RegulusPipeline researchPHMSA ok-2022-ungs-program-evaluation
OK UNGS Program Evaluation, 2022, page 1Official PDFPHMSA UNDERGROUND NATURAL GAS STORAGE (UNGS) OKLAHOMA CC PROGRAM EVALUATION – CY2022 CONDUCTED May 2-5, & Oct 30-Nov 2, 2023 A – PROGRESS REPORT AND PROGRAM DOCUMENTATION REVIEW 9 of 9 B – PROGRAM INSPECTION PROCEDURES 14 of 14 C – PROGRAM PERFORMANCE 32 of 32 (34) D – COMPLIANCE ACTIVITIES 21 of 21 E – INCIDENT INVESTIGATIONS 8 of 8 (13) F – DAMAGE PREVENTION 4 of 4 G – FIELD INSPECTIONS 12 of 12 H - 60106 AGREEMENT STATE (if applicable) 0 of 0 (6) TOTAL PROGRAM EVALUATION POINTS 100 of 100 (113)#
OK UNGS Program Evaluation, 2022, page 2PHMSA UNGS STATE PROGRAM EVALUATION – CY2022 A – PROGRESS REPORT AND PROGRAM DOCUMENTATION REVIEW THIS SECTION ANALYZES ACCURACY AND COMPLETENESS OF ANNUAL PROGRESS REPORT SCORE 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data – Progress Report Attachment 1 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. Attachment 1 is consistent with Attachment 3 & 8 and is consistent with program records. 1 2 Review of Inspection Days for accuracy – Progress Report Attachment 2 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. 47.5 total days spread between 4 inspectors. 1 3 Accuracy verification of Operators and Operators Inspection Units in State – Progress Report Attachment 3 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. 4 Operators and 3 Units; is consistent with program records. 1 4 Accuracy verification of Compliance Activities – Progress Report Attachment 5 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. No violations found in 2022 and all previous violations had been cleared in 2021. 1 5 Were UNGS program files well-organized and accessible? - Progress Report Attachment 6 (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. All necessary files are electronic and were available for review. Discussed that database links and relationships would make finding specific records easier. 2 6 Was employee listing and completed training accurate and complete? – Progress Report Attachment 7 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. 1 Supervisor and 4 inspectors listed in the 2022 UNGS Progress Report have completed the UNGS Class. Additional staff have taken the courses. It is planned that all pipeline and UNGS staff will take these courses over time. 1 7 Verification of Part 192 and 199 Rules and Amendments – Progress Report Attachment 8 (Yes= 1 point, No= 0 Points) Comments: Yes. OK has automatic adoption of applicable Federal Regulations. 1 8 List of Planned Performance - Did State describe accomplishments on Progress Report in detail – Progress Report Attachment 10 (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. Program goals and reports were well presented in Attachment 10. 1 9 General Comments: Todd Hiett, Chairman, PO Box 52000, OCC, OKC OK 73152-2000. Dennis Fothergill, Pipeline Safety Manager, same address. UNGS PROGRESS REPORT REVIEW score is 42 of 50: Highest percentage of inspectors were in categories III, IV, V. No incidents were reported in UNGS for 2018-2022. Part A scored 9 of 9 points. 9#
OK UNGS Program Evaluation, 2022, page 3B – PROGRAM INSPECTION PROCEDURES Does State Inspection Plan include procedures that address the following elements? (See Guidelines Section 5.1) 1 Does State have written inspection procedures? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. UNGS was added into the existing Pipeline Procedures. 2 Standard Inspections Do Standard Inspection procedures give guidance to State inspectors that insure consistency for inspections conducted by the State? The following elements should be addressed at a minimum. (Review of Procedures, Records, or Field Items to complete a PHMSA UNGS IA Question Set (RESERVOIR or CAVERN) – 2019.12.31) • Pre-Inspection Activities • Inspection Activities • Post Inspection Activities (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. See Page 5 & 6 for Pre; inspection; and Post Activities. 3 Integrity Management Inspections • Do Integrity Management Inspection procedures give guidance to State inspectors that insure consistency for inspections conducted by the State? The following elements should be addressed at a minimum. (Integrity Testing and Maintenance: Observing Integrity Testing (Tubing, Casing, Cement), reservoir integrity monitoring, & FLIR Camera inspections.) • Pre-Inspection Activities • Inspection Activities Post Inspection Activities (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. See Page 5 & 6 for Pre; inspection; and Post Activities. 