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PHMSA sc-2017-gas-program-evaluation
2017 SC NG Program Evaluation - sc-2017-gas-program-evaluation (South Carolina; Natural Gas State Program Evaluation)
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SC NG Program Evaluation, 2017, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2017 Gas State Program Evaluation for Office of Regulatory Staff of South Carolina 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: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 1#
SC NG Program Evaluation, 2017, page 22017 Gas State Program Evaluation -- CY 2017 Gas State Agency: South Carolina Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: No Date of Visit: 08/20/2018 - 08/24/2018 Agency Representative: Johnny Eustace, Program Manager Vernon Gainey, Retired Program Manager Tom Allen, ORS Director, Safety, Transportation & Emergency Response Larry Bryant, Inspector Will Berley, Inspector John Iglesias, Inspector PHMSA Representative: Glynn Blanton, PHMSA State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: Nannette S. Edwards, Executive Director Agency: Office of Regulatory Staff Address: 1401 Main Street, Suite 900 City/State/Zip: Columbia,, SC 29201 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 2017 (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 9 B Program Inspection Procedures 13 13 C Program Performance 45 44 D Compliance Activities 15 14 E Incident Investigations 11 11 F Damage Prevention 8 6 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 114 109 State Rating................................................................................................................................................... 95.6 DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 2#
SC NG Program Evaluation, 2017, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress 1 1 Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A review and comparison of 2016 & 2017 Attachment 1 found the information to be the same. They inspect all operators and inspection units each year. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Inspection days were higher in CY2017 than CY2016: 456.5/370. No Drug & Alcohol inspections conducted in CY2016/2017. The last inspections were conducted in CY2015. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress 1 1 Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The list of operators match attachment 1. Note section provided a description of a change in the purchase of AmeriGas to Youmans LP. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: One incident occurred on 09-26-17. This incident was due to a contractor hitting a gas line while installing a water main. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 0 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Verification of compliance activities found no civil penalties assessed in CY2017. Reviewed files to verify violations found, corrected and carry over for calendar year 2017 and found numerous errors. The number of violations carried over from previous year was listed as zero but actual number is 2, number of violation found during the year was listed 14 but actual number is 19, number corrected was listed as 12 but actual number was 21, number to be corrected at end of CY was listed as 2 but actual number is zero. Program Manager will need to correct this information via e-mail to Carrie Winslow. Improvement is needed in correctly reporting this data. A loss of one point occur due to the numerous errors on the attachment. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes, program files, records, letters and reports were reviewed and found well-organized. No issues of concern. 7 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, reviewed TQ training records and found four inspectors which includes the Program Manager have completed all required TQ training courses to meet the Gas Inspector Training requirements. Three of the four inspectors have completed the DIMP inspector training requirements. Two inspectors have completed the root cause course. DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 3#
SC NG Program Evaluation, 2017, page 48 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report 1 1 Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: They have automatic adoption of federal regulations. However, their current civil penalty amount, $10,000/$500,000, is below the federal government recommended amounts for violations of the pipeline safety regulations. 9 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A detailed description on past and future performance was provided. Suggested more information on meeting the nine elements be provided. 10 General Comments: Info Only = No Points Evaluator Notes: A loss of one point occurred on question A.5 in this section of the review. Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 10 DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 4#
SC NG Program Evaluation, 2017, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes, standard inspection procedures include pre-inspection, inspection and post inspection information are located on pages 2-4 under Inspection Activity in SC Office of Regulatory Staff, Procedures and Guidelines for the Pipeline Safety Program. 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, IMP & DIMP inspection procedures include pre-inspection, inspection and post inspection information are located on pages 2-4 under Inspection Activity in SC Office of Regulatory Staff, Procedures and Guidelines for the Pipeline Safety Program. 3 OQ Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes, OQ inspection procedures include pre-inspection, inspection and post inspection information are located on pages 2-4 under Inspection Activity in SC Office of Regulatory Staff, Procedures and Guidelines for the Pipeline Safety Program. 4 Damage Prevention Inspection procedures should give guidance to state inspectors that 1 1 insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, Damage Prevention procedures include pre-inspection, inspection and post inspection information are located on pages 2-4 & 8 under Inspection Activity in SC Office of Regulatory Staff, Procedures and Guidelines for the Pipeline Safety Program. 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, on-site training procedures are located on pages 2-4 under Inspection Activity in SC Office of Regulatory Staff, Procedures and Guidelines for the Pipeline Safety Program. 6 Construction Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes, construction procedures include pre-inspection, inspection and post inspection information are located on page 5 under Inspection Activity in SC Office of Regulatory Staff, Procedures and Guidelines for the Pipeline Safety Program. DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 5#
