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PHMSA la-2017-gas-program-evaluation
2017 LA NG Program Evaluation - la-2017-gas-program-evaluation (Louisiana; Natural Gas State Program Evaluation)
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LA NG Program Evaluation, 2017, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2017 Gas State Program Evaluation for Louisiana Department of Natural Resources 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: 809927387 2017 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 1#
LA NG Program Evaluation, 2017, page 22017 Gas State Program Evaluation -- CY 2017 Gas State Agency: Louisiana Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: No Date of Visit: 04/23/2018 - 05/04/2018 Agency Representative: Michael Peikert, Assistant Director PHMSA Representative: Don Martin Commission Chairman to whom follow up letter is to be sent: Name/Title: Richard Ieyoub, Commissioner Agency: Louisiana Department of Natural Resource-Office of Conservation Address: 617 North Third Street City/State/Zip: Baton Rouge, Louisiana 70802 INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2017 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 13 13 C Program Performance 49 44 D Compliance Activities 15 15 E Incident Investigations 11 11 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 118 113 State Rating................................................................................................................................................... 95.8 DUNS: 809927387 2017 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 2#
LA NG Program Evaluation, 2017, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Upon review of the LADNR's spreadsheet which lists operators and units, the entries on Attachment 1 are correct. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Upon review of the LADNR's Composite Breakdown, no inaccuracies on Attachment 2 were found. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: The listing of operators and inspection units on Attachment 3 was verified by the LADNR's records. The inspection unit totals for each operator type were consistent between Attachment 1 and Attachment 3. No issues found. 4 Were all federally reportable incident reports listed and information correct? - Progress 1 1 Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The reports listed in the Pipeline Data Mart (PDM) were covered in Attachment 4. There were an additional two reports that were not in the PDM. The two reports did not meet the $50,000 in damages threshold and therefore were not reportable by federal reporting requirements. There was a typo on the dated for Report No. 20170046. It should have been 5/31/2017 instead of 5/31/2018. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The LADNR's 2017 Citation Spreadsheet was reviewed and compared to Attachment 5. No inaccuracies were found. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The LADNR's hardcopy file were observed in the file room. All appeared to be well organized. The LADNR's electronic files were well organized and very easy to access. No issues were noted. 7 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No inaccuracies found in the employee listing on Attachment 7. Training was downloaded from PHMSA's Training and Qualification database. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 DUNS: 809927387 2017 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 3#
LA NG Program Evaluation, 2017, page 4No inaccuracies were found on the entries on Attachment 8. There are some updates that will be needed when completing the 2018 Progress Report. 9 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. The LADNR listed four accomplishments for 2017. The LADNR should continue to establish goals to be accomplished in its program. 10 General Comments: Info Only = No Points Evaluator Notes: The LADNR has generally complied with the requirements of Part A of this evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 809927387 2017 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 4#
LA NG Program Evaluation, 2017, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 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: The LADNR's INSPECTION GUIDANCE document, revised 4/2/18, was reviewed. The guidance meets the requirement that inspectors have procedures that promote consistency. Pre-inspection, inspection activity, and post-inspection portions of an inspection are covered. No issues. 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The LADNR's INSPECTION GUIDANCE document, revised 4/2/18, was reviewed. The guidance meets the requirement that inspectors have procedures that promote consistency. Pre-inspection, inspection activity, and post-inspection portions of an inspection are covered. The inspection modules provide additional information on details for IMP and DIMP inspections. 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: The LADNR's INSPECTION GUIDANCE document, revised 4/2/18, was reviewed. The guidance meets the requirement that inspectors have procedures that promote consistency. Pre-inspection, inspection activity, and post-inspection portions of an inspection are covered. The inspection modules provide additional information on details for OQ inspections. 4 Damage Prevention Inspection procedures should give guidance to state inspectors that 1 1 insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The LADNR's INSPECTION GUIDANCE document, revised 4/2/18, was reviewed. The guidance meets the requirement that inspectors have procedures that promote consistency. Pre-inspection, inspection activity, and post-inspection portions of an inspection are covered. The inspection modules provide additional information on details for Damage Prevention inspections. 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The LADNR's INSPECTION GUIDANCE document, revised 4/2/18, was reviewed. The guidance meets the requirement that inspectors have procedures that promote consistency. Pre-inspection, inspection activity, and post-inspection portions of an inspection are covered. The inspection modules provide additional information on details for Operator Training. 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: DUNS: 809927387 2017 Gas State Program Evaluation 1 1 Louisiana Louisiana Department of Natural Resources, Page: 5#
