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2011 TN NG Program Evaluation - tn2011ngprogramevaluation (Tennessee; Natural Gas State Program Evaluation)
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TN NG Program Evaluation, 2011, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2011 Natural Gas State Program Evaluation for Tennessee Regulatory Authority 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: 878586999 2011 Natural Gas State Program Evaluation Tennessee Tennessee Regulatory Authority, Page: 1#
TN NG Program Evaluation, 2011, page 22011 Natural Gas State Program Evaluation -- CY 2011 Natural Gas State Agency: Tennessee Rating: Agency Status: Date of Visit: 03/19/2012 - 03/23/2012 Agency Representative: Larry Borum, Director Gas Pipeline Safety Division PHMSA Representative: Don Martin Commission Chairman to whom follow up letter is to be sent: Name/Title: Kenneth C. Hill, Chairman Agency: Tennessee Regulatory Authority Address: 460 James Robertson Parkway City/State/Zip: Nashville, Tennessee 37243 60105(a): Yes 60106(a): No Interstate Agent: Yes 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 2011 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 15 15 C Program Performance 44 43 D Compliance Activities 14 14 E Incident Investigations 4 4 F Damage Prevention 8 8 G Field Inspections 11 11 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 106 105 State Rating................................................................................................................................................... 99.1 DUNS: 878586999 2011 Natural Gas State Program Evaluation Tennessee Tennessee Regulatory Authority, Page: 2#
TN NG Program Evaluation, 2011, 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 (A1a) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed the work papers used to tally operator and inspection unit information. Reviewed the inspection log and confirmed the number of operators and inspection units inspected. No issues found. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Reviewed the inspection information work papers and confirmed the number of inspection person days entered into Attachment 2. No issues found. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Reviewed the operator and inspection unit work papers and confirmed that Attachment 3 is accurate. No issues found. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 (A1d) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no incidents during 2011 which was confirmed from a review of PHMSA's ODES database. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed the inspection files and work papers. The compliance entries were accurate. No issues found. 1 1 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The inspection files were organized by operator. Five years of inspection report documents were in each operator file. All other files supporting the program were present and organized. 7 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 (A1g) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The listing of employees was correct and inspector categories were appropriate based upon training records, education and experience. Training entries were populated by TnQ's database. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 (A1h) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: The TRA has automatic adoption authority except for civil penalties. Civil penalty information for pipeline safety regulations were confirmed from a review of State Program Division's Rules and Regulations document. The civil penalty information for One Call violations stated Taking Steps to Adopt. Tennessee has adopted civil penalties for One Call violations but they DUNS: 878586999 2011 Natural Gas State Program Evaluation Tennessee Tennessee Regulatory Authority, Page: 3#
TN NG Program Evaluation, 2011, page 4are not the same level of federal penalties. Each violation can result in civil penalties up to $2500. The entry in Attachment 8 Part 198 h. should have stated Adopted but at different level than federal penalties. 9 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 (H1-3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The TRA has automatic adoption authority except for civil penalties. Civil penalty information for pipeline safety regulations were confirmed from a review of State Program Division's Rules and Regulations document. The civil penalty information for One Call violations stated Taking Steps to Adopt. Tennessee has adopted civil penalties for One Call violations but they are not the same level of federal penalties. Each violation can result in civil penalties up to $2500. The entry in Attachment 8 Part 198 h. should have stated Adopted but at different level than federal penalties. 10 General Comments: Info Only = No Points Evaluator Notes: No issues found in Part A. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 878586999 2011 Natural Gas State Program Evaluation Tennessee Tennessee Regulatory Authority, Page: 4#
TN NG Program Evaluation, 2011, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, they are covered. 2 2 2 IMP Inspections (including DIMP) (B1b) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, they are covered. 3 OQ Inspections (B1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, they are covered. 1 1 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, they are covered. 5 On-Site Operator Training (B1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, they are covered. 1 1 6 Construction Inspections (B1f) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, they are covered. 1 1 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, they are covered. DUNS: 878586999 2011 Natural Gas State Program Evaluation 8 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? (B2a-d, G1,2,4) Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Tennessee Tennessee Regulatory Authority, Page: 5#
