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PHMSA ms-2017-gas-program-evaluation
2017 MS NG Program Evaluation - ms-2017-gas-program-evaluation (Mississippi; Natural Gas State Program Evaluation)
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MS 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 MISSISSIPPI PUBLIC SERVICE COMMISSION Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 1#
MS NG Program Evaluation, 2017, page 22017 Gas State Program Evaluation -- CY 2017 Gas State Agency: Mississippi Rating: Agency Status: Date of Visit: 05/14/2018 - 05/18/2018 Agency Representative: PHMSA Representative: Patrick Gaume Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. Brandon Presley, Chairman Agency: Mississippi Public Service Commission Address: 501 N West St, suite 201A City/State/Zip: Jackson, MS 39201-1008 60105(a): Yes 60106(a): No Interstate Agent: No Mr. Rickey Cotton, Director Pipeline Safety, Mississippi Public Service Commission 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 9.5 B Program Inspection Procedures 13 13 C Program Performance 47 39 D Compliance Activities 15 14.5 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 116 107 State Rating................................................................................................................................................... 92.2 DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 2#
MS 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: A1. Yes. Attachment 1 is correct and is consistent with attachment 3 and attachment 8. Transmission Operators dropped from 16 to 15; Okatoma Products LLC ceased pipeline operations, the 400' transmission line has been abandoned, and the business is being served through the local LDC. After discussion, we agreed that Attachment 1 would be 'more correct' if Distribution LPG was changed from 'A' to '60105' with 0 operators and 0 units, and if Other Offshore Facilities was changed from 'A' to '60105' with 0 operators and 0 units. An edited Attachment 1 was submitted to FedStar along with Attachment 3 when an error in Attachment 3 was found and a corrected Attachment 3 had to be submitted to FedStar. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: A2. Yes. Conducted a review of the 2017 MS PSC Progress Report and found the number of inspection days entered matched the office files. No issues were found. 1222 inspection days 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 1 0.5 Evaluator Notes: A3. NI, 0.5 of 1 pt. Attachment 3 had errors concerning private distr units (to show 28 instead of 27), and transmission intrastate (to show 21 instead of 23). We discussed how Attachment 3 needed to be correct to December 31, 2017. A corrected Attachment 3 was submitted to Carrie Winslow and uploaded into FedStar. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A4. Yes. Verified that there was one reportable incident in 2017. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A5. Yes. Reviewed Attachment 5, 360 violations, 123 letters, $0 in fines, however, a multi-year consent agreement for replacing of pipe was done in three phases in lieu of a civil penalty which was fulfilled and closed in 2017 with Moss Point Municipal Utility. MS PSC is not using its civil penalty authority to promote pipeline safety. I strongly recommended that MS PSC start using its civil penalty authority. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 A6. Yes. All records listed in Attachment 6 are being kept electronically. They are accessible and well organized. 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: A7. Yes, Training agrees with state records and inspector time is correct with state records. Note: Lewis Davis is qualified as a Level II Inspector under criteria for II.D. in the State Guidelines. DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 3#
MS NG Program Evaluation, 2017, page 48 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A8. Yes. Attachment 8 is consistent with internal records; the main MS law is U-4252. 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A9. Yes. Attachment 10 was properly completed. 1 1 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only A10. There was a 0.5 point deduction in this section. 2017 Accomplishments: - Began enforcement of the Damage Prevention law. - Train all pipeline safety staff to conduct comprehensive damage investigations. - Provided operator training and offered locator training to all stake holder. - The Damage Prevention Enforcement Board was formed and collects data on all damages that are reported. - Provided code training to approx. 175 natural gas operators. - Provided small operator training to approx. 30 master meter operators. - Provided locator training to approx.. 40 stakeholders. - Canton Utilities is progressing in their cast iron replacement. About 4 miles were removed and have Ten miles remaining. Total points scored for this section: 9.5 Total possible points for this section: 10 DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 4#
MS 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 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: B1. Yes. see Sec 7, (pg 15) for pre and post inspection information. See section 7 for Standard Inspections. 2 2 2 IMP and DIMP 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: B2. Yes. see Sec 7, (pg 15) for pre and post inspection information. See section 7 for IM Inspections. 1 1 3 OQ 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: B3. Yes. see Sec 7, (pg 15) for pre and post inspection information. See section 7 for for OQ Inspections. 1 1 4 Damage Prevention Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 B4. Yes. see Sec 7, (pg 15) for pre and post inspection information. See section 7 for Damage Prevention Inspections. 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B5. Yes. see section 7, (pg 15) for Operator Training. Performed as required by State Law & 'as needed' 1 1 6 Construction Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 B6. Yes. see section 7, (pg 16) for pre and post inspection information. See section 7 for Construction Inspections. DUNS: 878639368 2017 Gas State Program Evaluation 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 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 5#
