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PHMSA tx-2021-gas-program-evaluation
2021 TX NG Program Evaluation - tx-2021-gas-program-evaluation (Texas; Natural Gas State Program Evaluation)
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TX 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 RAILROAD COMMISSION OF TEXAS 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: 028619182 2021 Gas State Program Evaluation Texas RAILROAD COMMISSION OF TEXAS, Page: 1#
TX NG Program Evaluation, 2021, page 22021 Gas State Program Evaluation -- CY 2021 Gas State Agency: Texas Rating: Agency Status: Date of Visit: 05/09/2022 - 06/17/2022 Agency Representative: Stephanie Weidman = Program Manager, PHMSA Representative: Michael Thompson, David Lykken, Clint Stephens Commission Chairman to whom follow up letter is to be sent: Name/Title: Wayne Christian, Chairman Agency: Rail Road Commission of Texas Address: 1701 N. Congress City/State/Zip: Austin, Texas 78701 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 42 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 92 State Rating................................................................................................................................................... 92.0 DUNS: 028619182 2021 Gas State Program Evaluation Texas RAILROAD COMMISSION OF TEXAS, Page: 2#
TX 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 Info Only Info Only 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. Number of operators does not correspond to Annual Reports submitted to PHMSA. Need to verify operators submit annual reports and assure PHMSA operators with annual reports are in the RRC operator list. Explain difference. B. Reviewed TX RRC person days data provided in DATA Base and data seems to be accurate. C. Number of operators does not correspond to Annual Reports submitted to PHMSA. Need to verify operators submit annual reports and assure PHMSA operators with annual reports are in the RRC operator list. D. Verified reportable incidents in PDM with Attachment 4. There were no issues identified. E. Verified compliance actions submitted on Attachment 5. F. TX RRC keeps all records electronically in their PES and now PIPES database. G. Reviewed qualifications and verified with Blackboard and the RRC training records. No issues identified. H. TX RRC has adopted all the regulations within the 2 year requirement. I. TX RRC listed their planned and past performance activities and damage prevention initiatives. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 028619182 2021 Gas State Program Evaluation Texas RAILROAD COMMISSION OF TEXAS, Page: 3#
TX 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: Yes, Section 3 addresses pre and post inspection activities for each type of inspection. A. Yes, Section 3 has comprehensive inspection procedures which give guidance to inspectors on conducting comprehensive procedures. B. Yes Section 7.1 and 7.2 has IMP and DIMP inspection procedures which give guidance to inspectors on how to conduct inspections. The procedures include pre and post inspection activities. c Yes Section 7.3 has OQ inspection procedures which give guidance to inspectors on how to conduct inspections. The procedures include pre and post inspection activities. D. Yes Section 7.7 has Damage Prevention inspection procedures which give guidance to inspectors on how to conduct inspections. The procedures include pre and post inspection activities. E. Section 6 has On-Site Training procedures which includes documentation of training on PES. F. Section 7.6 which gives guidance to inspectors on how to conduct construction inspections. G. Section 3.3.12 mentions LNG facility inspections. 2 Do written procedures address inspection priorities of each operator, and if necessary 4 4 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? Evaluator Notes: Yes, Section 3 has a risk based inspection priority. PES generates an inspection schedule each calendar year based on risk factors for each system. The risk factors include; previous violations, customer count, leaks, type of pipe, inspection frequency, incidents, HCAs, class location and non evaluated systems. Inspection units are broken down into systems which vary in size. 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 3.6 and Section 5 have procedures to notify operator of alleged violations. In 3.2.2 it states that contact must be an DUNS: 028619182 2021 Gas State Program Evaluation Texas RAILROAD COMMISSION OF TEXAS, Page: 4#
TX NG Program Evaluation, 2021, page 5officer of the company. In 3.4 it states the RRC sends a executive closing summary to the operator when they close out an inspection. Section 5 is for follow ups. 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 Evaluator Notes: A. Section 8.2 has On-Call procedures that include after hours response. RRC inspectors rotate on call duties. During operating hours, the RRC Accident Coordinator receives calls and routes them to the on-call inspector. B. Section 9 shows the requirements for an on-site investigation. The procedure states that all incidents that meet their requirements must have an on-site investigation on both regulated intrastate and non-regulated intrastate pipelines. 5 General Comments: Info Only = No Points Evaluator Notes: None Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 028619182 2021 Gas State Program Evaluation Texas RAILROAD COMMISSION OF TEXAS, Page: 5#
