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2014 KY NG Program Evaluation - ky2014ngprogramevaluation (Kentucky; Natural Gas State Program Evaluation)
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KY NG Program Evaluation, 2014, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2014 Gas State Program Evaluation for KENTUCKY PUBLIC SERVICE COMMISSION Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 1#
KY NG Program Evaluation, 2014, page 22014 Gas State Program Evaluation -- CY 2014 Gas State Agency: Kentucky Rating: Agency Status: Date of Visit: 03/30/2015 - 04/02/2015 Agency Representative: Jason Hurt, Manager, Gas Pipeline Safety Branch James D. Rice, Assistant Director of Engineering Bill Aitken, Utility Regulatory & Safety Investigator IV Steve Samples, Gas Pipeline Safety Investigator PHMSA Representative: Glynn Blanton, USDOT/State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: David Armstrong, Chairman Agency: Kentucky Public Service Commission Address: 211 Sower Boulevard City/State/Zip: Frankfort, Kentucky 40602-0615 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2014 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 9.5 B Program Inspection Procedures 13 13 C Program Performance 46 46 D Compliance Activities 15 15 E Incident Investigations 10 10 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 114 113.5 State Rating................................................................................................................................................... 99.6 DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 2#
KY NG Program Evaluation, 2014, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress 1 1 Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Conducted a review of attachment 1 progress report document and found the information was correctly entered with the jurisdictional authority over Gas facilities. All inspection unit data was checked and matched Attachment 3. Suggested in future filing, enter the letter "F" for Interstate LNG because KPSC is not an interstate agent and no facilities exist in the state No issues. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Conducted a review of Attachment 2 and found information was correct on the number of inspection activities per the type of inspections performed. Reviewed office files and found four inspection days charged to the "Other" section listed under distribution. These four inspections were field verification of potential gas gathering systems. Continue to list these inspection days in the "Other" category but provide a description of the activity in the Note section. No issues. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress 1 1 Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A review and comparison of Attachment 3, List of Operators, to Kentucky Public Service Commission database found the inspection units were the same. No issues. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes, three incidents were reported in CY2014. The first occurred on City of Carrollton and the cause of the explosion was undetermined. Service riser, meter and regulator were damaged during the explosion. A pressure test of the service line found no leaks. The second incident was on Columbia Gas of Kentucky when a vehicle drove over a curb and hit the gas meter. Gas was released and an explosion and damage occurred to the hotel. The third incident was on Louisville Gas & Electric Company involving the separation of an mechanical coupling on an existing transmission pipeline. No issues of concern. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 0.5 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: I conducted a comprehensive review of the data provided in Attachment 5, Stats on Compliance Actions, and found number of carryovers from previous CY was incorrect. The correct number was initially thought to be 84 instead of 85. However, an additional review and email from Jason Hurt on April 22, 2015, confirm the actual number is 98. Therefore a loss of half point occurred. The number of carryovers is incorrect and will need to be corrected in KPSC 2014 Progress Report attachment 5. We will contact Carrie Winslow, PHMSA State Program, pertaining to correcting the error or allow Jason Hurt to access the Progress Report in FedSTAR to make this change. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, office files and data base documentation were well-organized. 2 2 DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 3#
KY NG Program Evaluation, 2014, page 47 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Training transcript information was downloaded from SABA system administered by PHMSA's Training and Qualification Division. A review of each inspector/engineer training courses was conducted and compared to information listed in Attachment 7. No areas of concern. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report 1 1 Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: KPSC has automatic adoption of federal pipeline safety regulations per state statute. A review of web site and state laws verified the information is correct. No issues. 9 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Conducted a review of Attachment 10. Information was informative and all questions pertaining to the nine elements, planned and past performance were addressed correctly. No issues. 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Loss of points occurred in Question A.5. See comments below. I conducted a comprehensive review of the data provided in Attachment 5, Stats on Compliance Actions, and found number of carryovers from previous CY was incorrect. The correct number should be 84 instead of 85. Loss of half point occurred. The number of carryovers from previous CY is incorrect and will need to be corrected in KPSC 2014 Progress Report. Please contact Carrie Winslow, PHMSA State Program, pertaining to accessing FedSTAR to make this correction. Total points scored for this section: 9.5 Total possible points for this section: 10 DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 4#