TN NG Program Evaluation, 2011, page 6Evaluator Notes: risk. The TRA considers all of the items listed above. The TRA has a risk analysis process to schedule inspections based upon 9 General Comments: Info Only = No Points Evaluator Notes: No issues found. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 878586999 2011 Natural Gas State Program Evaluation Tennessee Tennessee Regulatory Authority, Page: 6#
TN NG Program Evaluation, 2011, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 (A12) Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 465.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 4.29 = 944.17 Ratio: A / B 465.00 / 944.17 = 0.49 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Yes. The calculated ratio was 465 inspection person days divided by (4.29X220) or .493. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines for requirements) Chapter 4.4 (A8-A11, G19) Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement Evaluator Notes: Yes. All training requirements as of 12/31/2011 were met. 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 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Larry Borum exhibited a good understanding of the pipeline safety program and regulations. 2 2 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 (A6-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Needs improvement. The TRA's response time was 185 days. 2 1 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) Yes = 2 No = 0 Evaluator Notes: Last seminar was conducted in 2010. 2 2 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 (B3) Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Yes. Each operator was inspected. 5 5 DUNS: 878586999 2011 Natural Gas State Program Evaluation Tennessee Tennessee Regulatory Authority, Page: 7#
TN NG Program Evaluation, 2011, page 87 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 (B4-5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The TRA uses federal forms for Standard, OQ, IMP, DIMP and Public Awareness. The TRA does not use federal form for construction. 8 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 (B7) Yes = 1 No = 0 Evaluator Notes: The TRA uses the federal form which covers this issue. 1 1 9 Did the state review operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 (B8) Yes = 1 No = 0 Evaluator Notes: The TRA uses the federal form which covers this issue. 1 1 10 Did the state review operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 (B9) Yes = 1 No = 0 Evaluator Notes: The TRA uses the federal form which covers this issue. 1 1 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 (B10,E5) Yes = 1 No = 0 Evaluator Notes: The TRA uses the federal form which covers this issue. 1 1 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Data Initiative (G6-9,G16) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The annual report data is input into the risk management analysis tool. 2 2 13 Did state input all applicable OQ, IMP inspection results into federal database in a timely 2 2 manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 (G10-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Upon a review of the OQ and IMP databases the TRA has entered the results of its inspection results in a timely manner. Responses to operator notifications appeared to be answered in the IMP database. 14 DUNS: 878586999 2011 Natural Gas State Program Evaluation Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? (G14) 1 1 Tennessee Tennessee Regulatory Authority, Page: 8#
TN NG Program Evaluation, 2011, page 9Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The TRA reviewed the NPMS information for operators in Tennessee during 2010 and sent notifications to operators that had not submitted information. The TRA uses the federal form which covers this issue. 15 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 (I1-3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The TRA continues to conduct Drug and Alcohol Plan inspections. The TRA also inspector test records during standard inspections. 16 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N (I4-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The TRA reviews OQ Plans changes. During standard inspections OQ records are reviewed and field observations of covered task being performed are conducted. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart 0 (I8-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Initial inspections of all transmission operator IMP plans have been completed. The TRA now inspects IMP records to determine if operators are implementing their plans in compliance with the regulations. 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart P Info Only = No Points Evaluator Notes: Info Only Info Only The TRA commenced DIMP inspections during the latter part of 2011 after the proper training was completed. 19 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. 49 CFR 192.616 (I13-16) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The TRA has inspected all operators' Public Awareness programs through the clearinghouse effort. The TRA has commenced the review of operator's effectiveness evaluations. 20 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). (G20-21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Pipeline Safety has page on TRA's website. The TRA mails a newsletter to all operators and is available to public on the website. Website has link to Tennessee 811 website. DUNS: 878586999 2011 Natural Gas State Program Evaluation Tennessee Tennessee Regulatory Authority, Page: 9#