LA NG Program Evaluation, 2017, page 6The LADNR's INSPECTION GUIDANCE document, revised 4/2/18, was reviewed. The guidance meets the requirement that inspectors have procedures that promote consistency. Pre-inspection, inspection activity, and post-inspection portions of an inspection are covered. The inspection modules provide additional information on details for Construction inspections. 7 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: The LADNR's PIPELINE SAFETY PROGRAMS GUIDELINES FIELD INSPECTIONS FOR GAS AND LIQUIDS OPERATORS INSPECTION PRIORITIZATION AND PROCEDURES document was reviewed. The guidance meets the requirement for prioritizing inspection units. The guidance includes the following statement: "If an inspection indicates portions of the operators' system is not being properly operated and maintained as required by the written procedures. Other means of criteria utilized for both Comprehensive (Standard) and Specialized inspections may be based upon the risk analysis (risk model developed by LDNR) for the operator's system and operations. This risk based approach could be based upon the inspectors' records, operators' records, historical high risk areas, past operator performance in those areas, etc. Non-routine activities undertaken by the operator such as construction, change of personnel, acquisitions and mergers, and significant changes, etc. in procedures would be activities which could require an inspection prior to the scheduled annual inspection." 8 General Comments: Info Only = No Points Evaluator Notes: The LADNR has generally complied with Part B of this evaluation. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 809927387 2017 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 6#
LA NG Program Evaluation, 2017, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 1370.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 13.91 = 3060.75 Ratio: A / B 1370.00 / 3060.75 = 0.45 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: The LADNR had 1370 inspection person-days which exceeded the minimum requirement. 5 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: A review was made of Training and Qualifications SABA database system. Inspectors have completed the core training requirements within the required timeframe and the recently hired inspectors are progressing satisfactory. No issues were found with inspectors leading inspections without obtaining the required training prior to the inspections. At least one inspector has completed root cause training. 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: Michael Peikert was named Program Manager in August, 2017. Michael was an Engineer in the LADNR pipeline safety program from 2004 to 2018. He is knowledgeable of the pipeline safety regulations. He has completed the core training classes for gas and hazardous liquid programs and is taking the additional classes for special inspections (OQ, IMP,etc.). Michael has spent considerable with Stephen Giambrone the previous program manager who is also Michael's immediate supervisor. 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: The LADNR responded in 47 days. The LADNR responded to all issues outlined in the Program Evaluation Letter to the Chairman. 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: The LADNR conducts a seminar on an annual frequency. No issues found. DUNS: 809927387 2017 Gas State Program Evaluation 1 1 Louisiana Louisiana Department of Natural Resources, Page: 7#
LA NG Program Evaluation, 2017, page 86 Did state inspect all types of operators and inspection units in accordance with time 5 0 intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Needs improvement. The LADNR has not inspected 34 gas inspection units out of a total of 350 within the five year time frame. 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: A sampling of questions on the LADNR's comprehensive inspection form was compared to the federal standard inspection forms. No discrepancies were found. The LADNR utilizes the federal inspection forms for all other inspection types. 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. There is a question on the LADNR's comprehensive inspection form that reviews an operators procedures related to cast iron and specifically includes investigating for graphitization. Cast Iron Mains in LA trended down from 305.3 at end of 2016 to 250.1 at end of 2017. Approximately 158 miles replaced over last five years. 9 Did the state review operator procedures for surveillance of cast iron pipelines, including 1 1 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: Yes. There is a question on the LADNR's comprehensive inspection form that reviews an operators procedures related to circumferential cracking failures. 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. The LADNR's comprehensive inspection forms has a question that covers this requirement. Upon a review of randomly selected inspection reports this question was completed by the inspector. 11 Did the state review operator records of previous accidents and failures including 1 1 reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes. The LADNR covers 192.617 records when conducting comprehensive inspections. The LADNR's comprehensive inspection has a question documenting the review of the operator's records. Upon a review of randomly selected inspection files this question was completed by the inspector. 12 DUNS: 809927387 2017 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? 2 2 Louisiana Louisiana Department of Natural Resources, Page: 8#
LA NG Program Evaluation, 2017, page 9Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The LADNR has procedures titled "Annual Report Data Gathering and Trend Analysis". The engineer on staff reviews the data and compares to previous annual reports. The engineer maintains the Annual Report spreadsheet where data is entered. The inspectors review the annual report as part of the pre-inspection work. 13 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes. The LADNR inspectors review submittal information during comprehensive inspections. The results are documented on the comprehensive inspection form. 14 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 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: During 2017, the LADNR had a significant focus on Drug and Alcohol inspections. The LADNR conducted 106 Drug and Alcohol Inspections during 2017. No issues found. 15 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: OQ was not a focus area during 2017. The LADNR experienced 12 Inspection Person-days conducting OQ inspections during 2017. 16 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). (Are the State's largest operators programs being contacted or reviewed annually? Are replies to Operator IM notifications addressed? (formerly part of Question C-13)). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 IMP inspections was not a focus area during 2017. The LADNR spent 53 inspection person-days conducting IMP and DIMP inspections during 2017. The LADNR has identified a higher focus for IMP and DIMP in future inspection plans. 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 2 This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The first round of DIMP plans has been completed. The LADNR has raised the priority of DIMP and DIMP implementation inspections in its inspection plan. 18 Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DUNS: 809927387 2017 Gas State Program Evaluation 2 2 Louisiana Louisiana Department of Natural Resources, Page: 9#
