# 2009 LA NG Program Evaluation - la2009ngprogramevaluation (Louisiana; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA la2009ngprogramevaluation
- **title:** 2009 LA NG Program Evaluation - la2009ngprogramevaluation (Louisiana; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2009-01-01
- **effective on:** Not available
- **summary:** 2009 PHMSA natural gas program evaluation for Louisiana.
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1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2009 Natural Gas State Program Evaluation for Louisiana Department of Natural Resources Document Legend PART: O -- Representative Date and Title Information A -- General Program Qualifications B -- Inspections and Compliance - Procedures/Records/Performance C -- Interstate Agent States D -- Incident Investigations E -- Damage Prevention Initiatives F -- Field Inspection G -- PHMSA Initiatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 809927387 2009 Natural Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 1

2009 Natural Gas State Program Evaluation -- CY 2009 Natural Gas State Agency: Louisiana Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: No Date of Visit: 07/19/2010 - 07/24/2010 Agency Representative: James Mergist, Asst Director Pipeline Division PHMSA Representative: Patrick Gaume, State Liaison Commission Chairman to whom follow up letter is to be sent: Name/Title: James Welch, Commissioner Agency: Louisiana Department of Natural Resources-Office of Conservation Address: 617 North Third St. 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 2009 (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 certification/agreement attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART F): 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 F, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A General Program Qualifications 26 26 B Inspections and Compliance - Procedures/Records/Performance 25 25 C Interstate Agent States 0 0 D Incident Investigations 7 7 E Damage Prevention Initiatives 9 9 F Field Inspection 12 12 G PHMSA Initiatives - Strategic Plan 10 9.5 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 101 100.5 State Rating................................................................................................................................................... 99.5 DUNS: 809927387 2009 Natural Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 2

PART A - General Program Qualifications Points(MAX) Score 1 Did the state submit complete and accurate information on the attachments to its most current 60105(a) Certification/60106 (a) Agreement? (NOTE: PHMSA Representative to verify certification/agreement attachments by reviewing appropriate state documentation. Score a deficiency in any one area as "needs improvement". Attachment numbers appear in parenthesis) Previous Question A.1, Items a-h worth 1 point each Yes = 8 No = 0 Needs Minor Improvement = 3-7 Needs Major Improvement = 2 a. State Jurisdiction and agent status over gas facilities (1) b. Total state inspection activity (2) c. Gas facilities subject to state safety jurisdiction (3) d. Gas pipeline incidents (4) e. State compliance actions (5) f. State record maintenance and reporting (6) g. State employees directly involved in the gas pipeline safety program (7) h. State compliance with Federal requirements (8) 8 8 SLR Notes: A.1 All items are listed and reported in the Natural Gas Certification Document. 2 Did the state have an adequate mechanism to receive operator reporting of incidents to ensure state compliance with 60105(a) Certification/60106(a) Agreement requirements (fatality, injury requiring hospitalization, property damage exceeding $50,000 - Mechanism should include receiving "after hours" reports)? (Chapter 6) Previous Question A.2 Yes = 1 No = 0 1 1 SLR Notes: compliance. A.2. LA DNR meets the Federal reporting requirements. LaDNR also compares NRC reports against reports to the LaDNR to assure full reporting 3 Has the state held a pipeline safety TQ seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar or if state requested seminar, but T&Q could not provide, indicate date of state request for seminar. Seminars must be held at least once every 3 calendar years.) (Chapter 8.5) Previous Question A.4 Yes = 2 No = 0 SLR Notes: A.3. Yes, in the 2nd week of July 2009. Practice is to schedule every year over the last week of July. 2 2 4 Were pipeline safety program files well-organized and accessible?(NOTE: This also includes electronic files) (Chapter 5) Previous Question A.5 Yes = 1 No = 0 SLR Notes: A.4. Yes, the paper files are in the File Room in the Pipeline Division area. 1 1 5 Did state records and discussions with the state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? (Chapter 4.1, Chapter 8.1) Previous Question A.6 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: A.5. Yes, The Program Manager & records review show a professional knowledge of the regulations. 2 2 6 Did the state respond in writing within 60 days to the requested items in the Chairman's letter following the Region's last program evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8 Yes = 1 No = 0 SLR Notes: A.6. Yes, the letters were received on December 19th, and response was sent on February 17th. 1 1 7 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the previous year? Did actions correct or address deficiencies from previous year's evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8/A.9 Yes = 1 No = 0 DUNS: 809927387 2009 Natural Gas State Program Evaluation 1 1 Louisiana Louisiana Department of Natural Resources, Page: 3

