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PHMSA mt-2022-gas-program-evaluation
2022 MT NG Program Evaluation - mt-2022-gas-program-evaluation (Montana; Natural Gas State Program Evaluation)
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MT NG Program Evaluation, 2022, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2022 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 2022 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 1#
MT NG Program Evaluation, 2022, page 22022 Gas State Program Evaluation -- CY 2022 Gas State Agency: Montana Rating: Agency Status: Date of Visit: 01/01/1900 - 01/01/1900 Agency Representative: Joel Tierney, Pipeline Safety Program Manager PHMSA Representative: Michael Thompson, State Liaison Commission Chairman to whom follow up letter is to be sent: Name/Title: James Brown, President Agency: Montana Public Service Commission Address: 1701 Prospect Ave, Vista Square Bulding City/State/Zip: Helena, MT 59620 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 2022 (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 50 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 100 State Rating................................................................................................................................................... 100.0 DUNS: 809588692 2022 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 2#
MT NG Program Evaluation, 2022, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress report) 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: Reviewed state records and documents to verify the progress report. Found no issues. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809588692 2022 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 3#
MT NG Program Evaluation, 2022, page 4PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities 5 5 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, Procedures for Pre-inspection, conducting inspections and post inspection are found in Section IV of the MTPSC Inspection, Enforcement and Incident Investigation Procedures. 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, All aspects of inspection scheduling is found in Section III (Inspection Planning) of the MTPSC Inspection, Enforcement and Incident Investigation Procedures. 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. The Commission Rules 38.5.2205-2209 ARM which address Notification, Review, & Closing of Probable Violations are found in Appendix C Administrative Rules of Montana (ARM), 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. 3 3 Evaluator Notes: DUNS: 809588692 2022 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 4#
MT NG Program Evaluation, 2022, page 5Yes, the procedures are found in Section V (Investigation of Incidents) This includes a procedure requiring the use of their Incident Investigation Checklist in V. 5 General Comments: Info Only = No Points Evaluator Notes: NONE Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 809588692 2022 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 5#
MT NG Program Evaluation, 2022, page 6PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines 5 5 Appendix C for requirements) Chapter 4.3 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 and John are fully qualified to conduct each type of inspection and have completed the Root Cause Course. Samuel is qualified to lead Standard Comp, OQ, DIMP, PAPI and Control Room Management inspections as well as do Root Cause inspections. 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Yes. Joel Has been a Program Manager for 19 years and has adequate knowledge of the PHMSA program and regulations. 3 General Comments: Info Only = No Points Evaluator Notes: NONE Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 809588692 2022 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 6#
MT NG Program Evaluation, 2022, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 5 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: Reviewed Random Operator List and found that two of the operators listed had been determined to be jurisdictional to PHMSA in 2019. 1. WBI energy and 2. OneOak, Reviewed the documentation for both showing PHMSA responsibility for oversight of the two different lines. All remaining operators were reviewed and found to be meeting the state's inspection scheduled time intervals. 2 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1. 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) 10 10 Evaluator Notes: Yes, the MTPSC uses the Inspector Assistant (IA) to do all of it's inspections and has a supplemental set of questions added to cover all PHMSA requirements. Inspections that were reviewed showed all forms were completed fully for an adequate review of each operator. 3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This should include verification 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, the state uses the form on each construction and standard field inspection. 2 2 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 Subparts O and P Yes = 2 No = 0 Needs Improvement = 1 a. Are the implementation plans of the state's large/largest operators(s) being reviewed annually to ensure they are completing full cycle of the IMP process? 2 2 DUNS: 809588692 2022 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 7#
