Inspectionhistorical
PHMSA id-2016-gas-program-evaluation
2016 ID NG Program Evaluation - id-2016-gas-program-evaluation (Idaho; Natural Gas State Program Evaluation)
Current as of source date Government source
RegulusPipeline researchRegulusPipeline researchPHMSA id-2016-gas-program-evaluation
ID NG Program Evaluation, 2016, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2016 Gas State Program Evaluation for IDAHO 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: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 1#
ID NG Program Evaluation, 2016, page 22016 Gas State Program Evaluation -- CY 2016 Gas State Agency: Idaho Rating: Agency Status: Date of Visit: 06/05/2017 - 06/08/2017 Agency Representative: June 13, 2017 Mr. Joe Leckie Pipeline Safety Program Manager PHMSA Representative: June 13, 2017 Clint Stephens State Evaluator Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. Paul Kjellander, President Agency: Idaho Public Utilities Commission Address: 472 West Washington Street, P.O. Box 83720 City/State/Zip: Boise, Idaho 83720-0074 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 2016 (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 10 B Program Inspection Procedures 13 13 C Program Performance 49 43 D Compliance Activities 15 15 E Incident Investigations 11 11 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 118 112 State Rating................................................................................................................................................... 94.9 DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 2#
ID NG Program Evaluation, 2016, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Data is accurate and all units were inspected in calendar year 2016 . 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Review of inspection days was analyzed to differentiate construction days with standard inspections. Review of inspection days was found to be accurate 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Operators and operator inspection units are accurate in Attachment 3 of Progress Report. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: All incident reports were listed and information was correct. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were two compliance actions that were found to be accurate from Attachment 5 of Progress Report. 6 Were pipeline program files well-organized and accessible? - Progress Report 2 2 Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: All pipeline program files were well-organized and accessible. These files were kept in paperback form in cabinet drawer 3 in inspector's office and by Program Manager. 7 Was employee listing and completed training accurate and complete? - Progress Report 1 1 Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Employee listings and completed training was accurate and complete. New employee Bruce Perkins started employment in October 2016 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Idaho's rules and amendments for adoption has been reported accurately. 1 1 DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 3#
ID NG Program Evaluation, 2016, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Program Manager stated that he had reviewed the DPAP in 2016, but Attachment 10 states 'No'. Carrie Winslow was contacted on June 13, 2017 to change response. Idaho is in the process of identifying new master meters (universities) for jurisdiction. Idaho is still working with State Legislature to increase civil penalty to meet DOT guidelines. The State has put an emphasis on inspecting Intermountain Gas due to the number of farm taps which are not being inspected by operator. 10 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part A of the IPUC Program evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 4#
ID NG Program Evaluation, 2016, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 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 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Process for Standard Inspections is included in Sections 3.8, 7.2, and Attachment E of Program Operation Procedures (POP). 2 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 No = 0 Needs Improvement = .5 Evaluator Notes: Process for IMP/DIMP Inspections is included in Sections 3.10, 7.2, and Attachment E of POP. 1 1 3 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 No = 0 Needs Improvement = .5 Evaluator Notes: Process for OQ Inspections is included in Sections 3.9, 7.2, and Attachment E of POP. 1 1 4 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 No = 0 Needs Improvement = .5 Evaluator Notes: Process for Damage Prevention Inspections is included in Sections 3.12, 7.2, and Attachment E of POP. 1 1 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Process for On-Site Operator Training is included in Sections 3.13, 7.2, and Attachment E of POP. 1 1 6 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 No = 0 Needs Improvement = .5 Evaluator Notes: Process for Construction Inspections is included in Sections 3.11, 7.2, and Attachment E of POP. 1 1 DUNS: 102589939 2016 Gas State Program Evaluation 7 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 5#
ID NG Program Evaluation, 2016, page 6c. 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) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: Process for Inspection priorities is included in Sections 8.0 of POP. Idaho has a risk based inspection procedure that has not been implemented into the inspection priority process. Idaho will start to incorporate a risk based approach when establishing inspection priorities. Attachment B in the POP is used to score the risk based analysis. 8 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part B of the IPUC Program evaluation. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 6#