SC NG Program Evaluation, 2017, page 67 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: Yes, items a thru e are located on pages 2-3 in SC Office of Regulatory Staff, Procedures and Guidelines for the Pipeline Safety Program. A review of inspection units found them to be broken down correctly. No issues of concern with this information. 8 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in the review of this section. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 6#
SC NG Program Evaluation, 2017, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 5 5 A. Total Inspection Person Days (Attachment 2): 456.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 2.55 = 561.00 Ratio: A / B 456.00 / 561.00 = 0.81 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: A.Total Inspection Person Days (Attachment 2)= 456 B.Total Inspection Person Days Charged to the program(220*Number of Inspection person years(Attachment 7)=560.99978 Formula:- Ratio = A/B = 456/560.99978 = 0.81 Rule:- (If Ratio >=.38 then points = 5 else Points = 0.) Thus Points = 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: a. All four inspectors have completed the OQ training requirements. b. Three of the four inspectors have completed the DIMP inspector training requirements. c. Two inspectors have completed the root cause course. d. No outside training courses were attended by inspectors. e. All four inspectors have met the requirement to be the lead inspector on a standard inspection. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 2 1 Evaluator Notes: Mr. Eustace has five years of experience as an inspector and 8 months' experience as a Program Manager. He previously worked for a natural gas distribution system for 18 years as the Senior Foreman over construction. He has completed all the training requirements at TQ. He is familiar with some of the requirements of the Program Manager but needs more experience in the day to day operations of the administrative, enforcement and compliance requirements. One point loss due to Mr. Eustace limited time as a program manager and errors that occurred on the 2017 Progress Report filing with PHMSA.. 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct 2 2 or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Executive Director's Duke Scott response letter to Zach Barrett was received on May 22, 2017 and within the sixty-day time requirement. DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 7#
SC NG Program Evaluation, 2017, page 85 Did State conduct or participate in pipeline safety training session or seminar in Past 3 1 1 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: Yes, the last seminar was conducted in Columbia, SC at the Embassy Suites on August 8-9, 2017. The number of attendees were 115 which consisted of personnel from master meter, distribution and transmission companies. 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Yes, all inspection units and operators were inspected annually not to exceed five years. 5 5 7 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, they use the Federal forms and have developed specific forms for construction and other activities. 2 2 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 Yes = 1 No = 0 Evaluator Notes: N/A. No cast iron piping in the State of South 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 Yes = 1 No = 0 Evaluator Notes: N/A. No cast iron piping in the State of South 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 Yes = 1 No = 0 1 1 Evaluator Notes: Yes, this question and item is listed in the Standard Comprehensive inspection form under Emergency Procedures section. 11 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: 1 1 Yes, this question is listed in the Standard Comprehensive inspection form under Failure Investigation Procedures section. 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DUNS: 805889529 2017 Gas State Program Evaluation 2 2 South Carolina Office of Regulatory Staff of South Carolina, Page: 8#
SC NG Program Evaluation, 2017, page 9Yes, inspectors review the operator's annual reports and perform an analysis on the data yearly with the program manager. This information is maintained by the Program Manager and used in the risk ranking of operators to be inspected. 13 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes, this item is listed on the Standard Comprehensive Transmission Inspection form page 3. It was suggested this question be added to the standard inspection form for distribution systems. 14 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is being checked during the inspection. The last drug & alcohol inspections were conducted in CY2015 and they are scheduled for another round of inspections in CY2019. 15 Is state verifying operators OQ programs are up to date? This should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is addressed on the standard inspection. 2 2 16 Is state verifying operator's gas transmission integrity management programs (IMP) are up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually? Are replies to Operator IM notifications addressed? (formerly part of Question C-13)). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is being addressed during informative meetings with the larger operators. 2 2 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 2 This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is addressed on the DIMP inspection form. The larger operators are being contacted via inspection or meetings to review their programs. 18 Is state verifying operators Public Awareness programs are up to date and being 2 2 followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, public awareness inspections were performed in CY2017. The effectiveness reviews were conducted at the same time as the inspections. DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 9#
