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PHMSA va2010ngprogramevaluation
2010 VA NG Program Evaluation - va2010ngprogramevaluation (Virginia; Natural Gas State Program Evaluation)
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VA NG Program Evaluation, 2010, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2010 Natural Gas State Program Evaluation for VIRGINIA STATE CORPORATION COMMISSION Document Legend PART: O -- Representative Date and Title Information A -- General Program Qualifications B -- Inspections and Compliance - Procedures/Records/Performance C -- Interstate Agent States D -- Incident Investigations E -- Damage Prevention Initiatives F -- Field Inspection G -- PHMSA Initiatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 1#
VA NG Program Evaluation, 2010, page 22010 Natural Gas State Program Evaluation -- CY 2010 Natural Gas State Agency: Virginia Rating: Agency Status: 60105(a): Yes 60106(a): Yes Interstate Agent: No Date of Visit: 05/24/2011 - 05/26/2011 Agency Representative: Massoud Tahamtani, Director of Utility and Railroad Safety and Jim Hotinger PHMSA Representative: Jim Anderson Commission Chairman to whom follow up letter is to be sent: Name/Title: Judith Williams Jagdmann, Chairman Agency: Virginia State Corporation Commission Address: Tyler Building: P.O. Box 1197 City/State/Zip: Richmond, Virginia 23218 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 2010 (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 certification/agreement attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART F): 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 F, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A General Program Qualifications 25 25 B Inspections and Compliance - Procedures/Records/Performance 29.5 29.5 C Interstate Agent States 0 0 D Incident Investigations 5 5 E Damage Prevention Initiatives 9 9 F Field Inspection 12 12 G PHMSA Initiatives - Strategic Plan 9.5 9.5 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 102 102 State Rating................................................................................................................................................... 100.0 DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 2#
VA NG Program Evaluation, 2010, page 3PART A - General Program Qualifications Points(MAX) Score 1 Did the state submit complete and accurate information on the attachments to its most current 60105(a) Certification/60106 (a) Agreement? (NOTE: PHMSA Representative to verify certification/agreement attachments by reviewing appropriate state documentation. Score a deficiency in any one area as "needs improvement". Attachment numbers appear in parenthesis) Previous Question A.1, Items a-h worth 1 point each Yes = 8 No = 0 Needs Minor Improvement = 3-7 Needs Major Improvement = 2 a. State Jurisdiction and agent status over gas facilities (1) b. Total state inspection activity (2) c. Gas facilities subject to state safety jurisdiction (3) d. Gas pipeline incidents (4) e. State compliance actions (5) f. State record maintenance and reporting (6) g. State employees directly involved in the gas pipeline safety program (7) h. State compliance with Federal requirements (8) SLR Notes: Yes. All information submitted on the 60105 Certification/60106 Agreement was completed was correct. 8 8 2 Did the state have an adequate mechanism to receive operator reporting of incidents to ensure state compliance with 60105(a) Certification/60106(a) Agreement requirements (fatality, injury requiring hospitalization, property damage exceeding $50,000 - Mechanism should include receiving "after hours" reports)? (Chapter 6) Previous Question A.2 Yes = 1 No = 0 1 1 SLR Notes: to the "on call" inspector. Yes. When operators call the VA SCC to report an incident, they call a dedicated line and should the call be placed after hours the line is line is forwarded 3 Has the state held a pipeline safety TQ seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar or if state requested seminar, but T&Q could not provide, indicate date of state request for seminar. Seminars must be held at least once every 3 calendar years.) (Chapter 8.5) Previous Question A.4 Yes = 2 No = 0 SLR Notes: Yes. October 19-21, 2010 in Virginia Beach, VA. 2 2 4 Were pipeline safety program files well-organized and accessible?(NOTE: This also includes electronic files) (Chapter 5) Previous Question A.5 Yes = 1 No = 0 SLR Notes: Yes. All records and reports are kept in file cabinets and electronically. 1 1 5 Did state records and discussions with the state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? (Chapter 4.1, Chapter 8.1) Previous Question A.6 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: Yes. Both Massoud Tahamtani and Jim Hotinger have exensive knowledge in pipeline safety, safety regulations and the state's relationship with PHMSA. Both have served on many NAPSR/PHMSA committees. 6 Did the state respond in writing within 60 days to the requested items in the Chairman's letter following the Region's last program evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8 Yes = 1 No = 0 1 1 SLR Notes: August 12, 2010. Yes. The letter referencing the 2009 evaluation from Zach Barrett was sent on July, 23, 2010 and the response letter from the VA SCC chair was dated DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 3#
