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PHMSA la-2020-gas-program-evaluation
2020 LA NG Program Evaluation - la-2020-gas-program-evaluation (Louisiana; Natural Gas State Program Evaluation)
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LA NG Program Evaluation, 2020, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2020 Gas State Program Evaluation for Louisiana Department of Natural Resources Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: 809927387 2020 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 1#
LA NG Program Evaluation, 2020, page 22020 Gas State Program Evaluation -- CY 2020 Gas State Agency: Louisiana Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: No Date of Visit: 10/25/2021 - 10/28/2021 Agency Representative: Michael Peikert, Assistant Director, LDNR PHMSA Representative: Agustin Lopez, State Liaison, PHMSA Commission Chairman to whom follow up letter is to be sent: Name/Title: Richard Ieyoub, Commissioner Agency: Louisiana Department of Natural Resources- Office of Conservation Address: 617 North Third Street City/State/Zip: Baton Rouge, Louisiana 70802 INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2020 (not the status of performance at the time of the evaluation). A deficiency in any one part of a multiple-part question should be scored as “Needs Improvement.” Determine the answer to the question then select the appropriate point value. If a state receives less than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their performance). This evaluation, together with selected factors reported in the state's annual progress report attachments, provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 49 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 99 State Rating................................................................................................................................................... 99.0 DUNS: 809927387 2020 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 2#
LA NG Program Evaluation, 2020, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress report) Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: a. Verified submitted data with spreadsheet to assure numbers are correct. b. Reviewed composite spreadsheet to verify inspection days on Attachment 2. c. Compared PDM data with operator list to verify accuracy. d. All reportable incidents were investigated and summary provided on Attachment 3. e. Compliance actions were verified with composite spreadsheet and citation spreadsheet. f. Records are kept by the LDNR as mentioned in Attachment 6. g. Verified qualifications of inspectors with T&Q Blackboard. h. The LDNR has adopted the federal regulations. i. LDNR provided initiatives and accomplishments in attachment 10. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809927387 2020 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 3#
LA NG Program Evaluation, 2020, page 4PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities 5 5 for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. TIMP and DIMP Inspections (reviewing largest operator(s) plans annually) c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) g. LNG Inspections Evaluator Notes: LDNR Standard Operating Procedures Section 5 includes each type of inspection conducted by the LDNR which provide guidance to inspectors. Pre and post inspections activities are included. Section 7 provides a detail guidance on performing inspections, exit interview and writing a final report. 2 Do written procedures address inspection priorities of each operator, and if necessary each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? 4 4 Evaluator Notes: Yes, LDNR Standard Operating Procedures Section 2 address the prioritization of inspections which include length of time since last inspection, history of unit, internal and external events of units, large unit rotations, and HCA mileage. 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 3 3 taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: cases. LDNR Standard Operating Procedures Section 10a includes the state's enforcement procedures for when a non compliance is found to the resolution of the non compliance. Section 4.7 of SOP includes a re-inspection for closing out non compliance 4 (Incident/Accident Investigations) Does the state have written procedures to address state actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. 3 3 DUNS: 809927387 2020 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 4#
LA NG Program Evaluation, 2020, page 5Evaluator Notes: LDNR Standard Operating Procedures Section 5 (4.5) and 9 include incident/accident investigation procedures and has mechanism to respond to incident notifications. The LDNR investigates all reportable incidents. 5 General Comments: Info Only = No Points Evaluator Notes: The LDNR is mainly complying with Part B of the Evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 809927387 2020 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 5#
LA NG Program Evaluation, 2020, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead b. Completion of Required DIMP/IMP Training before conducting inspection as lead c. Completion of Required LNG Training before conducting inspection as lead d. Root Cause Training by at least one inspector/program manager e. Note any outside training completed f. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) 5 5 Evaluator Notes: Verified lead inspector training in T&Q Blackboard to assure lead inspectors are qualified. Root cause has been taken by at least one inspector. Reviewed randomly selected inspection reports to verify lead was qualified to lead each type of inspection. 2 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 = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Michael Peikert is very knowledgeable of the pipeline safety program and regulations. He has been with the LDNR as an engineer and with Pipeline Safety for many years. 3 General Comments: Info Only = No Points Evaluator Notes: The LDNR is mainly complying with Part C of the Evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 809927387 2020 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 6#
