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2009 MS NG Program Evaluation - ms2009ngprogramevaluation (Mississippi; Natural Gas State Program Evaluation)
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MS NG Program Evaluation, 2009, page 1Official PDF1200 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 MISSISSIPPI PUBLIC SERVICE COMMISSION 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 Initatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 878639368 2009 Natural Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 1#
MS NG Program Evaluation, 2009, page 22009 Natural Gas State Program Evaluation -- CY 2009 Natural Gas State Agency: Mississippi Rating: Agency Status: Date of Visit: 05/17/2010 - 05/21/2010 Agency Representative: Mark McCarver, Director - Pipeline Safety PHMSA Representative: Don Martin Commission Chairman to whom follow up letter is to be sent: Name/Title: Brandon Presley, Chairman Agency: Mississippi Public Service Commission Address: 501 North West Street, Suite 201A 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 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 24 B Inspections and Compliance - Procedures/Records/Performance 24.5 24.5 C Interstate Agent States 0 0 D Incident Investigations 7 6 E Damage Prevention Initiatives 9 8 F Field Inspection 12 12 G PHMSA Initatives - Strategic Plan 10 9.5 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 100.5 96 State Rating................................................................................................................................................... 95.5 DUNS: 878639368 2009 Natural Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 2#
MS NG Program Evaluation, 2009, page 3PART A - General Program Qualifications Points(MAX) Score 8 6 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) SLR Notes: Attachment 1 Inspection Unit Totals do not match Attachment 3 totals. Attachment 3 totals to 173 Inspection Units while Attachment 1 totals 169 inspection units. Attachment 5 does not show any carryover of probable violations from 2008; however, Attachment 5 of 2009 Certification shows 165 probable violations to be corrected at the end of 2008. Attachment 8 states that the MPSC has not adopted civil penalties. The MPSC has not adopted the federal level but it has adopted $1000 per day per violation up to $200,000. 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: Yes. The MPSC maintains an electronic logging of the incident. A file is created when an incident is reported. A file is created in the report filing system on the MPSC's computer network drive. 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: Yes. The MPSC conducts a pipeline safety seminar for its operators each year. The MPSC conducted seminars in 2008 and 2009. 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: Yes. The file systems were organized and provided the information needed to perform the program evaluation. 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 Improvment = 1 2 2 SLR Notes: Mr. McCarver has been the program manager for the MPSC for over seven years. He was a MPSC investigator for several years prior to assuming the program manager job responsibilities. Mr. McCarver is knowledgable of pipeline safety regulations and the requirements for a state pipeline safety program outlined in the Guidelines For A State Pipeline Safety Program. 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: The 2008 Program Evaluation Letter to the Chairman of the MPSC did not identify any issues requiring a response from the MPSC. 1 1 DUNS: 878639368 2009 Natural Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 3#
MS NG Program Evaluation, 2009, page 47 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the 1 1 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 SLR Notes: No items were identified in the Chairman's letter that required action on the part of the commission. Items were identified in the Program Manager's letter that required action to achieve the maximum number of evaluation points. Those items were reviewed in the specific evaluation questions for the 2009 evaluation. 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: Training records for Lewis Davis indicate that Mr. Davis has not attended or completed PL3257, Pipeline Safety Regulation Application and Compliance Procedures Course. Mr. Davis ILT date is 2/7/2003. The MPSC was notified by TnQ during 2009 that Mr. Davis needed to reattend PL1250 and P3257 and pass the final exams to complete the Natural Gas training requirement. Mr. Davis completed PL 1250 in November, 2009. 9 Brief Description of Non-TQ training Activities: Info Only = No Points For State Personnel: Two inspectors attended training at Leak City facility in Athens, AL. For Operators: MPSC staff attended annual Trade Show in March 3, 2010 and Annual Gas Conference in Orange Beach, Al. For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: MPSC staff attended Damage Prevention Committee meetings and utility coordinating committee meetings. SLR Notes: See notes above. Info Only Info Only 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: inspections were conducted. Yes. Upon a review of the OQ database and training records, the inspectors assigned to lead OQ inspections completed the required training prior to the time 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: Lyla Carnley and Michael Sharp conduct the Integrity Management inspections for the MPSC. Lyla and Michael have one remaining course to complete, External Corrosion Direct Assessment. ECDA was an added requirement for which additional time to obtain the completion of all courses. The MPSC should obtain the training as quickly as possible to prevent the loss of points in future evaluations 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): 5 5 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): Ratio: A / B If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 SLR Notes: DUNS: 878639368 2009 Natural Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 4#
