Inspectionhistorical
PHMSA sd-2021-gas-program-evaluation
2021 SD NG Program Evaluation - sd-2021-gas-program-evaluation (South Dakota; Natural Gas State Program Evaluation)
Current as of source date Government source
RegulusPipeline researchRegulusPipeline researchPHMSA sd-2021-gas-program-evaluation
SD NG Program Evaluation, 2021, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2021 Gas State Program Evaluation for S. D. PUBLIC UTILITIES 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: 604570572 2021 Gas State Program Evaluation South Dakota S. D. PUBLIC UTILITIES COMMISSION, Page: 1#
SD NG Program Evaluation, 2021, page 22021 Gas State Program Evaluation -- CY 2021 Gas State Agency: South Dakota Rating: Agency Status: Date of Visit: 04/04/2022 - 04/05/2022 Agency Representative: Mary Zanter, Pipeline Safety Program Manager PHMSA Representative: Agustin Lopez, State Liaison Commission Chairman to whom follow up letter is to be sent: Name/Title: Chris Nelson, Chairman Agency: South Dakota Public Utilities Commission Address: 500 E. Capitol Ave. City/State/Zip: Pierre, SD 57501-5070 60105(a): Yes 60106(a): No Interstate Agent: No 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 2021 (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 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 100 State Rating................................................................................................................................................... 100.0 DUNS: 604570572 2021 Gas State Program Evaluation South Dakota S. D. PUBLIC UTILITIES COMMISSION, Page: 2#
SD NG Program Evaluation, 2021, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress report) 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. Verified operator data with SDPUC files and PDM. b. Verified inspection days with SDPUC tracking spreadsheet. Inspection days are accurate. c. Verified operator data with SDPUC data and PDM. d. There was one reportable incident in 2021 which the SDPUC investigated. e. Reviewed SDPUC 2021 Summary of Deficiencies to verify compliance actions issued and carry over. f. SDPUC retains records in their files. g. Reviewed TQ Blackboard to verify inspector qualifications. h. Have adopted regulations within 2 years. Reviewed state law/rules to verify rule adoptions. i. Have planned performance for 2022 and accomplishment from previous year. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 604570572 2021 Gas State Program Evaluation South Dakota S. D. PUBLIC UTILITIES COMMISSION, Page: 3#
SD NG Program Evaluation, 2021, 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: Section 5 of the South Dakota Pipeline Safety Program manual includes procedures for each type of inspection type. Procedures describes each type of inspection to give guidance to inspectors. Section B Pre-Inspection and Section D post inspection procedure outline activities conducted by the inspectors before an after each inspection. 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: Section 6 of the South Dakota Pipeline Safety Program manual includes metric risk factors to prioritize inspections. Risks include pre code pipe, corrosion leaks, number of services, HCA miles, excavation leaks, cast/bare pipe. 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: Section 3 of the South Dakota Pipeline Safety Program manual includes compliance procedures. Number 7 includes noncompliance resolution procedures which has steps to issue and track noncompliance actions. Procedures include to notify an operator company official as required in ARSD 20:10:37:07, (South Dakota Administrative Rules) 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: 604570572 2021 Gas State Program Evaluation South Dakota S. D. PUBLIC UTILITIES COMMISSION, Page: 4#
SD NG Program Evaluation, 2021, page 5Evaluator Notes: Section 7 of the South Dakota Pipeline Safety Program manual include incident investigation procedures. The procedure has a mechanism to receive notifications 24 hours a day. If onsite investigation is not conducted reasoning will be documented. Investigations include observations, contributing factors and recommendations to prevent recurrences. Added more detail to on-call procedures to give better guidance to inspectors. 5 General Comments: Info Only = No Points Evaluator Notes: The SDPUC is mainly complying with Part B of the Evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 604570572 2021 Gas State Program Evaluation South Dakota S. D. PUBLIC UTILITIES COMMISSION, Page: 5#
SD NG Program Evaluation, 2021, 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 4.3 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: Yes, reviewed training with Blackboard to verify qualification of personnel. Both Mary Zanter and Boice Hillmer have completed the Root Cause Analysis course. Both have completed the minimum courses to lead all types of inspections. 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Yes, Mary Zanter is very knowledgeable of the pipeline safety program and regulations 5 5 3 General Comments: Info Only = No Points Evaluator Notes: The SDPUC is mainly complying with Part C of the Evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 604570572 2021 Gas State Program Evaluation South Dakota S. D. PUBLIC UTILITIES COMMISSION, Page: 6#
