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PHMSA ky-2022-gas-program-evaluation
2022 KY NG Program Evaluation - ky-2022-gas-program-evaluation (Kentucky; Natural Gas State Program Evaluation)
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KY NG Program Evaluation, 2022, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2022 Gas State Program Evaluation for KENTUCKY PUBLIC SERVICE 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: 098099674 2022 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 1#
KY NG Program Evaluation, 2022, page 22022 Gas State Program Evaluation -- CY 2022 Gas State Agency: Kentucky Rating: Agency Status: Date of Visit: 06/20/2023 - 06/22/2023 Agency Representative: Melissa Holbrook PHMSA Representative: Joe Subsits Commission Chairman to whom follow up letter is to be sent: Name/Title: Kent Chandler, Chairman Agency: Kentucky Public Service Commission Address: 211 Sower Boulevard City/State/Zip: Frankfort, Kentucky 40602 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 2022 (not the status of performance at the time of the evaluation). A deficiency in any one part of a multiple-part question should be scored as “Needs Improvement.” Determine the answer to the question then select the appropriate point value. If a state receives less than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their performance). This evaluation, together with selected factors reported in the state's annual progress report attachments, provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 50 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 100 State Rating................................................................................................................................................... 100.0 DUNS: 098099674 2022 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 2#
KY NG Program Evaluation, 2022, 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. The progress report lists 19 private systems, 50 municipal systems, 104 master meters, 23 intrastate transmission systems, and 9 gathering lines. Progress report information is tracked by Melissa on a spreadsheet. Melissa has developed a spreadsheet specifically for filling out the progress report. b. The progress report identifies 601 inspection days. SICT requires 521 inspection days. 104 days need to be construction days. 121 of those days are construction days. This is greater than 20 % construction days. Inspection days are generated from weekly reports which are filled out in addition to time sheets by the inspectors. Progress report inspection days are calculated from Melissa's spreadsheet. c. Attachments 1 and 3 numbers are consistent. d. The progress report listed one incident. This was a transmission incident at the magnolia compressor station for Louisville gas and electric on 1/12/2022. This was designated as an equipment failure accident. I incident was listed on PDM. An NRC report was submitted. e. Compliance numbers add up. 28 carry over violations were left at the end of 2022. A $100.000 penalty was imposed on Atmos Energy. 17 violations were carried over from 2021. This was validated on the progress report. f. Melissa has many spreadsheets which are used to manage internal processes. Kentucky had adequate records which were readily available during the evaluation. g. Melissa tracks spreadsheets to manage T&Q training activities. Core inspectors are Chris Baily, Melissa Holbrook, Scott Morris, David Nash and Miker Nantz. John Gallimore is a new inspector undergoing T&Q training. h. Kentucky is up to date of rule amendments. i. Kentucky accomplishments are completing 114 inspections, chairing the Southern region for NAPSR, and they met the annual work plan Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 098099674 2022 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 3#
KY NG Program Evaluation, 2022, 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: Pre inspection, inspection and post inspection procedures are covered in Part V of the procedural manual. This section covers Record review, reports, inspection forms, field work, inspection types, exit interviews and compliance procedures. Inspection intervals are covered on pages 10 -13. These pages include a summary of risk based considerations. a. Standard inspections are covered in section G. Drug/alcohol inspections are covered in section N. CRM inspections are covered in section R and Public awareness effectiveness inspections are covered in section Q. b. b. TIMP and DIMP inspections are covered in sections O & P. Procedures state that integrity management plans are to be reviewed annually to ensure remedial activities are conducted. c. c. Operator Qualification inspections are covered in section I. d. d. Damage Prevention inspections are covered in section M. e. Operator training is covered in section L. f. Construction inspections are covered in Section H. g. There is no LNG in Kentucky. 2 Do written procedures address inspection priorities of each operator, and if necessary 4 4 each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? Evaluator Notes: Risk based inspection priorities are found in part IV section B. a-e. Risk based considerations are defined in section B in part IV. These include operating history, type activity, system location and system threats. f. Units appear to be broken down properly. 3 (Compliance Procedures) Does the state have written procedures to identify steps to be taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 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 3 3 Evaluator Notes: DUNS: 098099674 2022 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 4#
