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PHMSA va-2017-gas-program-evaluation
2017 VA NG Program Evaluation - va-2017-gas-program-evaluation (Virginia; Natural Gas State Program Evaluation)
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VA NG Program Evaluation, 2017, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2017 Gas State Program Evaluation for VIRGINIA STATE CORPORATION COMMISSION 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: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 1#
VA NG Program Evaluation, 2017, page 22017 Gas State Program Evaluation -- CY 2017 Gas State Agency: Virginia Rating: Agency Status: Date of Visit: 09/18/2018 - 09/20/2018 Agency Representative: Scott Marshall, Drew Akens, Jim Fisher PHMSA Representative: Jim Anderson Commission Chairman to whom follow up letter is to be sent: Name/Title: Mark C. Christie, Chairman Agency: Virginia State Corporation Commission Address: P.O. Box 1197 City/State/Zip: Richmond, Virginia 23218 60105(a): Yes 60106(a): Yes 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 2017 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 10 B Program Inspection Procedures 13 13 C Program Performance 47 47 D Compliance Activities 15 15 E Incident Investigations 10 10 F Damage Prevention 8 8 G Field Inspections 10 10 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 5 5 TOTALS 118 118 State Rating................................................................................................................................................... 100.0 DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 2#
VA NG Program Evaluation, 2017, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data - no issues. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data - no issues. 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data - no issues. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data - no issues. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data - number of noncompliances found did not include the number carried over. VA SCC considered the carry over as noncompliances found. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes - files kept electronically on the PIPES data system. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data - no issues. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Commission rules has an automatic adoption clause in the rules. 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 1 1 DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 3#
VA NG Program Evaluation, 2017, page 4Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed data - no issues. 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 4#
VA NG Program Evaluation, 2017, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 2 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: ? Pre-Inspection Activities ? ? Section V, B2, Preparation for Inspection Page 16 ? Inspection Activities- Section V, C, Types of Inspections, page 18-23, B3 pages 16 and 17 ? Post Inspection Activities ? Section V, B4, Inspection Records page 17, All types of inspections, and NOI/NOPV- Compliance page 49 (Appendix 6). 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: ? Pre-Inspection Activities ? Section V, B2, Preparation for Inspection ? Inspection Activities ? Section VIII, page 32 Integrity Management Programs. ? Post Inspection Activities - Section V, B4, Inspection Records page 17, All types of inspections, and NOI/NOPV- Compliance page 49 (Appendix 6). 3 OQ Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: ? Pre-Inspection Activities ? Section V, B2, Preparation for Inspection ? Inspection Activities ?Section V, G, pages 29-30. ? Post Inspection Activities - Section V, B4, Inspection Records page 17, All types of inspections, and NOI/NOPV- Compliance page 49 (Appendix 6). 4 Damage Prevention Inspection procedures should give guidance to state inspectors that 1 1 insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: ? Pre-Inspection Activities Section V, B2, Preparation for Inspection, and Section VI (Pre-MURBI) page 30 ? Inspection Activities ? Section IV, pages 30-31 ? Post Inspection Activities - Section V, B4, Inspection Records page 17, All types of inspections, and NOI/NOPV- Compliance page 49 (Appendix 6). 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: ? Section VII, pages 32 Operator Training. 1 1 DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 5#
VA NG Program Evaluation, 2017, page 66 Construction Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: ? Pre-Inspection Activities - Section V, B2, Preparation for Inspection, and Section V, F, page 25 ? Inspection Activities ? Section V, F, Pages 25-29 ? Post Inspection Activities - Section V, B4, Inspection Records page 17, All types of inspections, and NOI/NOPV- Compliance page 49 (Appendix 6). 7 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: ? Length of time since last inspection (Within five-year interval) - 10 year Inspection Plan, page 11 ? Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) ? Section V, pages 10-15. ? Type of activity being undertaken by operators (i.e. construction) ? LCP's, Facility Inspections, Location Sheets. ? Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Density, etc.) ? Inspection units binder ? 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) ? Section V, pages 10-15 and the Risk Model ? Are inspection units broken down appropriately? ? Inspection Unit Binder, reviewed annually 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 6#