MS NG Program Evaluation, 2009, page 5Yes. The MPSC had 553.5 inspection person days during 2009. The MPSC assigned 5.6 person years to the natural gas program during 2009. The resulting ratio is 0.45 which exceeds the minimum ratio of 0.38. 13 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Question B.13 Info Only = No Points SLR Notes: Info Only Info Only There were no changes to the inspector staffing levels during 2009. 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Point Deductions: Question A.1 - Attachment 1 Inspection Unit Totals do not match Attachment 3 totals. Attachment 3 totals to 173 Inspection Units while Attachment 1 totals 169 inspection units. Attachment 5 does not show any carryover of probable violations from 2008; however, Attachment 5 of 2009 Certification shows 165 probable violations to be corrected at the end of 2008. Attachment 8 states that the MPSC has not adopted civil penalties. The MPSC has not adopted the federal level but it has adopted $1000 per day per violation up to $200,000. 2 points were deducted. Total points scored for this section: 24 Total possible points for this section: 26 DUNS: 878639368 2009 Natural Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 5#
MS NG Program Evaluation, 2009, page 6PART 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: The MPSC has written procedures which state that each operator and unit will have a standard inspection completed once every two years. OQ field and damage prevention are covered in standard inspections. Construction inspections are scheduled as the MPSC is notified of construction plans. The MPSC has a construction notification rule for operators. Followup inspections are scheduled after each inspection that contains a probable violation(s). Incident and training inspections are scheduled on an as needed basis. 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: Yes. The primary factor for selecting operators to be inspected is the length of time since the last inspection. The time frequency can be over-riden if concerns were found during previous or recent inspections. 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 SLR Notes: Yes. The MPSC complied with its inspection frequency procedures. 2 2 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 1 1 SLR Notes: Yes. The MPSC uses the federal inspection forms for all inspections except for construction inspection. The MPSC developed its own construction inspection form. Upon a review of the form, it appears to cover all items covered on the federal construction inspection form. 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 Yes = 1 No = 0 SLR Notes: Upon a review of randomly selected inspection reports, the check off columns were completed. 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 DUNS: 878639368 2009 Natural Gas State Program Evaluation .5 NA Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 6#
MS NG Program Evaluation, 2009, page 7SLR Notes: There were no safety related conditions reported by intrastate natural gas operators during 2009. 7 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence .5 .5 of graphitization and if necessary remedial action was taken? (NTSB) Previous Question B.7 Yes = .5 No = 0 SLR Notes: Yes. The MPSC reviews this issue when conducting an operator headquarter's inspection which covers operation and maintenance procedures of the operator. The MPSC verifies that the operator has procedures to examine cast iron pipe for graphitization. The MPSC also provides a listing of advisory bulletins to operators when conducting standard inspections. 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 .5 .5 SLR Notes: Yes. The MPSC encourages operators to implement cast iron replacement programs. The MPSC reviews this issue when conducting an operator headquarter's inspection which covers operation and maintenance procedures of the operator. The MPSC verifies that a procedure exists to monitor circumferential cracking. The MPSC also provides a listing of advisory bulletins to operators when conducting standard inspections. 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: Yes. The MPSC verifies that operator's procedures have procedures to identify the extent of migration of underground leaks. The MPSC reviews leak survey and leak repair records during its standard inspections to verify operators are following their procedures. 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 1 1 B.10 Yes = 1 No = 0 SLR Notes: Yes. The MPSC covers Part 192.617 requirements when it conducts standard inspections of operators. The MPSC reviews operator's response times when reviewing operator's leak repair records. 