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PHMSA co2012ngprogramevaluation
2012 CO NG Program Evaluation - co2012ngprogramevaluation (Colorado; Natural Gas State Program Evaluation)
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CO NG Program Evaluation, 2012, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2012 Natural Gas State Program Evaluation for COLORADO PUBLIC UTILITIES COMMISSION 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 -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 1#
CO NG Program Evaluation, 2012, page 22012 Natural Gas State Program Evaluation -- CY 2012 Natural Gas State Agency: Colorado Rating: Agency Status: Date of Visit: 04/15/2013 - 04/19/2013 Agency Representative: Steve Pott, Chief Gas Pipeline Safety PHMSA Representative: Glynn Blanton, DOT/PHMSA State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: Joshua B. Epel, Chairman Agency: Colorado Public Utilities Commission Address: 1560 Broadway Suite 250 City/State/Zip: Denver, Colorado 80202 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 2012 (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. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 9 B Program Inspection Procedures 15 14 C Program Performance 46 43 D Compliance Activities 15 15 E Incident Investigations 9 9 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 115 110 State Rating................................................................................................................................................... 95.7 DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 2#
CO NG Program Evaluation, 2012, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress 1 0.5 Report Attachment 1 (A1a) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Information entered into Attachment 1 was incorrect. A review found the "Other" category for Distribution showed X/60105P. The information should be classified as "A" None in state and does not have jurisdiction. Needs improvement and half a point were deducted. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 (A1b) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: A review of attachment 2 pertaining to Drug & Alcohol inspections was discussed with State Program Manager. It was suggested the number of inspections need to be entered on the form since the engineer is reviewing the information during the standard inspection. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 (A1c) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The number of operators and inspection units on Attachment 3 match the records maintained by CO PUC. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress 1 1 Report Attachment 4 (A1d) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, a review of PHMSA's ODES database indicated incidents were reported as shown on Attachment 4 correctly. The investigation into the incident that occurred on 12/11/2012 on Public Service of Colorado facilities near Williams FK compressor has been completed by CO PUC. The cause of the incident was due to corrosion. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 (A1e) Yes = 1 No = 0 Needs Improvement = .5 1 0.5 Evaluator Notes: A review found the number of violations to be corrected at end of Calendar Year 2012 was 13 not 9. Needs improvement. Half a point was deducted. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 (A1f, A4) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A review of program files found the information is being maintained in the State Program Manager's office. Inspection reports contain a cover sheet that provides information on the type of inspection performed and violations cited. No areas of concerns. 7 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 (A1g) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A detailed review of employees listed on attachment 7 was conducted posting the date each individual completed the TQ courses. The Gas IM Lead inspector has not completed the PL31C course. However, information on the attachment 7 was found correct. DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 3#
CO NG Program Evaluation, 2012, page 48 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report 1 1 Attachment 8 (A1h) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A review of PHMSA State Program rules and regulations in SharePoint for CO PUC indicate civil penalty amounts for pipeline safety regulations match the federal amounts. All federal regulations pertaining to Part 192, 193, 198 and 199 have been adopted except for 198 (h) and amendments 115, 116 & 117. It is anticipated these regulations will be adopted in CY2013. 9 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 (H1-3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, CO PUC provided a description of their planned annual and long term goals for the pipeline safety program in attachment 10. 10 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: A.1 Information entered into Attachment 1 was incorrect. A review found the "Other" category for Distribution showed X/60105P. The information should be classified as "A" None in state and does not have jurisdiction. Needs improvement and half a point were deducted. A.5 A review found the number of violations to be corrected at end of Calendar Year 2012 was 13 not 9. Needs improvement and half a point was deducted. Total points scored for this section: 9 Total possible points for this section: 10 DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 4#