4 Design, Testing, and Construction Inspections Do Design, Testing, and Construction Inspection procedures give guidance to State inspectors that insure consistency for Inspections conducted by the State? The following elements should be addressed at a minimum. (Review of procedures, records, and field activities to complete PHMSA UNGS IA Question Set (RESERVOIR or CAVERN CONSTRUCTION) – 2019.12.31. Inspection activities for well design, drilling and completion activities, well workover, reservoir maintenance/repair activities, and abandonment (Plugging and cementing), temporary abandonment, and restoration.) • Pre-Inspection Activities • Inspection Activities • Post Inspection Activities (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. See Page 5 & 6 for Pre; inspection; and Post Activities. 2 2 2 1#
OK UNGS Program Evaluation, 2022, page 45 Wellhead Inspections Do Wellhead Inspection procedures give guidance to State inspectors that insure consistency for Inspections conducted by the State? The following elements should be addressed at a minimum. • Pre-Inspection Activities • Inspection Activities • Post Inspection Activities (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. OCC has no specialized Wellhead Inspections; they are addressed as part of the UNGS Standard Inspection. 1 6 Drug and Alcohol Inspections Do Drug and Alcohol Inspection procedures give guidance to State inspectors that insure consistency for Inspections conducted by the State? The following elements should be addressed at a minimum. (Using AI to complete the federal Comprehensive Drug and Alcohol program (Form 3.1.11). Includes time conducting joint inspections with other agencies for this type of inspection.) • Pre-Inspection Activities • Inspection Activities • Post Inspection Activities (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: Yes. See Page 5 & 6 for Pre; inspection; and Post Activities. 1 7 Does inspection plan address inspection priorities of each inspection unit, based on the following elements? • Length of time since last inspection (Within five-year interval per inspection unit) • Operating history of operator/unit and/or location (includes leakage, incident, Integrity Testing, and compliance activities) • Type of activity being undertaken by operators in inspection units (i.e. construction) • Locations of operator’s inspection units being inspected - (Geographic area, Population Density, etc.) • Process to identify high-risk inspection units considering integrity threats Are inspection units broken down appropriately? (Yes= 5 points, No= 0 Points, NI=1-4 points) Comments: Yes. See Pages 7, 8, 9, 12, 13, & 16 for length of time, and other considerations for the various inspection types. 5 8 General Comments: Part B scored 14 of 14 points. 14#
OK UNGS Program Evaluation, 2022, page 5C – PROGRAM PERFORMANCE 1 Was ratio of Total Inspection Person-Days to Total Person-Days acceptable? (Chapter 4.2) A = Total Inspection Person Days (Attachment 2) B = Total Inspection Person Days Charged to the program (220 x Number of Inspection person years from Attachment 7) Ratio = A/B If Ratio >= .38 then score = 5 points. If Ratio < .38 then score = 0 points. (Yes= 5 points, No= 0 Points) Comments: 47.5 inspection days, 220*0.36=79.2 Inspector person days, 47.5/79.2=.60 >.38, okay. 2 Has each Inspector and Program Manager fulfilled the TQ Training Requirements? (See Guidelines Appendix C for requirements and Chapter 4.3.1) (Yes= 5 points, No= 0 Points, NI=1-4) Comments: Yes. 2 Supervisors and 6 inspectors have completed the UNGS Class and D&A Class. The other inspectors will not be inspection Lead until they have successfully completed the UNGS & D&A Classes. 3 Does State use the PHMSA Inspection Assistant (IA) program to document inspections? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. UNGS Standard inspections are in IA. All UNGS related inspections are now in IA. Those trained in IA are now using IA for Gas & other related inspections also. 4 Did records and discussions with Program Manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. Dennis is a fully skilled Program Manager. 5 Did State respond to PHMSA's Evaluation Letter within 60 days and correct or address any noted deficiencies? Chapter 8.1 (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. The letter from PHMSA was received March 1, 2023. A response was received April 26, 2023. 6 Did State inspect all types of operators and inspection units in accordance with time intervals established in their written procedures? Chapter 5.1 (Yes= 5 points, No= 0 Points, NI=1-4 points) Comments: Yes. This is the fourth year of the UNGS Program with OK CC. Initial UNGS Standard inspections have been performed and D&A inspections have been performed. OCC procedures allow up 5 calendar years between inspections. 