Compliance Inspection - Attachment 8 - El Paso Natural Gas ... · El Paso Natural Gas Company Audit...

Compliance Inspections -Attachment 8 - El Paso Natural Gas Co. Audit Plan Validation

,

Memoi Attachment 8

U.S. Department of Transportation Research and Special Programs Administration Southwest Reeion Office Office of Pipeline Safety

Report Date: Subject: OPS Representatives : Juan Mendoza and John Haddow . Inspection Date:

January 3 1,2001 (Revised) El Paso Natural Gas Company Audit Plan Validation

September 25 - 2 9 , 2 0 0

Portion of System Inspected: Mainlines West of El Paso station associated With the El Paso Complex and mainlines associated with the Deming Complex in New Mexico. We went West on the mainline fkom El Paso station to Florida station. Next we followed the system West into the Deming Complex area to Lordsburg station.. We then Visited the lines in the Deming area. Various mainline valves, CP test stations, meter and regulator settings and compressor stations were inspected along the above described route.

Personnel Interviewed: At Headquarters - Richard Favila, Gilbert Aragon, Robert Morales. At Station #3 Warehouse - Don Payne, Bob Cassady. At El Paso Complex - Richard Favila, Cal b y , Ramon Vega, Femando Salcido, Jose Dim, Bruce Booth. At Deming Complex - Ramon Vega, Larry Meyer, Robert Miller, Hector Garcia, Jerry Ozbun.

Records Reviewed: Corrosion, Emergency Plans, valves, W O P listing, regulator inspections, over pressure protection devices, aerial patrols, leak surveys, public education, damage prevention, and previous El Paso internal audit inspection records.

Issues: No out of compliance deficiencies were noted during this inspection by either John Haddow or Juan Mendoza. However, amendment to the current procedures which involve revisions, reviews, approval and distribution of engineering and flow schematic drawings is needed.

Conclusions: All records requested were presented for our review and no major deficiencies were noted. All personnel interviewed gave satisfactory answers to questions concerning their operations and maintenance policies and procedures. There were some minor concerns noted at the facilities inspected which are mentioned below.

- Recommen dationsh3 es t Practices: We are confident that the internal audit plan for El Paso Natural Gas Company is working as

needed. Such procedures need to take into account the automated drawing distribution. The revision process must also make use of a distribution list which encompasses relevant personnel h m compliance, engineering design, operations and gas control. It was noted during the field inspections that maps of station line drawings were red lined but not up to date. At the Rio Grande river crossing of lines 1100 and 1103, it was recommended that addition markers set closer to the crossing would be beneficial. While reviewing records at Deming Complex, there was some confusion in reference to Valves 37 and 41 % as to whether they were being consistently picked up on the inspection reports. At Deming Complex, we discussed the ESD forms that are currently being used because it was unclear as to what was actually being checked. Apparently, the fom used previously was better formatted for recording ESD checks. Our understanding is that this item is going to be addressed system wide. At Lordsburg and Florida stations, fire extinguishers had not being checked since June and April 2000, respectively. Prior to those dates, they were not being chqked on a continuous monthly basis. It was unclear as to who (El Paso operators or contractors) should be performing these monthly inspections. El Paso needs to clarify this issue and make sure others stations are performing these monthly checks. This equipment is one that the company depends on to protect lives and minimize destruction to property and should be maintained accordingly. The fencing around Valve 35 had no signs. It is my understanding that this issue has been resolved. While at Deming, we reviewed the cleaning pig run data from line 1005. Any liquids or solids were analyzed for the purpose of disposal but not for the sake of internal corrosion concerns. The data revealed a high Fe (iron) content, but no data to discriminate the source. My understanding is that El Paso is working on procedures that will enhance communication between measurement analyses and corrosion control.