KY NG Program Evaluation, 2014, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 2 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A review of KPSC Procedure Manual found a new section 1 has been included in the document. This section addresses the risk ranking process they use in determining the type and frequency of their inspections. All operators are reviewed every three years by conducting a standard inspection. Procedures clearly demonstrate what they do, how often and include an exit interview with the operator. No areas of concern. 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, this item is listed in their procedures and Section F & T contain IMP and DIMP forms used by the inspectors. No areas of concern. 3 OQ Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, this item is also listed in their procedures and they use PHMSA Forms 14 & 15 when conducting the inspection. In CY2014, several operators were checked for OQ compliance during the standard inspection visits. It was suggested all future OQ inspections be separately identified and recorded from the standard inspections 4 Damage Prevention Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, this item is listed in their procedures. 1 1 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, this item is listed in their procedures. KPSC conducts onsite training based on request by the operator and at KGA meetings. No areas of concern. 6 Construction Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes, this item is listed in their procedures and performed routinely. KPSC has a requirement that all operators inform them of scheduled construction projects if the capital cost exceeds $100,000 or 100 psig pressures. No areas of concern. DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 5#
KY NG Program Evaluation, 2014, page 67 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: Yes, this information is located on page 6 of KPSC Pipeline Safety Branch Procedure Manual. The document states, ""The operators to be inspected are researched with the data available from previous inspections to determine the schedule of the annual safety inspection. Many items determine the priority of our inspections and may include the following: 1. The lost and unaccounted-for gas. 2. The number of leaks from recent surveys. 3. The known past history of the system (i.e. compliance history). 4. The type and condition of pipe. 5. The elapsed time since last inspection. 6. The total miles of main throughout the system. 7. The current number of customers. After the priority list of operators to be inspected has been determined, the operators are listed on a spreadsheet and a schedule is drafted indicating which inspector will conduct which inspection, as well as the approximate month for inspection. There will be times when the schedule will be changed for construction inspections or incident investigations. At that time the inspection will be rescheduled for a later date. All intrastate operators will be inspected at intervals dictated by the priority/risk-ranking, but should not exceed 3 years.". A review of inspection units found them to be broken down and identified correctly. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only No areas of concerns were found and KPSC has generally met the requirements of this section of the review. Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 6#
KY NG Program Evaluation, 2014, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 5 5 A. Total Inspection Person Days (Attachment 2): 491.50 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 4.50 = 990.00 Ratio: A / B 491.50 / 990.00 = 0.50 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: A.Total Inspection Person Days (Attachment 2)= 491.5 B.Total Inspection Person Days Charged to the program(220*Number of Inspection person years(Attachment 7)=990 Formula:- Ratio = A/B = 491.5/990 = 0.5 Rule:- (If Ratio >=.38 then points = 5 else Points = 0.) Thus Points = 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: Yes, KPSC personnel have completed mandatory training for Gas Integrity Management. Three inspectors have completed all DIMP courses and Steve Samples continues to be the lead on DIMP/IMP. Several web based and base courses have been completed by inspectors. The Pipeline Safety Manager and Assistant Director of Engineering have completed the PL1250 course. Three inspectors have completed the Root Cause course and all individuals have completed the PL3OQ & PL31C courses. No issues. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, Program Manager has successfully completed the PL1250 course in December, 2014. He has demonstrated excellent knowledge about the pipeline safety regulations and administrating the program. No issues. 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct 2 2 or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, KPSC Chairman Armstrong's response letter was received on July 9, 2014 and within the 60 day time schedule. No issues. 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 Yes = 2 No = 0 Evaluator Notes: DUNS: 098099674 2014 Gas State Program Evaluation 2 2 Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 7#
KY NG Program Evaluation, 2014, page 8Yes, the last seminar was held in May, 2013 at the Marriott Griffin Gate-Lexington, KY. A reminder was mentioned to the program manager to schedule a seminar in CY2016 to prevent a loss of evaluation question points in the future. 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Yes, a review of inspection reports, files and data base indicated all inspection units and operators were inspected within the required three year period described in their procedures manual. No issues of concern. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, KPSC procedure manual and a review of files found they utilize the federal inspection forms for all operators except Master Meter systems. They have a separate form they use which was developed from the federal distribution standard inspection form by eliminating portions that do not apply to Master Meter pipeline facilities. No issues of concern. 8 Did the state review operator procedures for determining if exposed cast iron pipe was 1 1 examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes, this is listed in the federal standard inspection document. As of December 2014, Louisville Gas & Electric has 52.5 miles of cast iron, Columbia Gas 15.5 miles and City of Fulton 3 miles. Total miles are 71. 9 Did the state review operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, this is reviewed and listed in the supplemental questions section of the federal standard inspection document they use. 10 Did the state review operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 1 1 Evaluator Notes: Yes, this is reviewed and listed in the supplemental questions section of the federal standard inspection document they use. 11 Did the state review 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? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, this is reviewed and listed in the supplemental questions section of the federal standard inspection document they use. 12 Evaluator Notes: DUNS: 098099674 2014 Gas State Program Evaluation 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 Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 8#