TX NG Program Evaluation, 2021, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines 5 5 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) Evaluator Notes: A. Yes lead inspectors are qualified to conduct inspections. The Program Manager has procedure to allow inspectors be qualified to conduct comprehensive inspections without completing the required T&Q courses. B. Yes, verified all lead inspectors are qualified to lead IMP inspections. C. Yes, there are RRC inspectors who have completed the Root Cause training course. D. RRC inspectors attend outside training. E. Verified during records review that all inspectors are qualified before leading any type of inspection. 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 5 5 Evaluator Notes: Yes, the Program Manager has been with the RRC for awhile and has completed T&Q courses. She demonstrates knowledge of the PHMSA program and regulations. 3 General Comments: Info Only = No Points Evaluator Notes: None Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 028619182 2021 Gas State Program Evaluation Texas RAILROAD COMMISSION OF TEXAS, Page: 6#
TX 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 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) 5 0 Evaluator Notes: A review of the inspections conducted on the "Random Operators List" for CY2021 showed that not all types of inspections had been conducted at the intervals listed in the TXRRC procedures. Although many operators had Comprehensive inspections conducted in the prescribed intervals, many specialized inspections had only recent inspection dates with few prior dates found. There were no records of the following inspections being performed; Tristate ETX , LLC (PAPEI, TIMP), Gulf Coast Energy Inc. (PAPEI, D&A, OQ, O&M, TIMP), Harvest Midstream Co. (PAPEI, D&A), White Marlin Operating Co., LLC (D&A, OQ), Fortune Resources (TIMP), Magnum Operating, LLC (PAPEI, D&A, OQ, TIMP), and Enterprise Products (PAPEI, O&M). Hilton Place Apartments did not meet the 5 year inspection interval (8/29/14 & 9/3/21). The TXRRC continues to make progress in this area with their inspection planning. 5 points deducted 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, the TXRRC utilizes a PHMSA equivalent form for all of their inspections that cover all the applicable code sections. Reviewed inspection reports to verify that inspectors are completing all applicable portions of the inspection. There were no issues identified. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This 2 1 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: The RRC is not reviewing all operator OQ Programs to verify plans are meeting the regulations. There was no record of the following operators having their OQ programs reviewed; Gulf Coast Energy Inc, White Marlin Operating Company, LLC, and Magnum Operating, LLC. 1 point deducted DUNS: 028619182 2021 Gas State Program Evaluation Texas RAILROAD COMMISSION OF TEXAS, Page: 7#
TX NG Program Evaluation, 2021, page 84 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? c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? 2 1 Evaluator Notes: There were no records of a TIMP inspection being performed on the following operators: Tristate ETX, LLC, Gulf Coast Energy Inc., Fortune Resources LLC, Magnum Operating, LLC, and Enterprise Products Operating LLC. The RRC has added questions to their standard inspection form and cover all large operators each year. 5 Did the state review the following (these items are NTSB recommendations to PHMSA that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. Operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance); c. Operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21; d. Operator records of previous accidents and failures including reported third- party damage and leak response to ensure appropriate operator response as required by 192.617; e. Directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? Evaluator Notes: Yes, the TX RRC form has incorporated the NTSB recommendations and ADB questions. 2 2 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the TX RRC form has incorporated the NTSB recommendations and ADB questions. 1 1 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations 10 9 DUNS: 028619182 2021 Gas State Program Evaluation Texas RAILROAD COMMISSION OF TEXAS, Page: 8#