VA NG Program Evaluation, 2017, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 1338.25 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 12.03 = 2645.59 Ratio: A / B 1338.25 / 2645.59 = 0.51 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: .51 ratio exceeds the needed .38 ratio. No issues. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: No issues. Reviewed staff training prior to evaluation on TQ SABA. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: No issues, Scott Marshall had just been promoted to program manager after being an inspector for 4 years. Prior to being an inspector Scott was involved in the VA SCC Damage Prevention Program. 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No response requested. 2 NA 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: Last conducted in October 2017. 1 1 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: DUNS: 015946759 2017 Gas State Program Evaluation 5 5 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 7#
VA NG Program Evaluation, 2017, page 8No issue. Reviewed Inspection Report Binders (Federal Inspection Forms), 10-Year Inspection Plan, and State Procedures. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Use Federal Inspection forms, Forms 1, 2, 13, 15, 23 etc. All portions completed. 2 2 8 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Uses PHMSA Form 2s and attached NTSB questions. 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 Yes = 1 No = 0 Evaluator Notes: Uses PHMSA Form 2s and attached NTSB questions. 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 Yes = 1 No = 0 Evaluator Notes: Uses PHMSA Form 2s and attached NTSB questions. 1 1 11 Did the state review operator records of previous accidents and failures including 1 1 reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: One NRC Incident; (WGL) in 2017, see 2017 Accident Report Binder. All Natural Gas damages are investigated by Damage Prevention and leak records are reviewed during required standard inspections. 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Located in the Natural Gas Annual Report Binder. Also, the Annual reports are entered into the PIPES database and semi- annually all leak data is reviewed for trends. Also in 2017, Staff began its liaison Accident Investigation Division ("AID") in regards to NRC incidents, Incident/Accident Report Submissions to PHMSA for accuracy and appropriate follow up between PHMSA, SCC and Operators. 13 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 015946759 2017 Gas State Program Evaluation 1 1 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 8#
VA NG Program Evaluation, 2017, page 9Staff reviews NPMS data of all other operators during Standard Inspections and review of Annual Reports for any mileage changes. In addition, Staff utilized NPMS data during Incident/Accident response and coordination with AID. During this year Staff has not noted any inconsistencies or major changes to NPMS since the addition of the Clinch River 5-mile transmission project for ANGD was entered in 2016. 14 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: MIS data sheets in the Standard Inspection binders. Some comprehensive Drug and Alcohol HQ inspections were performed 2017 per 10-year inspection plan and additional inspections are scheduled for 2018. 15 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: All Operator plans were reviewed and compliance action was taken in 2013. In addition, inspection protocol forms were uploaded to GT IMP Database December 2013. OQ HQ inspection were scheduled for CY18 per Division's 10-year Plan. Staff will schedule and conduct a PHMSA Form 14 headquarters inspection of all jurisdictional Operator OQ programs. Currently, Staff expects to complete these audits in CY18 and CY19. Additionally, Staff performs OQ certifications checks during field inspections and during Form 15 Protocol 9 inspections. See PHMSA Form 15 and OQ Binder. 16 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). (Are the State's largest operators programs being contacted or reviewed annually? Are replies to Operator IM notifications addressed? (formerly part of Question C-13)). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: All Operator plans were reviewed and compliance action was taken in 2013. In addition, inspection protocol forms were uploaded to GT IMP Database December 2013. (See 2017 TIMP inspections for WGL, CVA and RGC.) In addition, the Staff receives notifications of IM manners through its Large Construction Project Notices and operator SharePoint/Box/e-Rooms and/or TIMP and DIMP email notifications (beginning in 2018) for significant changes, associated work and digs. 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 2 This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Staff performed DIMP inspections for all municipal operators and LDCs in 2014. Master Meter and LPG DIMPS were inspected in 2016. Implementation inspections were scheduled per the Division's 10-year plan. 18 DUNS: 015946759 2017 Gas State Program Evaluation Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 192.616 2 2 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 9#
