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PHMSA ms-2018-gas-program-evaluation
2018 MS NG Program Evaluation - ms-2018-gas-program-evaluation (Mississippi; Natural Gas State Program Evaluation)
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MS NG Program Evaluation, 2018, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2018 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 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 1#
MS NG Program Evaluation, 2018, page 22018 Gas State Program Evaluation -- CY 2018 Gas State Agency: Mississippi Rating: Agency Status: Date of Visit: 04/22/2019 - 04/26/2019 Agency Representative: Rickey Cotton, Director Pipeline Safety PHMSA Representative: Agustin Lopez, State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: Brandon Presley, Chairman Agency: Mississippi Public Service Commission Address: 501 N. West Street, Suite 201 A City/State/Zip: Jackson, MS 39201 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2018 (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. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 13 12 C Program Performance 48 48 D Compliance Activities 15 15 E Incident Investigations 10 10 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 116 115 State Rating................................................................................................................................................... 99.1 DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 2#
MS NG Program Evaluation, 2018, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress 1 1 Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed Attachment 1 and compared with MS database and Annual Reports. Have 6 "other" operators which are Gas Districts. The numbers were accurate and no issues found. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Reviewed MS database and verified how days are tracked and for accuracy. Attachment 2 data seems to be accurate when compared with MS database. No issues found. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Reviewed MS operator list an annual reports and compared to Attachment 3. Operator list is accurate. No issues found. 4 Were all federally reportable incident reports listed and information correct? - Progress 1 1 Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were two incident notifications but were retracted due to not meeting the requirements. There were no incidents in PDM. No issues identified. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Last year's Progress Report had 95 compliance items to be corrected but this year's Progress Report had 97 carried over. The correct number is 95 so there was a typing error. The other numbers were not affected and were accurate so there were no point deductions. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, records are kept electronically and can be reviewed at any time. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes, reviewed qualifications and compared to TQ records. Qualifications of inspectors seem to be accurate. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Only rule not adopted is the dollar amount of civil penalties not being substantially the same as DOT. DUNS: 878639368 2018 Gas State Program Evaluation 1 1 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 3#
MS NG Program Evaluation, 2018, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Plan to have all inspectors qualified as inspectors. Continue working with damage prevention stakeholders to improve/reduce damage to underground facilities. 10 General Comments: Info Only = No Points Evaluator Notes: The MPSC is mainly complying with Part A of the Evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 4#
MS NG Program Evaluation, 2018, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 2 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Section VII of Operations and Enforcement Procedures includes standard inspection guidance to inspectors on performing inspections. The procedures include a pre and post inspection activities. 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure 1 0.5 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: Section VII has IMP and DIMP procedures to give guidance to inspectors on performing IMP and DIMP inspections. The procedures need more detail to give better guidance on how to perform the IMP and DIMP inspections. 3 OQ Inspection procedures should give guidance to state inspectors that insure 1 0.5 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: Section VII has OQ procedures to give guidance to inspectors on performing IMP and DIMP inspections. The procedures need more detail to give better guidance on how to perform OQ inspections. 4 Damage Prevention Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Section VII has Damage prevention inspection procedures that give guidance to the inspectors. 1 1 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Section IX has Operator Training on how to train operators that need or request the training. 1 1 6 Construction Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Section VII has construction inspection procedures that give guidance to inspectors on how to conduct construction inspections. Procedures give good guidance and have enough detail to conduct inspections. 7 Does inspection plan address inspection priorities of each operator, and if necessary each unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 6 6 DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 5#
MS NG Program Evaluation, 2018, page 6a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: Procedures address the prioritization of inspections in Section VII. The procedures take into consideration the length of time since last inspection, history of operator, activities undertaken by operator, location, high risk threats and compliance history. The units are broken down accordingly. 8 General Comments: Info Only = No Points Evaluator Notes: inspections. Info Only Info Only B.2 IMP and DIMP Inspection procedures need more detail to give guidance to inspectors when performing these types of B.3 OQ Inspection procedures need more detail to give guidance to inspectors when performing these types of inspections. Total points scored for this section: 12 Total possible points for this section: 13 DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 6#
MS NG Program Evaluation, 2018, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 5 5 A. Total Inspection Person Days (Attachment 2): 1268.50 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 8.75 = 1925.00 Ratio: A / B 1268.50 / 1925.00 = 0.66 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Total inspection person days to total person days ratio was .66 which met the requirement. Verified the days submitted with their database to assure numbers are correct. 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: Yes, all inspectors except two are have completed all required TQ courses. a. Yes, inspectors who lead inspections are qualified. b. There are two inspectors who are qualified as IMP inspectors. c. Yes three inspectors have taken the root cause course. d. No outside training only seminars and conferences. e. Verified that qualified inspectors are leading inspections. 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: Yes, Mr. Rickey Cotton is very knowledgeable of he pipeline safety rules and regulations. 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: Yes, the Chairman response was received in a timely manner. 2 2 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: Yes, last seminar was September 25-26, 2018 1 1 DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 7#