4 designed in this area. However, as noted above amendment to current mapping procedures is

1. - c, : . _ _ . . . . ; A

Name of Operator:

EQ Address:

El Pas0 Energy CorporaPian 1001 Louisiana street Houston, Texas 77002

El Paso Energy Corporation

Co. ofzicial (Pes or VP) Tom P. Morgan V.P. operations

Telephone number: 915-496-5733

Funumber: 915-496-5008

SystemAJnit Name Address:

1900 Deming Station Road Deming,NM 801

Deming-East COmprex

Telephone number: 505-544-5234

Far number:

Emergency Tdephone: 1-800-334-8047 Emergency Telephone: 1-800-334-8047

Operator ID: 4280 Unit ID: 34704 I ActivityID: 97536

Unit IDS of adjacent Operator units: Deming West; El Paso

Persons Intemiewed 1- I Phone Numbers

h p a y n e CompliaxlceManager 915-587-3770

RichadFavila principal Engineer 9 15-587-3771

coqliallce services 520-663-4243

Ramon Vega Senior Corrosion Coordinator 520-663-4258

Bob Cassady warello~coordinator 9 15-587-3762

Lead El Paso Complex 915-822-7330

GIs Adyst / Deming Operations Manager

Operation Specialists El Paso I Deming

Senior Controls I Comsion Specialist

tal =+Y Robert Morals I Robert Miller

Femando Salddo /Hector Garcia

Jose Dim/ Jeny Wuu

OiIbert Aragon /Bruce Booth /Senior Measurement Tech B15-822-7338

915-496-5716 I 505-544-5234

915-822-7302 I 505-544-5234

915-822-7302 1505-544-5234

OPS Representative(s): Juan A Mendoza and John Haddow Date: September 25-29,2000

Company system maps - (copies for regional mes, yes /no): System map already on file

Pipeline system from Florida station to the Arizona /New Mexico border.

Portion of Unit Inspected:

Class Ill areas around El Paso, Valve 27, Rio Grande River Xing, Afton Sta, Lordsburg Sh, Sta #4, Valve #35 and Florida Sta. Was a Team O&M inspection completed pdousXy? Yes 11 If yes, document date? 04 /ls-20 nom Note: If a Team O&M inspection was completed within the five (5) years, it is not necessary to review the eatire O&M manual. However, modifications to the “al should be reviewed.

MAOPIOverpressure Protection

Satisfactory Needs bpmvement W A Q1) Headquarters X Q1) Field X R1) Headquarters X

Rl) Field X

0 v e q ” e protection is essential to ptec t the pipeline fiom tmxpected events. The operator should have procedures m place to ensure that the overpressure ptective devices ~IZ adequate and in good wodcjng coruMo~. Discuss with perscrrmel how they would ensure a change m operating pressure, possiily due to a safety related conditio& is communicated throughout the company.

192.169 - Compressor Station hwsure Udting - Suitable protective devices of “kient capacity for atation Pfpfng.

cQ1) Have reHef valves, associated piping and exhaust ports been designed and tested for pressure getting and capacity periodically reviewed?

N/C

*

Satisfactory Needs Improvement NIA

Q2) Headquarters Joint Team

Q2) Field X

R2)Headquarters X

R2) Field X

Comments:

NJC

192.169@) GQ2) Have relief valve exhaust ports been routed and positioned away from potential ignition 8ources and electrical power lines or where gas build up may cause a hazardous atmosphere?

Page 1 of 41 March 2000

2) Comments:

The team O&M inspection addressed this question due to m e concem brought up by Arizona Corporation CommisSiOn. Relief vahre vents were piped properly at the field locations we visited.

Needs Improvement lVA

X

192.731 Compressor Station Relief Devices - Inspection and testing of prwsare controlling devices. 192731@)

6-43) Have dation pressure protective devices been inspected and tested within the required IS month and

W C

once per calendar gear?

R3) Associated Records?

43) Headquarters

Q3) Field

R3)Headquartera

Satisfactory

X

I X R3) Field

X

3) Comments: All records requested wem pmented and appeared the required insrpections were perfoxmed as required. However, ESDlpressun Switch Test Fonns have beenmodified. l'he new forms do not have details such as setting found and setting left and remarks. Compliance personnel said this would be addressed.


192.203 - Instrument, control and 6amphg lines - MateriaIs and design of takco€flines.

Satisfactory Needs Improvement W A Q4) Headquarters X

Q4) Field X R4) Headquarters X

R4) Field X

NIC

4) Comments:

Satisfactory Needs Improvement N/A

QS) Headquarters X

QS) Fjeld X RS) Headquarten X

R5) FieId X

192.605(~)(1) -Procedures lor Responding to Abnormal Operation -Responding to, investigating and correcting the cause of unintended closure of valves or 6hntdowns and an increase or decrease in pressure or flow rate outside normal operating limits.

NIC

ElPaso-Deming-StdInsp.wpd Page 3 of 41

March 2000

5) Comments:

EIPaso-Deming-StdInsp.wpd Page 4 of 41

March 2000

19%619(a) - MAOP and Pressure Records -Determining MAOP from design, teat, history and integrity.

