# 2009 ID NG Program Evaluation - id2009ngprogramevaluation (Idaho; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA id2009ngprogramevaluation
- **title:** 2009 ID NG Program Evaluation - id2009ngprogramevaluation (Idaho; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2009-01-01
- **effective on:** Not available
- **summary:** 2009 PHMSA natural gas program evaluation for Idaho.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/subdoc/521/id2009ngprogramevaluation.pdf
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1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2009 Natural Gas State Program Evaluation for IDAHO PUBLIC UTILITIES COMMISSION Document Legend PART: O -- Representative Date and Title Information A -- General Program Qualifications B -- Inspections and Compliance - Procedures/Records/Performance C -- Interstate Agent States D -- Incident Investigations E -- Damage Prevention Initiatives F -- Field Inspection G -- PHMSA Initiatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 102589939 2009 Natural Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 1

2009 Natural Gas State Program Evaluation -- CY 2009 Natural Gas State Agency: Idaho Rating: Agency Status: 60105(a): Yes 60106(a): No Interstate Agent: No Date of Visit: 10/17/2010 - 10/22/2010 Agency Representative: Ellis Hire, Inspector & Ron Law, Executive Administrator, Idaho Public Utilities Commission PHMSA Representative: Patrick Gaume Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. Jim Kemptom, Chairman Agency: Idaho Public Utilities Commission Address: (472 W Washington St, 83702) PO Box 83720 City/State/Zip: Boise, Idaho 83720-0074 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 2009 (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 certification/agreement attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART F): 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 F, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A General Program Qualifications 26 26 B Inspections and Compliance - Procedures/Records/Performance 17 17 C Interstate Agent States 0 0 D Incident Investigations 6 6 E Damage Prevention Initiatives 9 9 F Field Inspection 10 10 G PHMSA Initiatives - Strategic Plan 10 10 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 90 90 State Rating................................................................................................................................................... 100.0 DUNS: 102589939 2009 Natural Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 2

PART A - General Program Qualifications Points(MAX) Score 8 8 1 Did the state submit complete and accurate information on the attachments to its most current 60105(a) Certification/60106 (a) Agreement? (NOTE: PHMSA Representative to verify certification/agreement attachments by reviewing appropriate state documentation. Score a deficiency in any one area as "needs improvement". Attachment numbers appear in parenthesis) Previous Question A.1, Items a-h worth 1 point each Yes = 8 No = 0 Needs Minor Improvement = 3-7 Needs Major Improvement = 2 a. State Jurisdiction and agent status over gas facilities (1) b. Total state inspection activity (2) c. Gas facilities subject to state safety jurisdiction (3) d. Gas pipeline incidents (4) e. State compliance actions (5) f. State record maintenance and reporting (6) g. State employees directly involved in the gas pipeline safety program (7) h. State compliance with Federal requirements (8) SLR Notes: A.1 Yes, 8 points, but will make comments about Attachment 1, 6, & 7. A---on Attachment 1 make it clear that you are a 60105 Agent Status; code 'F' under Transmission Interstate should likely be changed to code 'B'. B---attachment 2, with 135 inspection days, okay. C---Attachment 3 okay. D--- attachment 4 okay. E---attachment 5 okay, it is of interest to note that there were NO probable violations in 2009. (there are 4 so far in 2010). F---attachment 6 okay, Please be more descriptive of records maintained. G---attachment 7, training & 1.03 inspection years. Two completion dates are juxtaposed and Completed Course PL3OQ 7/08 completion is not shown for Ellis Hire. Completed courses PL3OQ, PL3296, PL1297, & PL31C are not shown for Lysle Bartolome. H---okay 2 Did the state have an adequate mechanism to receive operator reporting of incidents to ensure state compliance with 60105(a) Certification/60106(a) Agreement requirements (fatality, injury requiring hospitalization, property damage exceeding $50,000 - Mechanism should include receiving "after hours" reports)? (Chapter 6) Previous Question A.2 Yes = 1 No = 0 SLR Notes: A.2 Yes, see Nat Gas Pipeline Safety Program-Program Operating Procedures (POP) 1 1 3 Has the state held a pipeline safety TQ seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar or if state requested seminar, but T&Q could not provide, indicate date of state request for seminar. Seminars must be held at least once every 3 calendar years.) (Chapter 8.5) Previous Question A.4 Yes = 2 No = 0 SLR Notes: A.3 Yes, in-state in May, 2008, & also with Oregon at Portland in June, 2009 2 2 4 Were pipeline safety program files well-organized and accessible?(NOTE: This also includes electronic files) (Chapter 5) Previous Question A.5 Yes = 1 No = 0 SLR Notes: A.4 Yes, the files are in a file cabinet next to Ron Law's office 1 1 5 Did state records and discussions with the state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? (Chapter 4.1, Chapter 8.1) Previous Question A.6 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: A.5 Yes, Ellis and Ron have a professional knowledge of the 49 CFR 190-194 regulations 6 Did the state respond in writing within 60 days to the requested items in the Chairman's letter following the Region's last program evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8 Yes = 1 No = 0 1 1 SLR Notes: A.6 Yes, no response was required. Ron Law did respond to the State Liaison letter DUNS: 102589939 2009 Natural Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 3