VA NG Program Evaluation, 2010, page 47 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the previous year? Did actions correct or address deficiencies from previous year's evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8/A.9 Yes = 1 No = 0 SLR Notes: No action was requested for the natural gas program evaluation. 1 NA Personnel and Qualifications 8 Has each inspector fulfilled the 3 year TQ training requirement? If No, has the state been granted a waiver regarding TQ courses by the Associate Administrator for Pipeline Safety? (NOTE: If the State has new inspectors who have not attended all TQ courses, but are in a program which will achieve the completion of all applicable courses within 3 years of taking first course (5 years to sucessfully complete), or if a waiver has been granted by the applicable Region Director for the state, please answer yes.) (Chapter 4.4) Previous Question A.10 Yes = 3 No = 0 SLR Notes: Yes. All inspectors have completed training or are on schedule to complete training in the time frame. 3 3 9 Brief Description of Non-TQ training Activities: Info Only = No Points For State Personnel: For Operators: For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: Info Only Info Only SLR Notes: 10 SLR Notes: Yes. Did the lead inspectors complete all required T&Q OQ courses and Computer Based Training (CBT) before conducting OQ Inspections? (Chapter 4.4.1) Previous Question A.12 Yes = 1 No = 0 1 1 11 Did the lead inspectors complete all required TQ Integrity Management (IMP) Courses/Seminars and CBT before conducting IMP Inspections? (Chapter 4.4.1) Previous Question A.13 Yes = 1 No = 0 SLR Notes: Yes. Jim Fisher and Brian Roberts have completed all training to be qualified to conduct integrity management inspections. 1 1 12 Was the ratio acceptable of Total inspection Person-days to Total Person-days charged to the program by state inspectors? (Region Director may modify points for just cause) (Chapter 4.3) Previous Question B.12 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 1762.04 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 7.70 = 1694.00 Ratio: A / B 1762.04 / 1694.00 = 1.04 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 SLR Notes: Yes. Ratio exceeds minimum needed for acceptable total inspection person days. 5 5 DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 4#
VA NG Program Evaluation, 2010, page 513 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Info Only Info Only Question B.13 Info Only = No Points SLR Notes: 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 25 Total possible points for this section: 25 DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 5#
VA NG Program Evaluation, 2010, page 6PART B - Inspections and Compliance - Procedures/Records/ Performance Points(MAX) Score Inspection Procedures 1 Does the State have a written inspection plan to complete the following? (all types of operators including LNG) (Chapter 5.1) Previous Question B.1 + Chapter 5 Changes + Incorporate LNG Yes = 6.5 No = 0 Needs Improvement = 50% Deduction a Standard Inspections (Including LNG) (Max points = 2) b IMP Inspections (Including DIMP) (Max points = .5) c OQ Inspections (Max points = .5) d Damage Prevention (Max points = .5) e On-Site Operator Training (Max points = .5) f Construction Inspections (Max points = .5) g Incident/Accident Investigations (Max points = 1) h Compliance Follow-up (Max points = 1) SLR Notes: 6.5 6.5 Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes. These items are included in the SCC Pipeline Safety Program procedures, last updated in May 2011. 2 Did the written Procedures for selecting operators adequately address key concerns? (Chapter 5.1) Previous 2 2 Question B.2, items a-d are worth .5 point each Yes = 2 No = 0 Needs Improvement = 50% Deduction a Length of time since last inspection Yes No Needs Improvement b History of Operator/unit and/or location (including leakage , incident and compliance history) Yes No Needs Improvement c Type of activity being undertaken by operator (construction etc) Yes No Needs Improvement d For large operators, rotation of locations inspected Yes No Needs Improvement SLR Notes: Yes. These are referenced in Section IV.I - Selecting Companies, of the VA SCC Pipeline Safety Program Procedures. Inspection Performance 3 Did the state inspect all types of operators and inspection units in accordance with time intervals established in its written procedures? (Chapter 5.1) Previous Question B.3 Yes = 2 No = 0 SLR Notes: Listed below are the time tables listed in the VA SCC Pipeline Safety Program Procedures. Inspection Intervals Records Facilities Gas 100% 10% LNG 100% 100% Master-Metered (gas) 20% 20% Propane-Air Facilities Once every 3 years Distribution Integrity Management Program Once every year Transmission Integrity Management Programs Once every 5 years Integrity Management Field Audits (pig digs, pig runs, etc.) As necessary 2 2 4 Did the state inspection form cover all applicable code requirements addressed on the Federal Inspection forms? (Chapter 5.1 (3)) Previous Question B.4 Yes = 1 No = 0 1 1 SLR Notes: Yes. Uses the federal form where available and uses state form for other types of inspections. 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 Yes = 1 No = 0 DUNS: 015946759 2010 Natural Gas State Program Evaluation 1 1 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 6#
