, No= 0 Points, NI=1-4 points) Comments: okay, still within the first three years. Re-emphasized that the UNGS Standard Inspections must get started. 7 Did State Inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Chapter 5.1 (Yes= 2 points, No= 0 Points, NI=1 point) Comments: NA. No Standard Inspections or D&A Inspections have been performed. There hasn’t been a Standard Inspection loaded into IA to allow for the attaching of applicable Wellhead Inspections. 8 Did State complete all applicable portions of inspection forms? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: NA. This work has yet to be started. This is a concern as this is the 2nd year of the program Partnership. 9 Has the State reviewed Operator Annual reports, along with Incident reports, for accuracy and analyzed data for trends and operator issues? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: NI, 1 of 2 points. Items related to the Annual Reports have been reviewed, but the Annual Reports have not been downloaded and studied. This is a repeat from last year (CY2019). 5 5 1 1 2 5 NA NA 1#
IN UNGS Program Evaluation, 2020, page 610 11 12 13 14 15 16 Is the State verifying operators are conducting drug and alcohol tests required by regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 (Yes= 2 points, No= 0 Points, NI= 1 point) Comments: NI. 1 of 2 points. Discussed the requirement for D&A Inspections. An improvement from last year is that IDNR has successfully contacted and arranged with the IURC to perform D&A inspections together for the operators subject to UNGS; with IURC as inspection lead. Was ‘No’ last year; has been upgraded to ‘NI’ this year. 1 Does the State have a mechanism for communicating with stakeholders regarding the inspection and enforcement program? (This should include making enforcement cases available to public). (Yes= 1 points, No= 0 Points, NI=.5 point) Comments: Yes. IDNR follows existing laws and Regulations; Indiana Applied Code (IAC) and Indiana Code (IC). The violation letters contain all information needed for appeal or making payment. See 312 IAC-29 and 312 IAC-30 for UNGS Regulations; also IC 14-37-3-9 which authorizes the IAC regulations. 1 Did State execute appropriate follow-up actions to Safety Related Condition Reports (SRCR)? Chapter 6.3 (Yes= 1 points, No= 0 Points, NI=.5 point) Comments: NA, none. NA Did the State participate in/respond to surveys or information requests from PHMSA? (Yes= 1 points, No= 0 Points, NI=.5 point) Comments: Yes. IDNR responds to all requests. 1 Did the State forward any potential waivers/special permits to PHMSA for review prior to issuing them to operators? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: NA, none. NA 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 point, No= 0 Points, NI=.5 point) Comments: NA, none. NA General Comments: Part C scored 23 of 27 points. Questions 7, 8, 12, 14, & 15 were NA. Questions 3, 4, 9, & 10 had point deductions. 27#
IN UNGS Program Evaluation, 2020, page 7D – COMPLIANCE ACTIVITIES 1 Does the State have written procedures to identify steps to be taken from the discovery to resolution of a probable violation? Chapter 5.1 • Procedures to notify an operator (company officer) when a noncompliance is identified (60105 States) • Procedures to routinely review progress of compliance actions to prevent delays or breakdowns • Procedures regarding closing outstanding probable violations (Yes= 4 points, No= 0 Points, NI=1-3 points) Comments: Yes. As a 60106 Partner have procedures for monitoring and closing probable violations: see Procedures: XVI. PROCEDURES FOR NOTIFYING AN OPERATOR WHEN NON- COMPLIANCE IS IDENTIFIED UNDER A 60106 PROGRAM, XVII. PROCEDURES FOR FOLLOW-UP ACTIVITIES TO ENSURE THAT CORRECTIVE ACTION HAS BEEN TAKEN BY THE OPERATOR WITHIN A SPECIFIC TIMEFRAME AFTER NOTIFICATION OF NON-COMPLIANCE, & XVIII. RECORDKEEPING PROCEDURES TO DOCUMENT THE RESULTS OF INSPECTION, FOLLOW-UP, AND COMPLIANCE ACTIONS TAKEN. 2 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 • Were compliance actions sent to company officer or manager/board member if municipal/government system (60105 States)? • Document probable violations • Resolve probable violations • Routinely review progress of probable violations (Yes= 4 points, No= 0 Points, NI=1-3 points) Comments: NA. Have no compliance issues found for the 2-year history of the UNGS Partnership. 3 Did State within 30 days of the end of an inspection conduct a post-inspection briefing with the owner or operator of the UNGS facility inspected outlining any concerns identified during the inspection? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes, for the Well Head Inspections. Any problems found would have been communicated immediately; no problems in 2019 or 2020. 4 Did State within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: NA for Wellhead inspections as no violations were found and no other work was done. The 30, 60, and 90 day notifications are in the procedures. 5 Did the State issue compliance actions for all probable violations discovered (60105 States)? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: NA, 60106 program. 6 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary (60105 States). (Yes= 2 points, No= 0 Points) Comments: NA, 60106 program. The process is described in the Procedures. 4 NA 2 NA NA 2#