LA NG Program Evaluation, 2020, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 4 intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction (did state achieve 20% of total inspection person-days?) g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: The LDNR has greatly improved in completing each inspection per the interval established in their procedures. With a full staff the LDNR was able to inspect units in accordance with the interval established in their procedure (5 years). Randomly selected inspections were reviewed to verify the inspection cycle. The only issue was with master meters that did not meet the five year interval inspection cycle. In reviewing the LDNR inspection schedule there were about 20 master meters that have not had either an OQ or a comprehensive inspection within the last 5 years. There was a one point deduction for this issue. 2 Did inspection form(s) cover all applicable code requirements addressed on Federal 10 10 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: Yes, randomly selected inspections were reviewed for completeness and to assure a complete inspection was performed. The LDNR uses their "Empire" software to electronically document all their inspection. In addition all inspections are available thru their Sonrise online website. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 2 2 should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the LDNR is conducting OQ inspection to assure operator's plans are meeting the regulations. Field OQ inspections are also performed during inspections. Reviewed randomly selected OQ inspection to assure the inspections are being conducted and documented. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 2 2 DUNS: 809927387 2020 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 7#
LA NG Program Evaluation, 2020, page 8a. Are the state's largest operator(s) plans being reviewed annually to ensure they are completing the full cycle of the DIMP/IMP process? b. Are states verifying with operators any plastic pipe and components that have shown a record of defects/leaks and mitigating those through DIMP plan? c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? Evaluator Notes: Yes, reviewed inspection plan for 2020 along with randomly selected IMP inspections to assure IMP inspection are being performed. The LDNR uses assessment activity as part of their IMP inspection schedule. Only one operator has low pressure system which the LDNR has discussed the potential threats with the operator. 5 Did the state review the following (these items are NTSB recommendations to PHMSA 2 2 that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. Operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance); c. Operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21; d. Operator records of previous accidents and failures including reported third- party damage and leak response to ensure appropriate operator response as required by 192.617; e. Directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? Evaluator Notes: The LDNR addresses the NTSB questions as part of the standard inspections. The comprehensive form covers a-e and are reviewed during the inspections. There is only one operator with low pressure system which the LDNR has met with to discuss the threats. 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: The LDNR works with their operators whenever advisory bulletins are issued. The LDNR holds annual seminars to educate their operators on advisory bulletins. 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? 10 10 DUNS: 809927387 2020 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 8#
LA NG Program Evaluation, 2020, page 9g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) Evaluator Notes: Reviewed randomly selected inspection reports which some had compliance actions issued. Compliance actions are documented properly and reviewed for progress by the program manager to assure there are no delays. State does issue civil penalties. Only concern is the amount of increased carry over from previous years. This was due to the covid and low staff so carry overs should improve in the coming years. In addition, in reviewing the LDNR spreadsheet which tracks open compliance cases, there are a few dating back several years. Although the probable violations have been corrected, the cases still show as open so it makes it seem that the cases are not being corrected within a reasonable time. 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly 10 10 documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? i. Does state share any lessons learned from incidents/accidents? Evaluator Notes: Yes, reviewed incident investigation reports and all reportable incidents were investigated. The LDNR has a good mechanism to receive and respond to incidents. The investigations were documented and had facts about the incident. The LDNR shares lessons learned during the NAPSR Region meetings. 9 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the LNDR responded within 60 days and addressed the deficiencies. 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Evaluator Notes: Yes, the LDNR has an annual seminar which has great operator turnout. Info Only Info Only 11 DUNS: 809927387 2020 Gas State Program Evaluation Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only Info Only Louisiana Louisiana Department of Natural Resources, Page: 9#
LA NG Program Evaluation, 2020, page 10Info Only = No Points Evaluator Notes: the inspections. Yes, the NPMS information verification is part of the comprehensive inspection. The question is in the form utilized during 12 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the LDNR communicates with the public by having seminars, attending meeting and also have alot of information on their website. All inspection reports are accessible to the public on their Sonrise website. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) 1 1 Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed SRCR in PDM and there were 3 SRCR which 2 were already closed. The LDNR is aware of the other SRCR and is working with the operator to close out. 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? Evaluator Notes: Yes, the LDNR responds to NAPSR and PHMSA surveys and WMS tasks. 1 1 15 If the State has issued any waivers/special permits for any operator, has the state verified 1 1 conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There is one waiver that is still ongoing which involves Roserock(now Maripaus). The waiver is on an insulated pipe with no cp carrying hazardous liquids. The pipeline is not in operation and the waiver has to be renewed every several years. The LDNR is aware and monitors the waiver. There are no waivers on gas pipelines. 16 Were pipeline program files well-organized and accessible? Info Only Info Only Info Only = No Points Evaluator Notes: Yes, all inspection reports are kept electronically in their Sonrise system. Compliance letters are still not in the Sonrise system. LDNR uses their "Empire" software to conduct standard and comprehensive inspections. 17 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 3 3 Evaluator Notes: Discussed the SICT with LDNR and there are no issues or concerns. Inspection days seem reasonable and LDNR reviews data yearly to assure days are accurate. 18 Discussion on State Program Performance Metrics found on Stakeholder Communication Info Only Info Only site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Reviewed and discussed performance metrics for trends and accuracy. The LDNR compares data with annual reports. Damages per 1,000 have steadily gone down probably due to having enforcement in 2018. DUNS: 809927387 2020 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 10#