KY NG Program Evaluation, 2014, page 9Yes, they review and conduct a trend analysis of the information contained in the reports. This review assist in rank risking their inspection visits. No issues. 13 Did state input all applicable OQ, IMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 2 2 5.1 Evaluator Notes: issues. Yes = 2 No = 0 Needs Improvement = 1 Yes, a review of OQ & IMP federal database found three OQ inspections and two IMP inspections corrected recorded. No 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, no issues of concern. 1 1 15 Is the state verifying operators are conducting drug and alcohol tests as required by regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is checked and reviewed during the standard inspection audit. No issues. 2 2 16 Is state verifying operators OQ programs are up to date? This should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is checked and reviewed during the standard inspection audit. No issues. 2 2 17 Is state verifying operator's gas transmission integrity management programs (IMP) are up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is checked and reviewed during the standard inspection audit. No issues. 2 2 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 2 This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart P DIMP ? First round of program inspections should be complete by December 2014 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, all DIMP inspections have been completed. A review of DIMP database found 66 inspections were entered in CY2014. No issues. 19 Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. 49 CFR 192.616 (I13-16) PAPEI Effectiveness Inspections should have been completed by December 2013 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DUNS: 098099674 2014 Gas State Program Evaluation 2 2 Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 9#
KY NG Program Evaluation, 2014, page 10Yes, all PAPEI inspections were completed in CY2014. Inspection reports could not be entered into Federal database due to a software issue. Documentations were mailed to PHMSA to be entered into the database program. No issues 20 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: Yes, this continues to be accomplished via an emergency contact list and an annual letter to all operators about updates at the KPSC. Additionally, information is provided by KPSC website. No issues. 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes, a review of DataMart found one Safety Related Condition Report for Columbia Gas of Kentucky, Inc. The report pertained to a slip along 10th Street in Catlettsburg, KY. KPSC follow-up on the SRC and the item was corrected by the operator and correspondence provided between the operator and KPSC. No issues. 22 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, discussion with operators about this item continues to occur during seminar and onsite training meetings. KPSC has encouraged operators to discuss and share failure data with AGA's Plastic Pipe Data Committee. No issues. 23 Did the state participate in/respond to surveys or information requests from NAPSR or 1 1 PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, response to NAPSR survey on cast iron replacement program was found in an email to Program Manager. 24 If the State has issued any waivers/special permits for any operator, has the state verified 0 0 conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate.(New Question for CY2013, no points until CY2015 evaluation conducted in CY2016) Info Only = No Points Evaluator Notes: A review of PHMSA Special Permit website found one special permit. The request for waiver issued on June 30, 2003 pertaining to Catlettsburg Refining, LLC. This waiver is still in effect. KPSC will review the current status of the waiver and notify PHMSA of the results. It may be necessary for KPSC to request the permit be withdrawn and removed from PHMSA website. 25 Did the state attend the National NAPSR Board of Directors Meeting in CY being 0 0 evaluated? (New Question for CY2014, no points first year) Info Only = No Points Evaluator Notes: Yes, Jason Hurt and James Price attended the NAPSR National meeting in August, 2014. They are aware of this new question and requirement to attend the National NAPSR Board of Directors Meeting in the future. 26 Discussion on State Program Performance Metrics found on Stakeholder Communication site. (question will be rolled up and included as part of Question C12 on future evaluations) http://primis.phmsa.dot.gov/comm/states.htm Info Only = No Points Evaluator Notes: 0 0 Yes, this item was reviewed and how to access the website was provided to the Program Manager. A review of charts DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 10#
KY NG Program Evaluation, 2014, page 11indicate leaks per 1,000 miles is up from previous years. KPSC may consider adding this risk ranking item in their inspection program priority list. 27 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only No areas of concerns were found and KPSC has generally met the requirements of this section of the review. Total points scored for this section: 46 Total possible points for this section: 46 DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 11#