7 Did State Inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Chapter 5.1 (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. All scheduled UNGS work was done in IA in 2022. This was the first year that not every operator was inspected, but the frequency is well within the 5-year frequency per the procedures. Inspections will typically be biannually with latitude for a 5-year span. 8 Did State complete all applicable portions of inspection forms? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. The 6 most common UNGS modules were selected. Discussed reviewing the other modules for completeness. OKCC intends to address every module at least once, even for NA questions, and applicable questions at least once every 5 calendar years. 9 Has the State reviewed Operator Annual reports, along with Incident reports, for accuracy and analyzed data for trends and operator issues? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. Verified that all Operators submitted annual reports. Verified that what was reported matched State Records. Trending analysis is still premature. 5 5 2 2 2 5 2 2 2#
OK UNGS Program Evaluation, 2022, page 610 11 12 13 14 15 16 Is the State verifying operators are conducting drug and alcohol tests required by regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 (Yes= 2 points, No= 0 Points, NI= 1 point) Comments: Yes. D&A is covered through the Pipeline Program. UNGS Applicable D&A are being done in IA. 2 Does the State have a mechanism for communicating with stakeholders regarding the inspection and enforcement program? (This should include making enforcement cases available to public). (Yes= 1 points, No= 0 Points, NI=.5 point) Comments: Yes. OCC website, Bi-Annual Pipeline Safety Meetings, Open records Requests, email, & phone. Next Pipeline Safety Seminar is scheduled for 2024. 1 Did State execute appropriate follow-up actions to Safety Related Condition Reports (SRCR)? Chapter 6.3 (Yes= 1 points, No= 0 Points, NI=.5 point) Comments: Yes. There was one SRC in 2019, but none since. 1 Did the State participate in/respond to surveys or information requests from PHMSA? (Yes= 1 points, No= 0 Points, NI=.5 point) Comments: Yes. Whenever requested. 1 Did the State forward any potential waivers/special permits to PHMSA for review prior to issuing them to operators? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: NA. None for UNGS. Have procedures to handle them. NA 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 point, No= 0 Points, NI=.5 point) Comments: NA. None for UNGS. Have procedures to handle them. NA General Comments: Part C scored 32 of 32 points. Two questions were NA: 14, & 15. 32#
OK UNGS Program Evaluation, 2022, page 7D – COMPLIANCE ACTIVITIES 1 Does the State have written procedures to identify steps to be taken from the discovery to resolution of a probable violation? Chapter 5.1 • Procedures to notify an operator (company officer) when a noncompliance is identified (60105 States) • Procedures to routinely review progress of compliance actions to prevent delays or breakdowns • Procedures regarding closing outstanding probable violations (Yes= 4 points, No= 0 Points, NI=1-3 points) Comments: Yes. See Procedures, pages 13 – 15. 2 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 • Were compliance actions sent to company officer or manager/board member if municipal/government system (60105 States)? • Document probable violations • Resolve probable violations • Routinely review progress of probable violations (Yes= 4 points, No= 0 Points, NI=1-3 points) Comments: Yes, No violations in 2022, but the 2021 Violation file was reviewed, the Owner of the company was notified, the violations were documented, the violations were brought into compliance, and a final review was conducted. 3 Did State within 30 days of the end of an inspection conduct a post-inspection briefing with the owner or operator of the UNGS facility inspected outlining any concerns identified during the inspection? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. It is OK CC policy to provide a verbal closing at the end of each inspection, and it is noted in the inspection file. A formal letter of violation Letter was sent out 28 days after the inspection for the 2021 Violation. 4 Did State within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: okay. Discussed that in accordance with §60108 of the 2020 pipeline reauthorization, a written notice needs to follow every inspection, but UNGS Guidelines 5.1.5 only require the 90-day notice if violations are found. 5 Did the State issue compliance actions for all probable violations discovered (60105 States)? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. All violations noted in the 2021 inspection were addressed in the Violation Letter. The process is in place. 6 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary (60105 States). (Yes= 2 points, No= 0 Points) Comments: Yes. OKCC followed all its internal policies for due process in the 2021 inspection. The process is in place. 4 4 2 2 2 2#