ID NG Program Evaluation, 2016, 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 Yes = 5 No = 0 5 0 A. Total Inspection Person Days (Attachment 2): 262.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 3.39 = 746.17 Ratio: A / B 262.00 / 746.17 = 0.35 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 0 Evaluator Notes: Ratio of Total Inspection person days does not meet requirement >=.38. Ratio = A/B = 262/ (220 x 3.39) = 262/745.8 = .35. Idaho will appeal results based on inspectors being at T&Q Training over half of the year in 2016. 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines Appendix C for requirements) Chapter 4.4 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 e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: Inspectors and Program Manager had fulfilled the T&Q Training requirements before conducting inspection as lead in 2016. 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 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, Pipeline Safety Program Manager indicated adequate knowledge of PHMSA program and regulations. 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 No = 0 Needs Improvement = 1 Evaluator Notes: Chair letter sent October 19, 2016, response received December 7, 2016. There were no issues. 2 2 5 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: Yes, there was a consolidated TQ Seminar with the States of WA, OR, and ID in May 2015. 1 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 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 7#
ID NG Program Evaluation, 2016, page 8The State inspected all operators and inspection units at intervals less than outlined in POP. Each operator has been inspected on an annual basis. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: For standard inspections in 2016, Idaho was using the IA inspection form, dated 1/20/16. Recommended that Idaho follow- up on inspections completed by Lyle Barthlome in 2016. Lyle left the IPUC on January 2017. Reviewed one of Lyle's inspection reports and found items that were incomplete and not documented in the report. 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 No = 0 Evaluator Notes: There was no cast iron pipe in the State of Idaho. 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 Yes = 1 No = 0 Evaluator Notes: There was no cast iron pipe in the State of Idaho. 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 Yes = 1 No = 0 1 1 Evaluator Notes: Reviewed form "IPUC Pipeline Safety Audit Inspection Checklist" (Form 2) which includes question for operator emergency response procedures for leaks caused by excavation damage near buildings. 11 Did the state review operator records of previous accidents and failures including 1 1 reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: Idaho collects data from annual reports on a "Leak Cause Spreadsheet" which list cause of leaks, excavation tickets, and excavation damage per 1000 tickets. Reviewed form "IPUC Pipeline Safety Audit Inspection Checklist" (Form 2) which included check operator records of previous accidents and failures including third party damage and leak response. 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 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: IPUC has reviewed operator annual reports, along with incident/accident reports and discovered that Avista Utilities had issues with not repairing all its leaks. IPUC with operator to discuss the issues to have all leaks classified and repaired. 13 DUNS: 102589939 2016 Gas State Program Evaluation Did state input all applicable OQ, DIMP/IMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 2 1 Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 8#
ID NG Program Evaluation, 2016, page 9Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: There were 11 OQ field inspections and 1 program inspection uploaded to the OQ database in 2016. There have been no IM inspections uploaded to the IMDB since 12/08/2011. 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, IPUC includes question in its PHMSA form 2 inspection checklist. 1 1 15 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A Drug and Alcohol inspection was performed on each operator in 2016 and those results were attached to the inspection reports that was reviewed during the evaluation. 16 Is state verifying operators OQ programs are up to date? This should include verification 2 2 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 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Northwest Gas OQ scheduled for October 2017; Intermountain Gas Co. OQ inspection performed in 2014 scheduled for November 2107, Avista OQ inspection performed in 2014 scheduled for 2017; and Questa OQ inspection performed in 2012 scheduled for 2017. Idaho performed 12 OQ protocol 9 inspections in 2016. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 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). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Intermountain Gas Co. IM inspection performed in 2015 scheduled for 2017; and Questar IM inspection performed in 2015 scheduled for 2017. 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 2 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). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P DIMP ? First round of program inspections should have been complete by December 2014 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: IPUC performed DIMP inspections on all operators in 2016. Questar previous DIMP performed in 2013; Avista previous DIMP performed in 2012; Intermountain Gas previous DIMP performed in 2013. 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. PAPEI Effectiveness Inspections should have been completed by December 2013. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 192.616 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: DUNS: 102589939 2016 Gas State Program Evaluation 2 2 Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 9#
ID NG Program Evaluation, 2016, page 10Intermountain Gas Co. PAP inspection performed in 2013 and 2016; Avista PAP inspection performed in 2014 and 2017; Questar PAP performed in 2014 and 2017; Northwest Gas Co. performed in 2017. Each operator is utilizing 3rd party consultants to verify effectiveness of PAP program. 20 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The Idaho State program will be working with the Pipeline Safety Trust to improve its website to include enforcement cases for the public view. The IPUC expects to have by 2018 transparency with enforcement cases and inspection reports being posted on website. 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: There were no open SRCRs for Idaho in 2016. 1 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 No = 0 Needs Improvement = .5 Evaluator Notes: Each operator is asked question which is included in the IPUC Form 2 (Supplemental Checklist). 1 1 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IPUC responded to surveys pertaining to jurisdictional gas storage facilities and States' use of IA. 1 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. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: There have been no active waivers or permits for IPUC in 2016. 1 1 25 Did the state attend the National NAPSR Board of Directors Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: IPUC attended the National NAPSR meeting in Indianapolis in 2016. 1 1 26 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: Idaho met with Avista to discuss leaks not being classified for repair. Leaks were being grouped together and not being scheduled for repair. Idaho is preparing a letter of concern to be mailed to the operator. DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 10#