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: Upon a reveiw of randomly selected inspection reports completed in 2008, probable violations were documented with descriptions of the operator's actions or lack of actions that resulted in a probable violation. 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a 1 1 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: Yes. The MPSC office procedures state the steps to be taken until the probable violations are corrected. The MPSC issues a non-compliance notification to an operators when a probable violation is found. Operators are given 30 days to respond to the notice. Followup inspections are conducted to monitor the progress of corrective actions. Operators are given the opportunity to povide information showing that a probable violation did not occur or an opportunity to request a hearing before the Commissioners to argue that a probable violation did not occur. 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: Yes. The MPSC's office procedures state that a written non compliance notification is sent to an operator whenever a probable violation is identified. Operators are given 30 days to respond. DUNS: 878639368 2009 Natural Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 7#
MS NG Program Evaluation, 2009, page 814 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: Yes. The MPSC's procedures state that follow up inspections will be scheduled after written notification of probable violation has been sent to an operator. 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: compliance. Upon a review of randomly selected inspection reports, all inspections that discovered probable violations were followed up with written notifications of non 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: Upon a review of randomly selected inspection report files, follow up inspection documentation was present to indicate that corrective actions had taken place or another follow up inspection was scheduled for a later date when corrective actions were not completed. 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: There were no show cause hearing information in the inspection files that were reviewed. The MPSC stated there were no actions on the part of an operator that required a "show cause hearing" in 2009. 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: Yes. The MPSC had response letters from operators in its files. The MPSC also documents the date that operators corrective actions were accepted by the MPSC. This date is entered into a spreadsheet record. 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 .5 .5 SLR Notes: official of public operators. Upon a review of randomly selected inspection files, any notification of non-compliance was addressed to a company officer or appropriate management 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: Yes. Operators are provided with the opportunity to provide information that shows that an probable violation did not occur or if unresolved, operators can petition the Commissioners for a "show cause" hearing. 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: 1 NA 22 Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question D(2).2 DUNS: 878639368 2009 Natural Gas State Program Evaluation 1 NA Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 8#
MS NG Program Evaluation, 2009, page 9Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: 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: 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: 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: 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: 27 Part B: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: The MPSC has generally complied with Part B of this evaluation. No deficiencies were noted that resulted in the reduction of evaluation points. Total points scored for this section: 24.5 Total possible points for this section: 24.5 DUNS: 878639368 2009 Natural Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 9#
MS NG Program Evaluation, 2009, page 10PART 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: The MPSC was not an interstate agent during 2009. 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: The MPSC was not an interstate agent during 2009. 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: The MPSC was not an interstate agent during 2009. 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 1 NA SLR Notes: The MPSC was not an interstate agent during 2009. 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: The MPSC was not an interstate agent during 2009. 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: The MPSC was not an interstate agent during 2009. 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: The MPSC was not an interstate agent during 2009. 1 NA 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: The MPSC was not an interstate agent during 2009. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 878639368 2009 Natural Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 10#
