ARKANSAS PUBLIC SERVICE COMMISSION PIPELINE SAFETY INSPECTION REPORT

NOTICE OF PROBABLE VIOLATION January 08,2008

Date of Inspection: January 08,2008 PSO Report Number: 2008-1-M

Ms. Velma Carter Resident Manager Crestwood Manor Apartments 3 802 Kavanaugh Boulevard Little Rock, AR 72205

Unit Name: Crestwood Manor Apartments

Company Rep.: Ms. Velma Carter

As provided by Arkansas Code Annotated 0 23-15-207, the results of the above inspection by the Pipeline Safety Office of the Arkansas Public Service Commission are listed on the following page@). The factual, statutory, or regulatory basis for the Pipeline Safety Offices' determination that a probable violation(s) exists are set out in this report.

In accordance with Subpart B, Paragraph 190.17 of the Arkansas Gas Pipeline Safety Code (Code), you must respond in writing by:

Date to Respond: March 10.2008

That response must: (1) provide evidence rebuttug the alleged probable violations(s), (2) enumerate those actions which have been taken to achieve compliance with the Code, or (3) request an extension of time to a date, not to exceed 60 days, when the probable violation(s) will be corrected in accordance with the compliance plan outlined in your response. Failure to respond will result in an enforcement action as authorized by Subpart B, Paragraph 190.19 of the Code.

Please provide your written response to the:

Pipeline Safety Office Arkansas Public Service Commission

P.O. Box 400 Little Rock, AR 72203-0400

Number of violations found: 2

Inspected by: Steve O'Connor and Risa Parker

ARKANSAS PUl3LIC SERVICE COMMISSION

PIPELINE SAFETY INSPECTION REPORT NOTICE OF PROBABLE VIOLATION

January 08, 2008

Datc of Inspection: January 08. :!008 PSO Report Number: 2008- 1 -M

Ms Shirley Ellis Propert! Managcr Rcctor-Phillips-Morse P 0 Bo\ 7300 Little Rock. AR 722 I79985

Unit Name: Crestwood Manor Apartments

Company Rep.: Ms Velma Carter

As provided b! Arkaiisas Code Annotated 0 23-15-207. the results of the above inspection by the Pipeliiie Safety Office of the Arkansas Public Senice Coiiunissioii are listed 011 the follouiiig page(s) The factual. statutory, or regulatory basis for thc Pipeliiie Safety Offices' deterniination that a probable violation(s) exists arc set out i n this report

In accordance nith Subpart B. Paragraph 190 17 of the Arkansas Gas Pipeline Safety Codc (Code). you must respond in nriting b j

Date to Respond: March 10, 2008

That responsc must ( I ) provide evidence rebutting the alleged probable violations(s). (2) enumerate tliosc actions nhich have been taken to achieve compliance with the Code. or (3) request an extension of time to a datc. iiot to exceed 60 dajs. when thc probable violation(s) will be corrected in accordance \\ ith the compliance plan outliiied in j our response Failure to respond will result 111 an enforcement action as authorized b? Subpart B, Paragraph 190 19 of the Code

PIease provide jour written response lo the

Pipeline Safety Office Arkansas Public Service Commission

P O Box400 L~ttlc Rock, AR 72203-0400

Number of violations found 2 Inspected by Steve O'Connor and h s a Parker

PIPELINE SAFETY INSPECTION REPORT NOTICE OF PROBABLE VIOLATION

PSO Report Number: 2008-1-M DATE: 1/8/2008

PD: 2 During this inspection, the following areas were examined:

Emergency Plan Leakage Control Odorization Inactive Services OMPlan Damage Prevention Construction Training Operator Qualification Security

0 0 0 0 0

Pressure Control Valve Maintenance Joining Procedures Corrosion Control Safety Related Conditions Drug -Headquarters Drug -Field Alcohol-Headquarters Alcohol-Field Integrity Management

Scope of Inspection:

The natural gas systems at Crestwood Manor Apartments was audited for compliance with the Arkansas Gas Pipeline Code. The system consists of bare steel pipe, coated steel pipe and plastic pipe. The system is on a two year leakage survey schedule which is current. Four pipe-to-soil measurements were taken, three of which were more negative than the minimum requirement of -850mV potential. One readmg, at the laundry building did not meet the minimum criterion of -85OmV. A cathodic protection survey has not been performed in the last fifteen months. Records for valve maintenance on the critical valves in the system were up to date. The operator is currently exempt fiom the membership requirement in the Arkansas One-Call Program.

~~~

Recommendations:

PSO Report Number: 2008-1-M Page 3 of 3

ITEM CODE NO. PARA.

PROBABLE VIOLATION

1. 192.465 External Corrosion Control: Monitoring.

(a) Each pipeline that is under cathodic protection must be tested at least once each calendar year, but with intervals not exceeding 15 months, to determine whether the cathodic protection meets the requirements of Paragraph 192.463. However, if tests at those intervals are impractical for separately protected short sections of mains or transmission lines, not in excess of 100 feet (30 meters), or separately protected service lines, these pipelines may be surveyed on a sampling basis. At least 10 percent of these protected structures, distributed over the entire system must be surveyed each calendar year, with a different 10 percent checked each subsequent year, so that the entire system is tested in each 10 year period.

1.1..

A cathodic protection monitoring survey was unavailable for the portions of the system which were found to be under cathodic protection. A cathodic protection monitoring survey must be performed and the results of the survey forwarded to the Pipeline Safety Office in response to th is report. Location PIS Reading

Building 1 -1 089 mV

Building 8 -1 280 mV

Building 9 -871 mV

Laundry Bldg -761 mV

2. 192.463 External Corrosion Control: Cathodic Protection.

(a) Each cathodic protection system required by this subpart must provide a level of cathodic protection that complies with one or more of the applicable criteria contained in Appendix D of this subpart. If none of these criteria is applicable, the cathodic protection system must provide a level of cathodic protection at least equal to that provided by compliance with one or more of these criteria.

..... Four pipe-to-soil measurements were taken, one of which, at the laundry building, did not meet the minimum requirement of -850mV. Remedial action must be taken to restore cathodic protection at this location. Documentation showing that cathodic protection has been restored at this location must be sent to the Pipeline Safety Office. Location PIS Reading

Laundry Bldg -761 mV

... . - c b,

: 1

.

7:-"

MASTER METER IXSPECTTON CHECKLIST

DATE: 11 7 /os REPORT NO. , iCMIDAYS: 3 1.

7 e.

- J .

1.

5.

6.

7.

8.

9.

10.

11.

12.

13.

14.

15.

16.

17.

18.

Where should any mail be sent? - unit address - operator address &er

Is the unit address correct? y e s IJ -no

Is the operator address correct? y e s J Is the contact name for the unit correct? - ves

no

- no

Is the operator’s representative (contact) on site? - 3 G a /

f How long has the operator’s rep. been mana,@g the facility? c3 Yew J

Is the CPM survey current? y e s - I</ Next CPM due date:

Is the leak survey current? v e s / - no / Next leak survey due: Y / y / o 7 What date was the pipeline constructed? lyd.(

Pipeline material? -Coaled steel - d i r e steel f

/ - O F ’-.-k’- W

Were the main topics ofthe O&M Plan reviewed?

was a copy ofthe O ~ M plan left with the contact? y e s .-/ - no

- ves - no

the Enfomment section of the Code left with the contact? no

L

Was a copy of the contrac:ors list left with the contact? - 4 s n o

Was the contact made aware of the location of the emergency valve and the inspection and maintenance that is required annually on the valve? --- d+ y e s - no 5 / ~ / a 7 We . d ~ , ~ O p . . ~ ~ c

/ Was Arkansas One-Call membership discussed with the contact? y e s - no

Does the operator have a written Operator Qualification program? 3 e s - no Are the records and qualification aspects of the OQ plan in order? y e s - no

6df

/

.

Probable Violations:

Unit Inspection Information Sheet Unit Name: Crestwood Manor Apartments

Unit Type: Master Meter (Distri

Address: 3802 Kavanaugh Boulevard fl 1 \ I City: Little Rock

Date Last Inspection: 6/5/2006

Number Inspection Units: 3

Area: 1

Proposed lnsp Da\e: 2/5/2008

State:

Zip:

District:

Contact:

Title:

Phone:

Operator Name:

Address:

City:

Contact:

Unit Comments:

AR 1 Mail To Unit: Both

72205- Monitor Current Date:

Crestwood Manor Apts. Monitor Due Date:

Ms. Velma Carter Monitor Suspense Date:

Resident Manager Leak Current Date: 5/4/2007

(501) 6642266 Leak Due Date: 5/4/2009

Rector-Phillips-Morse / Leak Suspense Date:

P. 0. Box 7300 Leak Survey Schedule: 2

Little Rock AR 7221 7-9985 Phone: (501) 905-4477