OK UNGS Program Evaluation, 2022, page 87 Is the Program Manager familiar with State process for imposing civil penalties (60105 States)? (describe any actions taken) (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes. Dennis is very familiar with OK CC civil penalty processes. 2 8 Were civil penalties considered for repeat violations, violations which can’t be corrected by other means, or violations resulting in incidents (60105 States)? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes, this is addressed in the Pipeline and Commission rules-OAC 165:20, & 165:5; civil penalties are imposed as needed for the pipeline program, Operators are cooperative and invested in safety. 2 9 Can the State demonstrate it is using their enforcement fining authority for safety violations (60105 States)? (Yes= 1 point, No= 0 Points, NI= .5 point) Comments: Yes. OK CC has issued several fines through its Pipeline Safety Program. 1 10 General Comments: Part D scored 21 of 21 points. 21#
OK UNGS Program Evaluation, 2022, page 9E – INCIDENT INVESTIGATIONS 1 Does the State have written procedures to address State actions in the event of an incident? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes, See page 4 & 12 of the Procedures. 2 2 Does State have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes, See OAC 165:20-5-11. 2 3 Did the State keep adequate records of Incident notifications received? (Yes= 2 points, No= 0 Points, NI=1 point) Comments: Yes, it is established practice and UNGS has been included in that practice. 2 4 If onsite investigation was not made, did State obtain sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 (Yes= 1 point, No= 0 Points, NI= .5 point) Comments: NA, no UNGS incidents. The Procedures, Policy, and Practice are in place. NA 5 Were all incidents investigated, thoroughly documented, and with conclusions and recommendations? • Observations and document review • Contributing Factors • Recommendations to prevent recurrences where appropriate (Yes= 3 points, No= 0 Points, NI=1-2 points) Comments: NA, no UNGS incidents. The Procedures, Policy, and Practice are in place. NA 6 Did the State initiate compliance action for violations found during any incident investigation? (60106 States forward violations to PHMSA) (Yes= 1 point, No= 0 Points) Comments: NA, no UNGS incidents. The Procedures, Policy, and Practice are in place. NA 7 Did the State assist the Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents and investigate discrepancies) Chapter 6 (Yes= 1 point, No= 0 Points, NI= .5 point) Comments: Yes. OK is always willing to help. The Procedures, Policy, and Practice are in place. 1 8 Does State share lessons learned from incidents with PHMSA? (Yes= 1 point, No= 0 Points) Comments: Yes. During Regional NAPSR Meetings. 1#
OK UNGS Program Evaluation, 2022, page 109 General Comments: Part E scored 8 of 8 points. Questions 4, 5, & 6 were NA. 8#
OK UNGS Program Evaluation, 2022, page 11F – DAMAGE PREVENTION 1 Did the State inspector verify UNGS operators are following their written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? (API 1171 Section 11.10 Public Awareness and Damage Prevention) (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: Yes. Damage is handled by the Pipeline Program 2 Did the State encourage and promote practices for reducing damages to all underground facilities to its regulated companies? (Common Ground Alliance Best Practices, support excavation damage prevention legislation, etc.) (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: Yes. Through scheduled meetings and email correspondence. See OAC 165:20-17-1. 3 General Comments: Part F scored 4 of 4 points. 2 2 4#