7 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the 1 1 previous year? Did actions correct or address deficiencies from previous year's evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8/A.9 Yes = 1 No = 0 SLR Notes: Awareness Programs A.7 Yes, no response was required. Ron Law's letter addressed that Inspectors are verifying that Operators are evaluating the effectiveness of their Public Personnel and Qualifications 8 Has each inspector fulfilled the 3 year TQ training requirement? If No, has the state been granted a waiver regarding TQ courses by the Associate Administrator for Pipeline Safety? (NOTE: If the State has new inspectors who have not attended all TQ courses, but are in a program which will achieve the completion of all applicable courses within 3 years of taking first course (5 years to sucessfully complete), or if a waiver has been granted by the applicable Region Director for the state, please answer yes.) (Chapter 4.4) Previous Question A.10 Yes = 3 No = 0 SLR Notes: A.8 Yes, both inspectors are trained. They are on track for the new HAZWOPR Training 3 3 9 Brief Description of Non-TQ training Activities: Info Only = No Points Info Only Info Only For State Personnel: State personnel- One inspector has taken Root Cause Analysis. For Operators: Operators- PUC is finding ways to have yearly Pipeline Safety Seminars, either in-state or joint with other State partners with the locations rotating. For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: Non-Operator- there were no activities in 2009 SLR Notes: A.9 info only. State personnel- One inspector has taken Root Cause Analysis. Operators- PUC is finding ways to have yearly Pipeline Safety Seminars, either in-state or joint with other State partners with the locations rotating. Non-Operator- there were no activities in 2009 10 Did the lead inspectors complete all required T&Q OQ courses and Computer Based Training (CBT) before conducting OQ Inspections? (Chapter 4.4.1) Previous Question A.12 Yes = 1 No = 0 SLR Notes: A.10 Yes, Ellis Hire was trained in July 2008 & Bud Barthlome was trained in Dec 2003. Course PL3OQ, (formerly 299) 1 1 11 Did the lead inspectors complete all required TQ Integrity Management (IMP) Courses/Seminars and CBT before conducting IMP Inspections? (Chapter 4.4.1) Previous Question A.13 Yes = 1 No = 0 1 1 SLR Notes: A.11 Yes, Ellis Hire was trained in PL1297 10/07, PL3293 4/08, & PL3254 4/08; PL3292 is NA because Idaho has no piggable pipe in HCAs. Bud Barthlome was trained in PL1297 4/05, PL3293 7/02, & PL3254 3/02; PL3292 is NA because Idaho has no piggable pipe in HCAs 12 Was the ratio acceptable of Total inspection Person-days to Total Person-days charged to the program by state inspectors? (Region Director may modify points for just cause) (Chapter 4.3) Previous Question B.12 Yes = 5 No = 0 5 5 A. Total Inspection Person Days (Attachment 2): 135.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 1.03 = 226.60 Ratio: A / B 135.00 / 226.60 = 0.60 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 SLR Notes: A.12- Yes. a- '09 total inspection days 135. DUNS: 102589939 2009 Natural Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 4

