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PHMSA ks-2021-gas-program-evaluation
2021 KS NG Program Evaluation - ks-2021-gas-program-evaluation (Kansas; Natural Gas State Program Evaluation)
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KS 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 KANSAS CORPORATION 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: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 1#
KS NG Program Evaluation, 2021, page 22021 Gas State Program Evaluation -- CY 2021 Gas State Agency: Kansas Rating: Agency Status: Date of Visit: 05/24/2022 - 05/25/2022 Agency Representative: Leo Haynos, Chief Engineer Suzanne Balandran, Assistant Supervisor PHMSA Representative: Agustin Lopez, State Evaluator Commission Chairman to whom follow up letter is to be sent: Name/Title: Dwight D. Keen, Chairman Agency: Kansas Corporation Commission Address: 1500 Southwest Arrowhead Road City/State/Zip: Topeka, KS 66604-4027 60105(a): Yes 60106(a): No Interstate Agent: No 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 49 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 99 State Rating................................................................................................................................................... 99.0 DUNS: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 2#
KS 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 Info Only Info Only report) Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: a. Operator data was verified by reviewing KCC files and PDM. KCC does not have jurisdiction over certain Transmission and gathering operators. Law may be adopted to give jurisdiction in 2022. b. Reviewed Pipeline Time Detail CY2021 to verify inspection activity. Days are tracked for each inspector and supervisor. c. Reviewed KCC database and PDM to verify operator data. KCC needs to assure the following operators submit Annual Reports: Sawyer and Walton. d. There were no reportable incidents in 2021. e. The KCC needs to make sure the "carry over from all previous CY's" match up from previous year's "Number to be corrected at end of CY". f. KCC keeps records as mentioned in the progress report. g. Verified inspector training and qualification with TQ Blackboard. h. Have some regulation changes that have not been adopted within the 2 year requirement. May have adoption in 2022. i. The KCC lists it's accomplishments and initiatives in Attachment 10. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 3#
KS 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 5.4 Inspections includes inspector guidance on conducting inspections which include; pre-inspection, post-inspection and inspection activities. Exit interview is included as part of the inspection activities. Section 5.5.2 at least 25% or percentage provided by PHMSA of total inspection days. 2 Do written procedures address inspection priorities of each operator, and if necessary 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? 4 4 Evaluator Notes: Section 5.3 Inspection Priorities had risk ranking of inspections. Factors may influence frequency and ranking of units. Factors include: date of last inspection, noncompliance history, percentage of lost and unaccounted gas, unprotected pipe, miles of bare pipe, number of meters, special considerations. Appendix 4 give example of risk model. 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 3 3 taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: Section 5.8 Procedures for notifying an operator when noncompliance is identified has details on how to notify and operator and steps to take for issuing compliance actions. Time frames are included to eliminate delays or breakdowns in processing and closing compliance cases. 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 3 3 DUNS: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 4#
KS NG Program Evaluation, 2021, page 5b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. Evaluator Notes: Section 6 Failure Investigation and Safety Related Conditions has detailed procedures and mechanism used to address actions taken in the event of an incident notification. 5 General Comments: Info Only = No Points Evaluator Notes: The KCC 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: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 5#
KS NG Program Evaluation, 2021, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines 5 5 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) Evaluator Notes: Verified inspector training to assure lead is qualified to lead inspections. TQ only has one qualified IMP inspector due to others not taking the CRM course. Most operators do not have CRM's in KS so inspectors are qualified to lead IMP inspections as long as the operator has no CRM. 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 Evaluator Notes: Leo Haynos has been with KCC for over 30 years and is very knowledgeable of the pipeline safety program. 5 5 3 General Comments: Info Only = No Points Evaluator Notes: The KCC 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: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 6#
