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PHMSA OK 2019 Gas Program Evaluation
2019 OK NG Program Evaluation - OK 2019 Gas Program Evaluation (Oklahoma; Natural Gas State Program Evaluation)
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OK NG Program Evaluation, 2019, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2019 Gas State Program Evaluation for Oklahoma Corporation Commission Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: 150235299 2019 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 1#
OK NG Program Evaluation, 2019, page 22019 Gas State Program Evaluation -- CY 2019 Gas State Agency: Oklahoma Rating: Agency Status: Date of Visit: 10/05/2020 - 10/31/2020 Agency Representative: Dennis Fothergill, Kelly Phelps, John Harper PHMSA Representative: Don Martin Commission Chairman to whom follow up letter is to be sent: Name/Title: Todd Hiett, Chairman Agency: Oklahoma Corporation Commission Address: 2101 N. Lincoln Blvd. City/State/Zip: Oklahoma City, OK 73105 60105(a): Yes 60106(a): No Interstate Agent: Yes INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2019 (not the status of performance at the time of the evaluation). 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 than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their performance). This evaluation, together with selected factors reported in the state's annual progress report attachments, provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 50 E Field Inspections 15 15 F Damage prevention and Annual report analysis 4 4 G Interstate Agent/Agreement States 0 0 TOTALS 94 94 State Rating................................................................................................................................................... 100.0 DUNS: 150235299 2019 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 2#
OK NG Program Evaluation, 2019, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? Info Only Info Only Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: (a. No discrepancies found when comparing with information in Pipeline Data Mart (PDM). (b. The OCC provided documentation that verified the information is accurate. (c. The OCC maintains a database for operators and units. No issues with accuracy. (d. Attachment 4 did not match up with incidents listed in the Pipeline Data Mart; however, the OCC provided a copy of a communication explaining the small difference. The corrections was communicated to PHMSA. (e. No issues found. (f. No issues found. (g. No issues found. (h. No issues found. (i. No issues found. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 150235299 2019 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 3#
OK NG Program Evaluation, 2019, page 4PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities 5 5 for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. TIMP and DIMP Inspections (reviewing largest operator(s) plans annually) c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) g. LNG Inspections Evaluator Notes: Yes. Procedures sufficiently give guidance to drive consistency when conducting inspections, to include pre-inspection, inspection and post-inspection activities. 2 Do written procedures address inspection priorities of each operator, and if necessary each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? 4 4 Evaluator Notes: The OCC's Guidelines provides procedures that comply with elements a. through f. above. The OCC guidelines state that all inspection types will be completed within five years; however, there some operator types that are scheduled more frequent than five years such as master meters and small municipals due to some risk factors that are more prevalent with those operators. 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 3 3 taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: Yes, the Inspection Guidelines provide for these procedures. The Commission Rules & Practice also provide procedures identifying steps. Also contained in Chapter 20 of Oklahoma Administrative Code Title 165. 4 (Incident/Accident Investigations) Does the state have written procedures to address state actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. 3 3 DUNS: 150235299 2019 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 4#
OK NG Program Evaluation, 2019, page 5Evaluator Notes: Process for telephonic notification is covered in Oklahoma Administrative Code 165:20-5-11. The instructions for contact is also contained in the operators' procedure manuals. The OCC verifies the contact information during an inspection. There is a voice mail message that directs who to call after hours. The on-call inspector is changed each week. 5 General Comments: Info Only = No Points Evaluator Notes: The OCC 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: 150235299 2019 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 5#
OK NG Program Evaluation, 2019, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead b. Completion of Required DIMP/IMP Training before conducting inspection as lead c. Completion of Required LNG Training before conducting inspection as lead d. Root Cause Training by at least one inspector/program manager e. Note any outside training completed f. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) 5 5 Evaluator Notes: Training and Qualification Division's Blackboard system was reviewed for OCC training. All inspectors have completed the training requirements for Standard Inspections. All inspectors have completed Gas Transmission IMP training except for Vince Eitzen, Chad Holliday and Jeff Overbey. All inspectors have completed DIMP course except Vincent Eitzen and Don Thaxton. All inspectors have completed the Operator Qualification course. 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Mr. Fothergill has been the program manager of the OCC's program for over thirty seven years. There are no issues with his knowledge of pipeline safety regulations and the pipeline safety grant program. 3 General Comments: Info Only = No Points Evaluator Notes: There were no issues that resulted in the loss of points in Part C. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 150235299 2019 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 6#