b- person days '09 is 1.03*220=226.6 days. c-score=A/B '09 score=135/226.6=.596. .596 is greater than .38. Okay 13 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Info Only Info Only Question B.13 Info Only = No Points SLR Notes: Management A.13. ? Staffing levels have remained the same with two trained inspectors each working about 50% on Pipeline Safety. Ron Law provides the Program 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: A.14 Last year, Oregon, Washington and Idaho worked together to sponsor a joint T&Q training seminar. The training was held June 17 ? 18, 2009, in Portland, Oregon. We plan to continue this joint effort, rotating the training year-to-year between the three states. In 2009, the IPUC program manager and inspectors met off site with Intermountain Gas Company senior company officials and satellite unit managers for an "annual exit interview." PowerPoint presentations were presented to the company illustrating any areas of concern that we had and recommendations. The presentations also covered follow-up procedures, new regulations, and the requirements followed by our inspectors in conducting inspections. As a result of the meeting, the company put new procedures in place to address our concerns and recommendations. It was a very productive meeting, and we plan to continue to hold these meetings Total points scored for this section: 26 Total possible points for this section: 26 DUNS: 102589939 2009 Natural Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 5

PART B - Inspections and Compliance - Procedures/Records/ Performance Points(MAX) Score Inspection Procedures 1 Does the State have a written inspection plan to complete the following? (all types of operators including LNG) 6.5 6.5 (Chapter 5.1) Previous Question B.1 + Chapter 5 Changes + Incorporate LNG Yes = 6.5 No = 0 Needs Improvement = 50% Deduction a Standard Inspections (Including LNG) (Max points = 2) b IMP Inspections (Including DIMP) (Max points = .5) c OQ Inspections (Max points = .5) d Damage Prevention (Max points = .5) e On-Site Operator Training (Max points = .5) f Construction Inspections (Max points = .5) g Incident/Accident Investigations (Max points = 1) h Compliance Follow-up (Max points = 1) Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement SLR Notes: B.1. Yes a- POP 1.5, 3.1 b- POP 1.5, 3.10 c- POP 1.5, 3.9 d- POP 1.5, 3.12 part of the Std Insp e- POP 1.5, 3.13 is opportunistically observed during Std Insp as available. Also the annual Pipeline Safety Seminars f- POP 1.5, 3.11 g- POP 1.5, 3.15, 3.20 h- POP 1.5, 3.7, 3.20, 5.3, 6.5 2 Did the written Procedures for selecting operators adequately address key concerns? (Chapter 5.1) Previous 2 2 Question B.2, items a-d are worth .5 point each Yes = 2 No = 0 Needs Improvement = 50% Deduction a Length of time since last inspection Yes No Needs Improvement b History of Operator/unit and/or location (including leakage , incident and compliance history) Yes No Needs Improvement c Type of activity being undertaken by operator (construction etc) Yes No Needs Improvement d For large operators, rotation of locations inspected Yes No Needs Improvement SLR Notes: B.2 Yes see POP 3.19 and attachment B Inspection Performance 3 Did the state inspect all types of operators and inspection units in accordance with time intervals established in its written procedures? (Chapter 5.1) Previous Question B.3 Yes = 2 No = 0 SLR Notes: B.3 Yes, most Units are inspected yearly. OQ & IMP will start being due in 2011. Damage Prevention is part of Std Insp 2 2 4 Did the state inspection form cover all applicable code requirements addressed on the Federal Inspection forms? (Chapter 5.1 (3)) Previous Question B.4 Yes = 1 No = 0 SLR Notes: B.4- Yes, Idaho uses the federal forms 1 1 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 1 1 Yes = 1 No = 0 SLR Notes: B.5- Yes. A spot check of OQ and Standard inspections showed the reports to be complete. U, NA, and NC items were generally explained, I advised that U, NA, and NC items need to be explained such that Supervision can defend the inspection to a third party. We observed that there were no violations in 2009, and discussed that inspection reports need to be consistent with the NOPV letters 6 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.6 Yes = .5 No = 0 SLR Notes: DUNS: 102589939 2009 Natural Gas State Program Evaluation .5 NA Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 6