ID NG Program Evaluation, 2016, page 11Gas Pipeline inspector qualification has decreased each year 2013-2015. The percentage of inspector staff that has the core training has decreased each year. As of 2016 the IPUC was fully staffed and two inspectors have completed their core courses. 27 Discussion with State on accuracy of inspection day information submitted into State Info Only Info Only Inspection Day Calculation Tool. (No points) Info Only = No Points Evaluator Notes: Idaho is concerned with not being able to meet the inspection days submitted in the inspection day calculation tool. Idaho has suggested to State Programs that the calculation tool should be opened up for modification of their numbers submitted as inspection days for the State of Idaho. Will not be able to meet those days in calculation tool without possibly an increase in budget funding and the inspectors increasing their inspection days in the field. Idaho needs to make modification of numbers in calculation tool to meet the 416 days compared with 262 inspection days in the 2016 Progress Report. Even with the 262 inspection days in 2016, IPUC did not meet the ratio of total inspection person days to total person days. 28 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Info Only Info Only Product Changes and Conversions to Service? See ADP-2014-04 (No Points) Info Only = No Points Evaluator Notes: Idaho contacted each operator in 2016 to notify them of the ADB and had them sign off on receiving the information and to inform the IPUC if they had any pipeline flow reversals, product changes, or conversions to service. Idaho could not find operators' submittal letters of return, so this should be reviewed for the CY2017 evaluation. 29 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: There were two issues identified in Part C of the evaluation. The IPUC did not meet the ratio of total inspection person days to total person days at >=.38. The IPUC ratio was calculated to .35. Lastly, the IPUC had not uploaded IM inspections into the IMDB since 12/08/2011. Total points scored for this section: 43 Total possible points for this section: 49 DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 11#
ID NG Program Evaluation, 2016, page 12PART 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 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 c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: Procedures are contained in Sections 5.5-5.7 of POP. 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 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. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Were applicable civil penalties outlined in correspondence with operator(s) Yes No Needs Improvement Evaluator Notes: Procedure included in POP 5.7. Idaho had two compliance actions in 2016 and the reports were mailed to the VP, Operations (Intermountain Gas, Co ? Hart Gilchrist) and Director, Natural Gas (Avista Corp, - Mike Faulkenberry). Probable violations were documented for both Intermountain Gas and Avista Corp. There were a total of five probable violations cited and they have not been resolved as of the date of this Program Evaluation. Idaho has scheduled meetings with both operators in June 2017 to resolve issues. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Avista, Corp.). Yes, all probable violations that warranted did have compliance actions issued to the operators (Intermountain Gas Co. and 4 Did compliance actions give reasonable due process to all parties? Including "show 2 2 cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes, the IPUC has not gotten to the stage of a show cause hearing with compliance actions that were issued in 2016. IPUC scheduled to meet with parties to discuss issues in June 2017. 5 Is the program manager familiar with state process for imposing civil penalties? Were 2 2 civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Procedures included in 5.7 of POP. Yes, the Program Manager has shown familiarity of the state process for imposing civil penalties. 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 1 1 DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 12#
ID NG Program Evaluation, 2016, page 13Evaluator Notes: The State of Idaho has not issued a fine in 10 years. The Idaho Program started writing more compliance actions in 2012, with 12 compliance actions issued to the date. Those compliance actions were resolved with no civil penalties being assessed. There are two compliance actions open in 2017 from inspections performed in 2016 with the possibility of civil penalties being assessed due to the nature of the probable violations. 7 General Comments: Info Only = No Points Evaluator Notes: There were no issues in Part D of the IPUC Program evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 13#
ID NG Program Evaluation, 2016, page 14PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Procedures is included in Section 6.0. of POP. 2 2 2 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 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: Procedures is included in Sections 6.2 and 6.5 of POP. The Program Manager is contacted by operator to report incidents after-hours. 3 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 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Procedures is included in Sections 3.15, 6.1, and 6.6 of POP. Idaho had two incidents in 2016 and performed a follow-up visit to investigate status of equipment failures. 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? 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: Procedures is included in Sections 6.6-6.7 of POP. Idaho had two incidents in 2016 and performed a follow-up visit to investigate status of equipment failures. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: 1 1 There were two incidents that occurred in 2016, and there were no violations found during the follow-up visits. 6 Did the state assist region office 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 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Procedure is included in Section 6.5 of POP. There were no PHMSA reportable accidents in 2016 for the State of Idaho. 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 DUNS: 102589939 2016 Gas State Program Evaluation 1 1 Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 14#