CO NG Program Evaluation, 2012, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspections (B1a) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This information is located on CPUC Program Guidelines document page 37. No issues. 2 2 2 IMP Inspections (including DIMP) (B1b) 1 0.5 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: CPUC Program Guideline document did not contain established frequencies or risk based methods to schedule the IMP and DIMP inspections. Needs improvement and a loss of 0.5 points occurred. 3 OQ Inspections (B1c) 1 0.5 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: CPUC Program Guideline document did not contain established frequencies or risk based methods to schedule the OQ Inspections. Needs improvement and a loss of 0.5 points occurred. 4 Damage Prevention Inspections (B1d) 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: This information is located on CPUC Program Guidelines document page 37. 5 On-Site Operator Training (B1e) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A review of CPUC Program Guideline found this information on page 38. 1 1 6 Construction Inspections (B1f) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: to the document. A review of CPUC Program Guideline found this information on page 38. It was suggested a copy of CPUC form be added 7 Incident/Accident Investigations (B1g) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: This information is located CPUC Program Guideline Appendix A. No issues or areas of concern. 8 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? (B2a-d, G1,2,4) Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection 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 areas, 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) DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 5#
CO NG Program Evaluation, 2012, page 6f. Are inspection units broken down appropriately? Evaluator Notes: Yes No Needs Improvement Yes, CPUC inspects all operators on a risk ranking model or within two years from the last standard inspection performed. 9 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: B.2 CPUC Program Guideline document did not contain established frequencies or risk based methods to schedule the IMP and DIMP inspections. Needs improvement and a loss of 0.5 points occurred. B.3 CPUC Program Guideline document did not contain established frequencies or risk based methods to schedule the OQ Inspections. Needs improvement and a loss of 0.5 points occurred Total points scored for this section: 14 Total possible points for this section: 15 DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 6#
CO NG Program Evaluation, 2012, 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 (A12) Yes = 5 No = 0 5 5 A. Total Inspection Person Days (Attachment 2): 523.70 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 3.00 = 660.00 Ratio: A / B 523.70 / 660.00 = 0.79 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: A. Total Inspection Person Days (Attachment 2) =523.7 B. Total Inspection Person Days charged to the program (220* Number of Inspection person years =220x 3.0=660 Formula Ratio A/B = 523.7/660 = 0.79 Five points awarded. No issues 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 4 Guidelines for requirements) Chapter 4.4 (A8-A11, G19) 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 DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement Evaluator Notes: Lead inspector for IMP has not completed required training course. A review of training records found one course has not been completed. Therefore, one point was deducted. 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 (A5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Program Manager demonstrated a good working knowledge about the pipeline safety program. 2 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 (A6-7) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, Chairman Epel response letter was received on December 17, 2012 and within the 60 day time requirement. 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 (A3) Yes = 2 No = 0 Evaluator Notes: Yes, the pipeline safety seminar was held on March 13-14, 2012 in Colorado Springs, CO. 2 2 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 (B3) Yes = 5 No = 0 Needs Improvement = 1-4 5 5 DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 7#
CO NG Program Evaluation, 2012, page 8Evaluator Notes: Yes, in accordance to their procedures. 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 (B4-5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: CPUC uses the Federal inspection form. No issues. 2 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 (B7) Yes = 1 No = 0 Evaluator Notes: Yes, this is reviewed during the inspection visit and contained in the federal inspection form. 1 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 history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 (B8) Yes = 1 No = 0 Evaluator Notes: Yes, this is reviewed during the standard inspection. 1 1 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 (B9) Yes = 1 No = 0 Evaluator Notes: Yes, this is reviewed during each inspection. 1 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 (B10,E5) Yes = 1 No = 0 Evaluator Notes: Yes. 1 1 12 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Data Initiative (G6-9,G16) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this item is annually reviewed by one of the staff members. 2 2 13 Did state input all applicable OQ, IMP inspection results into federal database in a timely 2 0 manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 (G10-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: No. This item was previously reviewed with Program Manager and no action was taken to upload OQ & IM data into the federal database. Two points were deducted. DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 8#