SD NG Program Evaluation, 2021, 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: Reviewed randomly selected inspection reports to verify each type of inspection is being conducted per the SDPUC procedures and within the 5 year inspection cycle requirement. Construction time was above the 20% requirement. Operators are inspected every year with a records inspections. 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: Yes ,reviewed randomly selected inspection reports to verify the inspection forms include all applicable code requirements. Standard records inspections are divided into two and each portion is completed every other year. All inspections are completed within a 5 year interval. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This should include verification 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: Yes, the SDPUC is conducting OQ inspections to verify operator OQ Plans are meeting the regulations. 2 2 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 Subparts O and P Yes = 2 No = 0 Needs Improvement = 1 a. Are the implementation plans of the state's large/largest operators(s) being reviewed annually to ensure they are completing full cycle of the IMP process? 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: 604570572 2021 Gas State Program Evaluation South Dakota S. D. PUBLIC UTILITIES COMMISSION, Page: 7#
SD NG Program Evaluation, 2021, page 8c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? Evaluator Notes: Yes, the SDPUC conduct IMP inspections to verify operators are meeting the regulations. Forms have IMP verification program to verify any updates or work being performed under the IMP program. Includes DIMP/IMP question at end of standard inspection form to ask about ongoing work on IMP activities. 5 Did the state review the following (these items are NTSB recommendations to PHMSA 2 2 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: NTSB recommendation questions, when applicable, are included in the Records or O&M inspection form. South Dakota does not have any cast iron nor do we have any low pressure systems. South Dakota also doe not have any additional regulations. a. No cast iron b. No cast iron c. O&M Inspection Form Section IV Emergency Plans - page 4 d. 2021 Records Inspection Form Section XII - page 7 & 2022 Records Inspection Form Section XIII page 13 e. O&M Inspection Form Section XXIII page 30 f. No low pressure systems. g. No indoor regulators. 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 1 1 Evaluator Notes: Advisory bulletins are a part of the O&M Manual inspection. O&M Manual Inspection question - part III, page 3. 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 10 10 DUNS: 604570572 2021 Gas State Program Evaluation South Dakota S. D. PUBLIC UTILITIES COMMISSION, Page: 8#
SD NG Program Evaluation, 2021, page 9e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. 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: Yes, reviewed inspection reports along with any applicable compliance correspondence to assure SDPUC is following it's procedures. Any issues identified are well within the 30 and 90 day notification requirements. 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly documented, with 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? 10 10 Evaluator Notes: Reviewed MDU incident which is investigation is still ongoing due to reviewing response by operator. SD PUC utilizes PHMSA incident investigation form 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: Response not required. 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: Last seminar was held virtually on October 11, 2020 Info Only Info Only 11 Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only = No Points Evaluator Notes: Question is included in records inspection form. Records Inspection Form, Section II, page 4 Info Only Info Only DUNS: 604570572 2021 Gas State Program Evaluation South Dakota S. D. PUBLIC UTILITIES COMMISSION, Page: 9#
SD NG Program Evaluation, 2021, page 1012 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: Program Manager has email list with all the operators that is used to routinely send information to operators. Anytime a new regulation, advisory bulletin, manufacturer bulletin, etc comes out this information is communicated with all the operators. Reviewed several emails which demonstrates communication. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No SRCR in 2021 1 1 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? Evaluator Notes: Yes, send response to NAPSR and PHMSA surveys or requests. 1 1 15 If the State has issued any waivers/special permits for any operator, has the state verified 1 1 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: Waivers have been issued and the SD PUC is aware of all waivers. Waivers are closed due to regulation changes which include waiver regulation or waivers have been withdrawn by operators. 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes, reviewed documents were reviewed electronically and seem to be well organized and accessible. Info Only Info Only 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: Discussed with Program Manager and there are no issues or concerns. SICT has good detail with risk ranking of operators. 18 Discussion on State Program Performance Metrics found on Stakeholder Communication Info Only Info Only site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Discussed state performance metrics with Program Manager. Damages per 1,000 have negative up trend. Excavation damages increased from 2019 to 2020 and slight decrease in 2021. State is aware of the rise in damages per 1,000 tickets. Seems to be due to locator and excavators. Due to pandemic work force turn over seems there needs to be more/better training. State is working with operators to reduce numbers. 19 DUNS: 604570572 2021 Gas State Program Evaluation 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 Info Only Info Only South Dakota S. D. PUBLIC UTILITIES COMMISSION, Page: 10#