ID NG Program Evaluation, 2016, page 15Evaluator Notes: Yes, a video was presented from Mr. Kevin Henderson, State of Oregon, which outlined investigation process and writing a comprehensive accident report. 8 General Comments: Info Only = No Points Evaluator Notes: There were no issues in Part E of the IPUC Program evaluation. Info Only Info Only Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 15#
ID NG Program Evaluation, 2016, page 16PART F - Damage Prevention Points(MAX) Score 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 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Procedure is included in Section 3.4 of POP. Idaho has question contained in its IPUC Form 2 (Supplemental Checklist) 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? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Procedure is included in Section 3.12 of POP. Idaho has question contained in its IPUC Form 2 (Supplemental Checklist) 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.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: IPUC is involved with a coalition to strengthen damage prevention laws with the establishment of the Damage Prevention Board; and IPUC encourages operators report to "DIRT". 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) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Idaho collects the data, but will be implementing a process to evaluate this data for trends on the number of pipeline damages per 1,000 locate requests. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues in Part F of the IPUC Program evaluation. Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 16#
ID NG Program Evaluation, 2016, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Intermountain Gas Co. Name of State Inspector(s) Observed: Robert Jamison and Darrin Ulmer Location of Inspection: 4050 Can Ada Road, Nampa, ID 83687 Date of Inspection: June 6, 2017 Name of PHMSA Representative: Clint Stephens Evaluator Notes: The IPUC performed a standard LNG inspection. Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 1 1 Evaluator Notes: Yes. The operator was notified and was present during the inspection. 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist 2 2 used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Idaho used the "PHMSA Form 4 (IA Equivalent) Standard Inspection Report of an LNG Facility", dated May 2015, during the inspection. 4 Did the inspector thoroughly document results of the inspection? 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The inspector thoroughly documented the results of the inspection. Those results were recorded on the IA equivalent LNG 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.) Yes = 1 No = 0 Evaluator Notes: Schematic diagram for the plant layout. 1 1 2 2 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: Yes, the inspectors reviewed records and procedures pertaining to operation, start-up/shutdown, reporting, emergency response, and control systems. During the field activities the inspector observed areas for atmospheric corrosion, ESDs, emergency exits, and fire equipment. DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 17#
ID NG Program Evaluation, 2016, page 187 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes. The inspector had adequate knowledge of the pipeline safety program and regulations during the inspection. 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) Yes = 1 No = 0 Evaluator Notes: Two recommendations made by the inspector were not having procedures for taking LNG tank out-of service and no documentation pertaining to NPMS submittals annually. 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: There were probable violations found during the inspections; however, the inspector did identify areas of concern (recommendations) during the exit interview. 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) 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 Info Only Info Only DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 18#
ID NG Program Evaluation, 2016, page 19C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: During the field activities the inspector observed areas for atmospheric corrosion, ESDs, emergency exits, and fire equipment. The inspector performed its duties adequately during the field activities. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 19#
ID NG Program Evaluation, 2016, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IPUC is not an interstate agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IPUC is not an interstate agent. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IPUC is not an interstate agent. 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.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IPUC is not an interstate agent. 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? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IPUC is not an interstate agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IPUC is not an interstate agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IPUC is not an interstate agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: IPUC is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 20#
ID NG Program Evaluation, 2016, page 21PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IPUC has no 60106 Agreement. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IPUC has no 60106 Agreement. 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.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IPUC has no 60106 Agreement. 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? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IPUC has no 60106 Agreement. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IPUC has no 60106 Agreement. 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: IPUC has no 60106 Agreement. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: IPUC has no 60106 Agreement. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 102589939 2016 Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 21#
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