CO NG Program Evaluation, 2012, page 914 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? (G14) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes, this information was reviewed by program manager or inspector by accessing the NPMS database and reviewing Black Hills Energy, Excel Energy and Source Gas submissions. 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 (I1-3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is reviewed and checked during the standard inspection review. 2 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 operators plan. 49 CFR 192 Part N (I4-7) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is performed during their standard inspection visit. 2 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 operators plan(s). 49 CFR 192 Subpart 0 (I8-12) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes. This is reviewed during semi-annual meetings with the companies on DIMP and IMP progress reports. 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 operators plan(s). 49 CFR 192 Subpart P DIMP ? First round of program inspections should be complete by December 2014 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, performed during the standard inspection review. They are using the federal inspection form. 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 (I13-16) PAPEI Effectiveness Inspections should be complete by December 2013 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. CPUC is using the federal PHMSA Form 21 to inspect the operator. Information is uploaded into the federal database. 20 DUNS: 106621282 2012 Natural Gas State Program Evaluation 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). (G20-21) Yes = 1 No = 0 Needs Improvement = .5 1 1 Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 9#
CO NG Program Evaluation, 2012, page 10Evaluator Notes: CPUC uses email notification to operators about changes in the pipeline safety regulations, bulletin notices and incidents that could affect the operator's facilities. 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 (B6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes, several SRC's were reviewed with Jerry Kenerson, PHMSA Western Region office. No issues or concerns were found. 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? (G13) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. This item is mentioned on the federal inspection form. 1 1 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? (H4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, no issues. 1 1 24 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: C.2 Lead inspector for DIMP/IMP has not completed required training course. A review of training records found one course has not been completed. Therefore, one point was deducted. C.13 No. This item was previously reviewed with Program Manager and no action was taken to upload OQ & IM data into the federal database. Two points were deducted. Total points scored for this section: 43 Total possible points for this section: 46 DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 10#
CO NG Program Evaluation, 2012, 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 (B12-14, B16, B1h) 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 Evaluator Notes: Yes, this is listed on page 35 of CO PUC Guidelines. However, additional examples of probable violations or warning letters need to be added to the document. 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? Chapter 5.1 (B11,B18,B19) Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Were probable violations documented? Yes No Needs Improvement c. Were probable violations resolved? Yes No Needs Improvement d. Was the progress of probable violations routinely reviewed? Yes No Needs Improvement Evaluator Notes: Yes, a review of office files and reports located in the program manager's office showed probable violations are issued and tracked. An example, the letter to the City Manager of Aguilar, CO 3 Did the state issue compliance actions for all probable violations discovered? (B15) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Action was taken when the operator failed to correct the probable violations. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. (B17, B20) Yes = 2 No = 0 Evaluator Notes: Yes. No areas of concern. 2 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) (B27) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. 2 2 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 1 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, CY2011 CPUC assessed and collected a civil fine of $150,000 against Excel Energy for non-compliance with safety regulations pertaining to the steel pipeline crossing at Platte River East of the Intersection of 88th Avenue and Colorado Blvd. 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 106621282 2012 Natural Gas State Program Evaluation Info Only Info Only Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 11#
CO NG Program Evaluation, 2012, page 12No loss of points occurred in this section. Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 12#
CO NG Program Evaluation, 2012, page 13PART E - Incident Investigations Points(MAX) Score 1 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 (A2,D1-3) 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. No issues. 2 If onsite investigation was not made, did state obtain sufficient information from the 1 1 operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 (D4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A review of the CPUC incident file folder indicated 6 potential incidents occurred in 2012. Information on the onsite investigations were in individual file folders. No issues. 3 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? (D5) 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 when appropriate Yes No Needs Improvement Evaluator Notes: Yes. No issues or areas of concern. 4 Did the state initiate compliance action for violations found during any incident/accident investigation? (D6) Yes = 1 No = 0 Evaluator Notes: No violations were sited or found during the investigation of the incidents for CY2012. 1 1 5 Did the state assist region office by taking appropriate follow-up actions related to the 1 1 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 (D7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, correspondence between PHMSA Western Region was maintained for follow-up action related to operator incident reports. No areas of concern. 6 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) (G15) Yes = 1 No = 0 Evaluator Notes: Information on incidents/accidents was discussed during the 2012 NAPSR Western Region Meeting. 1 1 7 General Comments: Info Only = No Points Evaluator Notes: DUNS: 106621282 2012 Natural Gas State Program Evaluation Info Only Info Only Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 13#