MS NG Program Evaluation, 2009, page 11PART 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 SLR Notes: Yes. The MPSC has followed the procedures contained in the Guidelines detailing the procedures and expectations for cooperation. 1 1 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 .5 .5 SLR Notes: Yes. The MPSC exhibited knowledge of the cooperation statements contained in the MOU between PHMSA and the NTSB. There were no incident investigations in 2009 whereby the MOU was needed. 3 Did the state keep adequate records of incident notifications received? Previous Question E.3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: There were two intrastate natural gas pipeline incidents that were reported by operators during 2009. One was reported by Entex, incident occurred on 12/4/2009, and the other was reported by Mississippi River Gas, LLC, incident occurred on 12/9/2009. Both incidents were caused by third party damage. Adequate records were kept for both incidents. 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 SLR Notes: All reportable incidents that occurred in 2009 were investigated by the MPSC. 1 .5 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 Upon a review of the completed PHMSA incident investigation form, it appeared that the MPSC was thorough in its investigation. The MPSC should consider producing a formal written report utilizing the documentation within the completed PHMSA incident investigation form. 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: Both reportable natural gas incidents that occurred in 2009 were the result of third party damage. There were no probable violations found during the MPSC's investigations. There was no cause to intiate enforcement actions. 7 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports .5 0 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: Needs Improvement ? One ODES follow-up on incident reports filed by operator's has been closed, there are several open. Southern Region Office has had difficulty getting word back on the review of the information ? the MPSC provides verbal resonse that they are working on it, but Southern Region has not received written communication back on it being worked/reviewed and completed 8 Part D: General Comments/Regional Observations Info Only = No Points DUNS: 878639368 2009 Natural Gas State Program Evaluation Info Only Info Only Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 11#
MS NG Program Evaluation, 2009, page 12SLR Notes: Question D.7 - Needs Improvement ? One ODES follow-up on incident reports filed by operator's has been closed, there are several open. Southern Region Office has had difficulty getting word back on the review of the information ? the MPSC provides verbal resonse that they are working on it, but Southern Region has not received written communication back on it being worked/reviewed and completed. 0.5 points was deducted. Total points scored for this section: 6 Total possible points for this section: 7 DUNS: 878639368 2009 Natural Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 12#
MS NG Program Evaluation, 2009, page 13PART 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: reviewed annually. Yes. The MPSC verifies that operators include directional/boring procedures in their Operation and Maintenance Procedures. Operator's procedures are 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 2 2 SLR Notes: Yes. During standard inspections, the MPSC verifies that operators follow through with their damage prevention programs required by Part 192.614. 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: Yes. The MPSC promoted the best practices in presentations at industry gatherings. The MPSC includes an item on its standard inspection form to promote discussion of best practices with operators. 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 0 SLR Notes: No. The MPSC or another organization within the state has not collected data on the number of pipeline damages per 1000 locate requests. 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 2 2 SLR Notes: Yes. The MPSC reviews operator's records on leaks and failures during its review of operator's records documenting compliance with Part 192.617. 6 Part E: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: point was deducted. Question E.4 - The MPSC or another organization within the state has not collected data on the number of pipeline damages per 1000 locate requests. One Total points scored for this section: 8 Total possible points for this section: 9 DUNS: 878639368 2009 Natural Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 13#
MS NG Program Evaluation, 2009, page 14PART 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: Atmos Energy Name of State Inspector(s) Observed: Bill Ward Location of Inspection: 5249 Pepper Chase Drive, Southaven, Mississippi 38671 Date of Inspection: 4/5/2010 Name of PHMSA Representative: Dale Bennett SLR Notes: Mark McCarver and Lewis Davis were on hand for this inspection. This inspection consisted of a field review of the city gate station to Horn Lake, Mississippi and the regulator station at Highway 51 and Church Road. Olive branch (Municipal) Mark McCarver and Bill Ward were on hand for this inspection. The inspection consisted of a field review of the city gate station at the ANR station and random points through the town. City of Vicksburg Lyla Carnley was the lead inspector. Mark McCarver, Neill Wood and Michael Sharp were on hand for this inspection. The field review consisted of the north (Smokey Lane) and south feeds (Washington Street) in Vicksburg 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: Yes The operators were notified in March 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 PHMSA'S inspection form for a standard inspection of a natural gas operator. 2 2 4 Did the inspector thoroughly document results of the inspection? Previous Question F.3 Yes = 2 No = 0 SLR Notes: Yes The inspectors checked the applicable box as they progressed through the inspection form. 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: Yes The inspectors check the necessary equipment needed by the operator 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 a standard field 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 DUNS: 878639368 2009 Natural Gas State Program Evaluation 2 2 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 14#