B.6- NA no SRCR in 2009 7 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) Previous Question B.7 Yes = .5 No = 0 SLR Notes: B.7- NA no cast iron in Idaho and they never had any .5 NA 8 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) Previous Question B.8 Yes = .5 No = 0 SLR Notes: B.8- NA no cast iron in Idaho and they never had any .5 NA 9 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) Previous Question B.9 Yes = .5 No = 0 .5 .5 SLR Notes: B.9- Yes, with only 4 operators it was easy for IPUC to ask this question of all operators in 2009. They have agreed to create an addendum sheet and place these questions on it. The addendum sheet will be attached to Standard Inspections 10 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? (NTSB) Previous Question 1 1 B.10 Yes = 1 No = 0 SLR Notes: B.10 ? Yes, by reviewing the operator's annual reports and then asking the operators to explain during the headquarters audit for each Operator each year Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous 1 NA Question B.14 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.11 NA for 2009 as there were no probable violations. Practice is to have written and photo documentation even on the follow up of the corrections. All information is kept in the same file; the inspection, the evidence, the violation letter, the response, the final finding? 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a probable violation as specified in the "Guidelines for State Participating in the Pipeline Safety Program"? (Chapter 5.1) Previous Question D(1).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.12 Yes, see POP 1.6 & 5.7 1 1 13 Does the state have written procedures to notify an operator when a noncompliance is identified as specified in the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(4)) Previous Question D (1).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.13 Yes, see POP 1.6 & 5.7 1 1 14 Does the state have a written procedure for routinely reviewing the progress of compliance actions to prevent delays or breakdowns of the enforcement process, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(5)) Previous Question D(1).3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.14 Yes, see POP 1.6 & 5.7 DUNS: 102589939 2009 Natural Gas State Program Evaluation 1 1 Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 7

15 Has the State issued compliance actions for all probable violations discovered? (Note : PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation) Previous Question D(1).4 Yes = 1 No = 0 SLR Notes: B.15 NA for 2009 as there were no probable violations. Procedures are in place, see POP 1.6 & 5.7 1 NA 16 Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that prompt corrective actions were taken by operators, within the time frames established by the procedures and compliance correspondence, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? Previous Question D(1).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.16 NA for 2009 as there were no probable violations. Procedures are in place, see POP 1.6 & 5.7 1 NA 17 If compliance could not be established by other means, did state pipeline safety program staff request formal action, such as a "Show Cause Hearing" to correct pipeline safety violations? (check each states enforcement procedures) Previous Question D(1).6 No = 0 Yes = 1 1 NA SLR Notes: B.17 NA for 2009 as there were no formal actions. It is an available process, but is rarely needed (Show Cause Hearing). Most Operators are cooperative. Even fines are seldom necessary. See POP 1.6 & 5.7. 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question 1 NA D(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: appropriate file B.18 NA for 2009 as there were no probable violations. Procedures are in place, see POP 1.6 & 5.7. Final resolutions are documented and placed in the 19 Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question D(1).8 Yes = .5 No = 0 .5 NA SLR Notes: B.19 NA for 2009 as there were no probable violations. Procedures are in place, see POP 1.6 & 5.7. IPUC sends notices to Corporate officers 20 Did the compliance proceedings give reasonable due process to all parties? (check each states enforcement procedures) Previous Question D(1).9 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: B.20 NA for 2009 as there were no probable violations. Procedures are in place, see POP 1.6 & 5.7. It is a formalized process that is followed and explained to the Operator in the notice letter. Per POP, it includes notices, response times, dispute opportunity, & show cause hearings Compliance - 60106(a) States 21 Did the state use the current federal inspection form(s)? Previous Question D(2).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.21 ? B.26 NA. Idaho is a 60105(a) program 1 NA 22 Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question D(2).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.21 ? B.26 NA. Idaho is a 60105(a) program 1 NA 23 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.) Previous Question D(2).3 DUNS: 102589939 2009 Natural Gas State Program Evaluation 1 NA Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 8

Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.21 ? B.26 NA. Idaho is a 60105(a) program 24 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(2).4 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: B.21 ? B.26 NA. Idaho is a 60105(a) program 25 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(2).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: B.21 ? B.26 NA. Idaho is a 60105(a) program 26 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Previous Question D(2).6 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: B.21 ? B.26 NA. Idaho is a 60105(a) program 27 Part B: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: B.27 It is IPUC practice to inspect every Unit every year, and with few exceptions that practice is achieved. There is a high level of cooperation and shared goals between IPUC and operators to achieve and maintain safety in Idaho's pipeline systems Total points scored for this section: 17 Total possible points for this section: 17 DUNS: 102589939 2009 Natural Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 9

PART C - Interstate Agent States Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Previous Question D(3).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: C.1 ? C.8. NA. Not an Interstate Agent 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Previous Question D(3).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: C.1 ? C.8. NA. 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? Previous Question D(3).3 Yes = 1 No = 0 SLR Notes: C.1 ? C.8. NA. Not an Interstate Agent 1 NA 4 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.) Previous Question D(3).4 Yes = 1 No = 0 1 NA SLR Notes: C.1 ? C.8. NA. Not an Interstate Agent 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(3).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: C.1 ? C.8. NA. Not an Interstate Agent 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(3).6 Yes = 1 No = 0 SLR Notes: C.1 ? C.8. NA. Not an Interstate Agent 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Previous Question D(3).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: C.1 ? C.8. NA. Not an Interstate Agent 1 NA 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: C.1 ? C.8. NA. Not an Interstate Agent Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 102589939 2009 Natural Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 10

PART D - Incident Investigations Points(MAX) Score 1 Are state personnel following the procedures for Federal/State cooperation in case of an incident? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6.1) Previous Question E.1 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: D.1 Yes, 'Appendix E ? Federal/State Cooperation in Case of an Incident/Accident' is being followed. Also the new proposed Federal Incident form is being studied. Also see POP 6.0 2 Are state personnel familiar with the jurisdictional authority and Memorandum of Understanding between NTSB and PHMSA? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6 ? Appendix D) Previous Question E.2 Yes = .5 No = 0 SLR Notes: D.2 Yes, the State has a good understanding of the MOU between NTSB and DOT (PHMSA). Also see POP 6.2 .5 .5 3 Did the state keep adequate records of incident notifications received? Previous Question E.3 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: D.3 YES, All incidents are investigated and a report is made. (two incidents in '09.) 1 1 4 If an onsite investigation of an incident was not made, did the state obtain sufficient information by other means to determine the facts and support the decision not to go on-site? Previous Question E.4 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Fire Marshall or local fire dept D.4 Yes, see POP 6.1 & 6.6. telephonic contact, and data (including emails and State Fire Marshall reports). Most incidents are responded to by the State 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? Previous Question E.5, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Observations and Document Review 2 2 b. Contributing Factors c. Recommendations to prevent recurrences where appropriate Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement SLR Notes: D.5 Yes, Yes, Yes, Both Federal incidents have been documented and the reports are in the file. Final reports are still pending. Recommendations to prevent recurrences are identified and will be included in the final report 6 Did the state initiate enforcement action for violations found during any incident investigation(s)? Previous Question E.6 Variation Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: D.6 NA, no violations were found. Procedures are in place, see POP 1.6 & 5.7 1 NA 7 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports .5 0.5 to ensure accuracy and final report has been received by PHMSA? (validate annual report data from operators concerning incidents/accidents and investigate discrepancies) (Chapter 6) Previous Question E.7/E.8 Yes = .5 No = 0 SLR Notes: D.7 Yes, the incidents were monitored and the Operators were reminded to submit final reports to the federal database. Both incidents are closed 8 Part D: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: both parties D.8 IPUC enjoys a great relationship with Western Region PHMSA on incident data sharing and investigation. That relationship is proving beneficial to DUNS: 102589939 2009 Natural Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 11