6-46) Does the Operator have records to support the MAOP applied to each line segment? (Note: If the operator previously verified the MAOP,]ast note the date of the verification.) R6) Associated Records?

Satisfactory Needs Improvement NIA 46) Headquarters X

46) Field X R6) Headquarters . x R6) meld X

IVC

6) Comments:

19%619(a)1 Best h.nctrce

6-47) Does the Operator have operating pressure records to reflect actual system pressurea?

7) comments:

Electronic are kept at control center.


192.619(a)

t

Satisfactory Needs Improvement IVA

QS) Headquartera X

Q9) Field X

W) Headquars X

R9) Meld X

6-48) Has the MAOP on m y line segment changed In the last year or two? ("he change may be due to a safety related condition or class locathn change?

N K


Tb;ere has been no changes in the last two years.

192619@) - Over-Pressure Protective Devices -Relief valva or other protective devices set b appropriate pressures.

G-Q9) Have recent occurrences of overpressure been investigated for the possibility of an equipment failure or design naw? How did the operator veHy that nu& conditions did not exist at other locations? .


EIPaso-Deming-StdInsp.wpd Page6of 41

Mar& 2000

9) Comments:

ElPaso-Demhg-Stdhsp .wpd Page 7 of 41

March 2000

192.739 Pressure Limiting and Regulating Stations -Inspection and testing of pressure influencing devices. 192-.739(a), @b (e)

Satisfactory

QlO) Headquarters

QlO) Field X

R10) Headquarters

R10) Field X

G-QlO) Have regnlators been inspected and tested to be in good mechanical condition and checked for adequate capacity within the required 15 months and once per calendar year? Were changes to the ret-points of regdators documented?

RlO) Associated Records?

Needs Improvement NIA WC

X

X

ElPaso-Deming-Stdhsp.wpd Page 8 of 41

March 2000

192.743 - Relief Capacity -Testing andlor cdculation of relief capacity. 192*743(a), OM)

Satisfactory

Qll) Headquarters

Qll) Field X

R1 1) Headquarters

R1 1) meld X

G-Qll) Have relief devices been checked for designed capacity within the required 15 months and once per calendar year? Were engineering calcuIations checked if an actual test wej not feasible? Xf the device was not of sufficient capacity, mrerc other device added or changed?

Needs Improvement W A NIC

X

X

R1 1) Associated Records?

If) Comments:


* Inspection Criteria relating to SCADA and other Alarm Systems

Ql2) Headquarters

Q12) Field

R12) Headquartera

R12) Reld

192.736@) - Gas Detection in Compressor Bddiugs - Wam personnel in or about to enter buildings. l92.736@)

Satisfactory Needs Improvement NlA NIC

X

X

X

X

G-Ql2) Have gas detection dann systems been installed in enclosed compressor buildings, mch that persons in, or about to enter, the buildings will be alerted to the presence of an unusually high level of gas? Are they audio-visual? How is the equipment calibrated to 25% LEL and how often?


12) Comments: I Almm have both audio and Visual indications. A calibrated gas sample is used to check each head during ESD

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March 2000

19%605(b)(S)Operating Procedures - Starting up and shutting down any part of the pipeline system. 192.605(~)(1) Abnormal Operating Procedures.

Best Practice: -13) Does the controller have the authority to shutdown the pipeline system as a result of an abnormal condition?

13) Comments:

Yes.

Best Practice: -14) Does the operator address controller fatigue Issues?

14) Comments: This question was covered during the recent Joint Team O&M Procedures audit. I

E1Paso-Demhg-StdInsp.wpd Page 11 of 41

March 2000

I

19%605(c)(I)@i)

G-Ql5) Will system operation be affected by communication outages or SeADA failure?

15) Comments: This question was covered d h g recent Joint Team O&M prooedures Audit.

ElPaso-Deming-StdInsp..wpd Page 12 of 41

March 2000

r Odorization


416) Headquarters X

416) FieId X

Rl6) Headquarters X

R16) field X

192.625 Odorkation of Transmission Pipelines in Class 3 and 4 Areas. Did the operator consider odorizing any trammission lines because of a change in cIass location? 192.625(a) - (t)

IVC

C-Ql6) Are odorant levels tested on 0 periodic basis?