IN UNGS Program Evaluation, 2020, page 87 Is the Program Manager familiar with State process for imposing civil penalties (60105 States)? (describe any actions taken) (Yes= 2 points, No= 0 Points, NI=1 point) Comments: NA, 60106 Program. However, the Program Manager is familiar with the Indiana DNR process for issuing civil penalties. NA 8 Were civil penalties considered for repeat violations, violations which can’t be corrected by other means, or violations resulting in incidents (60105 States)? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: NA, No violations or penalties for UNGS. Issuing civil penalties is a tool that is used by IDNR to achieve compliance. Discussed the concept of penalties for repeat violations and the others listed. IDNR has a violation matrix where these and related items are considered for assessing penalties. This will be part of the UNGS Procedures. NA 9 Can the State demonstrate it is using their enforcement fining authority for safety violations (60105 States)? (Yes= 1 point, No= 0 Points, NI= .5 point) Comments: NA, 60106 Program. NA 10 General Comments: Part D scored 8 of 8 points. Questions 2, 4, 5, 7, 8, & 9 were NA. 8#
IN UNGS Program Evaluation, 2020, page 9E – INCIDENT INVESTIGATIONS 1 Does the State have written procedures to address State actions in the event of an incident? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. See Procedures: XIII. Investigating Incidents/Accidents Procedures. 2 2 Does State have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes, IDNR has a 24hr phone number, 317-601-3087 for UNGS. Discussed that Russell is the primary contact for all things UNGS; backup contacts have been identified. 2 3 Did the State keep adequate records of Incident notifications received? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: NA. No incidents during the history of the Partnership. A process for keeping Incident Records has been developed. NA 4 If onsite investigation was not made, did State obtain sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 (Yes= 1 point, No= 0 Points, NI= .5 point) Comments: NA. No incidents during the history of the Partnership. NA 5 Were all incidents investigated, thoroughly documented, and with conclusions and recommendations? • Observations and document review • Contributing Factors • Recommendations to prevent recurrences where appropriate (Yes= 3 points, No= 0 Points, NI=1-2 points) Comments: Yes. There was one incident that was actively investigated with PHMSA and IN URC; The result of the joint investigation was that IN URC would exercise jurisdiction over the incident. Observations, Factors, and Recommendations were included in the investigation. (August, 2020 incident at the Dove Run Storage Field, Perkins #5 Well.) 3 6 Did the State initiate compliance action for violations found during any incident investigation? (60106 States forward violations to PHMSA) (Yes= 1 point, No= 0 Points) Comments: NA. the 2020 incident, (Dove Run Storage Field, Perkins #5 Well), was determined to be jurisdictional to the IN URC. NA 7 Did the State assist the Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents and investigate discrepancies) Chapter 6 (Yes= 1 point, No= 0 Points, NI= .5 point) Comments: Yes. IN DNR worked with PHMSA AID, PHMSA UNGS, and IN URC on the Dove Run Storage Field, Perkins #5 Well. 1 8 Does State share lessons learned from incidents with PHMSA? (Yes= 1 point, No= 0 Points) Comments: Yes. Had extensive communication with PHMSA during the investigation. Discussed that there is not a good Forum for sharing UNGS lessons learned. Lessons learned from the 2020 incident showed that Internal communications and training is needed for personnel, Contact back-up is needed, and prompt reports, morning, mid-day, & evening, are proved as a best practice. 1#
IN UNGS Program Evaluation, 2020, page 109 General Comments: Part E scored 9 of 9 points. Questions 3, 4, & 6 were NA. 13#
IN UNGS Program Evaluation, 2020, page 11F – DAMAGE PREVENTION 1 Did the State inspector verify UNGS operators are following their written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? (API 1171 Section 11.10 Public Awareness and Damage Prevention) (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: NA, IDNR has not conducted a UNGS Standard Inspection. Still in the First 3 years of the Program. Discussed the need to get started with this; strongly recommended that action be taken this year. 2 Did the State encourage and promote practices for reducing damages to all underground facilities to its regulated companies? (Common Ground Alliance Best Practices, support excavation damage prevention legislation, etc.) (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: NA, IDNR has not conducted a UNGS Standard Inspection. Still in the First 3 years of the Program. Discussed the need to get started with this; strongly recommended that action be taken this year. 3 General Comments: Part F scored 0 of 0 points. Both questions were NA. IDNR needs to make progress here in 2021. NA NA 4#