KY NG Program Evaluation, 2014, page 12PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement Evaluator Notes: Conducted a review of KPSC Procedure Manual and found correspondence is sent to the company officer/owner when a noncompliance is found. Procedures describe the following: "KPSC provides the operators with 30 days to respond to alleged probable violations. A form for the operator to complete (if a deficiency is found) is included with the letter to the operator detailing the results of each inspection. The operator must complete the three questions on the form for the KPSC to consider closing the file on the inspection. The operator has the opportunity to argue their case if they feel like a probable violation did not occur. The procedures state that follow up inspections are scheduled after written notification of non-compliance has been sent to an operator. Each inspection report describes the status of deficiencies found in previous inspections. Deficiency information is entered into the inspection database which can be used to report the status of probable violations." Reviewed random inspection reports and found no issues with this requirement. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Were probable violations documented? Yes No Needs Improvement c. Were probable violations resolved? Yes No Needs Improvement d. Was the progress of probable violations routinely reviewed? Yes No Needs Improvement Evaluator Notes: Yes, KPSC data base and files show compliance letters are sent to company officer or manager. KPSC staff verifies this information at the start of their inspection and changes are recorded and entered in the database during an inspection visit. A review of 2014 inspections indicated documentation of all probable violations were noted, corrective actions taken by the operator and closure of the inspection reports were complete. All violations opened or closed are maintained on a separate spreadsheet and reviewed monthly. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: the operator. No issues. Yes, reviewed Deficiency Tracking Report and found probable violations were followed up with written communication to 4 Did compliance actions give reasonable due process to all parties? Including "show 2 2 cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes, operators are given an opportunity to provide information that argues a probable violation did not occur by answering the three questions in the Deficiency Tracking Report. An informal meeting may be conducted to resolve the probable violation before going to a show cause hearing. 5 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the Program Manager is familiar with this process and it is described in KPSC Procedure Manual. DUNS: 098099674 2014 Gas State Program Evaluation 2 2 Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 12#
KY NG Program Evaluation, 2014, page 136 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 1 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the recent civil penalty of $1,000 assessed against, Duke Energy, Case Number 2014-00263 is a clear demonstration of their enforcement authority. No issues. 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only No areas of concerns were found and KPSC has generally met the requirements of this section of the review. Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 13#
KY NG Program Evaluation, 2014, page 14PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ 2 2 accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this item is located in the Procedures Manual page 322. A letter is sent to all operators about reporting events of an incident/accident. It was suggested the letter be sent on an annual time frame starting the first month of each year. No issues. 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: Yes, this is accomplished using a group email address to all pipeline safety personnel and other important staff members including the Commissioners. If a staff member receives a call from the operator, the inspector notifies the individual by the email address feature. No issues. State acknowledged they are aware of the MOU between NTSB/PHMSA and this information is located in their procedures manual. No issues. 3 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 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes, a review the investigative reports for the City of Carrollton, Columbia Gas of Kentucky and LG& E Gas indicated the investigations were thoroughly documented with contributing factors and other observations reviewed. No issues. 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: Yes, a review of incident reports found KPSC investigated correctly with observations, contributing factors and other recommendations in their notes and reports. KPSC followed their state procedures as described in their procedures in handling all reportable incidents. No issues of concern. 5 Did the state initiate compliance action for violations found during any incident/accident 1 1 investigation? Yes = 1 No = 0 Evaluator Notes: KPSC is considering taking action on two of the three incidents that occurred last year. This action may include compliance action and potential civil penalties. The cases are under review by KPSC legal division. 6 Did the state assist region office 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/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No action was necessary by KPSC to PHMSA. This is an NA. DUNS: 098099674 2014 Gas State Program Evaluation 1 NA Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 14#
KY NG Program Evaluation, 2014, page 157 Does state share lessons learned from incidents/accidents? (sharing information, such as: 1 1 at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: Information on incidents and accidents is shared with other state program managers at the NAPSR Southern Region meeting and during PHMAS Quarterly Liaison conference calls. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only No areas of concerns were found and KPSC has generally met the requirements of this section of the review. Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 15#
KY NG Program Evaluation, 2014, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is addressed during the standard and construction inspections. Observed this item being reviewed at the City of Carrollton inspection on April 2, 2015. This item is listed and discussed with the operator on their Supplemental Inspection form. 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this item is listed and discussed with the operator on their Supplemental Inspection form. 2 2 3 Did the state encourage and promote practices for reducing damages to all underground facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this item is listed and discussed with the operator on their Supplemental Inspection form. 2 2 4 Has the agency or another organization within the state collected data and evaluated 2 2 trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is in the supplemental inspection form and monitoring during their review of the annual reports submitted by the operators. No issues. 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only No areas of concerns were found and KPSC has generally met the requirements of this section of the review. Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 16#