March 2000 Page 13 of 41

Engineerin2 Drawing Review

Satisfastory Needs Improvement NIA

417) Headquarten X

417) Field X

R17) Headquarten X

R17) FSeld X

-

c

NIC

- Satisfactory Needs Improvement N/A NPC

Qls) Headquarters X

Qls) Field X

R18) Headquarters X

R18) Field X

17) Comments:

Maps on hand were maps indicating MAOP drawings, fk control, ESD switch control aad pipeline drawings. Maps are madced up mthe field then sent to HQ for changes.

Drawing Index (Access) Database with 120,000 drawings. AM drawings except Alignment sheets. Alig"t Sheets are in the -Ref data base. Both databases ae accessible from manned field offices with plotters.

192.605@)(3)

Q18) Do the operator% "as-buih" agree with field? Do the SCADA terminals get updates?

Rl8) Associated Records?

Page 14of 41 March 2000

It?) Comments:

Yes. Normal turn around time is about 3 months, however if needed it can be done the same day.

Satisfpctotg Needs Improvement N/A

Q19) Headqalvtcrs X

Ql9) Field X

Rl9) Headquarters X R19) Field X

I

N K

192.605@)(3)

Q19) How are completed construction activities, sa& w facility modifications, communicated to the controller?


19) Comments:

E1Paso-Deming-StdInsp.wpd Page 15 of 41

March 2OQO

Process Control and Flow Schematic Drawing Review Dif€enznces between process control engineering drawings and pipeline facilities have resulted m mcidents tamd a b n d operating umditions. We have found that physical changes made to facilities are sometimes not reflected m engineering drawing or SCADA displays. The company should have a procedure m place that cllsures changes m the field are Communicated to approPriate personnel and correspondence maps, recofds and drawings conected.

Q20) Headquarterti

Q20) Field

WO) Headqaarters

I U O ) Field

192.605(b) (3)

Satisfactory Needs Improvement NIA NIC

X

X X

X

G-QfO) Do engineering, process control, and flow rchematic drawings accurately depict current facilities and operation?

R20) Assodated Records?

20) Comments:

Process control and flow schematics drawings were reviewed and no problems were detected. Howevex, some station drawings were red lined. Complimce persannel stated that the cuerent drawing would be requested.


March 2000

r Review of First Discovery Reports

Satisfactory Needs Improvement NIA Q2l) Headquarters X

Q2l) Field X R21) Headquarters X

R21) Field X

First discovery repoIts are reports that may identify potential problems on, or in the vicinity of the pipeline, that could affect pipeline integrity and/or public safety. These reports could include my pipeline safety inspection and/or survey reports, landowner of general public reported concerns, patrol reports. Listed below are a few high impact

NIC

192.459,192.481,192.613,192.703 192.613 GQ21) Does the operator disseminate, monitor, urd follow-up the infomation obtained from fust discovery l%ports?

?


ElPaso-Deming_StdInsp.wpd March 2000 Page 17 of 41

NIA

X

Satisfactory Needs Improvement

Q22) Headquarters

Q22) FieId X

R22) Headquarters X

R22) Field X

22) Comments:

NIC

Yes.


192.614,192.613,192.703

423) Headqnartera

QU)

R23) Headquarters

R23) Field

G-QZS) How does the operator follow-up and document publidandowner compldnts concerning rdety and integrity issues?

Satisfactory Needs Improvement NIA NIC

X X

X

X


424) Headquartera

QW &hi R24) Headquarters

R24) Field

Satisfpctory Needs Improvement NIA NIC

Joint Team

X X

X

23) Comments:

Basically, if the call goes to the complex office the Lead takes the call and follows up on the complsint. If the call goes to Oas Control, the controUers notifies the Lead and the conbrouer calls the caller back with a follow up.

"hem had been no instances or oc"e in the past two years.

192613

-24) How does the operator fohv-up and docament Integrity issues Bystem-wide?

Fl24) Assodated Records?

ElPaso-Demhg-StdInsp.wpd Page 19of 41

March 2000

24) Comments:

Inf"tion is transrmtt edviaedddirectfacetoface meetings.