SLR Notes: A.7 Yes, all 4 issues were addressed and either corrected or explained or a plan of action was presented. Personnel and Qualifications 8 Has each inspector fulfilled the 3 year TQ training requirement? If No, has the state been granted a waiver regarding TQ courses by the Associate Administrator for Pipeline Safety? (NOTE: If the State has new inspectors who have not attended all TQ courses, but are in a program which will achieve the completion of all applicable courses within 3 years of taking first course (5 years to sucessfully complete), or if a waiver has been granted by the applicable Region Director for the state, please answer yes.) (Chapter 4.4) Previous Question A.10 Yes = 3 No = 0 3 3 SLR Notes: A.8 Yes, for 2009 they are in compliance with the State Guidelines with the 3 yr attend & 5 yr complete rule for new staff. For the 5 long term inspectors needing a total of 8 courses, 3 inspectors have come into compliance. The 4th inspector was first on the wait list and then was scheduled into 2010 for his two classes. The 5th inspector had significant health problems and is re-scheduled for his two courses into 2010. 9 Brief Description of Non-TQ training Activities: Info Only = No Points Info Only Info Only For State Personnel: State- Most inspectors attend the annual 195 Seminar & the 192 Seminar. In addition, several staff attended the 8 hr LSU HAZWOPER REFRESHER COURSE. For Operators: Operators ? Held the annual T&Q Pipeline Safety Seminar, Conducted and Co-sponsored the two annual small gas operator seminars in June, 2009. There were also several individual operator training sessions, usually associated with an inspection. Worked with CenterPoint Energy to practice a table-top emergency drill of a major gas leak. For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: Non-operator/public ? LDNR personnel made a presentation at an LSU fire fighting school, concerning pipeline safety. LDNR has established the Geaux Team who make Damage Prevention information available at County Fairs and other public events. SLR Notes: A.9. State- Most inspectors attend the annual 195 Seminar & the 192 Seminar. In addition, several staff attended the 8 hr LSU HAZWOPER REFRESHER COURSE. Operators ? Held the annual T&Q Pipeline Safety Seminar, Conducted and Co-sponsored the two annual small gas operator seminars in June, 2009. There were also several individual operator training sessions, usually associated with an inspection. Worked with CenterPoint Energy to practice a table-top emergency drill of a major gas leak. Non-operator/public ? LDNR personnel made a presentation at an LSU fire fighting school, concerning pipeline safety. LDNR has established the Geaux Team who make Damage Prevention information available at County Fairs and other public events. 10 Did the lead inspectors complete all required T&Q OQ courses and Computer Based Training (CBT) before conducting OQ Inspections? (Chapter 4.4.1) Previous Question A.12 Yes = 1 No = 0 1 1 SLR Notes: A.10. Yes. Dana Arabie (TSI 299 11/03) & Jacques Rotolo (TSI 299 9/04) are the OQ Leads. Two other inspectors & two Supervisors are OQ certified. 11 Did the lead inspectors complete all required TQ Integrity Management (IMP) Courses/Seminars and CBT before conducting IMP Inspections? (Chapter 4.4.1) Previous Question A.13 Yes = 1 No = 0 1 1 SLR Notes: completed). A.11 . Yes, IMP Leads are Dana Arabie (TSI 297 6/05, TSI 294 8/02, CBT are completed) & Jacques Rotolo (TSI 297 4/06, TSI 294 7/04, CBT are 12 Was the ratio acceptable of Total inspection Person-days to Total Person-days charged to the program by state inspectors? (Region Director may modify points for just cause) (Chapter 4.3) Previous Question B.12 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 1358.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 10.78 = 2372.33 Ratio: A / B 1358.00 / 2372.33 = 0.57 5 5 DUNS: 809927387 2009 Natural Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 4