KS 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 4 Evaluator Notes: Reviewed randomly selected inspection reports to verify inspection cycles are being met per the KCC procedures and the State Guidelines. Superior Pipeline has not had an IMP inspection since 2015 which is over the 5 year inspection cycle as per KCC procedures. Although Superior Pipeline does not have HCA's, the operator is required to comply with certain parts of the IMP regulations. The KCC had notes in database from 2017 but could not provide documentation to verify that an IMP inspection was conducted in 2017. There was a one point deduction for this issue. 2 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) 10 10 Evaluator Notes: Yes, reviewed randomly selected inspection reports and all were complete and covered applicable regulations. Forms are kept in their Pipeline Safety Database System (PSDS) which tracks all inspection data. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, KS CC conducts OQ Plan and Protocol 9 inspections to assure operators are in compliance. 2 2 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 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? 2 2 DUNS: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 7#
KS NG Program Evaluation, 2021, page 8c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? Evaluator Notes: Yes, KS CC conducts IMP inspections to assure operators are in compliance with the regulations. 5 Did the state review the following (these items are NTSB recommendations to PHMSA that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. Operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance); c. Operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21; d. Operator records of previous accidents and failures including reported third- party damage and leak response to ensure appropriate operator response as required by 192.617; e. Directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? 2 2 Evaluator Notes: Yes, the KCC has incorporated the NTSB recommendations into their inspection forms (Distribution Records and Procedures Guide). Cast iron was all removed but Kansas Gas Service found .2 miles when they took over operations of Ft. Riley distribution system. KCC is aware of the newly found cast iron. 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes. PHMSA Advisory Notices ADB-2020-01 (Inside Meters). In 2019, time was spent with the large operators looking at their inside meter sets and addressed during their inspections. Only the large operators have inside sets. ADB-2020-02 (Low Pressure Systems) was addressed with large operators during their inspections in 2020. This was also addressed in the 2019 municipal workshops. The KCC has added questions to their inspection guides to address ADBs. 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) 10 10 DUNS: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 8#
KS NG Program Evaluation, 2021, page 9h. 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 j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) Evaluator Notes: Yes, reviewed randomly selected inspection reports with corresponding compliance actions to verify compliance actions are processed in a timely manner. Compliance actions were sent to company officials with in the required 90 days and exit interview within 30 days. 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? i. Does state share any lessons learned from incidents/accidents? 10 10 Evaluator Notes: Supplemental report was submitted in 2021 on incident that occurred in 2020 by Kansas Gas Service Company. Due to 3rd party damaging a transmission line. KCC was aware of incident. 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: Yes, the KCC responded with in the 60 day requirement. 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: Last seminar was in October 2021 in Manhattan, KS. 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 transmission inspections question #23. Info Only Info Only 12 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 1 1 DUNS: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 9#
KS NG Program Evaluation, 2021, page 10Evaluator Notes: Conduct training sessions with Municipalities, send out quarterly newsletters to operators. Usually see/meet Large private operators thru business issues (rate cases, compliance cases, etc). 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes, there was one SRCR in 2021 which was closed out by the KCC but stilled showed open in PDM. The KCC investigated the SRC and submitted appropriate information to close out SRCR. 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? 1 1 Evaluator Notes: Yes, email with surveys are received and submitted to R. Clarillos. Also respond to PHMSA request when asked. Work on WMS tasks as they are received. 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: There are no open waivers that require monitoring by the KCC. 1 1 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes, keep inspection reports and compliance letters kept in the PSDS. 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: No issues to meet days or with days entered into the SICT. Utilize inspection time codes for SICT. Have met 20% of construction time with no issues. 18 Discussion on State Program Performance Metrics found on Stakeholder Communication Info Only Info Only site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Damage per 1,000 are steady around 2. No negative trend. Leaks are consistent with no negative trend. PSDS has damage data and metrics that is collected by the inspectors. 19 Did the state encourage and promote operator implementation of Pipeline Safety Info Only Info Only 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: Larger operators are looking into implementing PSMS. Municipalities still working on how to implement. Have included a question in Inspection Guide to discuss during inspections. DUNS: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 10#