VA NG Program Evaluation, 2017, page 10Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: PAP inspection were performed in 2013 and reevaluation was performed in 2017 per 10 year inspection plan. 19 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: The State has the following mechanisms for communication- State Website, Executive meetings, emails to operators, Annual Pipeline Safety Conference Agenda, and VGOA. 20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) 1 1 Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There was only one SRC in Virginia during the evaluation period and it was on the HL Inspection Program. All other SRCs in Virginia were PHMSA jurisdictional. 21 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? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Information is contained in the Operator's DIMP plan. This information is also in the 2017 Risk Model. 1 1 22 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Survey Information request located in the NAPSR/PHMSA binder. 1 1 23 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: There were no waivers or special permits issued in 2017. The last waiver was issued 1998 for VNG. 1 1 24 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Former Program Manager attended the National NAPSR meeting in September 2017. 1 1 25 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: Division representatives reviewed our State Program Metrics found on the PRIMIS PHMSA/DOT website. Evaluator discussed Performance Metrics with program staff. DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 10#
VA NG Program Evaluation, 2017, page 1126 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: SICT data is entered prior to due date based on 10-year plan. 1 1 27 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 1 1 Evaluator Notes: None of the operators in the State have the means to execute flow reversals, only tariff gas transported exception of a few Gathering lines, and none of the Operators have been a converted service. 28 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 47 Total possible points for this section: 47 DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 11#
VA NG Program Evaluation, 2017, page 12PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: ? Procedures to notify an operator (company officer) when a noncompliance is identified -NOI/NOPV-Compliance page 49 (Appendix 6) ? Procedures to routinely review progress of compliance actions to prevent delays or breakdowns - NOI/NOPV- Compliance page 49 (Appendix 6) ? Procedures regarding closing outstanding probable violations - NOI/NOPV-Compliance page 49 (Appendix 6) 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: Reviewed Closed Cases binders to confirm. All were listed in Appendix 6 - Pipeline Enforcement Procedures for Jurisdictional Operators. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes. Each noncompliance letter has "Response Options" as stated in Appendix 6, SectionV. 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 2 2 DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 12#
VA NG Program Evaluation, 2017, page 136 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 1 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: VA SCC issued $618,100 in fines in 2017. 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 13#
VA NG Program Evaluation, 2017, page 14PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Listed in the State Procedures, Incident Investigation Procedures, Appendix 7. 2 2 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: ? Acknowledgement of MOU between NTSB and PHMSA (Appendix 7, IV) ? Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix 7, IV) Inspector on call rotation binder, PIPES incident report binder, and Section IV for MOU. 3 If onsite investigation was not made, did state obtain sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Attachment 2 and 3, pages 64 and 65. This includes the Required Information Incident Report. 1 1 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: No reportable incident in 2017. There was one fire first incident that was investigated. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: N/A - No jurisdictional incidents/accidents in CY17. 1 NA 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking 1 1 appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Staff coordinated with PHMSA AID and ER relative to reportable events and other significant events (sheens, fires, etc.) and also coordinated about finalization of reports. DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 14#
VA NG Program Evaluation, 2017, page 157 Does state share lessons learned from incidents/accidents? (sharing information, such as: 1 1 at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: Division Staff attend various meetings where lessons learned are shared, such as Executive Meetings, Pipeline Safety Conference, Operator and Contractor Safety Stand Downs. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 15#
VA NG Program Evaluation, 2017, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Uses PHMSA forms and the question is on the forms. 2 2 2 Did the state inspector verify pipeline operators are following their written procedures 2 2 pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The Division reviews each Operator's written procedures regarding damage prevention activities. See associated standard inspections. During each gas inspection, the VA811 ticket is checked and the operator is inspected for damage prevention compliance. 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: See PHMSA Form 2's for NTSB/PHMSA question set. In Virginia 100% of all gas damages are investigated by Damage Prevention Staff. During each field inspection conducted by pipeline safety Staff, VA811 Tickets are checked. Damage Prevention Staff also conduct risk based inspection audits of all VA811 tickets called in by excavators across the state. 4 Has the agency or another organization within the state collected data and evaluated 2 2 trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The Division collects and monitors the damage prevention ratios for each operator per 1,000 ticket and trends damages per 1,000 for the state overall. These trends are shared during the Damage Prevention Advisory Committee, Damage Prevention Conferences and Damage Prevention Outreach/Trainings. See 2016 Damages per 1000 tickets binder. 1.09 ratio of damages per 1000 locate request. 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 16#