If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 SLR Notes: A.12 A=1363 person days. B=10.78 man years * 220 = 2371.6 person days. A/B= .57471. . .57471>.38, okay. 13 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Info Only Info Only Question B.13 Info Only = No Points SLR Notes: A.13 No, staffing levels for 2007 to 2008 were unchanged. There were two retirements in 2008 & two new hires in November 2008. An attempt to increase staff in 2009 was turned down due to State Budget constraints. In 2009 one inspector (Kenneth Peltier) passed away and Marvin Reed was hired to replace the vacancy. 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: A.14 In 2009, LDNR participated in every Pipeline Safety Emergency Drill that the pipeline operators invited them to. LDNR was a strong participant in NAPSR, and actively participated on three committees: Control Room Management; Liquid Pipeline Task Group; and Staffing Formula Task Group. Mr. Dana Arabie served to organize or re-organize NAPSR Committees: The Research and Development Committee, and the Gathering Line Task Group. LDNR actively participates in the quarterly Louisiana Regional Common ground alliance meetings. LDNR participates with and supports the efforts of Coastal And Marine Operators (CAMO) Pipeline Industry Initiative whose main purpose is to explore and discuss issues and challenges in preventing spills, releases, and damage to coastal and marine pipelines and environments. LDNR helps organize and co-sponsors the annual Pipeline Safety Seminars for Hazardous Liquid and Natural Gas operators. LDNR has established the Geaux Team who make Damage Prevention information available at County Fairs and other public events. LDNR works closely with the State Police and LaOneCall to promote 811 and implement safe excavation practices. Total points scored for this section: 26 Total possible points for this section: 26 DUNS: 809927387 2009 Natural Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 5

PART B - Inspections and Compliance - Procedures/Records/ Performance Points(MAX) Score Inspection Procedures 1 Does the State have a written inspection plan to complete the following? (all types of operators including LNG) 6.5 6.5 (Chapter 5.1) Previous Question B.1 + Chapter 5 Changes + Incorporate LNG Yes = 6.5 No = 0 Needs Improvement = 50% Deduction a Standard Inspections (Including LNG) (Max points = 2) b IMP Inspections (Including DIMP) (Max points = .5) c OQ Inspections (Max points = .5) d Damage Prevention (Max points = .5) e On-Site Operator Training (Max points = .5) f Construction Inspections (Max points = .5) g Incident/Accident Investigations (Max points = 1) h Compliance Follow-up (Max points = 1) Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement SLR Notes: B.1. Yes, Pipeline Safety Operations Manual, General Criteria Section, - Std, IMP, OQ, Damage Prevention, Operator Training, Constr, Incident, & Follow-up are all addressed. 2 Did the written Procedures for selecting operators adequately address key concerns? (Chapter 5.1) Previous 2 2 Question B.2, items a-d are worth .5 point each Yes = 2 No = 0 Needs Improvement = 50% Deduction a Length of time since last inspection Yes No Needs Improvement b History of Operator/unit and/or location (including leakage , incident and compliance history) Yes No Needs Improvement c Type of activity being undertaken by operator (construction etc) Yes No Needs Improvement d For large operators, rotation of locations inspected Yes No Needs Improvement SLR Notes: B.2. Yes, Pipeline Safety Operations Manual, General Criteria Section - Items a, b, c, & d are okay. Inspection Performance 3 Did the state inspect all types of operators and inspection units in accordance with time intervals established in its written procedures? (Chapter 5.1) Previous Question B.3 Yes = 2 No = 0 2 2 SLR Notes: B.3. Yes, Units are being inspected in accordance with the Manual Guidelines. Units are tracked through a spread sheet program which tracks Std and special inspections. Other inspections are tracked on the spreadsheet 'as needed'. 4 Did the state inspection form cover all applicable code requirements addressed on the Federal Inspection forms? (Chapter 5.1 (3)) Previous Question B.4 Yes = 1 No = 0 SLR Notes: B.4. Yes, the LaDNR Forms for OQ, IMP, & Standard inspections are the same as the Federal Forms. 1 1 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 Yes = 1 No = 0 SLR Notes: B.5. Yes. Checked Std, & Special inspections, all complete. 1 1 6 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.6 Yes = .5 No = 0 SLR Notes: DUNS: 809927387 2009 Natural Gas State Program Evaluation .5 .5 Louisiana Louisiana Department of Natural Resources, Page: 6

