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PHMSA MT 2019 Gas Program Evaluation
2019 MT NG Program Evaluation - MT 2019 Gas Program Evaluation (Montana; Natural Gas State Program Evaluation)
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MT NG Program Evaluation, 2019, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2019 Gas State Program Evaluation for MONTANA PUBLIC SERVICE COMMISSION Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: 809588692 2019 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 1#
MT NG Program Evaluation, 2019, page 22019 Gas State Program Evaluation -- CY 2019 Gas State Agency: Montana Rating: Agency Status: Date of Visit: 08/03/2020 - 08/05/2020 Agency Representative: Mr. G. Joel Tierney, Pipeline Safety Program Manager PHMSA Representative: Patrick Gaume Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. Bob Lake, Chairman Agency: Montana Public Service Commission Address: 1701 Prospect Avenue, PO Box 202601 City/State/Zip: Helena, Montana 59620-2601 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2019 (not the status of performance at the time of the evaluation). 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 than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their 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. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 47 E Field Inspections 15 15 F Damage prevention and Annual report analysis 4 4 G Interstate Agent/Agreement States 0 0 TOTALS 94 91 State Rating................................................................................................................................................... 96.8 DUNS: 809588692 2019 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 2#
MT NG Program Evaluation, 2019, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? Info Only Info Only Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: Yes. Attachments 1, 3, & 8 are internally consistent and agree with MT PSC records. Attachment 2, 4, 5, 6, 7, 8, & 10 are consistent with MT PSC internal records. Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809588692 2019 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 3#
MT NG Program Evaluation, 2019, page 4PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. TIMP and DIMP Inspections (reviewing largest operator(s) plans annually) c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) g. LNG Inspections Evaluator Notes: Yes*7. see section IV.1 for pre, during, and post inspection information for all inspections listed. 5 5 2 Do written procedures address inspection priorities of each operator, and if necessary 4 4 each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? Evaluator Notes: Yes. see Section IV Inspection Planning. It now has a Link the 'Inspection Schedule' spreadsheet. The 'inspection Schedule' spreadsheet has the detail for Unit and Operator ranking. 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 3 3 taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: Yes. See Procedures Section V.13 which references Commission Rules 38.5.2205-2209 ARM which address Notification, Review, & Closing of Probable Violations. and Pipeline Procedures Section IV Post inspection Activities. 4 (Incident/Accident Investigations) Does the state have written procedures to address state actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. Evaluator Notes: Yes. See Procedures Section VI.9 which address Conducting & Closing of Incident Investigations. 3 3 DUNS: 809588692 2019 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 4#
MT NG Program Evaluation, 2019, page 55 General Comments: Info Only = No Points Evaluator Notes: Part B scored 15 of 15 points. DUNS: 809588692 2019 Gas State Program Evaluation Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 5#
MT NG Program Evaluation, 2019, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See 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 b. Completion of Required DIMP/IMP Training before conducting inspection as lead c. Completion of Required LNG Training before conducting inspection as lead d. Root Cause Training by at least one inspector/program manager e. Note any outside training completed f. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) Evaluator Notes: Yes. Joel & John are fully qualified. 5 5 2 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 = 5 No = 0 Needs Improvement = 1-4 Evaluator Notes: Yes. Joel Has been a Program Manager for 19 years and is completely familiar with his program 5 5 3 General Comments: Info Only = No Points Evaluator Notes: Part C scored 10 of 10 points. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 809588692 2019 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 6#
MT NG Program Evaluation, 2019, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 4 intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction (did state achieve 20% of total inspection person-days?) g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: NI 4 of 5 points. DIMP inspections missed deadlines due to illness, and an inspector resigning. Attachment 2 showed 23 of 104 Field days was charged to Construction. 2 Did inspection form(s) cover all applicable code requirements addressed on Federal 10 8 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: NI 8 of 10 points. A PAPEI was missed on Abaco, and the focus concerning Master Meters has been to get them absorbed by the LDC, not to perform every type of inspection. Master Meter count has decreased from about 140 to 4 over the last 20 years. 3 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 established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Full OQ inspections were performed for all operators other than Master Meters in 2013 and 2018. In addition, Field OQ performance inspections are part of most Construction Inspections. 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 a. Are the state's largest operator(s) plans being reviewed annually? b. Are states verifying with operators any plastic pipe and components that have shown a record of defects/leaks and mitigating those through DIMP plan? c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? 2 2 DUNS: 809588692 2019 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 7#
MT NG Program Evaluation, 2019, page 8Evaluator Notes: Yes, IMP & DIMP inspections are up to date, complete, and within the 5-year inspection interval. Some operators had 'one & done' inspections to verify Imp as not needed or to Abandon the Facilities in the State. Review of Plastic is on-going and problems are reported. No recent Plastic Pipe problems requiring mitigations through DIMP plans. MDU has 6 low pressure systems, that are monitored as a threat due to having old vintage steel, that have enhanced monitoring through their DIMP Plan. 5 Did the state review the following (these items are NTSB recommendations to PHMSA that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. 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); c. 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; d. 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; e. 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; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? 2 2 Evaluator Notes: Yes, all items a through g, are addressed in a supplemental inspection sheet that are tied to every Standard Inspection. It is kept in an inspection folder, we discussed uploading this question set into IA as a pdf file. 6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, it is being done. We discussed that documentation has fallen off and will be re-emphasized. 1 1 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. 10 10 DUNS: 809588692 2019 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 8#