ElPaso-Demhg-Stdhsp.wpd Page 20 of 41

. March 2000

> Leak Detection, CIassification and Response

Responding to aotifications of leaks is critical to ensuring sdkty. The operator should have a plan and procedures instructing employees how to detect and respond to suspected leaks. Review the leak detectionprocedms, response time, and in+ about cmy impact due to maupowerreductionarwalignment and what procedures me mplace to grade leaks consistently. I

G-Q25) Does the Operator have adequate procedures that address leak deteetionlsumyhg, classificatiodgrading, and response?


Q25) Headquarters Joint Team

QZS) Field

R25) Headquarters

Needs Improvement NIA NIC

X

25) Comments:

Class III areas axe leak mnveyed .by Contractor (Heath consultant Services). Reviewed 1998 & 1999. 2000 final report was not completed yet


* 4

; Training

Operator errors result m pipeline incidents every year. We are trying to detexmjne what processes operators have m place to address the training requirements and safety needs of the pipeline industry. b

192605@)@)J92605(eX4), WZ6o5(& 19L.615@)(1) - (3) 6-26) Has the operator established and conducted I continuing trafning program to instruct operathg and maintenance personnel?

Satisfactory Needs Improvement

426) Headquarters Joint Team

426) Field X

R26) Headquarters

R26) Field

N/A NIC

X

X

26) comments:

OJTismainmeans of training,there are some company classes. They presently have askillspay base that will be modified to meet the new OQ Rule. Regulatory Complimce personnel actually observe individuals complefing various tasks at present. Records at HQ.


c Corrosion Control

Corrosion is a major cause of accidents and disboded coating is often the leading factor. A check of close intend surveys for depressed areas may reveal disboded coating. Pipe segments adjacent to locations whm comsion is found could easily develop corrosionbecause it may be subject to the same conditions. A d d i t i d preventivt measures should be taken m these areas such as bell hole examinations and smart pigging activities. Review locations where clockspring repairs were made to identify pipe segments that are subject to active corrosian. Ifthe facility is within or downstream of a storage field, inquk about jntemd comsion monitoring practices.

Q27) Headquarters

Qn) Field

R27) Headquarters

192.605@)(2), Subpart I (192451-192491) 6-427) Does the company maintain a comprehensive corrosion control progrm?

Joint Team

X

X

R27) Associated Reconls (annual survey, rectffiers)?

Satisfactory Needs Improvement EUA

QB) Headquarters Joint Team

428) FieId X

R28) Keadquarters X

R28) FieId X

?

e& Improvement NIA IVC I I I

NJC

R27) Field 1 X I I I I 27) Comments:

Compliance personnel ContinuaIly add items to there ongoing riser wipe to soil interface) program.

192.605@)(2), Subpart I (192451-192.491), RP0169, NACE

-28) Is the company% corrosion program under the direction of a qualified person? (List the qualifications in the comment field.)

Elpaso-Deming-StdInsp .wpd Page 23 of 41

March 2000

28) Comments:

Yes, Robert Babnick is the Principal coordinator of Corrosion S d c e s . Roberthas many years of OJT m additionto NACE Tdnhg.


QW) Headquartera Joht Team

Q29) Fkld X R29) Headquarters X

R29) Field X

1

NIC

192.605@)(2), Subpart I (192.451-192.491) 192.605@)(2), Subpart I (192451-192491)

G-QD) Are cormion control procedures in place and do they follow Part l92/NACE/indastry standards?

29) Comments:

A combmatian mdustry standards and NACE 8 f e used by this companp.

Page 24 of 41 March 20QO

192.613 -30) How is the gathered information reviewed and analyzed to identify problem uw?

Satisfactory Needs Improvement MA

430) Headquarters Joint team

430) Field X

R30) Headquarters X

R30) Field . x

NJC

30) Comments:

AI coposion infomation is given to the SI. operatioas Specialisp and to the qrihcipa~ coordinator ofcormsioo Savices. These individuals analyze the data and make remmenWons. Readings below -850 mV are identi6ed asproblemareas.


6-431) Under what conditions does the operator take prompt remedial action?


431) Headquarters X

431) Reid X

R31) Headquarters X

R31) field X

R31) Assodated Rccords?

NK

31) Comments:

An excqptioIls sheet is generated for any items that are not conrected by the technician at the time of discavery. This is e n t e r e d into their cocrosiOn data base and apprapriate remedial actions ure initiated.

E1Paso-Deming-Stdhsp.wpd Page26of 41

March 2000

I

Best Practice: 432) What factors are considered In determining the need for and timing of pigging and close interval aweys?

