2019 Program Evaluation.pdf

PIPELINE SAFETY NATURAL GAS STATE PROGRAM EVALUATION – CY2018
CONDUCTED CY2019

A – PROGRESS REPORT AND PROGRAM DOCUMENTATION REVIEW 10
B – PROGRAM INSPECTION PROCEDURES 13
C – PROGRAM PERFORMANCE 49
D – COMPLIANCE ACTIVITIES 15
E – INCIDENT INVESTIGATIONS 11
F – DAMAGE PREVENTION 8
G – FIELD INSPECTIONS 12
H – INTERSTATE AGENT STATE (if applicable) 7
I - 60106 AGREEMENT STATE (if applicable) 6
131

PIPELINE SAFETY NATURAL GAS STATE PROGRAM EVALUATION – CY2018
A – PROGRESS REPORT (CERTIFICATION) AND PROGRAM DOCUMENTATION REVIEW
THIS SECTION ANALYZES ACCURACY AND COMPLETENESS OF ANNUAL PROGRESS REPORT (CERTIFICATION) SCORE
1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data – Progress Report
Attachment 1
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
2 Review of Inspection Days for accuracy – Progress Report Attachment 2
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
3 Accuracy verification of Operators and Operators Inspection Units in State – Progress Report
Attachment 3
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
4 Were all federally reportable incident reports listed and information correct? – Progress Report
Attachment 4
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
5 Accuracy verification of Compliance Activities – Progress Report Attachment 5
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6
(Yes= 2 points, No= 0 Points, NI=1 point)
Comments:

2
7 Was employee listing and completed training accurate and complete? – Progress Report
Attachment 7
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
8 Verification of Part 192,193,198,199 Rules and Amendments – Progress Report Attachment 8
(Yes= 1 point, No= 0 Points)
Comments:

1
9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail –
Progress Report Attachment 10
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
10 General Comments:

10

B – PROGRAM INSPECTION PROCEDURES
Does State Inspection Plan include procedures that address the following elements? (Plan should
include expected time intervals between inspections, if necessary. See Guidelines Section 5.1)
1 Standard Inspections
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 points, No= 0 Points, NI=1 point)
Comments:

2
2 IMP Inspections (including DIMP)
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 point, No= 0 Points, NI=.5 point)
Comments:

1
3 OQ Inspections
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 point, No= 0 Points, NI=.5 point)
Comments:

1
4

Damage Prevention Inspections
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 point, No= 0 Points, NI=.5 point)
Comments:

1
5 On-Site Operator Training
Any operator training conducted should be outlined and appropriately documented as needed.

(Yes= 1 point, No= 0 Points, NI=.5 point)
1

Comments:
6 Construction Inspections
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 point, No= 0 Points, NI=.5 point)
Comments:
1

8 Does inspection plan address inspection priorities of each operator, and if necessary each unit,
based on the following elements?
 Length of time since last inspection (Within five-year interval)
 Operating history of operator/unit and/or location (includes leakage, incident and compliance
activities)
 Type of activity being undertaken by operators (i.e. construction)
 Locations of operator’s inspection units being inspected - (HCA's, Geographic area, Population
Density, etc.)
 Process to identify high-risk inspection units that includes all threats - (Excavation Damage,
Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any
Other Factors)
 Are inspection units broken down appropriately?
(Yes= 6 points, No= 0 Points, NI=1-5 points)
Comments:

6
9 General Comments:
13

C – PROGRAM PERFORMANCE
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
A = Total Inspection Person Days (Attachment 2)
B = Total Inspection Person Days Charged to the program
(220 x Number of Inspection person years from Attachment 7)
Ratio = A/B If Ratio >= .38 then score = 5 points. If Ratio < .38 then score = 0 points.
(Yes= 5 points, No= 0 Points)
Comments:
5
2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See
Guidelines Appendix C for requirements) Chapter 4.4
In addition -
Completion of Required OQ Training before conducting inspection as lead?
Completion of Required DIMP/IMP Training before conducting inspection as lead?
Root Cause Training by at least one inspector/program manager
Note any outside training completed
Verify inspector has obtained minimum qualifications to lead any applicable standard inspection
as the lead inspector.
(Yes= 5 points, No= 0 Points, NI=1-4)
Comments:

5
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 points, No= 0 Points, NI=1 point)
Comments:

2
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 points, No= 0 Points, NI=1 point)
Comments:

2
5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years?
Chapter 8.5
(Yes= 1 point, No= 0 Points)
Comments:

1
6 Did state inspect all types of operators and inspection units in accordance with time intervals
established in written procedures? Chapter 5.1
(Yes= 5 points, No= 0 Points, NI=1-4 points)
Comments:

5
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 points, No= 0 Points, NI=1 point)
Comments:

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 point, No= 0 Points)
Comments:

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 1

history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for
guidance) (NTSB) Chapter 5.1
(Yes= 1 point, No= 0 Points)
Comments:

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 point, No= 0 Points)
Comments:

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 point, No= 0 Points)
Comments:

1
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 points, No= 0 Points, NI=1 point)
Comments:

2
13 Comments:
0
14 Has state confirmed transmission operators have submitted information into NPMS database
along with changes made after original submission?
(Yes= 1 points, No= 0 Points, NI=.5 point)
Comments:

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 points, No= 0 Points, NI= 1 point)
Comments:

2
16 Is state verifying operators OQ programs are up to date? This should include verification of any
plan updates and that persons performing covered tasks (including contractors) are properly
qualified and requalified at intervals determined in the operator’s plan. 49 CFR 192 Part N
(Yes= 2 points, No= 0 Points, NI=1 point)
Comments:

2
17 Is state verifying operator’s gas transmission integrity management programs (IMP) are 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 operator plan(s).49 CFR 192 Subpart 0
 Are the state’s largest operator’s programs being contacted or reviewed annually?
 Are replies to Operator IM notifications addressed? (formerly part of Question C-13)

(Yes= 2 points, No= 0 Points, NI=1 point)
Comments:
2

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 operator’s plan(s). 49 CFR 192 Subpart P
 Are the state’s largest operator’s being contacted or reviewed annually?
(Yes= 2 points, No= 0 Points, NI=1 point)
Comments:

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
 PAPEI Effectiveness Inspections are to be conducted every four years by operators

(Yes= 2 points, No= 0 Points, NI=1 point)
Comments:

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 points, No= 0 Points, NI=.5 point)
Comments:

1
21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports?
Chapter 6.3
(Yes= 1 points, No= 0 Points, NI=.5 point)
Comments:

1
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 points, No= 0 Points, NI=.5 point)
Comments:

1
23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA?
(Yes= 1 points, No= 0 Points, NI=.5 point)
Comments:

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.
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
25 Did the state attend the NAPSR National Meeting in CY being evaluated?
(Yes= 1 point, No= 0 Points)
Comments:

1
26 Discussion on State Program Performance Metrics found on Stakeholder Communication site –
(Yes= 2 points, No= 0 Points, NI=1 point)
http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805
Comments:

2

27 Discussion with State on accuracy of inspection day information submitted into State Inspection
Day Calculation Tool (SICT). Has the state updated SICT data?
(Yes= 1 point, No= 0 Points)
Comments:

1
28 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product
Changes and Conversions to Service? See ADP-2014-04
(Yes= 1 point, No= 0 Points, NI=.5 point
Comments:

1
29 General Comments:
49

D – COMPLIANCE ACTIVITIES
1 Does the state have written procedures to identify steps to be taken from the discovery to
resolution of a probable violation? Chapter 5.1
 Procedures to notify an operator (company officer) when a noncompliance is identified
 Procedures to routinely review progress of compliance actions to prevent delays or
breakdowns
 Procedures regarding closing outstanding probable violations
(Yes= 4 points, No= 0 Points, NI=1-3 points)
Comments:

4
2 Did the state follow compliance procedures (from discovery to resolution) and adequately
document all probable violations, including what resolution or further course of action is needed
to gain compliance? Chapter 5.1
 Were compliance actions sent to company officer or manager/board member if
municipal/government system?
 Document probable violations
 Resolve probable violations
 Routinely review progress of probable violations
 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
 within 90 days, to the extent practicable, provide the owner or operator with written
preliminary findings of the inspection.
 Incident investigations do not need to meet 30/90-day requirement
(Yes= 4 points, No= 0 Points, NI=1-3 points)
Comments:

4
3 Did the state issue compliance actions for all probable violations discovered?
(Yes= 2 points, No= 0 Points, NI=1 point)
Comments:

2
4 Did compliance actions give reasonable due process to all parties? Including "show cause"
hearing if necessary.
(Yes= 2 points, No= 0 Points)
Comments:

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 points, No= 0 Points, NI=1 point)
Comments:

2
6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety
violations?
(Yes= 1 point, No= 0 Points, NI= .5 point)
Comments:

1
7 General Comments:
15

E – INCIDENT INVESTIGATIONS
1 Does the state have written procedures to address state actions in the event of an
incident/accident?
(Yes= 2 points, No= 0 Points, NI=1 point)
Comments:
2
2 Does state have adequate mechanism to receive and respond to operator reports of incidents,
including after-hours reports? And did state keep adequate records of Incident/Accident
notifications received? Chapter 6
 Acknowledgement of MOU between NTSB and PHMSA (Appendix D)
 Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E)
(Yes= 2 points, No= 0 Points, NI=1 point)
Comments:

2
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 point, No= 0 Points, NI= .5 point)
Comments:

1
4 Were all incidents investigated, thoroughly documented, and with conclusions and
recommendations?
 Observations and document review
 Contributing Factors
 Recommendations to prevent recurrences where appropriate
(Yes= 3 points, No= 0 Points, NI=1-2 points)
Comments:

3
5 Did the state initiate compliance action for violations found during any incident/accident
investigation?
(Yes= 1 point, No= 0 Points)
Comments:

1
6 Did the state assist Region Office or Accident Investigation Division (AID) by taking appropriate
follow-up actions related to the operator incident reports to ensure accuracy and final report has
been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate
discrepancies) Chapter 6
(Yes= 1 point, No= 0 Points, NI= .5 point)
Comments:

1
7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR
Region meetings, state seminars, etc)
(Yes= 1 point, No= 0 Points)
Comments:

1
8 General Comments:

11

F – DAMAGE PREVENTION
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 points, No= 0 Points, NI=1 Point)
Comments:

2
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 points, No= 0 Points, NI=1 Point)
Comments:

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 points, No= 0 Points, NI=1 Point)
Comments:

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 points, No= 0 Points, NI=1 Point)
Comments:

2
5 General Comments:

8

G – FIELD INSPECTIONS
1 Operator, Inspector, Location, Date and PHMSA Representative
 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)
Comments:

2 Was the operator or operator's representative notified and/or given the opportunity to be
present during inspection?
(Yes= 1 point, No= 0 Points)
Comments:

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 points, No= 0 Points, NI=1 Point)
Comments:

2
4 Did the inspector thoroughly document results of the inspection?
(Yes= 2 points, No= 0 Points, NI=1 Point)
Comments:

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 point, No= 0 Points)
Comments:

1
6 Did the inspector adequately review the following during the field portion of the state
evaluation? (check all that apply on list)
 Procedures
 Records
 Field Activities/Facilities
 Other (please comment)
(Yes= 2 points, No= 0 Points, NI=1 Point)
Comments:

2
7 Did the inspector have adequate knowledge of the pipeline safety program and regulations?
(Evaluator will document reasons if unacceptable)
(Yes= 2 points, No= 0 Points, NI=1 Point)
Comments:

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 point, No= 0 Points)
Comments:

1
9 During the exit interview, did the inspector identify probable violations found during the
inspections? (if applicable)
(Yes= 1 point, No= 0 Points)
Comments:
1

10 General Comments:
 What did the inspector observe in the field? (Narrative description of field observations and
how inspector performed)
 Best Practices to Share with Other States - (Field - could be from operator visited or state
inspector practices)
 Other

12
Field Observation Areas Observed (check all that apply)

Abandonment
Abnormal Operations
Break-Out Tanks
Compressor or Pump Stations
Change in Class Location
Casings
Cathodic Protection
Cast-iron Replacement
Damage Prevention
Deactivation
Emergency Procedures
Inspection of Right-of-Way
Line Markers
Liaison with Public Officials
Leak Surveys
MOP
MAOP
Moving Pipe
New Construction
Navigable Waterway Crossings
Odorization
Overpressure Safety Devices
Plastic Pipe Installation
Public Education
Purging
Prevention of Accidental Ignition
Repairs
Signs
Tapping
Valve Maintenance
Vault Maintenance
Welding
OQ - Operator Qualification
Compliance Follow-up
Atmospheric Corrosion
Other

H – INTERSTATE AGENT STATE (if applicable)
1 Did the state use the current federal inspection form(s)?
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
2 Are results documented demonstrating inspection units were reviewed in accordance with
“PHMSA directed inspection plan”?
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
3 Did the state submit documentation of the inspections within 60 days as stated in its latest
Interstate Agent Agreement form?
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
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 point, No= 0 Points, NI=.5 point)
Comments:

1
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 point, No= 0 Points, NI=.5 point)
Comments:

1
6 Did the state give written notice to PHMSA within 60 days of all probable violations found?
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
7 Did the state initially submit documentation to support compliance action by PHMSA on
probable violations?
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
8 General Comments:
7

I - 60106 AGREEMENT STATE (if applicable)
1 Did the state use the current federal inspection form(s)?
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
2 Are results documented demonstrating inspection units were reviewed in accordance with state
inspection plan?
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

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 point, No= 0 Points, NI=.5 point)
Comments:

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 point, No= 0 Points, NI=.5 point)
Comments:

1
5 Did the state give written notice to PHMSA within 60 days of all probable violations found?
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
6 Did the state initially submit adequate documentation to support compliance action by PHMSA
on probable violations?
(Yes= 1 point, No= 0 Points, NI=.5 point)
Comments:

1
7 General Comments:
6