OK NG Program Evaluation, 2019, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 5 intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction (did state achieve 20% of total inspection person-days?) g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: A list of randomly selected operators and inspection units was developed utilizing a random generator. The list represents 20% of the operators in Oklahoma. Upon a review of the OCC's records for the selected operators and inspection units, the OCC met time intervals for all inspection types. 2 Did inspection form(s) cover all applicable code requirements addressed on Federal 10 10 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: Upon a review of inspection report files of randomly selected operators and units, the inspection forms utilized covered applicable code requirements for (a. through (h. There were no instances found where a portion of an inspection form was not completed appropriately. 3 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 established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A list of randomly selected operators was developed utilizing a random generator. The list represents 20% of the operators in Oklahoma. Upon a review of the OCC's records for the selected operators, the OCC met time intervals for Operator Qualification. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 a. Are the state's largest operator(s) plans being reviewed annually? b. Are states verifying with operators any plastic pipe and components that have shown a record of defects/leaks and mitigating those through DIMP plan? 2 2 DUNS: 150235299 2019 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 7#
OK NG Program Evaluation, 2019, page 8c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? Evaluator Notes: A list of randomly selected operators was developed utilizing a random generator. The list represents 20% of the operators in Oklahoma. Upon a review of the OCC's records for the selected operators, the OCC met time intervals for IMP and DIMP. 5 Did the state review the following (these items are NTSB recommendations to PHMSA that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. 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); c. 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; d. 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; e. 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; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? Evaluator Notes: (a. and (b. - There is no cast iron pipe in Oklahoma. (c. Question on Standard Inspection Form covers this requirement. (d. Question on Standard Inspection Form covers this requirement. (e. Verified during inspection of procedures. (f. Covered in DIMP inspections. (g. There are no known installations of regulators within buildings in Oklahoma. 2 2 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. 1 1 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? 10 10 DUNS: 150235299 2019 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 8#
OK NG Program Evaluation, 2019, page 9g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) Evaluator Notes: Inspection files were reviewed for the randomly selected operators and units. Compliance actions were reviewed for the inspections that found probable violations. The OCC's compliance actions followed compliance procedures including follow up and closure. 8 (Incident Investigations) Were all incidents investigated, thoroughly documented, with 10 10 conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? i. Does state share any lessons learned from incidents/accidents? Evaluator Notes: Incident investigation files were provided for review. Upon a review of the files, all reportable incidents were investigated. The OCC utilizes PHMSA Form 11 to document its investigations. (a. No issues. (b. No issues. (c. NA. All incidents were investigations were on-site. (d.,(e and (f. - Documented on the OCC's investigation form. (g. No issues. (h. AID confirmed the OCC's assistance in an email dated 10/27/2020. (i. Yes, at NAPSR Southwest Region meetings. 9 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A response was not required for the CY2018 Program Evaluation. 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Evaluator Notes: Info Only Info Only The OCC held a seminar in November, 2018. The OCC is still within the three year time period. DUNS: 150235299 2019 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 9#
OK NG Program Evaluation, 2019, page 1011 Has state confirmed transmission operators have submitted information into NPMS Info Only Info Only database along with changes made after original submission? Info Only = No Points Evaluator Notes: The OCC obtains a report from NPMS annually. The reviewed for any operators that are delinquent. Operators are notified if delinquent. The OCC documents the review and actions on an Excel Spreadsheet. 12 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The OCC's website has a section for Pipeline Safety and provides access to the docket system. The OCC participates in the Okie One Call (OPAL) public awareness program. The OCC participates in small operator training seminars each year. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) 1 1 Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There was one Safety Related Condition Report for a gas operator under the jurisdiction of the OCC during 2019. The report is closed. No issues identified. 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; b. Operator IM notifications; and c. PHMSA Work Management system tasks? 1 1 Evaluator Notes: There were no identified instances where the OCC was not responsive to information requests. Upon a review of the Work Management System, no deficienceis were identified related to notifications and tasks. 15 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 The OCC does not have any active waivers with any operators. 16 Were pipeline program files well-organized and accessible? Info Only Info Only Info Only = No Points Evaluator Notes: No issues were identified in the CY2018 evaluation. The file organization has not changed since then. The files provided for the CY2019 evaluation were organized and complete. 17 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 3 3 Evaluator Notes: reasonable. There were no revisions requested as a result of the peer review. The information in the OCC's SICT submittal appeared 18 DUNS: 150235299 2019 Gas State Program Evaluation Discussion on State Program Performance Metrics found on Stakeholder Communication site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Info Only Info Only Oklahoma Oklahoma Corporation Commission, Page: 10#