MS NG Program Evaluation, 2017, page 6c. 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: B7. Yes. see section 7, (pg 16). Items 'a' through 'e' were addressed. No issues with 'f' how inspection units are organized. 8 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: B8. No loss of points occurred in this section. MS PSC has generally met the requirements of Part B. MS PSC Procedures have been improved relative to what was found last year. I strongly recommended Appendix S in the State Guidelines be reviewed and appropriate items be incorporated into the MS PSC PL Safety procedures. Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 6#
MS 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): 1222.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 9.00 = 1980.00 Ratio: A / B 1222.00 / 1980.00 = 0.62 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: C1. Yes. 1222 Field inspector days, 9.0 inspector years, 1222/(9*220)=0.62 okay 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 0 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: C2. Yes*4, No for 'e'. 0 of 5 points. Multiple year problem. A review of TQ transcripts found Lewis Davis has not completed all required courses within five years to meet the Gas Inspector Training Qualifications. This finding was noted in CY2012 and for each year since. Neil Wood and James Snyder have completed the Root Cause Course. Neill is the only qualified Lead Inspector for DIMP/IMP. A loss of five points is due to one inspector not completing all required courses within 5 years of attending the first course. 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 Evaluator Notes: C3. Yes, Rickey is trained and experienced. 2 2 4 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 = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C4. Yes. 6/27/17 & 8/15/17. The Chairman's response addressed every required item. 2 2 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 1 1 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: C5. Yes. conducted the last training in September 2017. Had 175 individuals in attendance. The MS Law that requires Operator personnel to have 36hr/3yr causes enhanced interest in the Seminars. DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 7#
MS NG Program Evaluation, 2017, page 86 Did state inspect all types of operators and inspection units in accordance with time 5 3 intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: C6. NI 3 of 5 points. A review of the MS inspection database shows that some OQ, IM, and D&A inspections are beyond the 5-year limit. 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: C7. Yes. MS PSC uses the applicable Fed Form. There are plans to move to lA, Several Inspectors are scheduled for the IA Training at TQ in November, 2018. The forms are completely filled out. 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: C8. Yes. 3 operators are known to have Cast Iron. They have committed to have all CI removed by 2022. One operator, Canton Utilities, was particularly active in removing CI in 2017. 9 Did the state review operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: C9. Yes. Cast Iron cracking and other threats are checked during Standard Inspections. 1 1 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 Evaluator Notes: C10. Yes. these are checked during Standard Inspections. 1 1 11 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: C11. Yes. these are checked during Standard Inspections. 1 1 12 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: C12. Yes, The Program Manager and Administrative Assistant Reviews and analyzes Annual Reports and Incident Report Forms. The analysis is provided to the inspectors who then review the information with operators during inspections. 13 DUNS: 878639368 2017 Gas State Program Evaluation Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? 1 1 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 8#
MS NG Program Evaluation, 2017, page 9Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C13. Yes. Question is on the Standard Inspection form, and they compare Annual Rpt versus NPMS. 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: C14. Yes. a review of files found 19 D&A inspections in 2017 and 30 D&A in 2016. A review of the inspections confirm the D&A tests were performed by the operators. 15 Is state verifying operators OQ programs are up to date? This should include verification 2 1 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: C15. NI 1 of 2 points. OQ inspections are being conducted. The few OQ inspections that appear to be outside of the 5-yr inspection interval will be re-inspected in 2018. 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: C16. Yes. IM inspections are being conducted. 2 2 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 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: 2 2 C17. Yes. MS PSC has a Procedural Review with large operators annually. It is a question on the Standard Inspection Form. 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: C18. Yes. PAPEI were done in 2014. Current for now. 2 2 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: C19. Yes. Mississippi has website, for information to all stakeholders. Always available by phone and email. They also conduct an annual pipeline safety seminar. DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 9#