SD NG Program Evaluation, 2021, page 11a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Evaluator Notes: Item on agenda for Pipeline Safety Seminars. Also, information has been provided in emails to operators. 20 General Comments: Info Only = No Points Evaluator Notes: The SDPUC is mainly complying with Part D of the Evaluation. Info Only Info Only Total points scored for this section: 50 Total possible points for this section: 50 DUNS: 604570572 2021 Gas State Program Evaluation South Dakota S. D. PUBLIC UTILITIES COMMISSION, Page: 11#
SD NG Program Evaluation, 2021, 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 Evaluator Notes: MidAmerican Energy Company Mary Zanter-Lead Inspector Virtual Inspection April 12-13, 2022 Agustin Lopez-PHMSA Evaluator Info Only Info Only a. Ms. Mary Zanter conducted a records inspection of MidAmerican distribution system. b. Last unit inspection was on 5/18/2020. c. Yes, pipeline company representatives were present during the inspection. d. Effort was made to observe/evaluate different lead inspetor. 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist 2 2 used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Pipeline Safety Records Inspection Checklist was utilized by the inspector as a guide and to document results of the inspection. 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: Ms. Mary Zanter reviewed records of MidAmerican to determine compliance with the regulations. Records inspection are conducted yearly on each operator on a rotating basis every other year. The inspection was adequate in length to conduct a thorough inspection. Field inspection was not part of this type of inspection. 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 Evaluator Notes: Yes, Ms. Mary Zanter is very knowledgeable of the pipeline safety program and regulations. 2 2 5 Did the inspector conduct an exit interview, including identifying probable violations? (If 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: DUNS: 604570572 2021 Gas State Program Evaluation 1 1 South Dakota S. D. PUBLIC UTILITIES COMMISSION, Page: 12#
SD NG Program Evaluation, 2021, page 13Yes, an exit briefing was performed at the conclusion of the inspection. There were no probable violations identified during the inspection. Only pending item was a welder qualification record. 6 Was inspection performed in a safe, positive, and constructive manner ? 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: Yes, the inspection was conducted in a safe, positive and constructive manner. Info Only Info Only 7 General Comments: Info Only = No Points Evaluator Notes: regulations. Info Only Info Only Ms. Mary Zanter performed an excellent inspection and was very thorough and knowledgeable of the pipeline safety Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 604570572 2021 Gas State Program Evaluation South Dakota S. D. PUBLIC UTILITIES COMMISSION, Page: 13#
SD NG Program Evaluation, 2021, 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: Yes, the SDPUC reviews Annual Reports and incident reports for accuracy and analyze for trends. See "Annual Report Checklist -Distribution" and "Annual Report Checklist - Transmission". Also see "SD Pipeline Safety Program Performance Metrics 5-12-21" 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 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: Operators are submitting reports to Program Manager monthly with excavation damage information. (see "2021 Excavation Damage Detail"). Also have a quarterly meeting to discuss issues, progress, best practices, etc. 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation 4 4 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: SDPUC reviews annual reports Part D and analyze for trends or concerns. Operators are submitting reports to Program Manager monthly with excavation damage information. (see "2021 Excavation Damage Detail"). Also have a quarterly meeting to discuss issues, progress, best practices, etc. 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: 604570572 2021 Gas State Program Evaluation South Dakota S. D. PUBLIC UTILITIES COMMISSION, Page: 14#
SD NG Program Evaluation, 2021, 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: update 3-2022.xlsx" SDPUD collects data on damages per 1,000 locates and analyzes for issues and trends. See "Damages per 1000 locates 5 General Comments: Info Only = No Points Evaluator Notes: The SDPUC is mainly complying with Part E of the Evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 604570572 2021 Gas State Program Evaluation South Dakota S. D. PUBLIC UTILITIES COMMISSION, Page: 15#
SD NG Program Evaluation, 2021, 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: SDPUC is not an interstate agent. 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: SDPUC is not an interstate agent. 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: SDPUC is not an interstate agent. 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: SDPUC is not an interstate agent. 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: SDPUC is not an interstate agent. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: SDPUC is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 604570572 2021 Gas State Program Evaluation South Dakota S. D. PUBLIC UTILITIES 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.