TN NG Program Evaluation, 2011, page 1021 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 (B6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no SRC reports filed by operators during 2011. 1 1 22 Did the State ask Operators to identify any plastic pipe and components that has shown a record of defects/leaks and what those operators are doing to mitigate the safety concerns? (G13) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. The TRA provided written notification to operators on this safety issue. 1 1 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? (H4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No instances were identified where the TRA did not respond. 1 1 24 General Comments: Info Only = No Points Evaluator Notes: Question C.4 - Needs improvement. The TRA's response time was 185 days. Info Only Info Only Total points scored for this section: 43 Total possible points for this section: 44 DUNS: 878586999 2011 Natural Gas State Program Evaluation Tennessee Tennessee Regulatory Authority, Page: 10#
TN NG Program Evaluation, 2011, page 11PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 (B12-14, B16, B1h) Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement Evaluator Notes: The procedures are contained in the Rules of the Tennessee Regulatory Authority, Section 1220-4-5-.47 - Enforcement Procedures Governing Gas Pipeline Safety. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 (B11,B18,B19) Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement Evaluator Notes: Upon a review of randomly selected inspection report files, all compliance notifications were sent to the appropriate level of the organizations. 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: results. Upon a review of randomly selected 2011 inspection report files compliance notifications were sent for all inspections that 4 Did compliance actions give reasonable due process to all parties? Including "show 2 2 cause" hearing if necessary. (B17, B20) Yes = 2 No = 0 Evaluator Notes: Yes. The TRA Rules provide for opportunity for response and proposal of alternatives, informal conference and to represent themselves in hearings before the directors. 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) (B27) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Mr. Borum is familiar with the process with imposing civil penalties because a civil penalty notice was issued in November, 2011. The TRA proposed a civil penalty of $250,000. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety Info Only Info Only violations? (new question) Info Only = No Points Evaluator Notes: In November, 2011, the TRA issued a civil penalty of $250,000 to an operator that failed to comply with 192.613. 7 General Comments: Info Only = No Points Evaluator Notes: The TRA has generally complied with the requirements of Part D. Info Only Info Only DUNS: 878586999 2011 Natural Gas State Program Evaluation Total points scored for this section: 14 Tennessee Tennessee Regulatory Authority, Page: 11#
TN NG Program Evaluation, 2011, page 12Total possible points for this section: 14 DUNS: 878586999 2011 Natural Gas State Program Evaluation Tennessee Tennessee Regulatory Authority, Page: 12#
TN NG Program Evaluation, 2011, page 13PART E - Incident Investigations Points(MAX) Score 1 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 (A2,D1-3) Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: Yes. The TRA has a mechanism to receive operator's notice of incident during and after work hours. Mr. Borum was aware of the MOU between the NTSB and PHMSA. He is also knowledgeable about the cooperation between PHMSA and TRA in the event of an incident. 2 If onsite investigation was not made, did state obtain sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 (D4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no incidents during 2011. 1 1 3 Were all incidents investigated, thoroughly documented, and with conclusions and 3 NA recommendations? (D5) Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: There were no incidents during 2011. 4 Did the state initiate compliance action for violations found during any incident/accident investigation? (D6) Yes = 1 No = 0 Evaluator Notes: There were no incidents during 2011. 1 1 5 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 (D7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no incidents during 2011. 1 NA 6 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) (G15) Yes = 1 No = 0 Evaluator Notes: There were no incidents during 2011. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 878586999 2011 Natural Gas State Program Evaluation Info Only Info Only Tennessee Tennessee Regulatory Authority, Page: 13#
TN NG Program Evaluation, 2011, page 14There were no incidents during 2011. Total points scored for this section: 4 Total possible points for this section: 4 DUNS: 878586999 2011 Natural Gas State Program Evaluation Tennessee Tennessee Regulatory Authority, Page: 14#
TN NG Program Evaluation, 2011, page 15PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed 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? NTSB (E1) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The TRA uses the federal distribution inspection form. This item is covered on the form. 2 2 2 Did the state inspector check to assure the pipeline operator is following its written 2 2 procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? (E2) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Upon a review of randomly selected files of inspections conducted in 2011, 192.614 portion of the federal inspection form was completed. This portion of the federal inspection form covers this requirement. 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) (E3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: During standard inspections while covering 192.614 operators are encoouraged to adopt best practices in their damage prevention programs. 4 Has the agency or another organization within the state collected data and evaluated 2 2 trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) (E4,G5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Tennessee 811 has provided this information to the TRA. The TRA reviews the information for trends. The TRA will use the information now required on the annual reports. 5 General Comments: Info Only = No Points Evaluator Notes: The TRA has generally complied with the requirements in Part F. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 878586999 2011 Natural Gas State Program Evaluation Tennessee Tennessee Regulatory Authority, Page: 15#
