RegulusPipeline researchPHMSA wv-2018-hazardous-liquid-program-evaluation
WV HL Program Evaluation, 2018, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2018 Hazardous Liquid State Program Evaluation for PUBLIC SERVICE COMMISSION OF WEST VIRGINIA 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 -- Accident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (if applicable) I -- 60106 Agreement State (if applicable) DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 1#
WV HL Program Evaluation, 2018, page 22018 Hazardous Liquid State Program Evaluation -- CY 2018 Hazardous Liquid State Agency: West Virginia Rating: Agency Status: Date of Visit: 10/21/2019 - 10/25/2019 Agency Representative: Mary S. Friend, Director PHMSA Representative: Agustin Lopez, State Evaluator Commission Chairman to whom follow up letter is to be sent: Name/Title: Charlotte R. Lane, Chair Agency: Public Service Commission of West Virginia Address: 201 Brooks St City/State/Zip: Charleston, WV 25301 60105(a): Yes 60106(a): No Interstate Agent: No 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 2018 (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. 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 43 43 D Compliance Activities 15 15 E Accident Investigations 11 11 F Damage Prevention 8 8 G Field Inspections 11 11 H Interstate Agent State (if applicable) 0 0 I 60106 Agreement State (if applicable) 0 0 TOTALS 111 111 State Rating................................................................................................................................................... 100.0 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 2#
WV HL Program Evaluation, 2018, 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 1 1 Evaluator Notes: Verified Attachment 1 with operator list with PDM, annual reports and inspection data. The numbers seem to be accurate. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Verified Attachment 2 data with WV PCS time sheet and inspection days data sheet. The numbers seem to be accurate on Attachment 2. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Verified operator list with PDM annual reports to assure numbers are correct. Attachment 3 seems to be accurate. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes there was only one reportable incident in 2018 which was investigated and listed on Attachment 4. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Verified compliance actions with inspection files and Attachment 5 compliance actions seem to be correct. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, keep all records electronically. Assign a Case Tracking Number to each inspection. This is a new process which was implemented in 2019. 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, verified training in T&Q Blackboard to assure qualifications were correct. 1 1 8 Verification of Part 195,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Verified that all rules and amendments have been adopted. 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 1 1 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 3#
WV HL Program Evaluation, 2018, page 4Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the WVPSC described their past accomplishments and planned performance with detail on Attachment 10. 10 General Comments: Info Only = No Points Evaluator Notes: The WVPSC is mainly complying with Part A of the Evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 4#
WV HL Program Evaluation, 2018, 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: Section A 6.2 addresses pre inspection activities. Section B. 2 has standard inspection procedures that outline how to conduct standard inspections. 2 IMP 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: Section 2.3(b) of Manual has IMP procedures. The procedures have enough detail to give enough guidance to state inspectors on how to conduct IMP inspections. 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: Section 2.2(e) has OQ inspection procedures and give guidance to state inspectors. 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: Section 2.1(l) has Damage Prevention/one-call procedures that give guidance to state inspectors. 1 1 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Section 3.2 of has procedures which outline Operator Training. 1 1 6 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. 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Section 2.2 (b) of procedures outlines in detail construction inspection procedures. The procedures give guidance to state inspectors on how to conduct construction inspections. Pre and post inspection procedures are outlined in the procedures. 7 Does inspection plan address inspection priorities of each operator, and if necessary each unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 6 6 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 5#
WV HL Program Evaluation, 2018, page 6a. 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 area, 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: Section B page 12 of Manual has procedures which account for the above criteria when scheduling and prioritizing inspections. The WV PSC developed a multiyear inspection plan that takes into account: -length of last inspection -Operator history -Annual reporting data; type of pipe, leaks, etch -type of activity undertaken by operator -HCA and population 8 General Comments: Info Only = No Points Evaluator Notes: The WVPSC is mainly complying with the requirements of Part B of the Evaluation. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 6#
WV HL Program Evaluation, 2018, 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): 32.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 0.30 = 66.18 Ratio: A / B 32.00 / 66.18 = 0.48 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Yes, the WVPSC met their required inspection person-days to total person days ratio. Verified inspection time and days with their data and time sheet tracking. 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 IMP Training before conducting inspection as lead Yes No Needs Improvement c. Root Cause Training by at least one inspector/prgram 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: There are no Breakout tanks in W. Virginia so the inspectors have not taken the TQ course so it shows them as not qualified as LIMP inspectors in TQ Blackboard. The inspectors have taken all other required courses. a. Yes, lead OQ inspectors have required training to lead OQ inspections. b. Yes all DIMP/IMP leads have required courses. c. Four inspectors have taken the Root Cause course. d. Appalachian underground corrosion short course was taken by an inspector. e. Yes verified that each lead is qualified to lead each type of inspection. 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: Yes, Mary Friend has over 25 years of pipeline safety experience and has been program manager for over 5 years. 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: Yes, the Chairman responded within the 60 day requirement. 2 2 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: Had two seminars in April 10 and 12, 2018, one on each part of the state, north and south. 1 1 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 7#