VA NG Program Evaluation, 2010, page 7SLR Notes: Yes. Reviewed Federal Form 2 (Distribution System Inspection) for the City of Richmond. 6 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.6 Yes = .5 No = 0 SLR Notes: There were no Safety Related Condictions reported for 2010. .5 NA 7 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) Previous Question B.7 Yes = .5 No = 0 SLR Notes: Looked at every operator's procedures that had cast iron in 2010. Going to start using federal form with the NTSB questions added. .5 .5 8 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) Previous Question B.8 Yes = .5 No = 0 SLR Notes: Looked at every operator's procedures that had cast iron in 2010. Going to start using federal form with the NTSB questions added. .5 .5 9 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) Previous Question B.9 Yes = .5 No = 0 SLR Notes: Yes. All damages are reviewed by the Damage Prevention Section of the VA SCC. .5 .5 10 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? (NTSB) Previous Question B.10 Yes = 1 No = 0 SLR Notes: Yes. All damages are reviewed by the Damage Prevention Section of the VA SCC. 1 1 Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous Question B.14 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. Reviewed Columbia Gas of Virginia - Case # URS-2010-00053. 1 1 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a probable violation as specified in the "Guidelines for State Participating in the Pipeline Safety Program"? (Chapter 5.1) Previous Question D(1).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. Section V - PIPELINE ENFORCEMENT PROCEDURES of the VA SCC Pipeline Safety Program Procedures. 1 1 13 Does the state have written procedures to notify an operator when a noncompliance is identified as specified in the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(4)) Previous Question D (1).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. Section V - PIPELINE ENFORCEMENT PROCEDURES of the VA SCC Pipeline Safety Program Procedures. 1 1 DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 7#
VA NG Program Evaluation, 2010, page 814 Does the state have a written procedure for routinely reviewing the progress of compliance actions to prevent delays or breakdowns of the enforcement process, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(5)) Previous Question D(1).3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. Section V - PIPELINE ENFORCEMENT PROCEDURES of the VA SCC Pipeline Safety Program Procedures. 1 1 15 Has the State issued compliance actions for all probable violations discovered? (Note : PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation) Previous Question D(1).4 Yes = 1 No = 0 SLR Notes: Yes. This was in Columbia Gas of Virginia Case # URS-2010-00053. 1 1 16 Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that prompt corrective actions were taken by operators, within the time frames established by the procedures and compliance correspondence, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? Previous Question D(1).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. This was in Columbia Gas of Virginia Case # URS-2010-00053. 1 1 17 If compliance could not be established by other means, did state pipeline safety program staff request formal action, such as a "Show Cause Hearing" to correct pipeline safety violations? (check each states enforcement procedures) Previous Question D(1).6 No = 0 Yes = 1 1 1 SLR Notes: Yes. This is included in APPENDIX NO. 5 - PIPELINE SAFETY ENFORCEMENT PROCEDURES FOR JURISDICTIONAL OPERATORS VII. COMMISSION ACTION If an operator disputes the probable violation(s) in the NOPV, or fails to respond to the NOPV in accordance with the procedures outlined herein, the matter may be presented to the Commission for formal resolution. The Commission may: (a) issue a temporary injunction if immediate potential danger to public and property exists; and/or (b) issue a Rule to Show Cause and schedule a hearing during which the operator is required to show cause why it should not be enjoined and/or penalized on account of the alleged probable violations. 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question D(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. The VA SCC issued a fine and reveived a check from the operator. 1 1 19 Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question D(1).8 Yes = .5 No = 0 SLR Notes: Yes. Correspondence was sent to Dan Cote, General Manager, Columbia Gas of Virginia. .5 .5 20 Did the compliance proceedings give reasonable due process to all parties? (check each states enforcement procedures) Previous Question D(1).9 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes. APPENDIX NO. 5 - PIPELINE SAFETY ENFORCEMENT PROCEDURES FOR JURISDICTIONAL OPERATORS Section V. RESPONSE OPTIONS The operator may respond to the Division in one of the following ways: (1) agree to the settlement terms outlined in the draft settlement order thereby making this document their offer to settle the outstanding enforcement issue(s). When this option is chosen, the Division must be in receipt of the complete settlement package by the deadline (see section labeled VII for a description of "settlement package"); DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 8#