Total points scored for this section: 6 Total possible points for this section: 6 DUNS: 102589939 2009 Natural Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 12

PART E - Damage Prevention Initiatives 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? Previous Question B.11 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: to Standard Inspections. E.1 Yes, IPUC does this per POP 7.7 and they have agreed to create an addendum sheet and place this question on it. The addendum sheet will be attached 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? New 2008 Yes = 2 No = 0 2 2 SLR Notes: (IGC), and Questar. E.2 Yes, it is in the Std Insp Form, under Damage Prevention. IPUC also checks the operator's 'Excavator Damage Report' for Avista, Intermountain Gas Co 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to 2 2 its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.7 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: E.3 Yes, the 3 main operators, many other underground utilities, both One-Call centers, IPUC, and some excavators are members of CGA, however MEMBERSHIP IS NOT MANDITORY. Two of the 4 operators have adopted DIRT, and a third operator is moving to adopt DIRT. The fourth operator has a miniscule amount of jurisdictional pipe in remote land. The IPUC is active in the CGA. The Idaho One-Call Law requires mandatory one-call membership for companies with underground facilities. The Idaho One-Call Law addresses many of the 9 elements within Damage Prevention of the 2006 PIPES Act, but enforcement has not been effectively addressed and mandatory excavator membership in One-Call is not required. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? New 2008 Yes = 1 No = 0 1 1 SLR Notes: E.4 Yes, per Digline Inc., Notifications and locates are by county, hits are reported by both county and operator. Hits per thousand is a calculated number. 5 Did the state review operators' records of accidents and failures due to excavation damage to ensure causes of failure are addressed to minimize the possibility of recurrence as required by 192.617? Yes = 2 No = 0 2 2 SLR Notes: E.5 Yes, generally during the annual headquarters audit. Annual reports, and work and repair tickets are used to ensure failure analysis is done 6 Part E: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: E.6 The Commission has been aggressively working to establish a statewide damage prevention program for Idaho. We are working with the Idaho Utility Coordinating Council, the utilities, and other stakeholder groups in this endeavor. We have met with different groups and made presentations on our draft proposed damage prevention program, and have requested their input, help, support and most importantly, their buy-in. We recently hosted a special damage prevention meeting at the Commission and invited senior management officials of the major utilities in the state. The meeting was very well attended and everyone there committed their support to the effort. We are working closely with the Idaho Utility Coordinating Council and others as we develop our State Damage Prevention Program utilizing the Nine Elements as a guide. We have conducted various surveys to identify all of the stakeholders. In addition, we have gathered input from stakeholders regarding the effectiveness of the state Underground Facilities Damage Prevention Act (dig law), their willingness to share damage stats and help facilitate a statewide damage prevention program. We have created task groups to work on various aspects of a good damage prevention program. These task groups are made up of representatives from different stakeholders. One task group is currently looking at the enforcement efforts in several other states to determine the model we may want to try to implement in Idaho. Another task group is working on a plan for establishing more local Utility Coordinating Councils (UCC) around the state, while other groups are working on the best ways to educate the public on calling before you dig and promoting the use of 811. We have applied for a state damage prevention program grant to help us facilitate the establishment of UCCs throughout the state and to enhance our advertising and education program in regard to "calling 811 before you dig." Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 102589939 2009 Natural Gas State Program Evaluation Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 13