KY NG Program Evaluation, 2022, page 5Compliance procedures are found in part V Section S. Procedures address Notice of violations, follow up, show cause, fines and deficiency tracking. Exit interview and findings letters are found in Part V Section S on page 26. a. Procedures for notification of enforcement are found in Part V Section S (a) found on page 27. b. Deficiency tracking is addressed in part V Section S (b). Extended violations are tracked on a spreadsheet. c. Closure of deficiencies is addressed in part V section S(c). 4 (Incident/Accident Investigations) Does the state have written procedures to address state 3 3 actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. Evaluator Notes: Investigation of Incidents is found in part V Section T. Part V section T(f) refers to a checklist used to encourage a more thorough investigation. a. The mechanism to receive reports of incidents is addressed in part V T(b). b. A procedure requiring a memo when an on-site investigation is not done is addressed at the end of part V Section T.(b). Considerations to evaluate initial incident conditions is identified in part V section T(c). 5 General Comments: Info Only = No Points Evaluator Notes: There are no issues in Part B. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 098099674 2022 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 5#
KY NG Program Evaluation, 2022, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines Appendix C for requirements) Chapter 4.3 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead b. Completion of Required DIMP/IMP Training before conducting inspection as lead c. Completion of Required LNG Training before conducting inspection as lead d. Root Cause Training by at least one inspector/program manager e. Note any outside training completed f. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) 5 5 Evaluator Notes: Darren Combs is a new inspector who has just started T&Q training. John Gillimore and John Park are new inspectors who are taking T&Q core classses. Mellissa goes out with new inspectors to ensure that they are qualified. a-b. After reviewing T&Q records , it has be determined that Chris Bailey, David Nash, Mike Nantz, Scott Morris and Melissa Holbrook have all completed gas core training, Gas IMP training, OQ qualification and investigation qualification. c. There is no LNG in Kentucky d. Melissa Holbrook, Chris Bailey and Mike Nantz completed root cause training. e. Inspectors went to the Kentucky gas expo for additional training. f. Inspectors were qualified to perform the inspections they performed. 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Mellissa is core gas trained, IMP qualified and has taken training to become investigation qualified, OQ qualified and root cause trained. She became program manager in 2019. She was hired as a Kentucky pipeline inspector in 2005 out of college. 3 General Comments: Info Only = No Points Evaluator Notes: The are no issues with Part C. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 098099674 2022 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 6#
KY NG Program Evaluation, 2022, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 5 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) Evaluator Notes: inspection frequencies for operators on the random inspection list were reviewed. Inspection frequencies were within required intervals. a. Standard inspections were conducted within required frequencies. b. Public Awareness effectiveness reviews were conducted within required frequencies. c. Drug and Alcohol inspections were conducted within required frequencies. d. Control Room Management inspections were conducted within required frequencies. e. There is no LNG in Kentucky. f. There were 121 construction days which is above the 20% construction day criteria. g. Operator Qualification Inspections were conducted within required frequencies. h. IMP and DIMP inspections were conducted within required frequencies. 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) Evaluator Notes: Kentucky uses the IA equivalent form. a. Standard inspection forms were filled out appropriately and completely. b. Public Awareness Effectiveness forms filled out appropriately and completely. c. Drug and Alcohol forms were filled out appropriately and completely. d. Control room management forms filled out appropriately and completely. e. There is no LNG in Kentucky. f. IA equivalent is used for construction forms. g. Operator Qualification inspection forms filled out appropriately and completely. h. IMP and DIMP inspection forms were filled out appropriately and completely. 10 10 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: DUNS: 098099674 2022 Gas State Program Evaluation 2 2 Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 7#