VA NG Program Evaluation, 2010, page 9(2) request an informal conference with the Commission Staff by the established deadline; or (3) submit a written reply disputing the probable violation(s) in the NOPV. The reply must include a complete statement of all relevant facts and a full description of the reasons why the operator disputes the violation(s) alleged in the NOPV. Compliance - 60106(a) States 21 Did the state use the current federal inspection form(s)? Previous Question D(2).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. 1 1 22 Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question D(2).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. All inspected in reference to PHMSA Region Inspection Plan. 1 1 23 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.) Previous Question D(2).3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. From the City of Richmond inspection. 1 1 24 SLR Notes: Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(2).4 Yes = 1 No = 0 Needs Improvement = .5 1 NA 25 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(2).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. The inspection was completed April, 18, 2010 and sent to PHMSA on June 23, 2010. 1 1 26 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Previous Question D(2).6 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. All documentation requested by the PHMSA region office was sent for Region follow-up. 1 1 27 SLR Notes: 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) Info Only = No Points Info Only Info Only 28 Part B: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only DUNS: 015946759 2010 Natural Gas State Program Evaluation Total points scored for this section: 29.5 Total possible points for this section: 29.5 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 9#
VA NG Program Evaluation, 2010, page 10PART C - Interstate Agent States Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Previous Question D(3).1 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Previous Question D(3).2 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Previous Question D(3).3 Yes = 1 No = 0 1 NA SLR Notes: 4 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.) Previous Question D(3).4 Yes = 1 No = 0 1 NA SLR Notes: 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(3).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(3).6 Yes = 1 No = 0 SLR Notes: 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Previous Question D(3).7 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 10#
VA NG Program Evaluation, 2010, page 11PART D - Incident Investigations Points(MAX) Score 1 Are state personnel following the procedures for Federal/State cooperation in case of an incident? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6.1) Previous Question E.1 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes. By following Section VI - INVESTIGATION OF PIPELINE INCIDENTS of the VA SCC Pipeline Safety Program Procedures. 2 Are state personnel familiar with the jurisdictional authority and Memorandum of Understanding between NTSB and PHMSA? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6 ? Appendix D) Previous Question E.2 Yes = .5 No = 0 .5 .5 SLR Notes: Yes. As stated in APPENDIX NO. 6 - INCIDENT INVESTIGATION PROCEDURES IV. On-Site Investigation After the determination is made that an on-site investigation is required, the inspector shall proceed to the incident site. Upon arrival at the site, the inspector should make contact with the appropriate operator officials, police, fire, and rescue personnel, if necessary. Federal agencies, such as the Pipeline and Hazardous Materials Safety Administration ("PHMSA"), the National Transportation Safety Board ("NTSB"), or the Bureau of Alcohol, Tobacco, Firearms, and Explosives, may be present and often take the lead in investigating incidents. The inspector shall coordinate his investigation activities with them pursuant to the applicable Memorandum of Understanding. 3 Did the state keep adequate records of incident notifications received? Previous Question E.3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. All incidents are logged into an electronic data base. 1 1 4 If an onsite investigation of an incident was not made, did the state obtain sufficient information by other means to determine the facts and support the decision not to go on-site? Previous Question E.4 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: All incidents are investigated. 