PART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Intermountain Gas Company, opid 8160 Name of State Inspector(s) Observed: Ellis Hire and Ron Law Location of Inspection: Nampa, ID Date of Inspection: October 21, 2010 Name of PHMSA Representative: Patrick Gaume SLR Notes: F.1 Intermountain Gas Company, opid 8160 Ellis Hire and Ron Law Nampa, ID October 21, 2010 Patrick Gaume Intermountain contacts; Tim Wold, Operations Mngr; Dave Call, Meter Inspector; Scott Hubbard, Corrosion Tech. Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? New 2008 Yes = 1 No = 0 SLR Notes: F.2 Yes, the Operator was notified in advance and they had up to 4 personnel participating in the inspection 1 1 3 Did the inspector use an acceptable inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Previous Question F.2 Yes = 2 No = 0 SLR Notes: F.3 Yes, Form 2, Standard Inspection Report of Gas Distribution Operator, Rev 03/28/10 2 2 4 Did the inspector thoroughly document results of the inspection? Previous Question F.3 Yes = 2 No = 0 2 NA SLR Notes: F.4 NA, Two days of field inspection was observed, the field notes were thorough, but filling out the Form was not the targeted objective on the days I observed. I have full confidence the Form will be filled out based on the field notes 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.) New 2008 Yes = 1 No = 0 1 1 SLR Notes: tools F.5 Yes, multi-meter, Half cell, valve operating tools, test gauge equipment to prove pressures and test pressure reliefs, compressed gas, hoses and hand 6 What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) New 2008 Info Only = No Points Info Only Info Only SLR Notes: F.6 Standard Inspection of a Distribution Unit, specifically a field inspection of 6 regulator stations, rectifier stations, cp points, casing cp, valve actuations, pressure relief tests, road and bridge crossings, atmospheric corrosion, exposed pipe, etc 7 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) New 2008, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Procedures DUNS: 102589939 2009 Natural Gas State Program Evaluation 2 2 Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 14

b. Records c. Field Activities/Facilities d. Other (Please Comment) SLR Notes: F.7 Yes, (field activities) This was a Field portion of a full standard inspection and was focused on field activities 8 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Liaison will document reasons if unacceptable) Previous Question F.8 Yes = 2 No = 0 SLR Notes: F.8. Yes, Ellis & Ron showed adequate knowledge of the pipeline safety program goals and regulations 2 2 9 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) Previous Question F.10 Yes = 1 No = 0 SLR Notes: F.9. Yes, it was an 'end-of-day' review 1 1 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous 1 1 Question F.11 Yes = 1 No = 0 SLR Notes: F.10. Yes, low cp reading, sticky rain flap, debris in some valve casings, short bolts, loose pipe wrap, some vegetation. All items were isolated and minor, and were generally corrected on site or were immediately scheduled for correction 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector Info Only Info Only performed) Info Only = No Points SLR Notes: F.11 field inspection of 6 regulator stations, rectifier stations, cp points, casing cp, valve actuations, pressure relief tests, road and bridge crossings, atmospheric corrosion, exposed pipe, emergency numbers, signs and markers, condition of ROW, vegetation, cp isolation districts, locks, chains, fences, verified operating pressures, equipment vents and weather protection 12 Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only Info Only Info Only = No Points SLR Notes: F.12 Noted the clear pressure marking for all parts of the regulator stations; was done for emergency responders, and it was discovered to be valuable for all 13 Field Observation Areas Observed (check all that apply) 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 DUNS: 102589939 2009 Natural Gas State Program Evaluation Info Only Info Only Idaho IDAHO PUBLIC UTILITIES COMMISSION, Page: 15

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 F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other SLR Notes: F.13 Yes, regulator stations, rectifier stations, cp points, casing cp, valve actuations, pressure relief tests, road and bridge crossings, atmospheric corrosion, exposed pipe, emergency numbers, signs and markers, condition of ROW, vegetation, cp isolation districts, locks
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