MS NG Program Evaluation, 2009, page 15Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities/Facilities d. Other (Please Comment) SLR Notes: Yes The inspectors checked the procedures with the field activity. 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: Yes The inspectors attended the minimum number of T&G courses to lead a natural gas pipeline safety inspection. 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 1 1 SLR Notes: Yes The inspectors briefed the operators at the conclusion of the inspection. The concerns and probable violations were explained in detail to the operators. 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous 1 1 Question F.11 Yes = 1 No = 0 SLR Notes: Yes The inspectors identified concerns and probable violations found during the inspection and were explained in detail to the operator. 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: Mark McCarver and Lewis Davis were on hand for this inspection. This inspection consisted of a field review of the city gate station to Horn Lake, Mississippi and the regulator station at Highway 51 and Church Road. Olive branch (Municipal) Mark McCarver and Bill Ward were on hand for this inspection. The inspection consisted of a field review of the city gate station at the ANR station and random points through the town. City of Vicksburg Lyla Carnley was the lead inspector. Mark McCarver, Neill Wood and Michael Sharp were on hand for this inspection. The field review consisted of the north (Smokey Lane) and south feeds (Washington Street) in Vicksburg 12 Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only = No Points SLR Notes: There were no best practices identified that should be shared with states or Regions. 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 DUNS: 878639368 2009 Natural Gas State Program Evaluation Info Only Info Only Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 15#
MS NG Program Evaluation, 2009, page 16i. 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 D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other SLR Notes: the inspectors reviewed procedures and records for the items listed above. 14 Part F: General Comments/Regional Observations Info Only = No Points SLR Notes: The inspectors did an excellent job condurcting their inspections DUNS: 878639368 2009 Natural Gas State Program Evaluation Info Only Info Only Total points scored for this section: 12 Total possible points for this section: 12 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 16#
MS NG Program Evaluation, 2009, page 17PART G - PHMSA Initatives - 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 history, etc.) Threats - (Excavation Damage, Corrosion, Natural Forces, Other Outside Forces, Material or Welds, Equipment, Operations, Other) SLR Notes: threats. Yes. The MPSC has developed a spreadsheet that quantifies relative risk of each operator. The relative risk spreadsheet considers a number of possible 2 Are inspection units broken down appropriately? (see definitions in Guidelines) Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. The inspection units are broken into units as described in the "Guidelines For States Participating in the Pipeline Safety Program" (Guideline). 3 Consideration of operators DIMP Plan? (if available and pending rulemaking) Info Only = No Points SLR Notes: Operators deadline for developing programs outlined by the DIMP rule will not be reached until after 2009. Info Only Info Only 4 Does state inspection process target high risk areas? Yes = .5 No = 0 .5 0.5 SLR Notes: The MPSC assigns it investigators with geographical areas of the state. The investigator manages and coordinates inspections of operators within the areas they are responsible. The investigators are very knowledgable (subject matter experts) of each operator's systems and operations. The MPSC utilizes the investigators knowledge to identify high risk areas and conduct focused inspections. The MPSC has focused on threats of third party excavation, pipe materials such as cast iron and bare steel, and compression fittings used to connect distribution piping. Use of Data to Help Drive Program Priority and Inspections 5 Does state use data to analyze effectiveness of damage prevention efforts in the state? (DIRT or other data, etc) .5 0.5 Yes = .5 No = 0 SLR Notes: in CGA's DIRT system. The MPSC reviews data from non- compliance issues from inspections and operator data related to damages to pipelines. The MPSC reviews data contained 6 Has state reviewed data on Operator Annual reports for accuracy? Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. The MPSC requires that operators provide it with a copy of its Annual Reports submission to PHMSA each year. The MPSC reviews the information for accuracy and comparison to the previous year report. The operators are informed of any inconsistencies found during the reviews. 7 Has state analyzed annual report data for trends and operator issues? Yes = .5 No = 0 .5 0.5 SLR Notes: The MPSC monitors the mileage of cast iron mains remaining in each operator's system and the total within the state of Mississippi. The MPSC maintains a spreadsheet with the mileage of cast iron for each operator over a period of ten years. 8 Has state reviewed data on Incident/Accident reports for accuracy? Yes = .5 No = 0 SLR Notes: DUNS: 878639368 2009 Natural Gas State Program Evaluation .5 0.5 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 17#