1 NA 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? Previous Question E.5, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Observations and Document Review b. Contributing Factors c. Recommendations to prevent recurrences where appropriate 2 2 Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement SLR Notes: Yes. 6 Did the state initiate enforcement action for violations found during any incident investigation(s)? Previous Question E.6 Variation Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: None found. 1 NA 7 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 annual report data from operators concerning incidents/accidents and investigate discrepancies) (Chapter 6) Previous Question E.7/E.8 Yes = .5 No = 0 SLR Notes: Kept PHMSA Region office informed by emails. .5 0.5 DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 11#
VA NG Program Evaluation, 2010, page 128 Part D: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 5 Total possible points for this section: 5 DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 12#
VA NG Program Evaluation, 2010, page 13PART E - Damage Prevention Initiatives 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? Previous Question B.11 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: Yes. Virginia has reviewed all operators' drilling/boring procedures. Two companies were cited in the last year for not having drilling/boring covered in OQ. 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? New 2008 Yes = 2 No = 0 2 2 SLR Notes: Yes. Every time Virginia performs a construction inspection, a review the Miss Utility ticket and a check of the positive response system is conducted. In addition, the VA SCC investigates all underground gas pipeline damages from excavation. 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to 2 2 its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.7 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: Yes. This is reinforced at the Damage Prevention and Pipeline Safety Conferences. Virginia serves on the CGA Board. Virginia has adopted a number of the best practices as part of its rules. 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? New 2008 Yes = 1 No = 0 1 1 SLR Notes: Yes. This has been for years and copies of the charts developed were given to the State Evaluator showing Virginia's damage ratios. 5 Did the state review operators' records of accidents and failures due to excavation damage to ensure causes of failure are addressed to minimize the possibility of recurrence as required by 192.617? Yes = 2 No = 0 2 2 SLR Notes: Yes. All gas pipeline excavation damages are investigated. Companies are required to report all damages. Data is reviewed with operators to help improve their damage prevention programs. 6 Part E: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 13#
VA NG Program Evaluation, 2010, page 14PART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Virginia Natural Gas Name of State Inspector(s) Observed: Rick Vanderploeg and David Schmidt Location of Inspection: Newport News and Virginia Beach, Virginia Date of Inspection: 5/25 & 26/2011 Name of PHMSA Representative: Dale Bennett SLR Notes: I observed two state inspectors at two different locations on separate days. Drew Eaken was also present Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? New 2008 Yes = 1 No = 0 SLR Notes: Yes The operators were notified. 1 1 3 Did the inspector use an acceptable inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Previous Question F.2 Yes = 2 No = 0 SLR Notes: Yes Rick and David both used the inspection checklist. 2 2 4 Did the inspector thoroughly document results of the inspection? Previous Question F.3 Yes = 2 No = 0 SLR Notes: Rick & David documented all the results of the inspection on the checklist. 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.) New 2008 Yes = 1 No = 0 SLR Notes: Rick & David checked the equipment and viewed operator using the equipment. 1 1 6 What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) New 2008 Info Only = No Points SLR Notes: Regulator stations and cathocidic protection survey Info Only Info Only 7 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) New 2008, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities/Facilities d. Other (Please Comment) 2 2 SLR Notes: DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 14#
