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PHMSA nc2012ngprogramevaluation
2012 NC NG Program Evaluation - nc2012ngprogramevaluation (North Carolina; Natural Gas State Program Evaluation)
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NC NG Program Evaluation, 2012, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2012 Natural Gas State Program Evaluation for NORTH CAROLINA UTILITIES 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: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 1#
NC NG Program Evaluation, 2012, page 22012 Natural Gas State Program Evaluation -- CY 2012 Natural Gas State Agency: North Carolina Rating: Agency Status: Date of Visit: 05/06/2013 - 05/09/2013 Agency Representative: Chris Isley, Director - Pipeline Safety PHMSA Representative: Don Martin Commission Chairman to whom follow up letter is to be sent: Name/Title: Edward S. Finley, Jr., Chairman Agency: North Carolina Utilities Commission Address: 430 North Salisbury Street City/State/Zip: Raleigh, North Carolina 27603-5918 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 2012 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 15 15 C Program Performance 43 43 D Compliance Activities 14 14 E Incident Investigations 3 3 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 105 105 State Rating................................................................................................................................................... 100.0 DUNS: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 2#
NC NG Program Evaluation, 2012, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 (A1a) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No inaccuracies found in operators and inspection units. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Inspection person days were accounted for correctly. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Office records verified the information on Attachment 3. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 (A1d) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 There were no incidents reported by operators in 2012 which matched information in the Pipeline Data Mart. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: 5. No issues found on Compliance Activities. Inspection report information supported the information entered into Attachment 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues for improvement were found in the organization of office records. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 (A1g) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Employees listed was accurate. TQ traininig records were uploaded to Attachment 7. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 (A1h) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No discrepancies were found with the adoption of amendments on Attachment 8. 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 (H1-3) 1 1 DUNS: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 3#
NC NG Program Evaluation, 2012, page 4Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues identified. 10 General Comments: Info Only = No Points Evaluator Notes: The NCUC complied with the requirements of Part A of this evaluation. DUNS: 780414723 2012 Natural Gas State Program Evaluation Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 4#
NC NG Program Evaluation, 2012, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: year. 2 2 Standard inspections were covered in the inspection procedures. Each operator and unit are inspected once each calendar 2 IMP Inspections (including DIMP) (B1b) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The procedures were revised after CY2011 program evaluation. 3 OQ Inspections (B1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 OQ inspections are covered in the inspection procedures. Each operator and unit are inspected once each calendar year. 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Damage prevention inspections were covered in the inspection procedures. Damage Prevention are covered during standard inspections when covering 192.614. Each operator and unit are inspected once each calendar year. 5 On-Site Operator Training (B1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: On site training is scheduled on an as needed basis. 1 1 6 Construction Inspections (B1f) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Construction inspections were covered in the inspection procedures. Construction inspections are scheduled as needed. 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Incident investigations are described in the inspection procedures. They are conducted as they occur. 8 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? (B2a-d, G1,2,4) Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection 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) DUNS: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 5#
NC NG Program Evaluation, 2012, page 6f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: The NCUC inspects each operator and unit once each year. The NCUC considers all of the factors above and analyzes risk factors to determine the priority of inspections within the calendar year. 9 General Comments: Info Only = No Points Evaluator Notes: The NCUC generally complied with the requirements of Part B of this evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 6#
NC NG Program Evaluation, 2012, 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 (A12) Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 513.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 4.00 = 880.00 Ratio: A / B 513.00 / 880.00 = 0.58 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Yes. The NCUC had a ratio of 0.58 which exceeded the minimum ratio of 0.38. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines for requirements) Chapter 4.4 (A8-A11, G19) 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 Evaluator Notes: All required courses for a Gas Inspector has been completed within required timeframes. Some IMP courses will need completion to avoid point reductions if the lead inspector does not complete them. At least one inspector has completed the Root Cause Analysis Training. 3 Did state records and discussions with state pipeline safety program manager indicate 2 2 adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Mr. Isley has been in the program manager role for six years and was an inspector for 14 years prior to being a program manager. He exhibited excellent knowledge of the regulations and managing a state program under PHMSA's certification. 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 (A6-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The response was received in 56 days. 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) Yes = 2 No = 0 Evaluator Notes: The NCUC conducted seminars in 2007, 2010 and 2013. 2 2 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 (B3) Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Each operator was inspected during 2012 which complied with the NCUC's inspection procedures. DUNS: 780414723 2012 Natural Gas State Program Evaluation 5 5 North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 7#