MS NG Program Evaluation, 2009, page 18Yes. The MPSC reviews data on incident repots to ensure that the reports are complete (all entries are completed), the proper status is checked (original, supplemental or final), and that the operator's stated cause of the gas release is reasonable and is consistent with the MPSC's investigation. 9 Does state do evaluation of effectiveness of program based on data? (i.e. performance measures, trends, etc.) .5 0.5 Yes = .5 No = 0 SLR Notes: The MPSC reviews data on Annual reports from operators. The MPSC reviews data on operators' progress on replacing cast iron and bare steel pipe. The MPSC reviews the number of leak repairs shown in the Annual Reports and compares to previous years. 10 Did the State input all operator qualification inspection results into web based database provided by PHMSA in a timely manner upon completion of OQ inspections? Previous Question B.15 Yes = .5 No = 0 .5 0.5 SLR Notes: The MPSC uploaded the results of its inspections of operator's OQ plans since 2004. The MPSC was very active in uploading these results. The MPSC continues to upload the results of inspections on operator's performance related to their plans as documented on Protocol 9 forms. 11 Did the State submit their replies into the Integrity Management Database (IMDB) in response to the Operators notifications for their integrity management program? Previous Question B.16 Yes = .5 No = 0 .5 0.5 SLR Notes: The MPSC responded to all notifications it received during 2009. 12 Have the IMP Federal Protocol forms been uploaded to the IMDB? Previous Question B.17 .5 0 Yes = .5 No = 0 SLR Notes: The MPSC has conducted IMP inspections for natural gas pipeline operators that have transmission pipelines except for one. These inspections total over twenty. The Gas IMP data base contains approximately eight inspections that have been uploaded. The MPSC has not complied with this requirement. 0.5 points is deducted. 13 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? Previous Question B.18 Yes = .5 No = 0 .5 0.5 SLR Notes: The MPSC has included this item to its standard inspection forms so that operators can be questioned about plastic pipe and fittings concerns. 14 Has state confirmed transmission operators have submitted information into National Pipeline Mapping System (NPMS) database along with any changes made after original submission? Yes = .5 No = 0 SLR Notes: Yes. This is verified during comprehensive inspections. The operator is questioned as to whether they have made their submittals. .5 0.5 Accident/Incident Investigation Learning and Sharing Lessons Learned 15 Has state shared lessons learned from incidents/accidents? (i.e. NAPSR meetings and communications) .5 0.5 Yes = .5 No = 0 SLR Notes: Yes. The MPSC presented an update of its program at the NAPSR Southern Region Meeting held in April, 2009. The MPSC included a topic on the incidents that occurred in Mississippi since the previous NAPSR Southern Region meeting. 16 Does the State support data gathering efforts concerning accidents? (Frequency/Consequence/etc) .5 0.5 Yes = .5 No = 0 SLR Notes: The MPSC has not been contacted about a request for data related to incidents or accidents. The MPSC has cooperated with any requests from the Southern Region Office related to incidents reported to the National Response Center. 17 Does state have incident/accident criteria for conducting root cause analysis? Info Only = No Points SLR Notes: DUNS: 878639368 2009 Natural Gas State Program Evaluation Info Only Info Only Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 18#
MS NG Program Evaluation, 2009, page 19Root cause is a new method for the MPSC and has not been incorporated as yet. 18 Does state conduct root cause analysis on incidents/accidents in state? Info Only = No Points SLR Notes: Not at this time. Info Only Info Only 19 Has state participated on root cause analysis training? (can also be on wait list) Yes = .5 No = 0 SLR Notes: Wiley Walker completed the root cause training in 2009. Michael Sharp is scheduled to attend in 2010. .5 0.5 Transparency - Communication with Stakeholders 20 Other than pipeline safety seminar does State communicate with stakeholders? (Communicate program data, .5 0.5 pub awareness, etc.) Yes = .5 No = 0 SLR Notes: Yes. The MPSC participates in the Mississippi Damage Prevention Committee. The MPSC participates in Mississippi Gas Association meetings and conferences. Mark McCarver authors an article each month in the damage prevention magazine circulated in Mississippi. The MPSC participates in local Utility Coordinating Committee meetings. 