MT NG Program Evaluation, 2019, page 9i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) Evaluator Notes: Yes. See Procedures Section IV 'Post Inspection Activities'; Directs an Exit Briefing at the close of the inspection, and 'if applicable a notice of probable violation will be issued within 90 days'. Section V.13 which references Commission Rules 38.5.2205-2209 ARM which address Notification, Review, & Closing of Probable Violations. 8 (Incident Investigations) Were all incidents investigated, thoroughly documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? i. Does state share any lessons learned from incidents/accidents? 10 10 Evaluator Notes: Yes. Both incidents were visited on-site. One is complete and one is still in process. No problems. The email and after-hours phone no. are known. Onsite observations, & contributing factors were documented. No violations found. Incidents are shared during Regional NAPSR Meetings. Contact is made with PHMSA AID immediately. 9 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 = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. A response was not required last year. 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Evaluator Notes: Yes. The most recent Session was 2/19/2019 in Helena, MT Info Only Info Only 11 Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only = No Points Evaluator Notes: Yes. During all Standard Inspections and during the Annual Report review. PDM is used. Info Only Info Only 12 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). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: DUNS: 809588692 2019 Gas State Program Evaluation 1 1 Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 9#
MT NG Program Evaluation, 2019, page 10Yes, the Seminar, an improving website, an open door policy, The Pipeline Safety Trust made some suggestions that were followed. 13 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: Yes. But no SRC in 2019. 1 1 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; b. Operator IM notifications; and c. PHMSA Work Management system tasks? Evaluator Notes: Yes. There are lots of Survey Monkeys! Prompt response is made to all items listed. 1 1 15 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. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes. PA12 pipe is about to be released & is working with PHMSA-Steve Nanny. The other 4 will be continued. 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes. Files are 100% electronic. Info Only Info Only 17 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 3 3 Evaluator Notes: Yes. SICT is calculated every year. 104 inspection-days was less than the 185 days required, due to illness and resignation. 18 Discussion on State Program Performance Metrics found on Stakeholder Communication Info Only Info Only site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Yes. MPSC closely monitors all 6 performance measures: Damage Prevention Program, Inspection Activity, Inspector Qualification, Leak Management, Enforcement, and Incident Investigation. The indicators are all neutral or positive. A major success was the 2017 revision of the Damage Prevention Law where MT now requires reporting of line hits and now has civil penalties associated with Damage Prevention violations. The success continued in 2018 & 2019 with the designated agency, MT Dept. of Labor, actively enforcing Damage Prevention violations with civil penalties ranging from $100 to $25,000. 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Info Only Info Only Evaluator Notes: Yes. Operators have been advised to implement this, it is possible that this will become part of the Regulations. DUNS: 809588692 2019 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 10#
MT NG Program Evaluation, 2019, page 1120 General Comments: Info Only = No Points Evaluator Notes: Part D scored 47 of 50 points. Questions D1 & D2 were NI. DUNS: 809588692 2019 Gas State Program Evaluation Info Only Info Only Total points scored for this section: 47 Total possible points for this section: 50 Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 11#
MT NG Program Evaluation, 2019, page 12PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Info Only Info Only Evaluator Notes: MONTANA - DAKOTA UTILITIES CO, OP ID 12684; MDU Exxon Line, Unit ID 88862, MS TEAMS inspection, All participants are remote; some from home and some from their office; 6 MDU, 3 MPSC, & 1 PHMSA in attendance. Standard Inspection using IA. 2 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) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Used IA. 2 2 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: Yes. This Inspection was a Standard Inspection for Procedures and Records 4 From your observation 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: Yes. John Torske demonstrated a professional level of knowledge, abilities, and demeanor. 2 2 5 Did the inspector conduct an exit interview, including identifying probable violations? (If inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. No violations found. No items of Concern. 1 1 6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only Info Only DUNS: 809588692 2019 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 12#
MT NG Program Evaluation, 2019, page 13d. Other Evaluator Notes: discussed. Yes. This inspection was via MS TEAMS, and was for Procedures and Records only. No best practices were discovered or 7 General Comments: Info Only = No Points Evaluator Notes: Part E scored 15 of 15 points. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 809588692 2019 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 13#
MT NG Program Evaluation, 2019, page 14PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 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: Yes, this cross references to Question D18. Annual Reports are compared with PDM data, and compared year to year. They are reviewed in comparison with the Performance Metrics. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 NA determining root causes and minimizing the possibility of a recurrence? (? 192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (? 192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Between the State Dept. of Labor & The Montana Utility Coordinating Council. Joel is a Board Member of the MT Utility Coordinating Council, (as required by the By-Laws of the Coordinating Council). The State One-Call Board is Lead for Damage Prevention. 3 Has the state reviewed the operator's annual report pertaining to Part D ? Excavation Damage? Yes = 4 No = 0 Needs Improvement = 1-3 a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: Yes, these items are part of the annual review of the annual reports. 4 NA 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? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? 2 2 Evaluator Notes: DUNS: 809588692 2019 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 14#
MT NG Program Evaluation, 2019, page 15Yes. Between the State Dept. of Labor & The Montana Utility Coordinating Council. Joel is a Board Member of the MT Utility Coordinating Council, (as required by the By-Laws of the Coordinating Council). The State One-Call Board is Lead for Damage Prevention. 5 General Comments: Info Only = No Points Evaluator Notes: Part F scored 10 of 10 points. Info Only Info Only Total points scored for this section: 4 Total possible points for this section: 4 DUNS: 809588692 2019 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 15#
MT NG Program Evaluation, 2019, page 16PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections. Info Only = No Points Evaluator Notes: NA not an Interstate Partner. Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days. Info Only = No Points Evaluator Notes: NA not an Interstate Partner. 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: NA not an Interstate Partner. Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: NA not an Interstate Partner. Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: NA not an Interstate Partner. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: NA not an Interstate Partner. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809588692 2019 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 16#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.