KY NG Program Evaluation, 2022, page 8OQ Protocol 9 is used for all standard inspections. Programmatic OQ plan review is performed during all standard inspections for smaller operators. Separate programmatic inspections are performed for the largest 5 operators. OQ forms were filled out completely and appropriately. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This 2 2 should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 Subparts O and P Yes = 2 No = 0 Needs Improvement = 1 a. Are the implementation plans of the state's large/largest operators(s) being reviewed annually to ensure they are completing full cycle of the IMP process? b. Are states verifying with operators any plastic pipe and components that have shown a record of defects/leaks and mitigating those through DIMP plan? c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? Evaluator Notes: a. Mellissa reviews all IMP programs annually. These inspections include a review of plan updates and a review of monitoring process. This review results in a review letter from the Commission. This information is tracked by Mellissa annually. b Mellissa has developed a supplemental checklist which addresses the pipe defect issue. This checklist is used during every standard inspection. There are three miles of cast iron in the City of Fulton. There are 343 miles of bare steel between five municipal operators. c. Mellissa has a supplemental checklist which addresses low pressure distribution risk. The supplemental question is used for every standard inspection. 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: a-g Email or postal notifications are used to notify operators of NTSB recommendations. All recommendations are addressed and evaluated in a supplemental checklist developed by Mellissa. 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 Evaluator Notes: The 2022 Advisory bulletin on land movement was sent to all operators. 1 1 DUNS: 098099674 2022 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 8#
KY NG Program Evaluation, 2022, page 97 (Compliance Activities) Did the state follow compliance procedures (from discovery to 10 10 resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns 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: 2021 inspections on the random operators list compliance activities were evaluated. a. Compliance letters were sent to the appropriate chief official. b. All violations were documented in the inspection checklist and found on the corresponding inspection letter. c. All 2021 violations were mitigated and closed when appropriate. d. Mellissa has a spreadsheet that she uses to track probable violations. This spreadsheet is reviewed periodically. e. Compliance actions were taken for all violations identified in the inspection checklists. f. $100,000 in penalties was assessed in 2022. g. Mellssa reviews, approves and monitors all compliance actions. Melissa signs all compliance letters. h. Operators have opportunities for hearing for probable violations. i. Exit interviews are conducted on the last day of the inspection. j. Findings letters are submitted within 60 days. 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly 10 10 documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? i. Does state share any lessons learned from incidents/accidents? Evaluator Notes: There was one Federally reportable incident in 2022. This was a Louisville gas compressor station fire. Two additional events were listed in WMS. These events were non jurisdictional. a. Staff can be called 24 hours/day. Calls come in from the Emergency response center. An email goes to Mellissa. Inspectors are deployed as required. DUNS: 098099674 2022 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 9#
KY NG Program Evaluation, 2022, page 10b. An incident report was produced for the incident. c. An inspector went on-site for the one inspection. d. Observations were in the report. e. Contributing factors were in the report. f. Recommendations were in the report. g. No violations were identified as a result of the investigation. h. Historically, Kentucky staff had been on-site for and assisted AID during the BP spill. Kentucky staff also assisted the Southern region when requested. i. Lessons learned are shared at the NAPSR Southern Region meeting. Lessons learned are also shared at the state's safety seminar. 9 Did state respond to Chairman's letter on previous evaluation within 60 days and correct 1 1 or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 2021 chair letter went out to Kent Chandler. There were no issues so a response was not required. Kent Chandler is still the Chairman. 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Info Only Info Only Years? Chapter 8.5 Info Only = No Points Evaluator Notes: A safety seminar was conducted August 23 and 24th, 2022. An agenda and attendance sheet is kept as documentation. Seminars are conducted every three years. 11 Has state confirmed transmission operators have submitted information into NPMS Info Only Info Only database along with changes made after original submission? Info Only = No Points Evaluator Notes: Melissa tracks NPMS submissions on a spreadsheet. This question is also addressed in the States supplemental checklist. Melissa also checks the Pipeline Safety Data Mart. 12 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The state has a web page which includes one call information, laws, statistics and radio spots. The site also includes statutes, regulations, notices and contact information. Other outreach strategies include emails and virtual meetings. The state also meets with municipal operators and Public Service Commission staff have made presentations at the Kentucky Gas Association expo. Kentucky also participates in the KGA (Kentucky Gas Assn) show case, PHMSA updates are fortwarded to operators. There is also outreach for weather alerts. 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: There were 2 Safety Related Condition (SRC), both on Columbia gas. 2/25/22 was a leak from a 4-inch line under water. 8/13/22 was damage from flooding in Hindman KY. Kentucky on scene for both SRCs, reports was written and both issues required line replacement which was completed. All SRC items were closed in WMS. 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? Evaluator Notes: DUNS: 098099674 2022 Gas State Program Evaluation 1 1 Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 10#