WV HL Program Evaluation, 2018, page 86 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 5 5 Evaluator Notes: Reviewed several inspection to verify that all inspection types are being inspected within their inspection cycle per their procedures. They track the inspection in their Multi year inspection plan. 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: 2 2 Yes, use IA for all inspections except construction, Drug and Alcohol and Type B Gathering line inspections. 8 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 195.402(c)(5)? Yes = 1 No = 0 Evaluator Notes: Accident investigation and response procedures are reviewed during O&M inspections. 1 1 9 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for 2 2 accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Review annual reports and incident/accident for accuracy and analyze for risks. There is a risk analysis performed by Jim Searls. 10 Has state confirmed intrastate operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, question is in IA and is asked during appropriate inspections. 1 1 11 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: Yes, reviewed inspection reports to assure Drug and Alcohol inspections are being conducted by the WVPSC in accordance with their procedures. 12 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 195 Part G Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, reviewed inspection reports to assure OQ Plan inspection are being conducted by the WVPSC in accordance with their time intervals. OQ Plan are inspected every 5 years per their procedures. DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 8#
WV HL Program Evaluation, 2018, page 913 Is state verifying operator's hazardous liquid integrity management (L IMP) Programs are 2 2 up to date? This should include a previous review of LIMP 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-10)). 49 CFR 195.452 Appendix C Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, IMP inspections are being performed in accordance with their procedures. Reviewed inspection reports to assure IMP inspections are being performed. 14 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 195.440 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the WVPSC conducts PAPEI inspections to assure operators are in compliance. 2 2 15 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: WVPSC emails operators with issues or to share information. Have links on website to pipeline safety information. Have online portal for operators to submit information to the WVPSC. 16 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: There was one SRCR in PDM and the PSCWV followed up on the report. Blue Racer Midstream reported anomalies which caused a pressure reduction. The PSC had follow up reports in their Case Tracking Program. 17 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, Mary Friend responds to surveys from NAPSR and PHMSA. 1 1 18 If the State has issued any waivers/special permits for any operator, has the state verified 1 1 conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: There was one waiver issued in 2016 to Union Carbide which was not objected by PHMSA. There are no stipulations that the operator has to conduct. 19 Did the state attend the NAPSR National Meeting in CY being evaluated? Needs Improvement = .5 No = 0 Yes = 1 Evaluator Notes: Yes, Mary Friend attended the NAPSR National in Santa Fe, NM. 1 1 20 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation Discussion on State Program Performance Metrics found on Stakeholder Communication site ? http://primis.phmsa.dot.gov/comm/states.htm 2 2 West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 9#
WV HL Program Evaluation, 2018, page 10Needs Improvement = 1 No = 0 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: Discussed performance metrics with PSC and the trending of each metric. There seems to be a positive trend on the damages per 1,000 tickets which is due to education and public awareness of underground facilities. The leaks on distribution systems seem to be steady. 21 Discussion with State on accuracy of inspection day information submitted into State 1 1 Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: Discussed the SICT and there does not seem to be any issues in the number entered. The WVPSC does not see a problem in meeting the required days. 22 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: WV in the recent years. The inspectors verify if any flow reversals have been or will be performed. There are no flow reversals that have occurred in 23 General Comments: Info Only = No Points Evaluator Notes: The WVPSC is mainly complying with Part C of the Evaluation. Info Only Info Only Total points scored for this section: 43 Total possible points for this section: 43 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 10#
WV HL Program Evaluation, 2018, 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 c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: Section C of the Gas Pipeline Safety Division Inspector Duties and Responsibilities manual include procedures for notifying an operator and how to issue and track compliance actions. a. yes the procedures manual references that a notification will be sent to a company official. b. Section C has steps to routinely review the progress of compliance actions to avoid breakdowns. c. Section C has procedures on how to close open cases. 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? (Incident Investigations do not need to meet 30/90 day requirement) Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board director 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: a.Yes, reviewed compliance letters to assure letters are sent to company officials. b. Yes, probable violations are documented c. Yes, probable violations are resolved thru compliance actions. d. Yes, WVPSC reviews cases to assure the progress and no breakdowns. e. Have procedure( Section C. 1.2) but the PSC needs to be consistent in how a 30 day exit interview will be conducted and documented. f. The procedures do not mention the 90 day preliminary findings notification requirement to the operator. There were some instances which the notification exceeded 90 days. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the state issued compliance actions for all probable violations discovered. 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: 2 2 Yes there is due process on every compliance action. The operator can contest compliance actions and have a hearing. 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) 2 2 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 11#
WV HL Program Evaluation, 2018, page 12Yes = 2 No = 0 Evaluator Notes: Yes, the Program Manager is aware of the civil penalties. Civil penalties were issued in 2018 and years in the past. 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, have issued enforcement findings in the last several years. 1 1 7 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: Only issue: D.2- need to improve on documenting 30 day exit interview and amend procedures to include the 90 day requirement for sending preliminary compliance notice to operators. Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 12#