VA NG Program Evaluation, 2010, page 15Rick & David reviiewed all procedures in the field. 8 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Liaison will document reasons if unacceptable) Previous Question F.8 Yes = 2 No = 0 SLR Notes: Rick & David are very knowledge inspectors. 2 2 9 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) Previous Question F.10 Yes = 1 No = 0 SLR Notes: Rick & David went over the events while we were there with the operator. 1 1 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous Question F.11 Yes = 1 No = 0 SLR Notes: No probable violations were noted. 1 1 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector Info Only Info Only performed) Info Only = No Points SLR Notes: Rick-LOCATIONS INSPECTED (All locations in Newport News Va.); Menchville Regulator Station N21, Beechmont Regulator Station N13, Diligence Regulator Station N28, Wythe Creek Regulator Station N136, Voyager Regulator Station N137 David-Identify what was inspected : Line Section "SPH16WST" (An electrically isolated unit of cathodically protected steel piping.) Inspected to verify compliance with 49 CFR 192.469. Began electrical survey (C.P. Testing) at the operator's annual test station at the intersection of College Park Drive and Barnard Avenue in Virginia Beach. Tested at approximately 50' intervals from the test station along the line out to a total of 350'. Tested four randomly selected electrically connected and protected risers on this line section. Line Section "SPE12KST" (An electrically isolated unit of cathodically protected steel piping.) Inspected to verify compliance with 49 CFR 192.469. Began electrical survey (C.P. Testing) at the operator's annual test station at the intersection of Brookeville Street and Bayberry Avenue in Virginia Beach. Tested at approximately 50' intervals from the test station along the line out to a total of 300'. Tested eight randomly selected electrically connected and protected risers on this line section. Both inspectors performed professionally 12 SLR Notes: None Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only Info Only Info Only = No Points 13 Field Observation Areas Observed (check all that apply) 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 Info Only Info Only DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 15#
VA NG Program Evaluation, 2010, page 16m. 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 F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other SLR Notes: None 14 Part F: General Comments/Regional Observations Info Only = No Points SLR Notes: None DUNS: 015946759 2010 Natural Gas State Program Evaluation Info Only Info Only Total points scored for this section: 12 Total possible points for this section: 12 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 16#
VA NG Program Evaluation, 2010, page 17PART G - PHMSA Initiatives - Strategic Plan Points(MAX) Score Risk base Inspections - Targeting High Risk Areas 1 Does state have process to identify high risk inspection units? Yes = 1.5 No = 0 1.5 1.5 Risk Factors (criteria) to consider may include: Miles of HCA's, Geographic area, Population Density Length of time since last inspection History of Individual Operator units (leakage, incident and compliance history, etc.) Threats - (Excavation Damage, Corrosion, Natural Forces, Other Outside Forces, Material or Welds, Equipment, Operations, Other) SLR Notes: Yes. Virginia uses a number of tools to evaluate risk. First, 23 different factors are evaluated to determine certain risks within each company. Virginia also reviews IMP programs to include HCA's and pipe size and MAOP's along with information from in-line inspections to identify specific risks for the transmission pipelines. The excavation damage data for each company is also reviewed. Virginia also receives information on all leaks repaired by the companies. This data is assessed and reviewed to focus inspection efforts. 2 Are inspection units broken down appropriately? (see definitions in Guidelines) Yes = .5 No = 0 SLR Notes: Yes. .5 0.5 3 Consideration of operators DIMP Plan? (if available and pending rulemaking) Info Only = No Points Info Only Info Only SLR Notes: 4 Does state inspection process target high risk areas? Yes = .5 No = 0 SLR Notes: .5 0.5 Yes. Based upon the evaluation performed pursuant to the response to the 23 different factors are evaluated to determine certain risks within each company. Use of Data to Help Drive Program Priority and Inspections 5 Does state use data to analyze effectiveness of damage prevention efforts in the state? (DIRT or other data, etc) .5 0.5 Yes = .5 No = 0 SLR Notes: Reports of all excavation damages to any gas pipeline is required to be sent to the Virginia State Corporation Commission. These incidents are investigated to determine root cause. Data is reviewed and analyzed continuously to identify effectiveness and areas of improvement. 6 Has state reviewed data on Operator Annual reports for accuracy? Yes = .5 No = 0 SLR Notes: Yes. .5 0.5 7 Has state analyzed annual report data for trends and operator issues? Yes = .5 No = 0 SLR Notes: Yes. .5 0.5 8 Has state reviewed data on Incident/Accident reports for accuracy? Yes = .5 No = 0 SLR Notes: DUNS: 015946759 2010 Natural Gas State Program Evaluation .5 0.5 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 17#