Ms. Shirley Ellis ' stf'-- MAIL REPORT TO BOTH FACILITY AND MGMT. FIRM (2 YEAR LEAK SURVEY) , system feeding buildings 4, and 6 replaced with PE pipe with anodeless risers

Title: Property Manager

Meter Description:

UnitCounter:

Year Constructed:

Other:

SizeP:

PSIG:

MM Serial #:

Regulator Mfg:

Located at east side of bldg. No. 7, feeds bldg's 7, 8, and 9

1 Coated Pipe: 0 Steel Risers: Low Pressure:

1965

Roots # 9533942

Rockwell with@ orafice

Bare Pipe: 0 Anodeless Risers: 0 High Pressure:

PE Pipe: 0

Meter Description:

UnitCounter:

Year Constructed:

Other:

SizeP:

PSIG:

MM Serial #:

Regulator Mfg:

Located just west of bldg. No. 5, feeds bldg's 4, 5 and 6

2 Coated Pipe: 0 Steel Risers: 0 Low Pressure:

1965 Bare Pipe: Anodeless Risers: High Pressure:

PE Pipe:

system main replaced with PE pipe and anodeless risers in 2004, bldg 3 converted to all electric utilities after fire

No. 081555, American Meter Co. meter (Iron Case)

Sprague with pilot 1 " I

Meter Description: Located between office and bldg. No. 2, feeds bldg's 1 and 2 and office

Unitcounter: 3 Coated Pipe: 0 Steel Risers: Low Pressure: 0 Year Constructed:

Other:

SizeP:

PSIG:

MM Serial #: Rockwell No. 601 6745

Regulator Mfg: Sprague ( 1 / 2 orifice)

Bare Pipe: 0 Anodeless Risers: 0 High Pressure:

PE Pipe: 0

ARKANSAS

Day1 E. Bassdt 1000 Center Commissioner P.O. Box400

C ~ O . H o n o n w e Chairman

(501) 682-1455 PUBLIC SERVICE COMMISSION

Little Rock, Arkansas 72203-0400 (501) 682-1453

David Newborn http://www.Arkansas.gov/psc Commissioner

(501) 682-1451

March 10,2008

Ms. Shirley Ellis Property Manager Rector-Phillips-Morse P. 0. Box 7300 Little Rock, AR 7221 79985

RE: 2008-1-M Crestwood Manor Apartments

Dear Ms. Shirley Ellis:

The Pipeline Safety Office (PSO) of the Arkansas Public Service Commission received your written response to the report. The information provided by your office to the PSO completes the inspection as required by the Arkansas Gas Pipeline Code.

In accordance with the Arkansas Gas Pipeline Code, Paragraph 190.17, the written response was accepted and the inspection report was closed on March I O , 2008.

If you have any questions concerning this notice, please catl mi office at (501) 682- 5716.

Sincerely ,

f&* Clint Stephens Chief, Pipeline Safety

CRESTWOOD MANOR 3802 Kavanaugh, Litttle Rock, 4R 72205

March 5,2008

Pipeline Safety Office Arkansas Public Service Commission P.O. Box 400 Little Rock, AR 72203-0400

To Whom It May Concern:

This is in responds to the notice of probable violation dated January 08,2008 report number 2008- 1 -M. Glen Rose with Security Cathodic Services conducted a survey on February 20,2008. Here are the results that he gave us: Test point No. 1 ANODE PROCTECTED RISER-BLDG. 8 -1.27

-1 .oo -1.26

NO. 2 ANODE PROCTECTED RISER-BLDG. 9 -EAST NO. 3 ANODE PROCTECTED RISER-BLDG. 9- NORTH

He also stated that the gas system on our property is composed o mixed materials including plastic, bare steel and coated steel. The monitoring results are the pipe-to-soil readings taken at the cathodically protected gas risers all exceeded the minimum required -850 mV. Other gas risers are either bare steel or anodeless risers.

If you need the copy from Mr. Rose please call and I will get that information to you. Please call if I can help in any other way.

Sincerely,

(/!!A - Velma Carter, ARM Resident Manager Crestwood Manor Apartments

CATHODIC PROTECTION MONITORING REPORT

2008

CRESTWOOD MANOR LITTLE ROCK, ARKANSAS

FEBRUARY 20,2008

Sex&& Cathodk Saulos, I= P. 0. Bax 30422 Lit& R t d , AR 72260-0122

CATHODIC PROTECTION SUMMARY

DATE OF SURVEY February 20,2008

OPERATOR Crestwood Manor Apartments

LOCATION Little Rock, Arkansas

GAS SYSTEM CHARACTERISTICS

Thegassystemonthispropertyiscomposedofmixedmaterialsincluding

bare steel, plastic and a short section of coated steel. There are time gas

risers with cathodic protection on the coated portion of the gas pipii.

MONITORING RESULTS

The pipe-to-soil readings taken at the m h d i d l y protected gas risers all

exceeded the minimum required -850 mV. Other gas risers are either bate

steel or anodeless risers.

i

~

f

C~btbD.Homrmbte Chai ian

D.yl E. B.sststt

(501) 682-1455

Commissioner (501) 882-1453

David Newbbm Commissioner (501) 882-1451

ARKANSAS PUBLIC SERVICE COWlMlSSiON

lo00 Center P.O. Box 400

Little Rock, Arkansas 72203.0400 http :/lmnw.Arkansas.gov/psc

March 10,2008

Ms. Velma Carter Resident Manager Crestwood Manor Apartments 3802 Kavanaugh Bouleuard Lime Rock, AR 72205

RE: 2008-14 Crestwood Manor Apartments

Dear Ms. Velma Carter:

The Pipeline Safety Office (PSO) of the Arkansas Public Service Commission received your written response to the report. The informatiin provided by your office to the PSO completes the inspection as required by the Arkansas Gas Pipeline Code.

In accordance with the Arkansas Gas Pipeline Code, Paragraph 190.17, the written response was accepted and the inspection report was dosed on March 10,2008.

If you have any questions concerning this notice, please cafl our offvce at (501) 682- 5716.

Clint Stephens Chief, Pipeline Safety