SC NG Program Evaluation, 2017, page 1019 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: This is accomplished by attending Utility Coordinating Committee meetings across the state along with the Southern Gas Association. Each inspector will attend one or more meetings and present information to the different stakeholder groups about the Office of Regulatory Staff South Carolina pipeline safety program. 20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No safety related conditions reports in CY2017. 1 1 21 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, this is addressed in the additional questions sections which is attached to the standard comprehensive inspection form. 22 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, Program Manager has participated in NAPSR & PHMSA surveys. 1 1 23 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. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: No waivers or special permits have been issued. 1 1 24 Did the state attend the National NAPSR Board of Directors Meeting in CY being 1 1 evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: No, Vernon Gainey was unable to attend the NAPSR 2017 Board of Directors meeting in Columbus, OH in September, 2017 due to illness and was granted a waiver of this requirement by Zach Barrett. 25 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: a & b. Reviewed PHMSA State Program Metrics with Program Manager and found leaks outstanding per 1,000 miles indicated an upward trend from previous year. The number of damages per 1,000 locate requests was determined to be 3.2. This is high in comparison to other states. Program Manager and inspectors will continue to monitor and review these items and discuss with operators during their inspections and take AA action. DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 10#
SC NG Program Evaluation, 2017, page 1126 Discussion with State on accuracy of inspection day information submitted into State 1 NA Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: Discussed with Johnny Eustace the SICT program. A few minor changes were made based on a change of the operator's risk factors. The anticipated CY2018 inspection person days will be 400. This is an increase of twenty inspection days from the previous year. 27 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: No pipeline flow reversals occurred in CY2017. This question is not relative to the operators in SC. 1 NA 28 General Comments: Info Only = No Points Evaluator Notes: A loss of one point occurred in this section of the review. See question C.3. Info Only Info Only Total points scored for this section: 44 Total possible points for this section: 45 DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 11#
SC NG Program Evaluation, 2017, page 12PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: a. This is located on page 9, South Carolina Office of Regulatory Staff Procedures and Guidelines for the Pipeline Safety Program, Non-Compliance Inspection Guidelines, page 9. Section 1. b. This item is located in Section 5-6. pages 10-11. c. This item is located in Section 7-9. page 11. 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 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: a Yes, a review of fifteen compliance action letters confirm they were to the company officer, general officer, director or other official officers. b. Yes, violations were described and noted in the letters. c. Violations were resolved within the established 45 day time schedule. d. All violations were reviewed monthly by Program Manager or Inspector. e. Yes, their procedures requires a fifteen days follow-up with a second follow-up in forty five days f.Yes. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. fifteen letters of non-compliance were issued in CY2017. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes, this is identified in section 8 under Non-Compliance Inspection Guidelines. 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 12#
SC NG Program Evaluation, 2017, page 13Yes, Program Manager is familiar with assessing civil penalties and has considered repeated violations as a base to recommend a penalty. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 0 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The agency has never in the life of the pipeline safety program assessed a civil penalty against an operator. They are aware and have tried to demonstrate enforcement by using other means. However, improvement is needed and a loss of one point occurred. 7 General Comments: Info Only = No Points Evaluator Notes: A loos of one point occurred in question D.6 in this section of the review. Info Only Info Only Total points scored for this section: 14 Total possible points for this section: 15 DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 13#