B.6. Yes, SRCR are tracked by Mike Spohrer & Mark Champagne, & updates are sent to the Feds. 7 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Previous Question B.7 Yes = .5 No = 0 SLR Notes: B.7. Yes, it is in the Distribution Std Inspection Form. See subpart M, 192.489. .5 .5 8 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) Previous Question B.8 Yes = .5 No = 0 SLR Notes: B.8. Yes, it is in the Distribution Std Inspection Form. See subpart M, 192.489. .5 .5 9 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) Previous Question B.9 Yes = .5 No = 0 .5 .5 SLR Notes: B.9. Yes, review procedures during inspections & assure pipeline is leak surveyed from the meter to the mainline during incident investigations. Added a comment at 192.615(A)(7) to check both pipe ends whenever a line gets impacted or pulled. 10 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? (NTSB) Previous Question B.10 Yes = 1 No = 0 SLR Notes: B.10. Yes it is on the Std Insp Form, and all accidents are followed up with most having on-site investigation 1 1 Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous 1 1 Question B.14 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: current B.11. Yes, the inspections reports are placed in the subject Unit File and the violation letter with evidence are kept together in a violation file. The violation report & evidence are moved to the subject Unit file when it is closed. Records are retained as long as space is available, & at least for 4 years plus 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a probable violation as specified in the "Guidelines for State Participating in the Pipeline Safety Program"? (Chapter 5.1) Previous Question D(1).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.12. Yes, in LAC 43:XI subpart 3 Chapter 5. 1 1 13 Does the state have written procedures to notify an operator when a noncompliance is identified as specified in the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(4)) Previous Question D 1 1 (1).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.13. Yes, in the LA Administrative Code (LAC 33 LIQUID, & LAC 43 GAS), & is cross referenced to the Pipeline Operations Manual. Through experience, a standard form has been developed. 14 Does the state have a written procedure for routinely reviewing the progress of compliance actions to prevent delays or breakdowns of the enforcement process, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(5)) Previous Question D(1).3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: DUNS: 809927387 2009 Natural Gas State Program Evaluation B.14 Yes, in the LA Administrative Code (LAC 33 LIQUID, & LAC 43 GAS), & is cross referenced to the Pipeline Operations Manual. Through Louisiana Louisiana Department of Natural Resources, Page: 7