VA NG Program Evaluation, 2010, page 18Yes. 9 Does state do evaluation of effectiveness of program based on data? (i.e. performance measures, trends, etc.) Yes = .5 No = 0 SLR Notes: Yes. The data is monitored closely to ensure inspections are prioritized. .5 0.5 10 Did the State input all operator qualification inspection results into web based database provided by PHMSA in a timely manner upon completion of OQ inspections? Previous Question B.15 Yes = .5 No = 0 SLR Notes: Yes. Checked OQ Data Base webpage. .5 0.5 11 Did the State submit their replies into the Integrity Management Database (IMDB) in response to the Operators notifications for their integrity management program? Previous Question B.16 Yes = .5 No = 0 SLR Notes: Yes, if necessary. None were received in 2010. .5 NA 12 Have the IMP Federal Protocol forms been uploaded to the IMDB? Previous Question B.17 Yes = .5 No = 0 SLR Notes: Yes. Checked the IMP Data Base Webpage. .5 0.5 13 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? Previous Question B.18 Yes = .5 No = 0 .5 0.5 SLR Notes: their progress and findings. Yes. Columbia Gas of Virginia had an issue with Polypipe and nonstandard wall thicknesses. They are addressing this and keeping Virginia informed as to 14 Has state confirmed transmission operators have submitted information into National Pipeline Mapping System (NPMS) database along with any changes made after original submission? Yes = .5 No = 0 SLR Notes: Yes. The last input was a result of Virginia Natural Gas's construction of the HRX line from Newport News into Norfolk, VA .5 0.5 Accident/Incident Investigation Learning and Sharing Lessons Learned 15 Has state shared lessons learned from incidents/accidents? (i.e. NAPSR meetings and communications) .5 Yes = .5 No = 0 SLR Notes: Yes. Virginia makes presentations at NAPSR and their Pipeline Safety Conference. 0.5 16 Does the State support data gathering efforts concerning accidents? (Frequency/Consequence/etc) .5 0.5 Yes = .5 No = 0 SLR Notes: Yes. As needed. 17 Does state have incident/accident criteria for conducting root cause analysis? Info Only = No Points SLR Notes: Yes. As part of VA SCC Pipeline Safety Program Procedures APPENDIX NO. 6 - INCIDENT INVESTIGATION PROCEDURES DUNS: 015946759 2010 Natural Gas State Program Evaluation Info Only Info Only Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 18#
VA NG Program Evaluation, 2010, page 19IV. On-Site Investigation The goals of an on-site investigation are: (l) Collect information to help determine the probable cause, contributing factors, and root cause(s). 18 SLR Notes: Does state conduct root cause analysis on incidents/accidents in state? Info Only = No Points Info Only Info Only 19 SLR Notes: Yes. Five inspectors in 2010. Has state participated on root cause analysis training? (can also be on wait list) Yes = .5 No = 0 .5 0.5 Transparency - Communication with Stakeholders 20 Other than pipeline safety seminar does State communicate with stakeholders? (Communicate program data, pub awareness, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: Participates with the Virginia Gas Operator's Association, periodic meetings with companies and contractor trainings. 21 Does state share enforcement data with public? (Website, newsletters, docket access, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: Website and inquiries from the public. 22 Part G: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 9.5 Total possible points for this section: 9.5 DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 19#
VA NG Program Evaluation, 2010, page 20PART H - Miscellaneous Points(MAX) Score 1 What were the major accomplishments for the year being evaluated? (Describe the accomplishments, NAPSR Activities and Participation, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: Training of contractors and emergency responders, DIMP plan review of Columbia Gas of Virginia as part of the Pilot Inspection with PHMSA, Intrastate Transmission IMP audits, and MAOP review. Mapping of excavation damages by zip code to better focus education and outreach. 2 What legislative or program initiatives are taking place/planned in the state, past, present, and future? (Describe initiatives (i.e. damage prevention, jurisdiction/authority, compliance/administrative, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: new locating tape (3M). Passage of new sewer marking legislation. Served on several NAPSR/PHMSA Committees. Future efforts include addressing abandoned lines and piloting 3 Any Risk Reduction Accomplishments/Projects? (i.e. Cast iron replacement projects,bare steel,third-party damage reductions, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: Ongoing cast iron, bare steel, and copper replacement projects, with several operators. As a result of a settlement with Virginia Natural Gas, approximately 100 miles of primarily bare steel, cast iron, and coated steel pipe is being replaced by VNG in 2009 and 2011. 4 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 1 1 SLR Notes: Yes. All surveys, such as the cast iron survey were completed and submitted as needed. 5 Sharing Best Practices with Other States - (General Program) Yes = .5 No = 0 .5 0.5 SLR Notes: Have assisted Indiana with damage prevention program. Share information at NAPSR Eastern Region. 6 Part H: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 20#