MS NG Program Evaluation, 2018, page 86 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Inspection time frames are kept in their database "System Compliance Dates" to track the types of inspections conducted on all operators. In reviewing the database and reports it seems that the MS PSC has conducted the inspections within their established timeframes. 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: The MS PSC utilizes PHMSA forms for their inspections. Current forms seem to be updated but the M PSC S as to assure that the forms being used is updated with any rule changes in the future. 8 Did the state review operator procedures for determining if exposed cast iron pipe was 1 1 examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes, there are three operators that have cast iron in their system, Canton Utilities, Iuka and Holly Springs. Removal program is in place to have all cast iron removed. Inspection form as cast iron examination for graphitization. 9 Did the state review operator procedures for surveillance of cast iron pipelines, including 1 1 appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes, there are three operators that still have cast iron and the MS PSC reviews cast iron pipe leakage history and failures during the inspections. 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: Review the operator emergency response procedures during comprehensive inspections. 1 1 11 Did the state review operator records of previous accidents and failures including 1 1 reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Yes, the operator records of failure response are reviewed during standard inspections to assure appropriate response is taken by he operator. 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: Review annual reports for accuracy and analyze for trends or areas of concern. Determine is prioritization of inspections is necessary due to high risk areas. DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 8#
MS NG Program Evaluation, 2018, page 913 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, verify NPMS submittal during standard inspections. 1 1 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: Yes, conducted Drug and Alcohol inspections in 2018 on operators. Reviewed their plan and testing as required by the regulations. 15 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, conduct OQ inspections to verify OQ plans are up to date and in compliance with the regulations. Conducted several OQ Plan inspections in 2018. Recommended that the MS PSC perform OQ Protocol 9 Field inspections. 16 Is state verifying operator's gas transmission integrity management programs (IMP) are up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually? Are replies to Operator IM notifications addressed? (formerly part of Question C-13)). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes, IMP plans are reviewed during the IMP inspections. There were several IMP inspections performed in 2018. 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 2 This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, DIMP Plans are reviewed by the MS PSC to assure the operator is in compliance. Recommended to make contact on larger operators to inquire of any changes or issues with their DIMP. Will incorporate into standard inspections 18 Is state verifying operators Public Awareness programs are up to date and being 2 2 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: Conduct Public Awareness Program inspections to assure operators are in compliance. The MS PSC conducted several Public Awareness inspections in 2018. 19 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 878639368 2018 Gas State Program Evaluation 1 1 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 9#
MS NG Program Evaluation, 2018, page 10Participate in MS Gas Association Seminars to communicate with stakeholders. Also attend and participate in 811 Summit at the end of every year. Enforcement cases are available but have to be requested through a record request. 20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: Did not have any SRC Reports in Mississippi. Reviewed records in PDM and there was no SRC report submitted. 21 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The issue is asked during integrity management inspections and review operator actions to mitigate safety concerns. 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: Yes, Mr. Rickey Cotton responds to NAPSR and PHMSA requests and surveys. 1 1 23 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. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: There was a waiver issued in 2009 to Atmos Energy allowing them to install a section of 6" PA12 with stipulations. There was a review done on 2014 by the MS PSC on the waiver to assure Atmos is complying with the stipulations. MS PSC is still following up on the waiver. 24 Did the state attend the NAPSR National Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes, Mr. Rickey Cotton attended the national meeting in 2018. 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: Yes, the MS PSC reviews the metrics along with the Annual Reports and analysis data for any trends. The data is also used to prioritize units if needed. 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: Discussed with Mr. Rickey Cotton on the accuracy of the SICT data. Data seems accurate and sees no issues in the total days needed. 27 DUNS: 878639368 2018 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 1 1 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 10#
MS NG Program Evaluation, 2018, page 11Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: There are no know flow reversals in Mississippi. Recommend to add the question to the standard inspection forms to assure the MS PSC is verifying that operators take appropriate actions if flow reversals are performed. 28 General Comments: Info Only = No Points Evaluator Notes: The MPSC is mainly complying with Part C of the Evaluation. Info Only Info Only Total points scored for this section: 48 Total possible points for this section: 48 DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 11#
MS NG Program Evaluation, 2018, 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: MS PSC has Operations and Enforcement Procedures which include procedures on compliance actions. The procedures details how to issue compliance actions, reviewing open compliance actions and closing out probable violations. a. Yes, compliance actions are sent to company officials and mayors. b. Yes, have procedures to avoid delays and breakdowns of compliance actions. c. Yes, procedures include closing of outstanding 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? (Incident Investigations do not need to meet 30/90 day requirement) 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: a. Yes, reviewed several inspection reports and all letters went to company officials or gov't official. b. Yes, reports reviewed addressed all probable violations found during inspections. c. Yes, MS PSC tracks all open and closed violations in their database. d. Yes, inspectors conduct a post inspection briefing after completing each inspection. e. Yes, provide letters to operators within 30 days. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, reviewed several inspection reports and all probable violations were addressed in compliance actions/letters. 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes, the MS PSC gives reasonable due process to all parties. 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: DUNS: 878639368 2018 Gas State Program Evaluation 2 2 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 12#