OK NG Program Evaluation, 2019, page 11Evaluator Notes: Upon a review of the performance metrics in PRIMIS, Oklahoma trends are moving in a positive direction. Based upon a discussion with the OCC it is apparent that the Program Manager is knowledgable of the metrics and the drivers that move the trends in the positive direction. 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Info Only Info Only Evaluator Notes: Major large operators in Oklahoma are either considering or implementing PSMS. The OCC supports and encourages operators to adopt PSMS in their operations. 20 General Comments: Info Only = No Points Evaluator Notes: There were no issues which resulted in the loss of points. Info Only Info Only Total points scored for this section: 50 Total possible points for this section: 50 DUNS: 150235299 2019 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 11#
OK NG Program Evaluation, 2019, page 12PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Info Only Info Only Evaluator Notes: The OCC conducted a Control Room Management inspection on Holly Energy Partners Operating LP (HEPO) from October 13-16, 2020. Bruce Campbell was the lead for the OCC. The previous Control Room Management Inspection for this operator was conducted March 10, 2016. HEPO was represented by Richard Townley, General Manager and Cody Allen, Lead Compliance Auditor. 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: The inspector utilized the PHMSA Gas Control Room Management form revised July 2020. The inspector used the form to step through the form protocols. 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: (a. - Yes, Control Room Management Plan was reviewed which contained the procedures. (b. - Records were reviewed as outlined in the protocols of the form. (c. No field activities were required for this type of inspection. (d. None noted. (e. The inspection took place over four days which was an adequate length to cover all of the protocols on the form. 4 From your observation did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: The Lead Inspector exhibited excellent knowledge of the regulations. He has eight years of experience with the OCC. 5 Did the inspector conduct an exit interview, including identifying probable violations? (If 1 1 inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: An exit briefing was conducted on 10/16/2020. Suggestions to clarify a few areas in the operator's Control Room Management Plan was provided. One probable violation was communicated to the operator but is subject to final determination by the OCC's Program Manager. The operator was notified that documentation was not provided for fatigue countermeasures per 192.631(d)(4). DUNS: 150235299 2019 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 12#
OK NG Program Evaluation, 2019, page 136 Was inspection performed in a safe, positive, and constructive manner ? Info Only Info Only Info Only = No Points a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Evaluator Notes: (a. Due to the Coronavirus pandemic, this inspection was conducted virtually using Webex software. Safety was maximized using virtual means without impact to the effectiveness of the inspection. (b. NA - No field observation required. (c. None noted. (d. None noted. 7 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified that resulted in the loss of points. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 150235299 2019 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 13#
OK NG Program Evaluation, 2019, page 14PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues. Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: The OCC maintains a Microsoft Excel Spreadsheets with data from annual reports. Report queries are used to report and observe certain data and trends. The information is used to assess risk factors for individual operators and compare to Performance Metrics contained on the PRIMIS webpage. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 NA determining root causes and minimizing the possibility of a recurrence? (? 192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (? 192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The OCC has initiated an effort to verify operators are taking action to identify problems areas and actions to minimize future damages. 3 Has the state reviewed the operator's annual report pertaining to Part D ? Excavation 4 NA Damage? Yes = 4 No = 0 Needs Improvement = 1-3 a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: Semi-annually, the OCC requests information that is consistent with the annual reporting in operators' annual reports. The quality and appropriate use of cause factors are reviewed by the OCC to increase the accuracy and to reduce the use of Other as a cause. 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? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. 2 2 DUNS: 150235299 2019 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 14#
OK NG Program Evaluation, 2019, page 15d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? Evaluator Notes: The OCC requires semi-annual reports from operators to report excavation damages with causes . The OCC analyzes the data and establishes trends using cause categories that are consistent with those in (c. The OCC addresses problem areas with operators. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues found that resulted in the loss of points. Info Only Info Only Total points scored for this section: 4 Total possible points for this section: 4 DUNS: 150235299 2019 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 15#
OK NG Program Evaluation, 2019, page 16PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections. Info Only = No Points Evaluator Notes: The OCC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days. Info Only = No Points Evaluator Notes: The OCC is not an interstate agent and does not have a 60106 agreement with PHMSA. 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: The OCC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: The OCC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: The OCC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: The OCC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 150235299 2019 Gas State Program Evaluation Oklahoma Oklahoma Corporation Commission, Page: 16#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.