VA NG Program Evaluation, 2010, page 21PART I - Program Initiatives Points(MAX) Score Drug and Alcohol Testing (49 CFR Part 199) 1 Has the state verified that operators have drug and alcohol testing programs? Yes = 1 No = 0 SLR Notes: Yes. 1 1 2 Is the state verifying that operators are conducting the drug and alcohol tests required by the operators program (random, post-incident, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. Drug and alcohol information is obtained subsequent to Incidents and Form 13 ? Field Drug and Alcohol Inspections are performed. The Division has also verified the random drug testing rates for each company. 3 Is the state verifying that any positive tests are responded to in accordance with the operator's program? Yes = .5 No = 0 SLR Notes: Yes. When noted. .5 0.5 Qualification of Pipeline Personnel (49 CFR Part 192 Subpart N) 4 Has the state verified that operators have a written qualification program? Yes = 1 No = 0 SLR Notes: Done in 2005 and program is continuously monitored via field and headquarter inspections. 1 1 5 Has the state reviewed operator qualification programs for compliance with PHMSA rules and protocols? .5 0.5 Yes = .5 No = 0 SLR Notes: Yes, all programs have been done and continue to be done as inspections involving OQ tasks are performed. For example, in 2010, a pipeline contractor was found directionally drilling without being trained through his own or the operator's OQ program. Virginia inspectors have also identified OQ tasks that the operator had not identified or qualified employees to do. 6 Is the state verifying that persons who perform covered tasks for the operator are qualified in accordance with the operator's program? Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. Inspectors review OQ records when performing Protocol 9 inspections and whenever "probable violations" involving OQ tasks are found. 7 Is the state verifying that persons who perform covered task for the operator are requalified at the intervals specified in the operator's program? Yes = .5 No = 0 .5 0.5 SLR Notes: Yes. Inspectors review OQ records when performing Protocol 9 inspections and whenever "probable violations" involving OQ tasks are found. Gas Transmission Pipeline Integrity Management (49 CFR Part 192 Subpart O) 8 Has the state verified that all operators with transmission pipelines have either adopted an integrity management program (IMP), or have properly determined that one is not required? Yes = 1 No = 0 1 1 SLR Notes: Yes. Inspections were conducted in 2010. Both the HCA's and non-HCA's were verified as well. 9 Has the state verified that in determining whether a plan is required, the operator correctly calculated the potential impact radii and properly applied the definition of a high consequence area? Yes = .5 No = 0 SLR Notes: DUNS: 015946759 2010 Natural Gas State Program Evaluation .5 0.5 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 21#
VA NG Program Evaluation, 2010, page 22Yes. Virginia inspected each operator's HCA's via site visits and documented and reviewed the calculation of the impact radii. 10 Has the state reviewed operator IMPs for compliance with Subpart O? (In accordance with State Inspection .5 0.5 plan) Yes = .5 No = 0 SLR Notes: Yes. A complete review was performed in CY08 and will be again in CY11. Virginia inspectors monitor all IMP activities for operators every year. 11 Is the state monitoring operator progress on the inspections, tests and remedial actions required by the operator's IMP, including that they are being done in the manner and schedule called for in its IMP? Yes = .5 No = 0 .5 0.5 SLR Notes: phone of the activities. Yes. Virginia strives to inspect all of the inspections, tests, and remedial actions required by each operator's IMP program. They are notified via email or 12 Is the state verifying that operators are periodically examining their transmission line routes for the appearance of new HCAs? Yes = .5 No = 0 SLR Notes: Yes. Patrolling records for companies in Form 1 along with Virginia's own examination of the rights of way. .5 0.5 Public Awareness (49 CFR Section 192.616) 13 Has the state verified that each operator has developed a continuing public awareness program? (due date was 6/20/06 for most operators, 6/20/07 for certain very small operators,6/13/08 for master meters) Yes = .5 No = 0 .5 0.5 SLR Notes: An evaluation was conducted in 2006 and oversight has been maintained. Inspections are scheduled for CY11 to monitor the effectiveness of the programs. 14 Has the state reviewed the content of these programs for compliance with 192.616 (by participating in the Clearinghouse or by other means)? Yes = .5 No = 0 SLR Notes: All materials and information have been reviewed by Virginia. .5 0.5 15 Is the state verifying that operators are conducting the public awareness activities called for in its program? Yes = .5 No = 0 SLR Notes: Yes. Again, materials and information being disseminated by each of the operators is reviewed. .5 0.5 16 SLR Notes: Is the state verifying that operators have evaluated their Public Awareness programs for effectiveness as described in RP1162? Info Only = No Points Info Only Info Only 17 Part I: General Comments/Regional Observations Info Only = No Points SLR Notes: Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 015946759 2010 Natural Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 22#
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