LA NG Program Evaluation, 2017, page 10The first round of Public Awareness Plan inspections and effectiveness reviews have been completed. The LADNR will be conducting a second round of these inspections during 2018. 19 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: Examples are Website, damage prevention conference, LGA two each year, Public Awareness Liaison routinely through state, LA Mid Continent OG Midstream Committee. 20 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: There were SRCR's listed for gas operators in the Pipeline Data Mart (PDM). The LADNR files contained the SRCR's that were listed in the PDM. The LADNR had documentation that the reports are being followed up. 21 Did the State ask Operators to identify any plastic pipe and components that has shown a record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Included on 192.703(b, Page 17, on distribution comprehensive form. 1 1 22 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No instances were found where the LADNR did not respond. 1 1 23 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. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: 1 1 There is one active waiver granted by the LADNR. The LADNR's actions and follow up have been satisfactory. 24 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: The LADNR had representatives attend the meeting in Columbus, OH. 1 1 25 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: The LADNR was aware of the performance of measures for Louisiana. The LADNR is monitoring the trends. Damages per 1000 locates is the most concerning of the performance measurement. The LADNR is focusing on this measure. The LADNR was successful in obtaining enforcement authority of damage prevention law in Louisiana. DUNS: 809927387 2017 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 10#
LA NG Program Evaluation, 2017, page 1126 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: No problems were identified with the LADNR's use of the SICT. 1 1 27 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 1 1 Evaluator Notes: bulletin issue. Yes. The LADNR has a question on its comprehensive inspection form for gas transmission operators to cover this advisory 28 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: The LADNR has generally complied with the requirements of Part C of this evaluation but needs improvement to achieve the five year inspection interval on standard, OQ and IMP inspections. Total points scored for this section: 44 Total possible points for this section: 49 DUNS: 809927387 2017 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 11#
LA NG Program Evaluation, 2017, page 12PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: Yes. The LADNR has established procedures describing the steps to execute non-compliance actions and communicate the issues to operators. Non-compliance letters to operators provide a description of the steps. The LADNR's inspection and compliance database system is able to monitor the progress of the steps until the inspection file is closed. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: Upon a review of randomly selected inspection report files, there were no instances found where the LADNR did not comply with the requirements of this question. The LADNR has a review process that upholds the validity of the alleged violations and promote consistency in the pipeline safety program. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Upon a review of randomly selected inspection reports, there were no instances found where a probable violation did not result in a compliance action. 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes. The operator is allowed to request informal conferences or formal hearings to argue their positions. 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 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 stated a methodical process with pre-determined criteria for the decision to issue a citation and the amount of the civil penalty. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? DUNS: 809927387 2017 Gas State Program Evaluation 1 1 Louisiana Louisiana Department of Natural Resources, Page: 12#
LA NG Program Evaluation, 2017, page 13Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. There were several 2017 inspections reviewed that resulted in civil penalties. The LADNR has shown penalties amounts cited in previous year progress reports. 7 General Comments: Info Only = No Points Evaluator Notes: The LADNR generally complied with the requirements of Part D of this evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 809927387 2017 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 13#
LA NG Program Evaluation, 2017, page 14PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ 2 2 accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The LADNR has procedures titled "GUIDELINES FOR FORMING AN ACCIDENT RESPONSE TEAM". No deficiencies were found in the procedures. 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. The LADNR has an established phone number for operators to call in the event of an incident. Operators also have the contact information for inspectors in the LADNR. The Assistant Director and Director will be notified by these methods of contact. They will initiate the needed actions to perform investigations of the incidents/accidents. They are aware of their investigation responsibilities and coordination with federal authorities. 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 The LADNR understands the methods to gather the needed information is an on-site investigation is not required. Upon a review of the reported incidents during 2017, no issues were found with the LADNR's handling of the incident investigations. 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. The inspection/investigation files were reviewed for all reported incidents during 2017. No significant issues were found during the review. 5 Did the state initiate compliance action for violations found during any incident/accident 1 1 investigation? Yes = 1 No = 0 Evaluator Notes: Upon a review of the 2017 inspection/investigation files, non-compliance actions were taken if probable violations were found. 6 Did the 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? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 The AID's feedback to the evaluator: "The AID has nothing but the highest regard for our LA State Partners w.r.t. their assistance in supplying information on regulated and non-regulated events in their state. They have been responsive DUNS: 809927387 2017 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 14#