OK UNGS Program Evaluation, 2022, page 12G – FIELD INSPECTIONS 1 Operator, Inspector, Location, Date and PHMSA Representative Comments: SALT PLAINS STORAGE, LLC (OPID: 31528), Billy Anglin, Lead, OCC team members include Bruce Campbell, Jedediah Davidson, Randy Snyder, & Travis Burns. Virtual and at the Salt Plains Storage facility. Oct 30-Nov 2, 2023. Patrick Gaume, UNGS Liaison. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? (Yes= 1 point, No= 0 Points) Comments: Yes. Five Salt Plains personnel participated; Jeff Taylor, Jared Jackson, Randy Wilson, & others. 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: Yes. IA was used and six UNGS modules were selected. 4 Did the inspector thoroughly document results of the inspection? (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: Yes. It was discovered that Spire was still in its first 15 months of operation and this inspection was changed into a workshop to help Spire better prepare their Procedures and the inspection is postponed to 1st or 2nd quarter of 2024. 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Yes= 1 point, No= 0 Points) Comments: The operator provided what they had, but it was discovered that several detailed procedures and some associated records were missing. The information was available in 2021 with the previous operator, nothing has been thrown away, so it should still be there, but they couldn’t find it. It was apparent that the new operator has not assimilated the existing procedures into their working knowledge. 6 Did the inspector adequately review the following during the field portion of the State Program Evaluation? • Procedures • Records • Field Activities/Facilities • Other (please comment) (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: This inspection became a workshop to help Spire learn and addressed Procedures, Records, and Observations. 7 Did the inspector have adequate knowledge of the UNGS safety program and regulations? (Evaluator will document reasons if unacceptable) (Yes= 2 points, No= 0 Points, NI=1 Point) Comments: Yes. All OCC inspectors have the required UNGS training and the inspection was by committee. 1 2 2 1 2 2#
OK UNGS Program Evaluation, 2022, page 138 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) (Yes= 1 point, No= 0 Points) Comments: Yes. OCC was confident that the necessary procedures and records existed, but the operator was unable to provide many of them during the workshop. They were given notice that the inspection is now postponed to 1st half of 2024, and they must be prepared and knowledgeable of their O&M manual and show that their personnel are properly trained. 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) (Yes= 1 point, No= 0 Points) Comments: Yes. OCC was confident that the necessary procedures and records existed, but the operator was unable to provide many of them during the workshop. They were given notice that the inspection is now postponed to 1st half of 2024, and they must be prepared and knowledgeable of their O&M manual and show that their personnel are properly trained. 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 Field Observation Areas Observed (check all that apply) Site security, site anchors, signs and markers, atmospheric corrosion, site cleanliness, animal and vehicle barriers, valve identification tags, (advised that the valves needed unique identification as there were multiple master valves and wing valves on the wellhead assemblies). Locks and chains, removed handles for unauthorized valve operation, road conditions, ease of access to all sites, (recommended that the exterior flange on the appropriate wing valves be marked to identify the jurisdiction between UNGS and 192 Pipeline. Part G scored 12 of 12 points. 1 1 12#
OK UNGS Program Evaluation, 2022, page 14H - 60106 AGREEMENT STATE (if applicable) 1 Did the State use the current federal inspection form(s)? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: H1-6; NA, not a 60106 Agreement Partner. 2 Are results documented demonstrating inspection units were reviewed in accordance with State inspection plan? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: H1-6; NA, not a 60106 Agreement Partner. 3 Were all probable violations identified by State referred to PHMSA for compliance action? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: H1-6; NA, not a 60106 Agreement Partner. 4 Did the State immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: H1-6; NA, not a 60106 Agreement Partner. 5 Did the State give written notice to PHMSA within 60 days of all probable violations found? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: H1-6; NA, not a 60106 Agreement Partner. 6 Did the State initially submit adequate documentation to support compliance action by PHMSA on probable violations? (Yes= 1 point, No= 0 Points, NI=.5 point) Comments: H1-6; NA, not a 60106 Agreement Partner. 7 General Comments: Part H is NA, not a 60106 Agreement Partner. Part H scored 0 of 0 points NA NA NA NA NA NA NA#
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