IN UNGS Program Evaluation, 2020, page 12G – FIELD INSPECTIONS 1 Operator, Inspector, Location, Date and PHMSA representative Comments: Indiana Gas Company Dba Vectren, opid 8070; Tim Higginbottom, Sr. Field Inspector; Oliver Field, Posey Co, IN; 9/23/21; Patrick Gaume, UNGS State Liaison 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? (Yes= 1 point, No= 0 Points) Comments: Yes. Operator had an employee present to greet IN DNR. 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: Okay for this year. The Inspection questions reside in a database that is referenced on site; however, the database does not have a report function and can’t print out the questions. Discussed the need for the database to be modified to have that function. 2 4 Did the inspector thoroughly document results of the inspection? (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: Yes. Tim showed his computer screen and demonstrated completing the questions in the database for a wellsite inspection. 2 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Yes= 1 point, No= 0 Points) Comments: Yes. Access to the wellsite was arranged and gauges were available to take required readings. Valve actuation and CP readings were not performed for this inspection. 1 6 Did the inspector adequately review the following during the field portion of the State Program Evaluation? • Procedures • Records • Field Activities/Facilities • Other (please comment) (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: Yes. This was a Field inspection of an individual well site. 2 7 Did the inspector have adequate knowledge of the UNGS safety program and regulations? (Evaluator will document reasons if unacceptable) (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: Yes. Tim performed this inspection in compliance with IN PUC procedures. 2 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) (Yes= 1 point, No= 0 Points) NA Comments: NA, this was a routine inspection and the operator was released to do other things. No violations were expected, and no violations were found.#
IN UNGS Program Evaluation, 2020, page 139 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) (Yes= 1 point, No= 0 Points) Comments: NA, this was a routine inspection and the operator was released to do other things. No violations were expected, and no violations were found. 10 General Comments: • What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) • Best Practices to Share with Other States - (Field - could be from operator visited or State inspector practices) • Other Field Observation Areas Observed (check all that apply) Areas of focus for this Field inspection of a wellsite included, signs, markers, site access, site cleanliness, atmospheric corrosion, gauges in operable condition, steps and rails in good order, also observed that the work to install remote monitoring was progressing well. Part G scored 10 of 10 points. NA 10#
IN UNGS Program Evaluation, 2020, page 14H - 60106 AGREEMENT STATE (if applicable) 1 Did the State use the current federal inspection form(s)? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: NA. no inspection work has been done other than wellhead inspections; therefore, no federal forms were used. Discussed that staffing for UNGS has been a problem partially due to COVID 19 impacts on policy, procedures, and activities. 2 Are results documented demonstrating inspection units were reviewed in accordance with State inspection plan? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: NA. Procedures have been developed but UNGS inspections have not started. 3 Were all probable violations identified by State referred to PHMSA for compliance action? (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 point, No= 0 Points, NI=.5 point) Comments: NA. Procedures have been developed but UNGS inspections have not started. 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 point, No= 0 Points, NI=.5 point) Comments: NA. There have no reported conditions that may pose an imminent safety hazard. 5 Did the State give written notice to PHMSA within 60 days of all probable violations found? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: NA. Procedures have been developed but UNGS inspections have not started. No violations found during the Wellhead Inspections. 6 Did the State initially submit adequate documentation to support compliance action by PHMSA on probable violations? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: NA. No violations have been found. 7 General Comments: Part H scored 0 of 0 point. 6 of 6 questions were NA. UNGS work needs to be started. UNGS Procedures have been written. NA NA NA NA NA NA NA#
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