TX 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: C. Master meter inspections identified multiple PV's with no resolution to date. Abbey Road Apartments (Still open >1 year), Havenhurst Apartments, Herwick House Apts., La Patrice Townhomes and Lupine Terrace Apts.. Operator failure to respond-multiple delinquent compliance notices sent (Aquave Courtyard Apartments, Arcos Apartments, Broadway Oaks Apartments, Cedar Grove Manufacturing, Crestview Apartments, Doniphan Apartments). Several MM's have history of non- compliance going back several years (Alamo Apartments, Altitude Apartments, Aquave Courtyard Apartments, Balboa Place Mobile Home Park, Broadway Oaks Apartments, Cedar Grove Manufacturing, Center Point Mobile Home Park, Crestview Apartments, Duniphan Apartments. A 'bug' in the TXRRC new PIPES database resulted in uncorrected violations not being tracked correctly in program's 'delinquent list" resulting in the operator not being notified. To fix this issue, the TXRRC ran a report and found a total of 50 Gas & HL inspection packages and updated the status so they are now tracked. A delinquent letter was sent to each operator to start the process. 1 point deducted 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly 10 10 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? Evaluator Notes: a. Yes, The program utilizes a 24-hour notification system which notifies the on-call engineer. b. Yes, the program maintains records of operator incident notifications and copies of NRC reports. c. On site investigations were conducted on 12 of 15 federally reportable gas incidents. Sufficient information was collected for the 3 non-onsite investigations to determine facts. d, e, & f. Yes, all elements were included in investigation reports. The program utilizes PHMSA Form 11 and TXRRC Incident Investigation Reports to document on-site observations, contributing factors and recommendations to prevent reoccurrences. g. Yes, the program initiated compliance actions where probable violations were identified and routinely reviews progress of PV's. Two incidents investigated resulted in penalties being assessed in the amounts of $10,000 and $5,000. h. Yes, the program maintains good communications with AID i. Yes, during NAPSR regional and national meetings DUNS: 028619182 2021 Gas State Program Evaluation Texas RAILROAD COMMISSION OF TEXAS, Page: 9#
TX NG Program Evaluation, 2021, page 109 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: Yes, Letter out to state on 12/9/2021, state response 1/11/2022 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: Yes, the Texas RRC has conducted safety seminars on an annual basis. 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: Yes, the inspection form addresses the NPMS database changes question. Info Only Info Only 12 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, website has pipeline safety section which provides information to stakeholders. 1 1 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Reviewed SRCR in WMS and the TX RRC is responding to notifications. All SRCR were reviewed by the TX RRC. 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, the RRC responded to surveys by NAPSR and PHMSA 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: Reviewed all waivers issued by the state. The TX RRC is working with PHMSA to close those that are no longer active or necessary. 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Info Only Info Only Yes, the TX RRC is moving their records over to a new data base, "PIPES". It seems to be very functional and effective. 17 DUNS: 028619182 2021 Gas State Program Evaluation Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? 3 3 Texas RAILROAD COMMISSION OF TEXAS, Page: 10#
TX NG Program Evaluation, 2021, page 11Yes = 3 No = 0 Needs Improvement = 1-2 Evaluator Notes: TX Gas = SICT ? 5029 2019 Progress Report ? 8392 3363 more than SICT The TX RRC continues to work on this. 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 metrics with the program manager. PHMSA site not updated to 2021 stats at this time. Talked about importance of reviewing them. 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Evaluator Notes: Discussed at seminar with operators. Info Only Info Only 20 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 42 Total possible points for this section: 50 DUNS: 028619182 2021 Gas State Program Evaluation Texas RAILROAD COMMISSION OF TEXAS, Page: 11#
TX 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 Info Only Info Only Evaluator Notes: 1. ATMOS, Johnathan Sauceda Lead Inspector, DIMP Inspection, 2. TXRRC conducted a Standard Inspection and Construction Inspection in CenterPoint Energy's Kilgore Region 3 Unit. The Standard Inspection covered the Kilgore Spinks Chapman Rural Extension System. The Construction Inspection covered a project installing distribution main to transfer farm taps off of Gulf South Pipeline's Index 8 pipeline in the Longview, TX area. The last Standard Inspection of this unit was August 17, 2020. CenterPoint was represented by Bubba Verana, District Operations Manager. Justin Markham was the lead inspector for the Standard Inspection and Ross Richardson was the lead inspector for the Construction Inspection. Justin has three years experience and Ross has four and a half years experience. 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: 1. Yes, the inspection was conducted using an appropriate form and a checklist. 