MS NG Program Evaluation, 2017, page 1020 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C20. NA. No Safety Related Condition Reports have been submitted in years, certainly since 2015. 1 NA 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: C21. Yes. plastic pipe problems are addressed during every Distribution Standard Inspection. 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: C22. Yes. NAPSR & PHMSA requests are responded to. 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: C23. NA. MS has no active waivers/special permits. 1 NA 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: C24. Yes, Rickey & John Thompson attended Nat'l NAPSR. 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: C25. Yes. MS PSC monitors all 6 performance measures: Damage Prevention Program, Inspection Activity, Inspector Qualification, Leak Management, Enforcement, and Incident Investigation. The indicators are all neutral or positive. A major success was the 2016 passage and the 2017 enforcement of the Damage Prevention Law where MS now has a mechanism for issuing civil penalties associated with Damage Prevention violations. 26 Discussion with State on accuracy of inspection day information submitted into State 1 1 Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: C26. Yes. MS finds the SCIT to be an exercise in frustration. MS does not consider SCIT to be worthy of an annual review, perhaps bi or tri-annually. MS has staffed up from 6 to 9 inspectors per SCIT results and passage of the Damage Prevention Law. 27 DUNS: 878639368 2017 Gas State Program Evaluation 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 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 10#
MS NG Program Evaluation, 2017, page 11Evaluator Notes: C27. Yes. MS PSC is prepared to address inspection of flow reversals. No known flow reversals in MS. 28 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: C28. 8 points were lost in this section; see C2, C6, C15. MS PSC has staffed up to meet demand. MS PSC will become fully current in its inspection duties. Total points scored for this section: 39 Total possible points for this section: 47 DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 11#
MS 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: D1. Yes*3. See Procedures Section 8, page 17 which address Notification, Review, & Closing of Probable Violations. 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: D2. Yes*6. MS PSC followed their own procedures. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: D3. yes, all 360 discovered probable violations were issued a compliance action through 123 letters. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: D4. Yes. due process is given to all. 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 D5. Yes, Program Manager is familiar with imposing civil penalties. A multi-year consent agreement for replacing of pipe was done in three phases in lieu of a civil penalty which was fulfilled and closed in 2017 with Moss Point Municipal Utility. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 .5 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: D6. NI, 0.5 of 1 point. MS PSC continues to be unable to demonstrate they have used their enforcement fining authority for pipeline safety violations in the last eight years. This item and loss of points was mentioned previously in the Chairman's DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 12#
MS NG Program Evaluation, 2017, page 13letter pertaining to the State Program Evaluation letters. This item was also discussed during the Exit interview with the Executive Director and Program Manager. A new item, that was disclosed for the first time this year, was the issuance of a Consent Agreement in lieu of a fine that resulted in the replacement of sub-standard pipe by a municipal operator. This new information resulted in upgrading this problem from a 'unsatisfactory' to a 'NI' and the loss of 0.5 point rather than the full point. 7 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: D7. A loss of 0.5 points occurred. See question D6. Due process is given to all. Reasonable use of civil penalties must start happening, and this problem has been mentioned for the last eight years. Total points scored for this section: 14.5 Total possible points for this section: 15 DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 13#
MS 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: E1. Yes. See Procedures Section 4, page 12, which address Conducting & Closing of Incident Investigations. 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: E2. Yes. See Procedures Section 4, page 12. Also, Appendix D & E are known. The 24hr Emergency Contact phone numbers are available through the PSC website and is verified in all operator Emergency Response Procedures during Standard Procedures. 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 E3. Yes. It is MS PSC practice to onsite investigate all significant incidents. See Procedures Section 4, page 12. 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: E4. Yes. The Incident was investigated and documented. There tends to be a reportable incident every 3 years. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: E5. Yes. there were violations for the incident in 2017. Corrective actions were ordered. 1 1 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking 1 1 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: E6. Yes. MS PSC has good communications with PHMSA Southern Region and the AID. Reports were made to the AID concerning the reportable incident in 2017. 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) 1 1 DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 14#