experience, a standard form has been developed. The compliance action specifies the time available for response, and each inspector is responsible to ensure the time frames are adhered to or time extensions are justified. Managers hold inspectors accountable for the timely handling of compliance actions. 15 Has the State issued compliance actions for all probable violations discovered? (Note : PHMSA representative 1 1 has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation) Previous Question D(1).4 Yes = 1 No = 0 SLR Notes: B.15. Yes, there were 9 Natural Gas actions in 2009. Reviewed the violation files and the Safety Division is following its procedures. 16 Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that 1 1 prompt corrective actions were taken by operators, within the time frames established by the procedures and compliance correspondence, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? Previous Question D(1).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.16. Yes, the Pipeline Division uses a hand written spread sheet maintained by Arlene Andrus to track dates of inspection, citation, time limit for response, targeted re-inspection due date, actual re-inspection date, outcome, & closure dates. 17 If compliance could not be established by other means, did state pipeline safety program staff request formal action, such as a "Show Cause Hearing" to correct pipeline safety violations? (check each states enforcement procedures) Previous Question D(1).6 No = 0 Yes = 1 1 1 SLR Notes: B.17. Yes, minor violations were handled informally or with a letter and verified by re-inspection. For 2009, there were no actions where 'show cause' hearings were requested by Pipeline Division, which means that all cited operators complied (or are in the process of complying) with the enforcement actions. The process for 'show cause' hearings is in place. 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question 1 1 D(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: compliance action. B.18. Yes, they use an internal document ? 'Re-Inspection Form' & if the operator response is sufficient, the form is used to document closure of the 19 Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question D(1).8 Yes = .5 No = 0 SLR Notes: B.19. Yes, See Form PLS-OR-1: Organization Report, Also see Pipeline Operations Manual, Glossary, Noncompliance. .5 .5 20 Did the compliance proceedings give reasonable due process to all parties? (check each states enforcement procedures) Previous Question D(1).9 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: B.20. Yes, due process is afforded all & is stated in the violation letters. See LA Administrative Code (LAC 33: V subpart 3 Chapter 313 LIQUID, & LAC 43: XI subpart 3 Chapter 5 GAS) Compliance - 60106(a) States 21 Did the state use the current federal inspection form(s)? Previous Question D(2).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.21- B.26. NA, is a 60105(a) program. 1 NA 22 Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question D(2).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.21- B.26. NA, is a 60105(a) program. 1 NA DUNS: 809927387 2009 Natural Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 8

23 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.) Previous Question D(2).3 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: B.21- B.26. NA, is a 60105(a) program. 24 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(2).4 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: B.21- B.26. NA, is a 60105(a) program. 25 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(2).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: B.21- B.26. NA, is a 60105(a) program. 26 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Previous Question D(2).6 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: B.21- B.26. NA, is a 60105(a) program. 27 Part B: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: B.27. LDNR continues to focus on achieving 100% Gas Unit inspections per year, either Std or special. Inspection results became publically available on the LDNR web site in 2008. Created the Louisiana Common Ground Alliance in 2008 and are using it as a mechanism to fulfill the 9 elements of the 2006 PIPES Act. LDNR continues to make personnel available to support NAPSR and PHMSA initiatives. Total points scored for this section: 25 Total possible points for this section: 25 DUNS: 809927387 2009 Natural Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 9

PART C - Interstate Agent States Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Previous Question D(3).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: C.1-8. NA, NOT AN INTERSTATE AGENT 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Previous Question D(3).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: C.1-8. NA, 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? Previous Question D(3).3 Yes = 1 No = 0 SLR Notes: C.1-8. NA, NOT AN INTERSTATE AGENT 1 NA 4 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.) Previous Question D(3).4 Yes = 1 No = 0 SLR Notes: C.1-8. NA, 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? Previous Question D(3).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: C.1-8. NA, NOT AN INTERSTATE AGENT 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(3).6 Yes = 1 No = 0 SLR Notes: C.1-8. NA, NOT AN INTERSTATE AGENT 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Previous Question D(3).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: C.1-8. NA, NOT AN INTERSTATE AGENT 1 NA 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: C.1-8. NA, NOT AN INTERSTATE AGENT Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809927387 2009 Natural Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 10