NC NG Program Evaluation, 2012, page 87 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 (B4-5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Upon a review of randomly selected 2012 inspection reports, all applicable portions of the inspection forms were completed. The NCUC uses the federal form for LNG and IMP inspections. The standard inspection form was developed by the NCUC by revising the federal form. Operation and maintenance procedures are not reviewed during each unit inspection of an operator. The Operation and Maintenance Procedures related questions were removed from the federal form. They are included when an Operation and Maintenance Procedures review is conducted. The NCUC uses a form it developed for construction inspections. 8 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 (B7) Yes = 1 No = 0 Evaluator Notes: There is no cast iron pipe in service in North Carolina. 1 NA 9 Did the state review operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 (B8) Yes = 1 No = 0 Evaluator Notes: There is no cast iron pipe in service in North Carolina. 1 NA 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 (B9) Yes = 1 No = 0 1 1 Evaluator Notes: During its annual review of operator Operation and Maintenance Procedures, the NCUC has checked all operators' procedures to insure that leak repair procedures include this requirement. 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 (B10,E5) Yes = 1 No = 0 Evaluator Notes: The NCUC reviews operators' records of incidents, leaks and failures when it covers 192.617 requirements as part of the standard inspection of an operator each year. The NCUC's standard inspection form includes a section on Part 192.617 requirements. The form is used for all annual standard inspections. 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for 2 2 accuracy and analyzed data for trends and operator issues? Data Initiative (G6-9,G16) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NCUC reviews operators' annual reports each year. Operators are required to submit their annual reports to the NCUC in addition to PHMSA by March 15 of each year. The NCUC has entered data from operators' annual reports into spreadsheets that display the data over a period years. DUNS: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 8#
NC NG Program Evaluation, 2012, page 913 Did state input all applicable OQ, IMP inspection results into federal database in a timely 2 2 manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 (G10-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Upon a review of the OQ and IMP databases, the NCUC has complied with the requirement to update the OQ and IMP databases. 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? (G14) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no issues identified. 1 1 15 Is the state verifying operators are conducting drug and alcohol tests as required by regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 (I1-3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NCUC verifies this information while conducting standard inspections. 2 2 16 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 (I4-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NCUC reviewed operators' OQ programs for compliance within two years after the rule was published. The NCUC has condcucted Protocol Nine (field verification) inspections since the programs were reviewed. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 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). 49 CFR 192 Subpart 0 (I8-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NCUC has completed the review of the IMP programs of all gas transmission pipeline operators. Inspections monitoring the progress of assessments and the implementation of remedial actions have been conducted. 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart P DIMP ? First round of program inspections should be complete by December 2014 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NCUC has begun the inspections of operators' DIMP programs and is on schedule to completing the first inspection of operators' DIMP programs by the end of 2014. DUNS: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 9#
NC NG Program Evaluation, 2012, page 1019 Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. 49 CFR 192.616 (I13-16) PAPEI Effectiveness Inspections should be complete by December 2013 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NCUC completed all PAPEE inspections during 2012. 20 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). (G20-21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC has page for pipeline safety on the Commission's web site. On its web page, the NCUC has posted summary information that it includes on Attachment 5 of the annual Progress Report. 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 (B6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were SRC reports during 2012. 1 NA 22 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? (G13) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC has requested operators to monitor its plastic pipe mains and service lines for failures of the pipe and fittings. The NCUC encouraged operators to participate in the American Gas Association's (AGA) plastic pipe initiative by submitting failure information to the AGA's database. Operators have not communicated any information to the NCUC related to an identified concern on any plastic pipe or components. 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? (H4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There was no information available that warranted a reduction in evaluation points. 1 1 24 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only The NCUC generally complied with the requirements of Part C of this evaluation. Some IMP courses will need completion by year end 2013 to avoid point reductions. Please review Appendix C to the Guidelines for the requirements and compare against the training records of each inspector. Total points scored for this section: 43 Total possible points for this section: 43 DUNS: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 10#