TN NG Program Evaluation, 2011, page 16PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: Cookeville Gas Department Name of State Inspector(s) Observed: Eric Cherry Location of Inspection: Cookeville Gas Department's Operation Center Date of Inspection: March 22, 2012 Name of PHMSA Representative: Don Martin Evaluator Notes: Eric Cherry of the TRA conducted an inspection of the Cookeville Gas Department's Distribution Integrity Management Program. Jeff Mills, Administrative & Compliance Superintendent, represented the operator. The operator's DIMP was developed from the SHRIMP software developed by the American Public Gas Association. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? (F2) Yes = 1 No = 0 Evaluator Notes: Yes. The operator was notified one week prior to the inspection. 1 1 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) (F3) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Mr. Cherry used the federal Distribution Integrity Management Program inspection form revised 9/23/2011. 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. All appropriate portions of the form were completed on the electronic version of the form as the inspection progressed through the questions on the form. 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) (F5) Yes = 1 No = 0 Evaluator Notes: This was a DIMP Plan inspection. There were no inspection activities conducted in the field. 1 NA 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) (F7) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: This inspection covered the operator's DIMP Plan. There were no records or field testing performed 2 2 DUNS: 878586999 2011 Natural Gas State Program Evaluation Tennessee Tennessee Regulatory Authority, Page: 16#
TN NG Program Evaluation, 2011, page 177 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) (F8) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes. Mr. Cherry has ten years of experience with the TRA. He exhibited excellent knowledge of the regulations. 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) (F9) Yes = 1 No = 0 Evaluator Notes: Yes, the operator representative was provided with a summary of the results of the inspection at the end. Mr. Cherry did an excellent job of summarizing the results. 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) (F10) Yes = 1 No = 0 Evaluator Notes: No probable violations were found during the inspection; however, the operator was advised to amendments that should be developed and included in its DIMP program. 10 General Comments: What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping Info Only Info Only DUNS: 878586999 2011 Natural Gas State Program Evaluation Tennessee Tennessee Regulatory Authority, Page: 17#
TN NG Program Evaluation, 2011, page 18D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Not applicable. This was a DIMP program inspection. DUNS: 878586999 2011 Natural Gas State Program Evaluation Total points scored for this section: 11 Total possible points for this section: 11 Tennessee Tennessee Regulatory Authority, Page: 18#
TN NG Program Evaluation, 2011, page 19PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (C1) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The TRA is not an interstate agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? (C2) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The TRA is not an interstate agent. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? (C3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The TRA is not an interstate agent. 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) (C4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The TRA is not an interstate agent. 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? (C5) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The TRA is not an interstate agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? (C6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The TRA is not an interstate agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? (C7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The TRA is not an interstate agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: The TRA is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 878586999 2011 Natural Gas State Program Evaluation Tennessee Tennessee Regulatory Authority, Page: 19#
TN NG Program Evaluation, 2011, page 20PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (B21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The TRA does not have a 60106 Agreement. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? (B22) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The TRA does not have a 60106 Agreement. 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) (B23) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The TRA does not have a 60106 Agreement. 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? (B24) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The TRA does not have a 60106 Agreement. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? (B25) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The TRA does not have a 60106 Agreement. 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? (B26) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The TRA does not have a 60106 Agreement. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: The TRA does not have a 60106 Agreement. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 878586999 2011 Natural Gas State Program Evaluation Tennessee Tennessee Regulatory Authority, Page: 20#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.