PART D - Incident Investigations Points(MAX) Score 1 Are state personnel following the procedures for Federal/State cooperation in case of an incident? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6.1) Previous Question E.1 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: D.1. Yes. Pipeline SOP, General Criteria, Accident Investigations. Appendix C specifies: 1. Determine if safety violations occurred. 2. Determine root causes of the incident if asked by NTSB. 3. Cooperate with NTSB. 2 Are state personnel familiar with the jurisdictional authority and Memorandum of Understanding between NTSB and PHMSA? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6 ? Appendix D) Previous Question E.2 Yes = .5 No = 0 SLR Notes: D.2. Yes, the MOU between NTSB and OPS is understood, and LDNR Pipeline Division fully cooperates with NTSB. .5 .5 3 Did the state keep adequate records of incident notifications received? Previous Question E.3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: D.3. Yes, 3 reportable incidents, 3 reports, plus follow up of several non-reportable incidents when notification was received. 1 1 4 If an onsite investigation of an incident was not made, did the state obtain sufficient information by other means to determine the facts and support the decision not to go on-site? Previous Question E.4 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: D.4. Yes, telephonic contact is made, and the 'Telephonic Leak Report' is used. The information received is used to determine if an on-site visit is required. 3 of the 3 Federally reportable incidents had a field visit. 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? Previous Question E.5, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Observations and Document Review 2 2 b. Contributing Factors c. Recommendations to prevent recurrences where appropriate SLR Notes: Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement D.5. Yes, LaDNR uses the federal pipeline failure investigation form when an on-site investigation is made. The events are documented and Appendix C is followed. Including findings of fact, probable cause, and to determine if Pipeline Safety Regulations were followed. 6 Did the state initiate enforcement action for violations found during any incident investigation(s)? Previous Question E.6 Variation Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: investigation. D.6. Yes, of the 3 incidents, 2 reviews are complete and no violations have been found. There may be violations concerning the on-going incident 7 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports .5 0.5 to ensure accuracy and final report has been received by PHMSA? (validate annual report data from operators concerning incidents/accidents and investigate discrepancies) (Chapter 6) Previous Question E.7/E.8 Yes = .5 No = 0 SLR Notes: D.7 Yes, the reports are reviewed for completeness & to ensure that a final report is submitted. Corrective Action Orders are considered. The Safety Division has regular contact with PHMSA SW Region and DC to ensure that accident/incident reports are accurate & updated. 8 Part D: General Comments/Regional Observations Info Only = No Points SLR Notes: DUNS: 809927387 2009 Natural Gas State Program Evaluation Info Only Info Only Louisiana Louisiana Department of Natural Resources, Page: 11

D.8 There were 3 reportable incidents in 2009, and there were three injuries associated with one of the incidents. Replacement of cast iron will continue. It is not known if cast iron replacement activities caused the crack in a nearby cast iron line which may have been the cause of the house fire. Total points scored for this section: 7 Total possible points for this section: 7 DUNS: 809927387 2009 Natural Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 12

PART E - Damage Prevention Initiatives Points(MAX) Score 1 Has the state reviewed 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? Previous Question B.11 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: prevention, 192.614(a). E.1. Yes, it is on LDNR's advisory bulletin list attached to the Std Insp Form. Starting in 2009, it was also added to the Std Insp Form, subpart L, Damage 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? New 2008 Yes = 2 No = 0 SLR Notes: E.2. Yes, it is in the Std Insp Form, under Damage Prevention. 2 2 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to 2 2 its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.7 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: E.3. Yes, LDNR helped create the Louisiana Common Ground Alliance in 2008. LDNR has been promoting the Best Practices document for the past several years. The State Police are issuing citations and fines for excavation damages. 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? New 2008 Yes = 1 No = 0 1 1 SLR Notes: E.4. Yes, the Louisiana One Call is tracking this data in the form of number of locate requests per damage event. In 2007 it was 176 locates per damage, in 2008 it was 185 locates per damage, and in 2009 it was 226 locates per damage. 5 Did the state review operators' records of accidents and failures due to excavation damage to ensure causes of failure are addressed to minimize the possibility of recurrence as required by 192.617? Yes = 2 No = 0 SLR Notes: E.5. Yes, it is addressed during Std Inspections, per 192.617. 2 2 6 Part E: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: E.6. LDNR helped create the Louisiana Common Ground Alliance in 2008. The State Police are issuing citations and fines for excavation damages. There is increasing effort to have operators capture and evaluate ALL excavation damages to maximize opportunities for lessons learned. The Governor's office declared May, 2009 as Damage Prevention month and encouraged calling 811 before digging. Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 809927387 2009 Natural Gas State Program Evaluation Louisiana Louisiana Department of Natural Resources, Page: 13