32) Comments:

Trends and results of CIS and other information relative to the line segment are used to make recan"m&ons; however much of their system is not pigable at the present time. A risk model is being populated that will be used to influence! the decisions in the hme.


~ ~ ~~

VaIves It is important that isolation valves be m good working order aud accessible when needed.

192.179(a),(b)(l-2)


433) Headquarters X

4s) mid X

R33) Headquarters X

R33) Field X

433) Does each redonaling block valve on a transmission h e , other than offshore regments, comply with the following:

Spaced as required by code? Review as-bailt drawings. The valve and the operating device to open or close the valve must be readily accessible and protected from tamperhg and damage. The valve must be supported to prevent settling of the valve or movement of the pipe to which it is attached.

NIC


33) Comments:

Valves appear to adequately spaced on the segments inspected,


Best Practice: 434) Are there any locdons where special features, such as valve stem extension in flood plains, had to be incorporated because of di0icuQ in complying with the above? Are there any automatic or remotely controlled valves? What is the operator policy for providing backup (bottles) in case pressure b lost to operate the sectiona?izing block valved

34) Comments:

Satisfactory Needs Improvement NJA 435) Headquarters X

435) Field X

R35) Headqaartera X

R35) meld X

. .

NIC

192.179 (c)

435) Does each section of a transmission line, other than offshore segments, between main line valves have a blow dona vahrr with enough capacity to allow the transmfssbn line to be blown down rapidly u practicable?

35) Comments:

ElPaso-Deming-StdInsp.wpd Page29of 41

March 2000

192.179(d)

436) Headquarters

436) F’Md

R36) Headquarters

R36) Field

436) Are offshore repents of transmission lines equipped dth valves or other components to shut off the flow of gas b an offshore platform in m emergency? M e w as-bnilt drawings.

Satisfactory Needs Improvement NA NIC

X

X

X X


36) Comments: . .


March 2000

192.745

Saiisfactory Needs Improvement W A

Q37) Headquarters X

437) X

R37) Headquarter8 X

R37) Field X

437) Is each transmission line valve that might be required during an emergency inspected and partially operated at intervals not exceeding 15 months, but at least once each calendar year?

WC


ElPaso-Demhg-StdInsp.wpd Page 31 of 41

March 2000

. PatroX Program

An ef€wtive patrol program will combme i n € o d o n throughout the company to prevent damage to the pipeline and detect damage that has dmidy occurred. Companies m encouraged to correlate infi."tion from a variety of sources such 8s comparing patrolling records with intmd inspection data Commrmicstion and ureas of responsiiility between patrol pilots and the persolme1 who follow-up and track the rep& should be clearly defined so that both parties understand their role in preventing outside force damage.

Satisfactory Needs Improvement NJA

438) Headquarters Joint Team

438) Field X R38) Headquartera X

R38) Reld X

192.705(a) GQ3S) Does the operator have an adequate patroUing program ?

NIC

38) Comments:

l!42.705(a)

439) Are patrols conducted at regular intends appropriate for the class location, and by qualied personnel?


Satisfactory

439) Field

R39) field I X

Needshprovement I N/A I NIC I I X I I

X

ElPaso-Deming-StdInsp.wpd Page32of 41

March 2000

of 41 March 2000

Line Markers & Damage Prevention (Locating and Marking Pipelines) It is critical that personnel who locate buried pipe in the course of their work are qualified and competent. Personnel performing this work may be operator or contract service company employees (line locate comgmy, cotTosion mvey company, pipeline mweyars, etc.).

192.707 Line Markers - each operator shall place and maintain line markers over each buried pipeline.

Q40) Headquarters

-0) Are markers located at public road crossing, railroad crossings, and in sufficient number dong the remainder of each buried line?

Satisfactory Needs Improvement NIA NJC

X


Q40) Headquarters

Q40) Field

R40) Headquarters

R40) Field

Satisfactory Needs Improvement NIA NJC

X

X

X

X

Q40) Field

R40) Headquarters

R40) Field

X

X

X

40) Comments:


!

192.605&)(8) Procedural manual for operations, mahtenance, and emergencies - Maintenance and normal

Q4l) Headquarters

441) Field

R41) Headquarters

R41) Field

. _ - ~

operations -the manual must hchde p - d k for periodic& revi&g the work done by operator personnel to determine the effectiveness of the procedures used in normal operation and maintenance and taking corrective action where deficiencies are found.