LA NG Program Evaluation, 2020, page 1119 Did the state encourage and promote operator implementation of Pipeline Safety Info Only Info Only Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Evaluator Notes: The LADNR has encouraged the use of Safety Management Systems and API RP1173 with operators during its annual pipeline safety seminar. 20 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: The LDNR is mainly complying with Part D of the Evaluation. The LDNR has greatly improved in their inspection cycles mainly due to the increase or having a full inspector staff. Total points scored for this section: 49 Total possible points for this section: 50 DUNS: 809927387 2020 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 11#
LA NG Program Evaluation, 2020, page 12PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Evaluator Notes: Enable Gas David Burket- Lead Inspector, LDNR Virtual Inspection due to pandemic May 4-5, 2021 Agustin Lopez- State Evaluator a. An Operator Qualification Program inspection was conducted by Mr. David Burket. b. Last OQ was in 2017 c. Yes, pipeline operator representatives were present virtually. d. First time David Burket is evaluated. Info Only Info Only 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Mr. Burket utilized the OQ Protocol form as a guide and to document the results of the inspection. 2 2 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: a. Inspector reviewed the OQ Plan. b. Inspector reviewed randomly selected OQ records. c. The field portion of inspection was not part of the evaluation. d. No other inspection activities were evaluated. e. Yes, the inspection was adequate in length to perform a thorough inspection was performed. 4 From your observation did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Mr. Burket demonstrated adequate knowledge of the pipeline safety program and regulations. 2 2 5 Did the inspector conduct an exit interview, including identifying probable violations? (If inspection is not totally completed the interview should be based on areas covered during time of field evaluation) 1 1 DUNS: 809927387 2020 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 12#
LA NG Program Evaluation, 2020, page 13Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: violations identified. Yes, Mr. Burket concluded the inspection with an exit interview to summarize the inspection results. There were no probable 6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Info Only Info Only Evaluator Notes: Yes, the inspection was conducted in a safe manner. The inspection was conducted virtually due to pandemic. 7 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Mr. David Burket was evaluated while performing an OQ Program inspection of Enable Gas. He did a very thorough inspection and reviewed procedures and records. He concluded with an exit interview to summarize the results of the inspection. Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 809927387 2020 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 13#
LA NG Program Evaluation, 2020, page 14PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues. Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, the LDNR reviews Annual Reports and discusses any issues with operators. Unaccounted gas is a prioritization for the inspection plan. Incidents are also reviewed for causes and reviewed with operators. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The LDNR has enforcement of the one call so data is analyzed for root causes and discussed with operators to minimize recurrence. The data is also discussed with David Appelbaum during his Damage Prevention/Excavation Damage evaluations. 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation 4 4 Damage? Yes = 4 No = 0 Needs Improvement = 1-3 a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: Annual Reports are reviewed for accuracy and for issues with excavation damages. Since having enforcement in 2018 the LDNR has more data to analyze and find root causes for excavation damages. With the new law the LDNR should see more improvement on excavation damages in the future. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. 2 2 DUNS: 809927387 2020 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 14#
LA NG Program Evaluation, 2020, page 15d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? Evaluator Notes: The LDNR collects data from annual reports and enforcement to be able to analyze and trend excavation damages. With the LDNR now having enforcement more data will be available to analyze and trend in the near future. 5 General Comments: Info Only = No Points Evaluator Notes: The LDNR is mainly complying with Part F of the Evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 809927387 2020 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 15#
LA NG Program Evaluation, 2020, page 16PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections? Info Only = No Points Evaluator Notes: LDNR is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days? Info Only = No Points Evaluator Notes: LDNR is not an interstate agent and does not have a 60106 agreement with PHMSA. 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: LDNR is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: LDNR is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: LDNR is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: LDNR is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809927387 2020 Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 16#
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