2. Yes, appropriate forms were used for both the Standard Inspection and Construction Inspection. No issues. 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: 1. Procedures, records and other operator systems were reviewed and inspected. The inspection was for 2 weeks and was an appropriate length for the size of the system. 2. Procedures and records were reviewed for both the Standard Inspection and the Construction Inspection. The Standard Inspection included field activities of pressure control inspection and testing, cathodic protection test point readings and observing conditions of above ground facilities and marker/signs. The inspections were an appropriate length for the facilities involved. No issues. 4 From your observation did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: 1. Yes, all inspectors performing the inspection had adequate knowledge of the pipeline safety program and regulations. 2. The inspectors have completed all of the required courses and Training and Qualifications. They were versed in pipeline safety regulations. No issues. DUNS: 028619182 2021 Gas State Program Evaluation Texas RAILROAD COMMISSION OF TEXAS, Page: 12#
TX NG Program Evaluation, 2021, page 135 Did the inspector conduct an exit interview, including identifying probable violations? (If 1 1 inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1. Yes, a summary of each days work was conducted with the operator at the end of the day, as well as an exit interview was conducted at the end of the two weeks identifying all concerns and any PVs. 2. Yes, the inspectors provided an exit briefing at the endo the day on June 29, 2022. A summary was given for the Standard Inspection and Construction Inspection. There were no probable violations found during the two inspections. 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 Info Only Info Only Evaluator Notes: 1. The inspection was performed in a safe, positive and constructive manner. 2. Yes, the proper PPE was worn in the field. The inspectors scheduled field activities for the morning hours and in office procedures and records review in the afternoon. This scheduling avoided the heat in the afternoon for field activities. No issues. 7 General Comments: Info Only = No Points Evaluator Notes: RRC of Texas. Info Only Info Only 1.The inspection was a deep dive look into the ATMOS DIMP Program for a response to an NTSB recommendation to the 2. There were no issues that resulted in the loss of points for these two inspections. Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 028619182 2021 Gas State Program Evaluation Texas RAILROAD COMMISSION OF TEXAS, Page: 13#
TX 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: The TXRRC reviews operator's annual and incident reports to complete the yearly risk assessment for their work plan. They also track top ten root causes, types of equipment, work performed and excavators in order to thoroughly and completed analyze the entire data for trends and issues. 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: The TXRRC reviews operator's annual and incident reports to complete the yearly risk assessment for their work plan. They also track top ten root causes, types of equipment, work performed and excavators in order to thoroughly and completed analyze the entire data for trends and issues. 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: The TXRRC has a dedicated damage prevention department who analyzes data and provides support to pipeline safety related to excavation damages. Discussed with the TXRRC the need to review and analyze Part D data provided in Annual Reports. 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: 028619182 2021 Gas State Program Evaluation Texas RAILROAD COMMISSION OF TEXAS, Page: 14#
TX 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: Yes their damage prevention personnel and 811 collect damage data which includes damages per 1,000 locates, top ten root causes, types of equipment, work performed and excavators in order to thoroughly and completed analyze the entire data for trends and issues. The damage prevention personnel analyze data and encourage the utilization of best practices. 5 General Comments: Info Only = No Points Evaluator Notes: NONE Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 028619182 2021 Gas State Program Evaluation Texas RAILROAD COMMISSION OF TEXAS, Page: 15#
TX 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: The RRC of Texas 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: The RRC of Texas 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: The RRC of Texas 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: The RRC of Texas 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: The RRC of Texas is NOT an interstate agent Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: The RRC of Texas is NOT an interstate agent Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 028619182 2021 Gas State Program Evaluation Texas RAILROAD COMMISSION OF TEXAS, Page: 16#
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