Satisfactory Needs Improvement NIA N/C

X

X X

X

192614(a) Damage prevention program -I the operator does not participate in a public service program, such as a one-call system, then the operator of a buried pipeline must carry out a written program to prevent damage to that pipeline from excavation activities.

G-Q?l) Does the operator participate in a public service program? If not, does the operator evaluate their damage prevention procedures and take corrective action where deficiencies are found?


4 1) Comments:

EIPaso-Deming_StdInsp.wpd Page 35 of 41

March 2000

192614(c)(l) Damage prevention proirun -the operator must identify, on a current basis, persons who normally engage in excavation activities in the area in which the pipeline ls located; notify the public and persons who n o d y engage in excavation activities of the damage prevention program; provide a means of receiving and recording notification of planned excavation activities; provide for actual notification of persons who give notice of their Intent to excavate of the type of temporary marking to be provided and how to identify the markings; and provide inspection of excavation activities, if the operator believes the pipeline a d d be damaged by excavation activities.

Q42) Headquarters

Q42) Field

R42) Headquarters

R42) Field

192.614(e)@) Damage prevention program - If the operator participates in a public service program, ruch as a qaalified o n d l system, then the operator mast: provide a means of receiving and recording notification of planned excavation activities.

Satisfactory Needs Improvement N/A N/C

X

X

X

X

-2) Does the operator have an adequate damage prevention program?


42) Comments:

EIPaso-Demhg-StdInsp .wpd Page36of 41

March 2000

Best Practice: NPRM Qualificatfon of Pipeline Personnel G-Q43) Are tmined/qaalified persoriheldsed for pipeline locating & marking?

43) Comments:

Yes, trained on the job, with m e cumpimy classes.

EIPaso-Deming-StdInsp..wpd MWh 2000 Page 37 of 41

Liaison with Construction Project and Land-Use Officials (Public Education)

Encroschment muxi pipekes poses skious safety risks as third parties excavate in pximity to buried pipelines. A strong damage p m d o n p p m w i n provide advance notification of co11stfllcton plans near the pipeline and win establish communication with the people invohed m the project.

192616 Public Education - each operator shall establish a continuing educational program to enable the public, appropriate government organizations, and persons engaged in excavation related lctMties to recognize a hazardous liquid or a carbon dioxide pipeline emergency and to report it to the operator or the like, police, or other public officials.

k

QM) Field

R44) Headquarters

G-Q.21) How does the operator implement its continuing education program?

X

X


I Needs Improvement NIA I NIC I (244) Headquarters Joint team I I I I

R44) Field I X I I I I 44) Comments:

This question was adequately covered during the Joint team O&M Procedures Audit. However, face-to-face with all public officials may not be on 8n annual basis.


Best Practice: -5) Does the operator’s damage prevention program include pro-active W o n with pubk construction project and land-use offrdals, engineers, and contractom?

45) Comments:

This is avery sparsely populated area As projects lire developed there is an interface with the appropriate individuals. ’Ihe interface continues until the Project is complete.

Best Practice: Q46) Does the operator’s damage preVtntion program include pro-acthe liafson with local achool officials, where the pipelme traverses or is adjacent to, school property?

46) Comments:

Not at this time.

Best Practice: -7) Does the operator have a liaison program that includes local developers and construction project OffiCiaIs?

47) Comments:

Just on an individual project bases. Varies from location to location.


r THE COMMON GROUND STUDY OF ONE CALL SYSTEMS

AND DAMAGE PREVENTION BEST PRACTICES -8) Best Practice: Has the operator reviewed the "Common Ground" Study of One Call Systems and Damage Prevention Best Practices?

48) Comments:

Yes, some ofthe recommendations were aheady been used. Additional work mthis area is plaxmed in the fuhae.

6-449) Best Practice: €&the operator compared and measured the best practices against existing damage prevention practices contained in the operator's damage prevention plan?

49) Comments:

No.

G-QSO) Best Practice: Has the operator implemented any of the best practices in addition to their existing damage prevention activities subsequent to review of the Common Ground Study?


50) Comments:

Not at this time.

r

GQ51) Best Practice: Has the operator improved communication witb other stakeholders In damage prevention as a resdt of the best practices?

51) Comments:

Not at this time.

GQS2) Is the operator's overall damage prevention program more efiectivc as a rwdt of implementation of any best practices?

52) Comments:

Not at this time.

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M€UCh 2000

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