21 Does state share enforcement data with public? (Website, newsletters, docket access, etc.) .5 0.5 Yes = .5 No = 0 SLR Notes: The public has access to the MPSC docket system where enforcement cases seeking civil penalties or other Commission action is available. The MPSC provides access to the Commission's website and the MPSC produces an Annual Newsletter that is provided to the public. 22 Part G: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Question G.12 - The MPSC has conducted IMP inspections for natural gas pipeline operators that have transmission pipelines except for one. These inspections total over twenty. The Gas IMP data base contains approximately eight inspections that have been uploaded. The MPSC has not complied with this requirement. 0.5 points is deducted for this evaluation question. Total points scored for this section: 9.5 Total possible points for this section: 10 DUNS: 878639368 2009 Natural Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 19#
MS NG Program Evaluation, 2009, page 20PART H - Miscellaneous Points(MAX) Score 1 What were the major accomplishments for the year being evaluated? (Describe the accomplishments, NAPSR Activities and Participation, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: The MPSC continues its focus on operators' cast iron and bare steel replacement programs. The MPSC has been instrumental in supporting changes to the underground facility damage prevention laws in Mississippi. The MPSC works very closely with the one call system in Mississippi and has partnered with them on damage prevention initiatives. The MPSC has developed a system to risk rank operators' systems and operations on a relative basis. 2 What legislative or program initiatives are taking place/planned in the state, past, present, and future? (Describe initiatives (i.e. damage prevention, jurisdiction/authority, compliance/administrative, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: The MPSC participated in an effort to get legislation passed to enhance damage prevention. Mississippi now requires utilities to install underground facilities in such a manner that they are locatable with standard methods and that utility operators must positively respond to individuals that provide excavation notification. 3 Any Risk Reduction Accomplishments/Projects? (i.e. Cast iron replacement projects,bare steel,third-party damage reductions, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: The MPSC has identified cast iron mains as a key risk factor for pipeline safety in Mississippi. The MPSC has encouraged the replacement of cast iron mains. The MPSC's data shows that cast iron main mileage is trending downward. The MPSC has identified that some master meter systems could be operated with less risks if operated and maintained by the local distribution company transporting gas to the master meter. The MPSC has been successful in convincing some local distribution operators to take over master meter systems. The number of master meter operators is trending downward in Mississippi. The MPSC has partnered with stakeholders in Damage Prevention to propose legislative changes in Mississippi law related to damage to underground utilities. Developed relative risk ranking model to determine inspection priorities. 4 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 SLR Notes: Yes. The MPSC adequately responded to all requests that it received. 1 1 5 Sharing Best Practices with Other States - (General Program) Yes = .5 No = 0 .5 0.5 SLR Notes: others. The MPSC is sharing information with Texas and Lousiana during the seminar that occurs each year in Lousiana. The MPSC has learned a lot about compression fitting problems in this effort and has made it a priority in its pipeliine safety program. The MPSC is sharing the results of this effort with 6 Part H: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only The MPSC has generally complied with Part H of this evaluation. No deficiencies were noted that resulted in the reduction of evaluation points. Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 878639368 2009 Natural Gas State Program Evaluation Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 20#
MS NG Program Evaluation, 2009, page 21PART I - Program Initiatives Points(MAX) Score Drug and Alcohol Testing (49 CFR Part 199) 1 Has the state verified that operators have drug and alcohol testing programs? Yes = 1 No = 0 1 1 SLR Notes: Yes. The MPSC has completed the review of all operators' drug and alcohol testing programs and has followed up with reviews when Part 199 rules have been amended or operator's plans have been revised. 2 Is the state verifying that operators are conducting the drug and alcohol tests required by the operators program (random, post-incident, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. Operators records are reviewed during standard inspections to verify random drug testing rates exceed 25 percent. The MPSC checks records of tests for cause or post incident tests of employees who may have been involved in an incident. 3 Is the state verifying that any positive tests are responded to in accordance with the operator's program? .5 0.5 Yes = .5 No = 0 SLR Notes: Yes. If positive results are shown in an operator's records, the MPSC questions operators of the actions taken as a result of the positive test(s). The MPSC compares the action taken with the procedure described in the operator's plan. Qualification of Pipeline Personnel (49 CFR Part 192 Subpart N) 4 Has the state verified that operators have a written qualification program? Yes = 1 No = 0 1 1 SLR Notes: OQ database. Yes. The MPSC has completed the review of all operators' Operator Qualification Plans. The results of these inspections have been uploaded to PHMSA's 5 Has the state reviewed operator qualification programs for compliance with PHMSA rules and protocols? .5 Yes = .5 No = 0 SLR Notes: Yes. The MPSC utilized the protocol forms to inspect operators' OQ Plans. The protocol forms were uploaded into PHMSA's OQ database. 