Internal Compliance Audits. Evan Martin Engineer Gas Standards and DOT Compliance

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1 Internal Compliance Audits Evan Martin Engineer Gas Standards and DOT Compliance

2 Goals for Today Spur meaningful discussion Share your companies procedures Ask Questions Walk away with new ideas, ways to improve 2

3 Black Hills Corporation Overview A growth-oriented, vertically-integrated energy company with a tradition of exemplary service and a vision to be the energy partner of choice. Based in Rapid City, S.D., the company serves 777,000 electric and gas utility customers in Colorado, Iowa, Kansas, Montana, Nebraska, South Dakota and Wyoming. The company generates wholesale electricity and produces natural gas, crude oil and coal. Employees partner to produce results that improve life with energy. Utilities, Power Generation & Fuel Production Utilities Electric Utilities Black Hills Power Cheyenne Light* Colorado Electric Gas Utilities Colorado Gas Iowa Gas Kansas Gas Nebraska Gas Non-Regulated Energy Power Generation Black Hills Electric Generation Coal Mining Wyodak Resources Oil and Gas Black Hills Exploration and Production * Utility supplies electric and gas service to Cheyenne, Wyoming and vicinity 3

4 Electric and Gas Utilities Electric Utilities* Generates, transmits and distributes electricity to approximately 206,000 customers and distributes natural gas to 36,000 customers Operations include Black Hills Power (SD, WY and MT), Cheyenne Light (WY) and Colorado Electric (CO) Includes 841 MW of generation and 8,565 miles of transmission and distribution lines East-West interconnection located near Rapid City, SD optimizes the off-system sale of power and improves system reliability (1 of only 7 east-west ties) Natural Gas Utilities* Distributes natural gas to approximately 543,000 customers in CO, IA, KS, NE and WY Includes 604 miles of intrastate gas transmission pipelines and 20,413 miles of gas distribution mains and service lines Provides contract appliance repair service to approximately 62,000 customers through Service Guard Program in CO, IA, KS and NE. * Information from 2014 Form 10-K, unless otherwise noted 4

5 Introductions Where are you from? Size and location of your company/facilities? What is your role? How does it relate to compliance? 5

6 How do you determine if O&M procedures are being followed? Does your company perform job site constructions audits? Audits for both contractors and company crews? Initial Audits for new Construction Crews? -1 st week At least one audit per month? What construction activities are audited? Who can perform these audits? What steps are taken when a deficiency is found? 6

7 What Records are you Auditing? Odorization Records? Odorometer Readings? Odorometer testing locations? Odorant Usage? 7

8 Corrosion Records? C.P. Zones Inspections? Isolated Services and short segments? IR Drop considered? Bare pipe surveys? C.P. Maps? Examination of exposed buried pipeline? Rectifier Inspections? Atmospheric Corrosion? Casing Surveys? Stray Current Surveys? 8

9 Leak Control/Patroling? Leak Surveys? CGI and FI Calibrations? EFV installation Records? Patrols Records? 9

10 Pressure Control Records? MAOP Documentation? Pressure Charts? DRS Inspections? Up-rating Records? Pressure Gauge Records? Pressure Testing Records? 10

11 Measurement? Meter Set Sizing Documents? Large Volume Meter Testing? 11

12 Emergency Plan Records? Emergency Plans? Emergency Valves? Emergency Training? 12

13 Construction? Construction Records? Materials? Construction Audits? 13

14 Programs? OQ Records? DIMP? TIMP? Public Awareness? 14

15 Facility Audits? Emergency Valves? Domestic Meter Sets? Large Volume Meter Sets? DRS/TBS? Line Markings? Cathodic Protection 15

16 Internal Compliance Audits How often are Internal Compliance Audits performed? Are the audits broken down by region, office or department? Who performs this type of audit at your company? How much staff is dedicated to this? How are the audits performed? Electronic records, paper records, field audits? How much time is dedicated to compliance audits? 16

17 Verifying Corrective Action Is there a formal process to verify corrective action after finding a construction audit deficiency? Is there a formal process to verify corrective action after finding a deficiency during internal compliance audit? How can you ensure that deficiencies are corrected going forward? 17

18 Final Questions What is the biggest challenge to ensuring compliance? What is one thing that could most improve compliance at your company? 18

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