KY NG Program Evaluation, 2022, page 11a. Melissa keeps copies of survey e-mails with the date she responded written on the e-mail. b. Melissa goes into WMS every time she receives a notice. All WMS items were closed. 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: 1 1 Two waivers can be closed. Melissa was instructed on how to close the waivers. She was referred to the State guidelines. 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Information was readily available and retrievable. 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: 521 SICT days are required in 2022. 104 construction days were required. SICT days were met. There were no peer review comments for Kentucky's SICT submission. 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: On May 3, 2022, an evaluation of state metrics was performed by Mellissa. Staff goes over metrics with Mellissa during this evaluation. The review of the metrics is documented. 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Info Only Info Only Evaluator Notes: A presentation was made at the pipeline safety seminar in 2022. On 6/27, 2022 a email was sent supporting WMS. 20 General Comments: Info Only = No Points Evaluator Notes: There were no issues with Part D. Info Only Info Only Total points scored for this section: 50 Total possible points for this section: 50 DUNS: 098099674 2022 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 11#
KY NG Program Evaluation, 2022, 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: a. This was a public awareness effectiveness inspection of Columbia Gas. b. This inspection was last done three years ago. c. Columbia Gas representatives were Lisa Smith and James Rice. d. Chris Bailey has 4 years of experience. Info Only Info Only 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Chris used the IA equivalent form. This form was followed electronically during the inspection. 2 2 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. Review of the PA plan was done during the inspection. b. PA activity records were reviewed. c. This was a program inspection that did not involve field work. d. N/A e. The inspection took 1 day 4 From your observation did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Chris had a good understanding of the program and its requirements. He asked good questions and good follow-up questions. 5 Did the inspector conduct an exit interview, including identifying probable violations? (If inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: An exit interview was conducted. there were a couple follow up issues. 1 1 6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points Info Only Info Only DUNS: 098099674 2022 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 12#
KY NG Program Evaluation, 2022, page 13a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Evaluator Notes: a. Inspection was performed in the office. b There was no field work during this inspection. c-d. N/A 7 General Comments: Info Only = No Points Evaluator Notes: There were no issues with Part E. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 098099674 2022 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 13#
KY NG Program Evaluation, 2022, 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: Annual report information is tracked on a spreadsheet. Mellissa reviews annual reports. The operator is emailed when there are issues. Damage prevention inspections are done when an operator has more than 20 hits. 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: A damage prevention checklist was developed for this requirement. The questions in F2 are addressed in questions 27 and 28 of the damage prevention checklist. This checklist is used for damage prevention inspections. 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: a-j These issues are addressed during the damage prevention inspection. The above questions are addressed in questions 36-45 of the checklist. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? Evaluator Notes: DUNS: 098099674 2022 Gas State Program Evaluation 2 2 Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 14#
KY NG Program Evaluation, 2022, page 15a. Excavators are the largest stakeholder group causing damage. Damages per 1000 locate information is gathered from data mart. Questions 38, 39, 40 41-45 of the b-d. damage prevention checklist address the above questions. 5 General Comments: Info Only = No Points Evaluator Notes: No issues with Part F. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 098099674 2022 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 15#
KY NG Program Evaluation, 2022, 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: KY PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. 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: KY PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. 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: KY PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. 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: KY PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. 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: KY PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: KY PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 098099674 2022 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 16#
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