0.5 6 Is the state verifying that persons who perform covered tasks for the operator are qualified in accordance with the operator's program? Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. The MPSC reviews OQ Qualification records as a part of its standard inspections. The verifies that requalifications are performed within the timeframes established in the operator's OQ Plan. The MPSC also conducts Protocol 9 inspections to randomly verify that qualified individuals can perform the covered tasks as outlined in operators' plans. 7 Is the state verifying that persons who perform covered task for the operator are requalified at the intervals specified in the operator's program? Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. The MPSC verifies qualification records during its standard inspections to insure that operators are requalifying individuals according to the operators' requalification intervals outlined in their plans. Gas Transmission Pipeline Integrity Management (49 CFR Part 192 Subpart O) 8 Has the state verified that all operators with transmission pipelines have either adopted an integrity management program (IMP), or have properly determined that one is not required? Yes = 1 No = 0 1 1 SLR Notes: The MPSC has completed Integrity Management Plan inspections for all operators that have gas transmission pipelines except for one. The MPSC has verified that the remaining operator has adopted a program. 9 Has the state verified that in determining whether a plan is required, the operator correctly calculated the potential impact radii and properly applied the definition of a high consequence area? DUNS: 878639368 2009 Natural Gas State Program Evaluation .5 0.5 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 21#
MS NG Program Evaluation, 2009, page 22Yes = .5 No = 0 SLR Notes: covers this requirement. The MPSC uses and completes all information in the protocol forms while conducting its inspections of Integrity Management Plans. The protocol form 10 Has the state reviewed operator IMPs for compliance with Subpart O? (In accordance with State Inspection .5 0.5 plan) Yes = .5 No = 0 SLR Notes: Subpart O. The MPSC uses the Integrity Management Plan inspection protocols while conducting its IMP inspections. The protocol forms covers the requirements in 11 Is the state monitoring operator progress on the inspections, tests and remedial actions required by the operator's IMP, including that they are being done in the manner and schedule called for in its IMP? Yes = .5 No = 0 SLR Notes: The MPSC has conducted these reviews on some of the operators. .5 0.5 12 Is the state verifying that operators are periodically examining their transmission line routes for the appearance of new HCAs? Yes = .5 No = 0 SLR Notes: The MPSC has reviewed this requirement for the operators that it has conducted an IMP inspection. .5 0.5 Public Awareness (49 CFR Section 192.616) 13 Has the state verified that each operator has developed a continuing public awareness program? (due date was 6/20/06 for most operators, 6/20/07 for certain very small operators,6/13/08 for master meters) Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. The MPSC partiicpated in the Public Awareness Clearinghouse review of operator's plans. The MPSC verified that all operators submitted their Public Awareness Plans within the timeframe prescribed by the regulations. 14 Has the state reviewed the content of these programs for compliance with 192.616 (by participating in the Clearinghouse or by other means)? Yes = .5 No = 0 .5 0.5 SLR Notes: The MPSC participated in the review conducted by the Public Awareness Clearinghouse. The MPSC reviewed the results submitted by the Clearinghouse. The MPSC followed up with operators on any deficiencies identified by the Clearinghouse. 15 Is the state verifying that operators are conducting the public awareness activities called for in its program? .5 0.5 Yes = .5 No = 0 SLR Notes: Yes. The MPSC reviews an operator's activity records when conducting standard inspections. The MPSC will need to review operators' effectiveness evaluations beginning June of 2010. 16 Is the state verifying that operators have evaluated their Public Awareness programs for effectiveness as described in RP1162? Info Only = No Points SLR Notes: The MPSC has not begun this effort since the due date for operators to complete their evaluations until June of 2010. Info Only Info Only 17 Part I: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: The MPSC has completed Integrity Management Plan inspections for all operators that have gas transmission pipelines except for one. The MPSC has verified that the remaining operator has adopted a program. DUNS: 878639368 2009 Natural Gas State Program Evaluation Total points scored for this section: 9 Total possible points for this section: 9 Mississippi MISSISSIPPI PUBLIC SERVICE COMMISSION, Page: 22#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.