KS NG Program Evaluation, 2021, page 1120 General Comments: Info Only = No Points Evaluator Notes: The following were issued identified in Part D: Info Only Info Only D.1-Superior Pipeline has not had an IMP inspection since 2015 which is over the 5 year inspection cycle as per KCC procedures. Although Superior Pipeline does not have HCA's, the operator is required to comply with certain parts of the IMP regulations. The KCC had notes in database from 2017 but could not provide documentation to verify that an IMP inspection was conducted in 2017. There was a one point deduction for this issue. Total points scored for this section: 49 Total possible points for this section: 50 DUNS: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 11#
KS 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: City of Partridge Jon Bolinder- KCC Inspector Remote Evaluation June 14, 2022 Agustin Lopez- PHMSA Evaluator a. Records review and Drug and Alcohol b. Last inspected in April 7,2021. c. Yes, pipeline operator was present along with a contractor. d. Jon Bolinder has not been evaluated in the past. Info Only Info Only 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist 2 2 used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Mr. Jon Bolinder utilized the Records Inspection Guide during the inspection 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. Procedures were only reviewed if issues were found. b. Records were reviewed thoroughly by Jon Bolinder. c. Field activities were not part of the evaluation. d. No other reviews were conducted. e. Yes, Partridge is a small distribution system so one day inspection is appropriate for records review. 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. Bolinder has been with the KCC for many years and is very knowledgeable of the pipeline safety program and regulations. DUNS: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 12#
KS NG Program Evaluation, 2021, page 135 Did the inspector conduct an exit interview, including identifying probable violations? (If 1 1 inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, Mr. Bolinder concluded the inspection with an exit briefing to discuss any issues or findings. The following were identified: 1.Discussed the need to identify the cause of 3rd party damages such as mismarked, not maintaining marks and reasonable care. It was also advised that if a damage occurs to meet with the excavator and discuss the cause with an emphasis on the importance of having documentation of such meeting. 2. Discussed one document missing the regulator and relief calculation field. After looking at past records showing the calculations it was determined the same equipment is in place and no changes have been made upstream or downstream to change the capacity calculations. Code 192.743 was reviewed with the operator. It was determined that this was an isolated case and more of a lack of entering the data then not reviewing calculations. At this time a NPV is not being recommended. 3. It was advised that if above ground piping is being coated to protect from atmospheric corrosion the it would be considered a covered task and the individual should be qualified and under the operator drug and alcohol program. 6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Info Only Info Only Evaluator Notes: Yes, the inspection was performed in a safe, positive and constructive manner. A good practice was that Mr. Bolinder asked the operator if it was okay to share their locator/locating documentation with other small operators, since it was a good detailed document. I thought this was a good practice to share with other inspectors/states. 7 General Comments: Info Only = No Points Evaluator Notes: great asset to the KCC. Info Only Info Only Mr. Bolinder conducted a very thorough inspection and was very knowledgeable of the pipeline safety regulations. He is a Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 13#
KS 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: Collect operator pipeline data in PSDS which include, leaks, type of pipe ,etc. Utilize as part of the risk rank. Monitor unaccounted for gas, mainly with municipalities. Is part of Pre-inspection activities which is reviewed by inspectors. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 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: Damage Prevention questions are included in the Distribution inspection guide which address root cause and minimizing the possibility of recurrence. 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: Have identified some issues with locating practices in the state. Working on show cause hearings to reduce damages caused by locating practices. Also issue penalties for violations. 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: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 14#
KS NG Program Evaluation, 2021, page 15One call law has mandatory notification of damages for utilities with 2,000 locates or more. Annual report also includes damages per 1,000 which are analyzed for trends. 5 General Comments: Info Only = No Points Evaluator Notes: The KCC 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: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 15#
KS 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: KCC 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: KCC 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: KCC 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: KCC 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: KCC is not an Interstate Agent nor has a 60106 Certification. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: KCC 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: 102979593 2021 Gas State Program Evaluation Kansas KANSAS CORPORATION COMMISSION, Page: 16#
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