LA NG Program Evaluation, 2017, page 15whenever AID staff has made requests. They have also provided AID staff with valuable knowledge of some specific concerns in LA like leaks from production wells and small sheens offshore." 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes. The LADNR has shared facts about its investigations at the NAPSR Southwest Region meeting each year. 8 General Comments: Info Only = No Points Evaluator Notes: The LADNR has generally complied with the requirements of Part E of this evaluation. Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 809927387 2017 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 15#
LA NG Program Evaluation, 2017, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The LADNR has Question 192.614(a in its comprehensive inspection form that covers operator's procedure for protecting its pipeline facilities. 2 Did the state inspector verify pipeline operators are following their written procedures 2 2 pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The LADNR has several questions on its comprehensive inspection form (page 8 for distribution and page 11 for transmission). 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Adopted the nine elements. The LADNR provides presentation for all stakeholders in the LA Damage Prevention Summit, LA Gas Assoc. and pipeline safety seminar. The LADNR has enforcement since June of 2017. 4 Has the agency or another organization within the state collected data and evaluated 2 2 trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The LADNR has taken information from the annual reports and entered into a spreadsheet to view trends on excavation damage. The information is also kept at the operator level in order to drill down on troubled operators in relation to damages. Discussions have been held with operators that have poor statistics. 5 General Comments: Info Only = No Points Evaluator Notes: The LADNR has generally complied with the requirements of Part F of this evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 809927387 2017 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 16#
LA NG Program Evaluation, 2017, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: XTO Name of State Inspector(s) Observed: Ronald Day Location of Inspection: XTO's Office in Cotton Valley, LA Date of Inspection: April 24 - 26, 2018 Name of PHMSA Representative: Don Martin Evaluator Notes: The LADNR conducted a Standard Inspection of XTO's gathering and transmission system in the Cotton Valley, LA area. XTO was represented by Jameson Gowin, Regulations Compliance, Bridget Langston PSM/MI, and Mark Clements Corrosion Technician. The inspection was led by Ronald Day. 2 Was the operator or operator's representative notified and/or given the opportunity to be 1 1 present during inspection? Yes = 1 No = 0 Evaluator Notes: XTO's Superintendent was notified of the inspection during the last week of January, 2018. The operator was represented during the inspection. Jameson Gowin of XTO's compliance office was present along with Mark Clement and Bridget Langston. 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 2 2 Evaluator Notes: Yes. The inspector utilized the Pipeline Safety Field Inspection Supplement Form during the inspection of pipeline facilities in the field. Cathodic protection readings were the primary results documented on the form. During the records review portion of the inspection, the inspection form in the Empire database system was completed online as the inspection progressed. 4 Did the inspector thoroughly document results of the inspection? 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The Field Inspection Supplement Form was completed during the field facility inspection and the Empire database form for the record portion. 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: Yes. The voltage meter and half cell were verified. 1 1 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities 2 2 DUNS: 809927387 2017 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 17#
LA NG Program Evaluation, 2017, page 18d. Other (please comment) Evaluator Notes: This inspection was a specific inspection (no procedures review). An inspection of facilities and cathodic protection readings was performed on 4/24/2018. Records of testing and maintenance were reviewed on 4/25/2018. No issues were found. 7 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. Ronald Day has completed all of the required training at PHMSA Training and Qualifications. He has been an inspector with the LADNR for 38 years. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: Yes. The inspector conducted an exit briefing in the afternoon of 4/25/2018. 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: The inspector stated no probable violations were found during 4/24 and 4/25. 1 1 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education Info Only Info Only DUNS: 809927387 2017 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 18#
LA NG Program Evaluation, 2017, 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: The LADNR generally complied with Part G of this evaluation. DUNS: 809927387 2017 Gas State Program Evaluation Total points scored for this section: 12 Total possible points for this section: 12 Louisiana Louisiana Department of Natural Resources, Page: 19#
LA NG Program Evaluation, 2017, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The LADNR 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: The LADNR 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: The LADNR 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: The LADNR 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: The LADNR 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: The LADNR 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: The LADNR is not an interstate agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: The LADNR is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809927387 2017 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 20#
LA NG Program Evaluation, 2017, page 21PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The LADNR does not have a 60106 agreement. 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: The LADNR does not have a 60106 agreement. 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: The LADNR does not have a 60106 agreement. 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: The LADNR does not have a 60106 agreement. 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: The LADNR does not have a 60106 agreement. 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: The LADNR does not have a 60106 agreement. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: The LADNR does not have a 60106 agreement. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809927387 2017 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 21#
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