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PHMSA va2015ngprogramevaluation
2015 VA NG Program Evaluation - va2015ngprogramevaluation (Virginia; Natural Gas State Program Evaluation)
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VA NG Program Evaluation, 2015, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2015 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 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 1#
VA NG Program Evaluation, 2015, page 22015 Gas State Program Evaluation -- CY 2015 Gas State Agency: Virginia Rating: Agency Status: 60105(a): Yes 60106(a): Yes Interstate Agent: No Date of Visit: 01/01/1900 - 01/01/1900 Agency Representative: Massoud Tahamtani, Director, Division of Utility and Railroad Safety PHMSA Representative: Jim Anderson, Transportation Specialist Commission Chairman to whom follow up letter is to be sent: Name/Title: James C. Dimitri, Chairman Agency: Virginia State Corporation Commission Address: PO 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 2015 (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 46 45 D Compliance Activities 15 15 E Incident Investigations 9 9 F Damage Prevention 8 8 G Field Inspections 11 11 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 5 5 TOTALS 117 116 State Rating................................................................................................................................................... 99.1 DUNS: 015946759 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 2#
VA NG Program Evaluation, 2015, 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: No issues found. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues found. 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: No issues found. 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: No issues found. Incident listed on 2015 Progress Report is the same incident listed in Pipeline Data Mart. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues found. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No issues found. All inspections and data are stored on VASCC PIPES program on Commission server. 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: No issues found. 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: VA SCC rules automatically adopt federal regulations. 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: 015946759 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 3#
VA NG Program Evaluation, 2015, page 4Evaluator Notes: No issues found. 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 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 4#
VA NG Program Evaluation, 2015, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that 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 = 2 No = 0 Needs Improvement = 1 Evaluator Notes: All listed in written procedures - Pre-Inspection Activities - Section V, B2, Preparation for Inspections. Inspection Activities - Section V, B3, General Inspection Guidelines. Post Inspection Activities - Section V, B4, General Post Inspection record Guidelines. 2 2 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that 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: All listed in written procedures - Pre-Inspection Activities - Section V, B2, Preparation for Inspections. Inspection Activities - Section X, Integrity Management Programs. Post Inspection Activities - Section V, B4, General Post Inspection record Guidelines. 1 1 3 OQ Inspection procedures should give guidance to state inspectors that 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: All listed in written procedures - Pre-Inspection Activities - Section V, B2, Preparation for Inspections. Inspection Activities - Section V, G. Post Inspection Activities - Section V, B4, General Post Inspection record Guidelines. 1 1 4 Damage Prevention Inspection procedures should give guidance to state inspectors that 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: All listed in written procedures - Pre-Inspection Activities - Section V, B2, Preparation for Inspections. Inspection Activities - Section IV. Post Inspection Activities - Section V, B4, General Post Inspection record Guidelines. 1 1 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: All listed in written procedures - Pre-Inspection Activities - Section V, B2, Preparation for Inspections. Inspection Activities - Section VII, Operator Training. Post Inspection Activities - Section V, B4, General Post Inspection record Guidelines. 1 1 DUNS: 015946759 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 5#
VA NG Program Evaluation, 2015, page 66 Construction Inspection procedures should give guidance to state inspectors that 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: All listed in written procedures - Pre-Inspection Activities - Section V, B2, Preparation for Inspections. Inspection Activities - Section F. Post Inspection Activities - Section V, B4, General Post Inspection record Guidelines. 1 1 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: No issues found. 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 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 6#
VA NG Program Evaluation, 2015, 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 5 5 A. Total Inspection Person Days (Attachment 2): 1833.12 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 7.63 = 1679.70 Ratio: A / B 1833.12 / 1679.70 = 1.09 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Modified numbers - Deleted DP days from total inspection days. Total inspection days were 733. 220*7.64 = 1681. 733/1681 = .436 ratio which exceeds the needed .38 ratio. No issues. 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 found. 3 Did state records and discussions with state pipeline safety program manager indicate 2 2 adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Massoud Tahamtani is very knowledgeable in the State/Federal partnership of pipeline safety program and its rule and regulations. 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: None requested. 2 NA 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 Yes = 2 No = 0 Evaluator Notes: Yes. In 2015. 2 2 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 5 4 DUNS: 015946759 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 7#
VA NG Program Evaluation, 2015, page 8Yes = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Guidelins state that master meter operators will be inspected 20% per year so that 100% of operators will be inspected over a 5 year period. Only 4 of 37 master meter operators were inspected in 2015. This was only 10.8% of the operators inspected. 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: Yes. Uses Federal form 2 for inspections. No issues in reviewing inspection reports. 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: Yes. This is one of the 5 questions that is attached to the Form 2 inspection report. 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: Yes. This is one of the 5 questions that is attached to the Form 2 inspection report. 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: Yes. This is one of the 5 questions that is attached to the Form 2 inspection report. 1 1 11 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: 1 1 One NRC Incident (VNG) in 2015. All Natural Gas damages are investigated and leak records are reviewed. 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 Evaluator Notes: Annual reports are entered into the PIPES database and semi-annually all leak data is reviewed for trends. 2 2 13 Did state input all applicable OQ, DIMP/IMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DUNS: 015946759 2015 Gas State Program Evaluation 2 2 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 8#