NC NG Program Evaluation, 2012, page 11PART 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 (B12-14, B16, B1h) 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 Evaluator Notes: The NCUC requires written notification be sent to an operator when a non-compliance is found. The NCUC procedures states that non-compliance notifications must be sent to a company officer. The NCUC requires that the operator respond in writing, within 30 days, describing its corrective action plans. A log is kept regarding the status of the inspection report. The NCUC follows up with operators until corrective action is completed. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 (B11,B18,B19) 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. Were probable violations documented? Yes No Needs Improvement c. Were probable violations resolved? Yes No Needs Improvement d. Was the progress of probable violations routinely reviewed? Yes No Needs Improvement Evaluator Notes: Upon a review of randomly selected 2012 inspection report files, all reports containing probable violations documented the actions or lack of actions that the operator took that caused the probable violations. The NCUC reviewed the responses to written notifications during 2012. All compliance notifications reviewed were responded to by the operator. All actions were acceptable to the NCUC and the reports were closed. 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Upon a review of randomly selected 2012 inspection report files, all reports containing probable violations had compliance letters sent to the operators. 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. (B17, B20) Yes = 2 No = 0 Evaluator Notes: 2 2 Operators are given the opportunity to respond to non-compliance notifications and provide evidence that a probable violation did not take place. An operator can petition for a hearing to present its case before the Commissioners of the NCUC. 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) (B27) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The program manager explained the authority for civil penalties, process for requesting show cause hearings and the factors considered for initiating civil penalty proceedings. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 780414723 2012 Natural Gas State Program Evaluation 1 NA North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 11#
NC NG Program Evaluation, 2012, page 12There were no probable violations found during 2012 that the NCUC's criteria for the issuance of civil penalties. 7 General Comments: Info Only = No Points Evaluator Notes: The NCUC generally complied with the requirements of Part D of this evaluation. Info Only Info Only Total points scored for this section: 14 Total possible points for this section: 14 DUNS: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 12#
NC NG Program Evaluation, 2012, page 13PART E - Incident Investigations Points(MAX) Score 1 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 (A2,D1-3) 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: The NCUC communicated contact information and instructions to its operators. NCUC rules require that operators contact the NCUC when an incident is discovered. The NCUC is aware of the MOU between NTSB and PHMSA. The NCUC also understands the cooperation with PHMSA that is required when an incident occurs. 2 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 (D4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no incidents reported in North Carolina during 2012. 1 NA 3 Were all incidents investigated, thoroughly documented, and with conclusions and 3 NA recommendations? (D5) 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 incidents reported in North Carolina during 2012. 4 Did the state initiate compliance action for violations found during any incident/accident investigation? (D6) Yes = 1 No = 0 Evaluator Notes: There were no incidents reported in North Carolina during 2012. 1 NA 5 Did the state assist region office 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 (D7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no incidents reported in North Carolina during 2012. 1 NA 6 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) (G15) Yes = 1 No = 0 Evaluator Notes: The NCUC did share incident information during the 2012 NAPSR Southern Region Meeting. 1 1 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 780414723 2012 Natural Gas State Program Evaluation Info Only Info Only North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 13#
NC NG Program Evaluation, 2012, page 14Most of Part E did not apply since incidents were reported in North Carolina during 2012. Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 14#