MS NG Program Evaluation, 2018, page 13Yes, Mr. Rickey Cotton is familiar with the state process for imposing civil penalties. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 1 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: civil penalty until 2019. The MS PSC issued a civil penalty to the City of Utica in 2018 for being out of compliance. The MS PSC did not collect the 7 General Comments: Info Only = No Points Evaluator Notes: The MS PSC is mainly complying with Part D of the Evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 13#
MS NG Program Evaluation, 2018, 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: incident. Section IV of the Operations and Enforcement Procedures include procedures that address the state action in the event of an 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: Yes the operator contacts the inspectors or director to report any reportable incidents. An inspector is assigned to conduct the investigation on reportable incidents. The MS PSC is aware of the MOU with NTSB and PHMSA and cooperation during an incident/accident. 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: There were no reportable incidents in Mississippi in 2018. 1 NA 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: There were no reportable incidents in 2018 so no investigations were conducted. There were two incidents that were reported but turned out not to be reportable. MS PSC went on site and documented findings. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: There were no violations found during their investigations. 1 1 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the MS PSC kept the AID updated on incident investigations that turned out not to be reportable. 1 1 DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 14#
MS NG Program Evaluation, 2018, page 157 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, the MS PSC shares lessons learned during the NAPSR Region meeting. 8 General Comments: Info Only = No Points Evaluator Notes: The MS PSC is mainly in compliance with Part E of the Evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 15#
MS NG Program Evaluation, 2018, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Review procedures during O&M inspections and construction inspections if they are using directional drilling/boring activities. 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: Review procedures during O&M inspections to assure operator responds to one call notifications. 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: Yes, attend several conferences and seminars to promote pipeline safety. 811 Summit is held every year in which the MS PSC attends. 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: 2 2 The damage prevention board gathers the data from the AVR (complaints) to calculate the damages per 1,000. 5 General Comments: Info Only = No Points Evaluator Notes: The MS PSC is mainly complying with Part F of the Evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 16#
MS NG Program Evaluation, 2018, 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: Centerpoint Energy Name of State Inspector(s) Observed: Kaleb Gibson, Pipeline Safety Investigator I Location of Inspection: Byram, MS Date of Inspection: April 25, 2019 Name of PHMSA Representative: Agustin Lopez, State Programs Evaluator Notes: Evaluated Mr. Kaleb Gibson perform a standard inspection on Centerpoint Energy's Laurel Unit. He reviewed O&M Manual procedures and records. The field portion will be conducted at a later date. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 Evaluator Notes: Yes, the operator was notified with enough notice to have representatives present during the inspection. 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the inspectors used PHMSA Distribution Form during the inspection as a guide. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Mr. Gibson used the PHMSA Distribution form to document his results of the inspection. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: The field portion of the inspection was not evaluated but when asked the inspector verified that the technician has appropriate equipment to conduct tasks performed during the inspection. 2 2 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: The inspector reviewed procedures and records during the evaluation. He asked questions of the operator to explain any issues and was very thorough in the review. DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 17#
MS NG Program Evaluation, 2018, page 187 Did the inspector have adequate knowledge of the pipeline safety program and 2 2 regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, for only being with the Commission for almost three years Mr. Kaleb Gibson is knowledgeable of the pipeline safety rules and regulations. He is a good asset for the Commission. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, Mr. Gibson concluded the inspection with an exit interview and covered any issues found during the inspection. 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Yes, the inspector identified several issues which included rectifier and critical bond inspections. 1 1 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping Info Only Info Only DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 18#
MS NG Program Evaluation, 2018, page 19D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Mr. Kaleb Gibson conducted himself very professionally and performed a very good inspection. He demonstrated good knowledge of the pipeline safety rules and regulations for only being an inspector for less than three years. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 19#
MS NG Program Evaluation, 2018, 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: MS PSC is not an Interstate Agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: MS PSC is not an Interstate Agent. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: MS PSC is not an Interstate Agent. 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: MS PSC is not an Interstate Agent. 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: MS PSC is not an Interstate Agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: MS PSC is not an Interstate Agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: MS PSC is not an Interstate Agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: MS PSC is not an Interstate Agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 20#
MS NG Program Evaluation, 2018, 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: MS PSC is not an Interstate Agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: MS PSC is not an Interstate Agent. 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: MS PSC is not an Interstate Agent. 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: MS PSC is not an Interstate Agent. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: MS PSC is not an Interstate Agent. 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: MS PSC is not an Interstate Agent. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: MS PSC is not an Interstate Agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 878639368 2018 Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 21#
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