VA NG Program Evaluation, 2017, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Washington Gas Light Name of State Inspector(s) Observed: Jimmy Maass Location of Inspection: Gainesville, VA Date of Inspection: September 20, 2018 Name of PHMSA Representative: Jim Anderson Evaluator Notes: Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 Evaluator Notes: Northern Pipeline contractor was on site 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) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes - computer generated inspection form in inspector vehicle. Inspector completes inspection form on site. 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 2 2 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.) Yes = 1 No = 0 Evaluator Notes: Yes. 1 1 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: Installation of PE main in new residential subdivision. 2 2 7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) 2 2 DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 17#
VA NG Program Evaluation, 2017, page 18Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: No company representative on site. No issuses found. 1 NA 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: None found. 1 NA 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance E. Vault Maintenance Info Only Info Only DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 18#
VA NG Program Evaluation, 2017, page 19F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 19#
VA NG Program Evaluation, 2017, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? 1 NA Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: N/A- Although the Division had a Natural Gas Interstate Agent Agreement for the inspection of the Atlantic Coast Pipeline construction and Mountain Valley Pipeline construction neither project started until CY2018. 2 Are results documented demonstrating inspection units were reviewed in accordance with 1 NA "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: N/A- Although the Division had a Natural Gas Interstate Agent Agreement for the inspection of the Atlantic Coast Pipeline construction and Mountain Valley Pipeline construction neither project started until CY2018. 3 Did the state submit documentation of the inspections within 60 days as stated in its latest 1 NA Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: N/A- Although the Division had a Natural Gas Interstate Agent Agreement for the inspection of the Atlantic Coast Pipeline construction and Mountain Valley Pipeline construction neither project started until CY2018. 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: 1 NA PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: N/A- Although the Division had a Natural Gas Interstate Agent Agreement for the inspection of the Atlantic Coast Pipeline construction and Mountain Valley Pipeline construction neither project started until CY2018. 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: N/A- Although the Division had a Natural Gas Interstate Agent Agreement for the inspection of the Atlantic Coast Pipeline construction and Mountain Valley Pipeline construction neither project started until CY2018. 6 Did the state give written notice to PHMSA within 60 days of all probable violations 1 NA found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: N/A- Although the Division had a Natural Gas Interstate Agent Agreement for the inspection of the Atlantic Coast Pipeline construction and Mountain Valley Pipeline construction neither project started until CY2018. 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: N/A- Although the Division had a Natural Gas Interstate Agent Agreement for the inspection of the Atlantic Coast Pipeline construction and Mountain Valley Pipeline construction neither project started until CY2018. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 20#
VA NG Program Evaluation, 2017, page 21Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 21#
VA NG Program Evaluation, 2017, page 22PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Uses Federal Inspection Forms 2, 13 etc. 1 1 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: State follows PHMSA Eastern Region Inspection Plan and tracking spreadsheet binder. 1 1 3 Were any probable violations identified by state referred to PHMSA for compliance? 1 1 (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Completed inspection reports and final report emails City of Richmond were sent to PHMSA Eastern Region. 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: N/A-None in 2017. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes. Yes = 1 No = 0 Needs Improvement = .5 1 1 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. 1 1 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 5 Total possible points for this section: 5 DUNS: 015946759 2017 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 22#
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