SC NG Program Evaluation, 2017, page 14PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ 2 2 accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, they have a minimum description of how they will perform incident investigations in their procedures. It was suggested the procedures be enhancement. 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: a&b. These items are listed in the South Carolina Office of Regulatory Staff Procedures and Guidelines for the Pipeline Safety Program on page 9 under Incidents. Yes. After hour notification telephone number to contact an inspector is posted on the agency's website and provided in handout material given to the operator at meetings or during an inspection. 3 If onsite investigation was not made, did state obtain sufficient information from the 1 1 operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A review of files appear to show they have been documented a decision to go or not go on site to perform an investigation. No areas of concern. 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: Yes, one incident occurred in CY2017. The incident was on 09/26/2017 at Wescott Blvd in Summerville, SC. The incident was investigated and documented with information and findings of fact via emails and phone conversations with operator representatives. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: No violations were found or noted in the investigation. 1 1 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, they communicated with Pete Kachmar, PHMSA, about the incident and updating the incident report. 1 1 DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 14#
SC NG Program Evaluation, 2017, page 157 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: Yes, this incident was presented at the 2018 NAPSR Southern Region Meeting in Montgomery, AL. 1 1 8 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section of the review. Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 15#
SC NG Program Evaluation, 2017, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 0 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No, this item has not been asked or included in the standard or construction inspection form. Improvement is needed and a loss of two points occurred. 2 Did the state inspector verify pipeline operators are following their written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this item is covered in the Standard Comprehensive inspection form. 2 2 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is accomplished by attending the Utility Coordinating committee, SC811 one call center, Southern Gas Association and Carolina Public Gas Association meeting. During attendance the Program Manager will present information about the pipeline safety program. 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) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The SC811 collects data and evaluates the trends on the number of pipeline damages per 1,000 locate request. This information is send to the Program Manager on a quarterly schedule. He uses the information in the rank risking of operators to be inspected. 5 General Comments: Info Only = No Points Evaluator Notes: A loss of two points occurred in question F.1 in this section of the review. Info Only Info Only Total points scored for this section: 6 Total possible points for this section: 8 DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 16#
SC NG Program Evaluation, 2017, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Greenwood Commissioners of Public Work Name of State Inspector(s) Observed: John Iglesias & Will Berley Location of Inspection: Greenwood, SC Date of Inspection: August 22, 2018 Name of PHMSA Representative: Glynn Blanton, PHMSA State Programs Evaluator Notes: Info Only Info Only This inspection was performed on the Greenwood Commission of Public Work facilities in Greenwood. SC Dereck Pendley, Compliance Supervisor Greg Barnes, Corrosion Control/Leak Foreman 2 Was the operator or operator's representative notified and/or given the opportunity to be 1 1 present during inspection? Yes = 1 No = 0 Evaluator Notes: Yes. the operator representatives were informed of the proposed inspection several weeks in advance of the scheduled inspection. 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, Office of Regulatory Staff (ORS) Inspectors, John Iglesias and Will Berley used the agency's inspection form entitled, "Pipeline Safety Corrosion Control Inspection Form". 4 Did the inspector thoroughly document results of the inspection? 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, a review of the Pipeline Safety Corrosion Control Inspection Form found all information was listed and responses to questions filled in correctly. 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: Yes, ORS Inspectors, John Iglesias and Will Berley checked the operator's pipe to soil potential meter and other equipment during the field portion of the inspection. 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) 2 2 DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 17#
SC NG Program Evaluation, 2017, page 18Evaluator Notes: John Iglesias and Will Berley reviewed the operator's records prior to and after the field inspection in the operator's office. 7 Did the inspector have adequate knowledge of the pipeline safety program and 2 2 regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, John Iglesias and Will Berley have completed all required TQ courses to meet the gas inspector training requirements. Will Berley has two remaining courses to complete to meet the DIMP requirements. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: Yes, John Iglesias conducted an exit interview with Dereck Pendley and Greg Barnes immediately after the field inspection review was completed. 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Yes,, John Iglesias identified a probable violation during the exit interview. The probable violation was ? 192.465 External corrosion control: Monitoring. (d) Each operator shall take prompt remedial action to correct any deficiencies indicated by the monitoring. 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education Info Only Info Only DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 18#
SC NG Program Evaluation, 2017, page 19y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Multiple cathodic protection readings were taken in the Greenwood Commission of Public Work service area. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 19#
SC NG Program Evaluation, 2017, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 20#
SC NG Program Evaluation, 2017, page 21PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 805889529 2017 Gas State Program Evaluation South Carolina Office of Regulatory Staff of South Carolina, Page: 21#
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