NC NG Program Evaluation, 2012, page 15PART 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 (E1) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This item is covered when the NCUC conducts a review of operators' Operation and Maintenance Procedures that are required under 192.605. The NCUC uses an inspection form that is derived from the federal inspection which covers this requirement. 2 Did the state inspector check to assure the pipeline operator is following its written 2 2 procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? (E2) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Locating records are reviewed when the NCUC conducts a standard inspection of pipeline operators. This area is covered when the inspector is reviewing operators' damage prevention programs required by 192.614. 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.) (E3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NCUC promoted the Common Ground Alliance Best Practices document with operators. The NCUC encourages operators to adopt and support implementation of best practices in their operations and other stakeholders such as the state's One Call System. The NCUC staff participate in local utility coordinating committee meetings that are sponsored by the North Carolina One Call System. The NCUC supported legislation to improve its damage prevention law. 4 Has the agency or another organization within the state collected data and evaluated 2 2 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) (E4,G5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Operators are now required to report damages on the federal annual reports. The NCUC is compiling this information but not enough data is available to evaluate trends. 5 General Comments: Info Only = No Points Evaluator Notes: The NCUC generally complied with the requirements of Part F of this evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 15#
NC NG Program Evaluation, 2012, page 16PART 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: Piedmont Gas on 5/8/2013 and Public Service North Carolina Gas (PSNCG) on 5/9/2013 Name of State Inspector(s) Observed: Harry Bryant for Piedmont and Steve Woods for PSNCG Location of Inspection: Fayetteville, NC for Piedmont and North Durham for PSNCG Date of Inspection: 05/08/2013 and 5/9/2013 Name of PHMSA Representative: Don Martin Evaluator Notes: Standard inspections were in progress for Piedmont and PSNCG. Valve inspections were observed for Piedmont on 5/8/2013 and Cathodic Protection readings were observed for PSNCG on 5/9/2013. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? (F2) Yes = 1 No = 0 Evaluator Notes: Yes. Both operators had representatives present and were notified two weeks prior to the inspections. 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) (F3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Both inspectors used Federal Form 2 for the standard inspections. 2 2 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Both inspectors documented the results on workpaper forms for each of the code sections reviewed on these days. The results will be transferred to Form 2 prior to the completion of the inspections. 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.) (F5) Yes = 1 No = 0 Evaluator Notes: Yes. Both inspectors checked the technicians testing equipment prior to observing the test readings. Calibration records were verified. 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) (F7) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: No issues were identified with the scope of the inspections. 2 2 DUNS: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 16#
NC NG Program Evaluation, 2012, page 177 Did the inspector have adequate knowledge of the pipeline safety program and 2 2 regulations? (Evaluator will document reasons if unacceptable) (F8) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Both inspectors have considerable experience in natural gas pipeline operations prior to employment with NCUC and several years experience conducting inspections for the NCUC. 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) (F9) Yes = 1 No = 0 Evaluator Notes: yes. 1 1 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) (F10) Yes = 1 No = 0 Evaluator Notes: Both inspectors communicated that no probable violations were found during the inspection activities on 5/8/2013 and 5/9/2013. 10 General Comments: What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 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: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 17#
NC NG Program Evaluation, 2012, page 18D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: The two inspections on the days of the field evaluation covered valve maintenance and cathodic protection readings. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 18#
NC NG Program Evaluation, 2012, page 19PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (C1) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC is not an interstate agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? (C2) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC 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? (C3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC 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.) (C4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC 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? (C5) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC is not an interstate agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? (C6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC is not an interstate agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? (C7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC is not an interstate agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: The NCUC is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 19#
NC NG Program Evaluation, 2012, page 20PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (B21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC does not have a Section 60106(a) agreement. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? (B22) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC does not have a Section 60106(a) agreement. 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.) (B23) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC does not have a Section 60106(a) agreement. 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? (B24) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC does not have a Section 60106(a) agreement. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? (B25) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC does not have a Section 60106(a) agreement. 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? (B26) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NCUC does not have a Section 60106(a) agreement. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: The NCUC does not have a Section 60106(a) agreement. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 780414723 2012 Natural Gas State Program Evaluation North Carolina NORTH CAROLINA UTILITIES COMMISSION, Page: 20#
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