WV HL Program Evaluation, 2018, page 13PART E - Accident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ 2 2 accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Section D of Inspector Duties and Responsibilities Manual addresses accident/incident investigation procedures. There is an inspector on call 24 hrs a day every on a monthly rotation. There is an emergency number that is assigned to each inspector who is on call. 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 accidents, 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: Yes, the PSC WV has an inspector on call on a monthly rotation who is on call 24 hrs a day. The emergency number is assigned/forwarded to the on call inspector's cell phone. After gathering enough information the inspector uses guidelines to weather contact Director and to decide to go on site. 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: 1 1 There was one accident which was investigated by the WVPSC with help from PHMSA due to personnel shortage. 4 Were all accidents 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 where appropriate Yes No Needs Improvement Evaluator Notes: Yes, PHMSA helped with the investigation. Documentation was available which included contributing factors. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: There were no compliance actions issued due to an accident investigation. 1 1 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator accident 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: The PSC assists the AID whenever they ask for assistance or requests updates. 1 1 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 13#
WV HL Program Evaluation, 2018, page 147 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: Yes, the PSC shares lessons learned during their state of the state address at the NAPSR Regional Meeting. 1 1 8 General Comments: Info Only = No Points Evaluator Notes: The WVPSC is mainly complying with Part E of the Evaluation. Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 14#
WV HL Program Evaluation, 2018, page 15PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, an email was sent to operators to respond to the question. Inspectors also review during construction inspections which is included in the construction inspection form. 2 Did the state inspector verify pipeline operators are following their 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: Yes, review during their inspection and construction inspections. 2 2 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, during seminars and during inspections. 2 2 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 PSC gathers information from Performance metric data and distribution annual reports. Analyze for trends and for areas of concern. 5 General Comments: Info Only = No Points Evaluator Notes: The PSC of WV is mainly complying with Part F of the Evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 15#
WV HL Program Evaluation, 2018, page 16PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: Williams Field Services Name of State Inspector(s) Observed: Girija Bajpayee, Engineer; Mary Friend, Program Manager Location of Inspection: Pittsburgh, PA Date of Inspection: September 18-19, 2019 Name of PHMSA Representative: Agustin Lopez, PHMSA State Programs Evaluator Notes: Evaluated Mr. Girija(Gee) Bajpayee and Ms. Mary Friend while conducting an OQ inspection of Williams Field Services. Mr. Girija lead the inspection on September 18 and Ms. Friend was the lead on September 19. 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: Yes, the operator was notified in advance to have any representative present. 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: Yes, the inspectors used IA to document and use as a guide during the inspection. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the inspectors documented hthe inspection results in IA. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps,valve keys, half cells, etc) Yes = 1 No = 0 Evaluator Notes: There was not a field inspection conducted during the OQ Plan inspection. 1 NA 2 2 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: The inspectors reviewed the OQ Plan procedures and records to verify that technicians who perform covered tasks are qualified. DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 16#
WV HL Program Evaluation, 2018, page 177 Did the inspector have adequate knowledge of the pipeline safety program and 2 2 regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, all three inspectors demonstrated knowledge of the pipeline safety program and regulations. All three have extensive experience with government or private industry. 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: Yes, the inspectors concluded the inspection with an exit interview of all the findings. 1 1 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Yes, there were several issued identified during the inspection that was brought to the operators attention during the exit interview. 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 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation Info Only Info Only West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 17#
WV HL Program Evaluation, 2018, page 18D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Mr. David Hancock, Girija S. Baypayee and Ms. Mary S. Friend conducted an OQ Plan inspection of Williams Midstream. They reviewed the OQ Plan and records. They performed and excellent job. Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 18#
WV HL Program Evaluation, 2018, 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: The WVPSC is not an Interstate Agent. 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: The WVPSC is not an Interstate Agent. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The WVPSC is not an Interstate Agent. 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The WVPSC is not an Interstate Agent. 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The WVPSC is not an Interstate Agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The WVPSC is not an Interstate Agent. 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: The WVPSC is not an Interstate Agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: The WVPSC is not an Interstate Agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 19#
WV HL Program Evaluation, 2018, 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: The WVPSC does not have a 60106 Agreement. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The WVPSC does not have a 60106 Agreement. 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The WVPSC does not have a 60106 Agreement. 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The WVPSC does not have a 60106 Agreement. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The WVPSC does not have a 60106 Agreement. 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The WVPSC does not have a 60106 Agreement. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: The WVPSC does not have a 60106 Agreement. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 134236632 2018 Hazardous Liquid State Program Evaluation West Virginia PUBLIC SERVICE COMMISSION OF WEST VIRGINIA, Page: 20#
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