KY NG Program Evaluation, 2014, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: Carrollton Utilities Name of State Inspector(s) Observed: Steve Samples, KPSC, Gas Pipeline Safety Investigator Location of Inspection: Carrollton, KY Date of Inspection: April 1, 2015 Name of PHMSA Representative: Glynn Blanton, US DOT/PHMSA State Programs Evaluator Notes: The following Carrollton Utilities representatives were present during the standard inspection being performed. Tim Pearson, Safety Officer, Terry Roach, Utility Engineer & Bill Osborne, General Manager. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 Evaluator Notes: Yes, notification was provided to the operator two weeks in advance of the inspection. 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Steve Samples used PHMSA Standard Inspection Form. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, detailed documentation on answers to questions was entered into the form. Observed inspector asking a lot of follow up questions to clarify the answers. No issues. 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: Yes, regulator relief equipment and gauges were checked and verified the accuracy of the devices before performing a regulator relief check. 2 2 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: Yes, procedures, records and regulator station equipment were adequately reviewed during office and field inspections. DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 17#
KY NG Program Evaluation, 2014, page 187 Did the inspector have adequate knowledge of the pipeline safety program and 2 2 regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Steve Samples has completed all TQ courses, is a lead inspector in DIMP & IMP and has over twenty years of experience in Gas transmission and distribution systems. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: Yes, at the end of the day Steve Samples, KPSC, conducted an exit interview with Time Pearson, Safety Officer with Carrollton Utilities and mentioned three potential violations. 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Yes, at the end of the day several potential violations and areas of concerns were discussed with the operator. The following three potential violations may be issued against the operator. (1) 192.616(c) ? Carrollton Utilities did not complete the public awareness evaluation effectiveness survey within the 4 year requirement as the plan and API 1162 states. (2) 192.465(b) ? Carrollton Utilities exceeded the 2 1/2 month interval for checking CP monitoring during the 2014 CP inspections at the Blue Lick rectifier station. (3) 191.9 -- Carrollton Utilities exceeded the 30 day reporting criteria to PHMSA after reporting an incident. 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education Info Only Info Only DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 18#
KY NG Program Evaluation, 2014, page 19y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: This was an inspection that started on March 26 and ended on April 2, 2015. I only observed the April 1st inspection. This was a standard inspection conducted on Carrollton Utilities. The last inspection was also a standard inspection on May 16, 2012 and resulted in 0 deficiencies. The piping system consists of 10'' and under coated steel and plastic piping with pressures ranging from 30 to 280 PSIG. Carrollton Utilities has 2 points of delivery from Texas Gas Transmission. The Operating and Maintenance, Emergency, Damage Prevention, Operator Qualification, Drug and Alcohol, Distribution Integrity Management, and Public Awareness Plans were reviewed during the office visit. Also inspected were samples of 2013, 2014, and 2015 records pertaining to leakage surveys and repairs, valve inspections, patrolling, corrosion control, regulator inspections,pressure recordings, distribution integrity management, public awareness, and odorant verifications. The field portion of the inspection consisted of inspecting regulator settings, pipeline markers, mainline valve locations, and meter installations. Also inspected the 2 points of delivery from Texas Gas Transmission and performed a protocol 9 field check on a relief regulator and valve setting in Sparta, Ky. Many corrosion field checks were checked by PSC and Carrollton Utilities personnel to verify corrosion protection on standard CP check points and one casing check. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 19#
KY NG Program Evaluation, 2014, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: KPSC is not an interstate agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: KPSC is not an interstate agent. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: KPSC is not an interstate agent. 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: KPSC is not an interstate agent. 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: KPSC is not an interstate agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: KPSC is not an interstate agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: KPSC is not an interstate agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: KPSC is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 20#
KY NG Program Evaluation, 2014, page 21PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: KPSC is not an interstate agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: KPSC is not an interstate agent. 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: KPSC is not an interstate agent. 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: KPSC is not an interstate agent. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: KPSC is not an interstate agent. 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: KPSC is not an interstate agent. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: KPSC is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 098099674 2014 Gas State Program Evaluation Kentucky KENTUCKY PUBLIC SERVICE COMMISSION, Page: 21#
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