PART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Info Only Info Only Name of Operator Inspected: Cleco Power LLC/Gulf States, Inc Name of State Inspector(s) Observed: Mark Champagne/Walter Blocker Location of Inspection: Boyce, Louisiana/Baton Rouge, Louisiana Date of Inspection: 4/27/2010/4/28/2010 Name of PHMSA Representative: Dale Bennett SLR Notes: 4/27/2010 - Cleco Power LLC - Mark Champagne 48 miles of coated steel natural gas pipe from Trunkline Compressor Station to Cleco Power Plant was inspected. 4/28/2010 - Gulf States, Inc - Walter Blocker McCellemb regulator station, brown field, plank stone view, airline & choctaw and the purchase point at old hammond highway in the Baton Rouge natural gas system was inspected. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? New 2008 Yes = 1 No = 0 SLR Notes: Gulf States was noticied on 3/25/2010 and Cleco was notifice on 3/22/2010 1 1 3 Did the inspector use an acceptable inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Previous Question F.2 Yes = 2 No = 0 SLR Notes: The inspectors used the Federal Gas Inspection Forms 2 2 4 Did the inspector thoroughly document results of the inspection? Previous Question F.3 Yes = 2 No = 0 SLR Notes: The Inspcetors covered every question and documented the results. 2 2 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.) New 2008 Yes = 1 No = 0 SLR Notes: The operator had the equipment necessare during the inspection. 1 1 6 What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) New 2008 Info Only = No Points SLR Notes: The inspectors conducted the field portion of the standard inspection. Info Only Info Only 7 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) New 2008, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records DUNS: 809927387 2009 Natural Gas State Program Evaluation 2 2 Louisiana Louisiana Department of Natural Resources, Page: 14

c. Field Activities/Facilities d. Other (Please Comment) SLR Notes: The inspectors covered the procedures during the field activities. 8 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Liaison will document reasons if unacceptable) Previous Question F.8 Yes = 2 No = 0 SLR Notes: The inspectors were knowledgeable of the pipeline safety program and regulations. 2 2 9 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) Previous Question F.10 Yes = 1 No = 0 SLR Notes: During the exit review the inspectors went over all the areas covered during the field inspection. 1 1 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous Question F.11 Yes = 1 No = 0 SLR Notes: The inspectors found no probable violations during the inspection. 1 1 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector Info Only Info Only performed) Info Only = No Points SLR Notes: The inspectors observed CP monitoring, atmosphere corrosion insspection, valve operations, signs, line markers, pipe supports and regulator stations. 12 Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only = No Points SLR Notes: No best practices were shared. Info Only Info Only 13 Field Observation Areas Observed (check all that apply) 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 DUNS: 809927387 2009 Natural Gas State Program Evaluation Info Only Info Only Louisiana Louisiana Department of Natural Resources, Page: 15

r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. 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 SLR Notes: The field observations are marked above. 14 Part F: General Comments/Regional Observations Info Only = No Points SLR Notes: The inspectors are very knowledgeable and did an excelllent job during the inspections. DUNS: 809927387 2009 Natural Gas State Program Evaluation Info Only Info Only Total points scored for this section: 12 Total possible points for this section: 12 Louisiana Louisiana Department of Natural Resources, Page: 16

PART G - PHMSA Initiatives - Strategic Plan Points(MAX) Score Risk base Inspections - Targeting High Risk Areas 1 Does state have process to identify high risk inspection units? Yes = 1.5 No = 0 1.5 1.5 Risk Factors (criteria) to consider may include: Miles of HCA's, Geographic area, Population Density Length of time since last inspection History of Individual Operator units (leakage, incident and compliance hist
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