MS NG Program Evaluation, 2017, page 15Yes = 1 No = 0 Evaluator Notes: E7. Yes, at the NAPSR Southern Region Meeting and during the Pipeline Safety Seminars. 8 General Comments: Info Only = No Points Evaluator Notes: incidents occur. Info Only Info Only E8. No loss of points occurred. MS PSC has generally met the requirements of Part E. MS PSC response is detailed when Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 15#
MS 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 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: F1. Yes. Question has been on the Std Insp Form for the last few years. 2 2 2 Did the state inspector verify pipeline operators are following their written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: F2. Yes. Question has been on the Std Insp Form for the last few years. 2 2 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: F3. Yes. they encourage operators to adopt the CGA best practices for any procedures. MS PSC also encourages participation in One Call and CGA meetings, and to use DIRT. 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? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: F4. Yes. This information is gathered through Annual Reports. It is graphed and studied on a spreadsheet. 2 2 5 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: F5. No loss of points occurred. MS PSC has generally met the requirements of Part F. A major success was the 2016 passage and the 2017 enforcement of the Damage Prevention Law where MS now has a mechanism for issuing civil penalties associated with Damage Prevention violations. Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 16#
MS 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: Chickasawhay Natural Gas District, opid 2336, Quitman Unit Name of State Inspector(s) Observed: James Snyder, Inspector Location of Inspection: 306 S Archusa Ave, Quitman, MS, 39355 Date of Inspection: 5/16/2018 Name of PHMSA Representative: Patrick Gaume Evaluator Notes: G1. Chickasawhay Natural Gas District, opid 2336, Quitman Unit, 306 S Archusa Ave, Quitman, MS, 39355, James Snyder, Inspector; 5/16/2018, Patrick Gaume 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: G2. Yes, Mike Evans, District Manager, participated in the inspection & it was held at the Chickasawhay Natural Gas District office in Quitman. 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: G3. Yes, the Federal Std Distr Insp form was used. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: G4. Yes. The portion I observed was filled out. 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.) Yes = 1 No = 0 Evaluator Notes: G5. Yes. It was an office Inspection and all procedures and records were available. 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 d. Other (please comment) Evaluator Notes: G6. Yes*2. The focus of the inspection was procedures and records. 2 2 DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 17#
MS NG Program Evaluation, 2017, page 187 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: G7. Yes. James was very knowledgeable, thorough and conducted himself in a professional manner. 2 2 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: G8. Yes. some violations & procedure improvements are needed; .467 lack of csg inspections; .459 inadequate work order information; .283 lacked procedures for work being performed in the field. .605 Improve procedures for the joining of plastic pipe. The operator was very cooperative. 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: G9. Yes. some violations & procedure improvements are needed; .467 lack of csg inspections; .459 inadequate work order information; .283 lacked procedures on-site for work being performed in the field. .605 Improve procedures for the joining of plastic pipe. The operator was very cooperative. 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 y. Purging z. Prevention of Accidental Ignition A. Repairs Info Only Info Only DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 18#
MS NG Program Evaluation, 2017, page 19B. 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: G10. Yes. This was a standard inspection for procedures and records. The inspection was performed in a professional, courteous, and thorough manner. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 19#
MS 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: H1-8. NA 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: H1-8. NA 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: H1-8. NA 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: H1-8. NA 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: H1-8. NA 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: H1-8. NA Yes = 1 No = 0 Needs Improvement = .5 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: H1-8. NA 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: H1-8. NA Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 20#
MS 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: I1-7. NA 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: I1-7. NA 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: I1-7. NA 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: I1-7. NA 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: I1-7. NA Yes = 1 No = 0 Needs Improvement = .5 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: I1-7. NA 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: I1-7. NA Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 878639368 2017 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 21#
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