CO NG Program Evaluation, 2012, page 14No loss of points occurred in this section. Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 14#
CO NG Program Evaluation, 2012, 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? NTSB (E1) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, CPUC has two questions listed on the Standard Inspection Report of a Gas Distribution System about this item. Questions are listed on page 2, section 192.614(c). 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? (E2) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, this is discussed with the operator and verified in accordance to their written plan. 2 2 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) (E3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: CPUC working with CO One Call organization has attended several public awareness meetings with contractors and utility representatives promoting damage prevention. An example, February 15, 2012 CPUC attend the Greeley, CO meeting presenting information to over 400 people in attendance. 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) (E4,G5) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, CPUC has created a new Gas Pipeline Safety Database via rulemaking which requires all natural gas distribution operators to report damages occurring on their facilities. This information is being used to establish a risk ranking in performing gas pipeline safety inspections. 5 General Comments: Info Only = No Points Evaluator Notes: No loss of points occurred in this section. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 15#
CO NG Program Evaluation, 2012, 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: Colorado Natural Gas Name of State Inspector(s) Observed: Steve Potts Location of Inspection: Littleton, Colorado Date of Inspection: April 18, 2013 Name of PHMSA Representative: Glynn Blanton, USDOT/PHMSA State Programs Evaluator Notes: Due to inclement weather, the inspection was conducted in the operator's headquarter office. This was a DIMP records review and compliance inspection. No field observation was performed. 2 Was the operator or operator's representative notified and/or given the opportunity to be 1 1 present during inspection? (F2) Yes = 1 No = 0 Evaluator Notes: The operator was notified on Monday, April 15, 2013 about the inspection. The following personnel were present. Michelle Moorman, Director Regulatory Affairs, Bill Shaw, Colorado Operations Manager & David Crosby, Regulatory Program Analysis. 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) (F3) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, Steve Pott used DIMP inspection form for Operators of Gas Distribution System version 9/23/2011. 2 2 4 Did the inspector thoroughly document results of the inspection? (F4) 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, each question was asked to the operator and the response recorded in the DIMP inspection form. 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.) (F5) Yes = 1 No = 0 Evaluator Notes: Records and information on the operator's system was available during the inspection. 1 1 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) (F7) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: Yes. No field inspection was performed due to inclement weather. 2 2 DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 16#
CO NG Program Evaluation, 2012, page 177 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) (F8) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, he demonstrated an excellent knowledge about the regulations and DIMP requirements. 2 2 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) (F9) Yes = 1 No = 0 Evaluator Notes: Yes, areas of concern were discussed during the inspection and at the end of the exit interview. No issues or areas of concern. 9 During the exit interview, did the inspector identify probable violations found during the inspections? (if applicable) (F10) Yes = 1 No = 0 Evaluator Notes: No violations were found or noted during the inspection. 1 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. 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 D. Valve Maintenance E. Vault Maintenance DUNS: 106621282 2012 Natural Gas State Program Evaluation Info Only Info Only Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 17#
CO NG Program Evaluation, 2012, page 18F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: This was a DIMP Program Review Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 18#
CO NG Program Evaluation, 2012, page 19PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (C1) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? (C2) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? (C3) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 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.) (C4) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 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? (C5) Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? (C6) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? (C7) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 19#
CO NG Program Evaluation, 2012, page 20PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? (B21) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? (B22) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 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.) (B23) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 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? (B24) Yes = 1 No = 0 Needs Improvement = .5 1 NA Evaluator Notes: 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? (B25) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? (B26) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 106621282 2012 Natural Gas State Program Evaluation Colorado COLORADO PUBLIC UTILITIES COMMISSION, Page: 20#
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