VA NG Program Evaluation, 2015, page 9Yes. TIMP and DIMP inspections are inspected per the Divisions 10 year inspection plan. 14 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: No changes from original submissions but are checked during Standard Inspections. 1 1 15 Is the state verifying operators are conducting drug and alcohol tests as required by 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: Yes. The MIS data sheets are in the Standard Inspection binders. 2 2 16 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: OQ is verified during each inspection for contractors and operator personnel see PHMSA form 15's. Also the Enhanced VGOA OQ Task Force, located in the Commonwealth of Virginia Operators OQ Program Binder. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: All Operator plans were reviewed and compliance action was taken in 2013. Also inspection protocol forms were uploaded to GT IMP Database December 2013. 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart P DIMP ? First round of program inspections should have been complete by December 2014 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: First round was completed for all Muni and LDC in 2014. 2 2 19 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. 49 CFR 192.616 (I13-16) PAPEI Effectiveness Inspections should be conducted every four years per RP1162 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Completed in 2013 and reevaluation due in 2017 per 10 year inspection plan. 2 2 20 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 015946759 2015 Gas State Program Evaluation 1 1 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 9#
VA NG Program Evaluation, 2015, page 10: State Website, Executive meetings, emails to operators, Pipeline Safety Conference Agenda, and VGOA. 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No SRC's in 2015. 1 NA 22 Did the State ask Operators to identify any plastic pipe and components that has shown a record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Information is contained in the Operator's DIMP plan. This information is also in the 2015 Risk Model. 1 1 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. 1 1 24 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 are no waivers in effect in 2015. 1 NA 25 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes. 1 1 26 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: Reviewed State Program Performance Metrics page with VA SCC staff. 27 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 45 Total possible points for this section: 46 DUNS: 015946759 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 10#
VA NG Program Evaluation, 2015, page 11PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement Evaluator Notes: In written procedures - Appendix 5 (flow chart) and also in 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. Were applicable civil penalties outlined in correspondence with operator(s) Yes No Needs Improvement Evaluator Notes: Reviewed all 4 cases and all were sent to company offices. 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. 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. Notice of possible fines are noted in compliance action letters. 2 2 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. $296,000 in fines were issued in 2015. 1 1 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 015946759 2015 Gas State Program Evaluation Info Only Info Only Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 11#
VA NG Program Evaluation, 2015, page 12Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 015946759 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 12#
VA NG Program Evaluation, 2015, page 13PART 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. In written procedures under - Incident Investigation Procedures. 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: Inspector on call rotation binder, PIPES incident report binder, and page 58 for MOU. Operators have 1-800 number to call. 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: VA SCC investigates all NRC calls. 1 1 4 Were all incidents investigated, thoroughly documented, and with conclusions and recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review 3 3 Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: One incident in 2015. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: None found. 1 NA 6 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: 1 1 DUNS: 015946759 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 13#
VA NG Program Evaluation, 2015, page 14Executive Meetings, Pipeline Safety Conference, Safety Stand down. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 015946759 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 14#
VA NG Program Evaluation, 2015, page 15PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. This is one of the 5 questions that is attached to the Form 2 inspection report. 2 2 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? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 PHMSA Form 2's and all damages are investigated. Every pipeline safety inspection Miss Utility Tickets are checked. 3 Did the state encourage and promote practices for reducing damages to all underground 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: Yes. VA SCC is a national leader in Underground Damage Prevention. 2 2 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? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 VA SCC keep this. SCC has lowered its Damages per 1000 tickets from 4.99 in 1996 to 1.35 in 2015 - 70% reduction rate. 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 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 15#
VA NG Program Evaluation, 2015, page 16PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: (1) Virginia Natural Gas (2) Columbia of Virginia (3) Virginia Natural Gas Name of State Inspector(s) Observed: (1) Bradley Chamberlain (2) Mike Smith (3) Scott Marshall Location of Inspection: (1) Chesapeake, VA (2) Sullolk, VA (3) Newport News, VA Date of Inspection: (1) July 28, 2016 (2) September 13, 2016 (3) September 14, 2016 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: (1) Yes, supervisor came out to be with VNG contractor - Curling Construction (2) VNG rep - Kevin Krawiec (3) Col of VA rep - Robert Sanderlyn 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 Evaluator Notes: (1) Inspectors took notes while onsite and transfers information to PIPES database on tablet at site. (2) Yes. (3) Yes. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: (1) Yes, No issues. (2) Yes, No issues. (3) Yes, No issues. 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: (1) Yes, No issues. (2) Yes, No issues. (3) Yes, No issues. 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 2 2 DUNS: 015946759 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 16#
VA NG Program Evaluation, 2015, page 17d. Other (please comment) Evaluator Notes: (1) Yes, No issues - New construction. (2) Yes, No issues - Exposed pipe inspection. (3) Yes, No issues - Overpressure pressure protection inspection. 7 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: (1) Yes, Bradley Chamberlain has completed all TQ Standard Inspection classes. (2) Yes, Mike Smith has completed all TQ Standard Inspection classes. (3) Yes, Scott Marshall has completed all TQ Standard Inspection classes. 2 2 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: (1) Yes, no issues. (2) Yes, no issues. (3) Yes, no issues. 1 1 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: (1) None found (2) None found (3) 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 Info Only Info Only DUNS: 015946759 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 17#
VA NG Program Evaluation, 2015, page 18t. 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 Evaluator Notes: DUNS: 015946759 2015 Gas State Program Evaluation Total points scored for this section: 11 Total possible points for this section: 11 Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 18#
VA NG Program Evaluation, 2015, page 19PART H - Interstate Agent 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: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 015946759 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 19#
VA NG Program Evaluation, 2015, page 20PART 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: Yes. 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: Eastern Region Inspection Plan and tracking spreadsheet binder sets inspection schedule. 1 1 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. One operator, City of Richmond, did not pressure test service line properly. 1 1 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: None in 2015. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Evaluator Notes: Yes = 1 No = 0 Needs Improvement = .5 Yes. Inspection conducted 4/14/2015 and sent to PHMSA on 6/4/2015. 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. it is in the COC PHMSA Enforcement packet. 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 2015 Gas State Program Evaluation Virginia VIRGINIA STATE CORPORATION COMMISSION, Page: 20#
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