MT NG Program Evaluation, 2022, page 8b. 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? Evaluator Notes: Yes, the MTPSC meets with their largest operators after annual reports are submitted and is tracking the implementation and conduct of planned mitigation efforts. They also verified that MDU now has 2 low pressure systems, that are monitored as a threat due to having old vintage steel, and have enhanced monitoring through their DIMP Plan. 5 Did the state review the following (these items are NTSB recommendations to PHMSA 2 2 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? Evaluator Notes: Yes, the state verified that operators with low pressure systems and of bare steel pipe in their systems have included these threats in their DIMP plans. 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 1 1 Evaluator Notes: Yes, they are doing what they can thru the inspection process and in meetings with operators. As mentioned before, Montana Dakota Utilities has low pressure systems listed as threats in their DIMP plan. They are also working with operators to move inside meter sets outside. 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? 10 10 DUNS: 809588692 2022 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 8#
MT NG Program Evaluation, 2022, page 9g. 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. i. 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, after review of several compliance actions from 2022 the MTPSC has a good process and procedures in place and were encouraged to develop more detailed procedures for monitoring compliance actions. The state meets the requirements of this question set. 8 (Incident Investigations) Were all federally reportable 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: accidents. There were no reportable incidents in 2022. The state does have adequate procedures in place to cover incidents and 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: No letter was due for 2021 evaluation. 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: The state conducted a safety seminar on February 8 & 9 of 2022 with participation from PHMSA TQ. 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. this topic is covered during Standard Inspections and during the Annual Report review. Info Only Info Only DUNS: 809588692 2022 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 9#
MT NG Program Evaluation, 2022, page 1012 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: Yes, they have a web site and have used the Pipeline Safety Trust to review and provide suggestions for improving it. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: There were 5 SRCRs in the PHMSA records. The state has followed up on all five. The five were caused by flooding. 14 Was the State responsive to: Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? 1 1 Evaluator Notes: Yes, a review of surveys sponsored by NAPSR showed the MTPSC was very active in providing input and information on a variety of topics and issues. 15 If the State has issued any waivers/special permits for any operator, has the state verified 1 1 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: The MTPSC has 5 active waivers listed on the PHMSA web site at this time, and have reviewed each one to verify the conditions are being met. 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Info Only Info Only Yes, the MTPSC has all records electronically stored and is working to get a data base set in place to help track efforts. 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: The MTPSC estimated and was required to complete 187 days of inspections. They were able to complete 195. They completed 37 days of construction inspections for a 19.7% of all estimated inspection days being construction. 18 Discussion on State Program Performance Metrics found on Stakeholder Communication site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Montana State Program Metrics: 2022 Info Only Info Only Damage Prevention: The numbers have increased from 2020 at 2.7 to 4.7 in 2022. What's up and what are you going to do to fix it? Inspection days per 1000 mile of gas pipe: The number of days has increase from 10.64 in 2020 to 11.67 in 2021. Inspection Days per MMO/LPG Unit: The number of days has moved down from 2.22 in 2020 to 1.78 in 2021. DUNS: 809588692 2022 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 10#
MT NG Program Evaluation, 2022, page 11Inspection days per 1000 mile of HL pipe: Since 2016 the inspection days for HL pipelines has gone up and down with 2018 being the low point at 4.83 days and then increasing to 8.7 days in 2020. Inspector Qualifications: The gas pipeline inspector qualifications have increased in the core training category from 2020 to 2021. The other two categories stayed the same. Gas Distribution system leaks: Leak repairs per 100 miles of pipe have gone downward from 2021 to 2022 in total leaks and Hazardous leaks repaired. The number of leaks scheduled for repairs has increase from 5 in 2021 to 32 in 2022. Gas pipeline enforcement program evaluation: The annual evaluation score has been 100 since 2015. Incident evaluation Program: Numbers have been at 100% since 2010. 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 Evaluator Notes: Yes. the 2 largest operators have been advised to implement this and have. Info Only Info Only 20 General Comments: Info Only = No Points Evaluator Notes: NONE Info Only Info Only Total points scored for this section: 50 Total possible points for this section: 50 DUNS: 809588692 2022 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 11#
MT NG Program Evaluation, 2022, 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 Evaluator Notes: LNG inspection - Energy West in West Yellowstone, MT. Last inspected in 2020 Pipeline operator had several representatives present during the inspection. Observed inspectors, Sam Harworth, John Torske and Joel Tierney Info Only Info Only 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, the inspection was conducted using 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: A. Yes, the inspectors questions were adequate to determine compliance. B. Yes, the inspector adequately reviewed the operator's records. C. The inspectors went to the LNG plant and observed and covered the operation of the vaporization system and the tank and other processes. D. Completed the inspection and did exit interview at the plant site. E, Yes, the inspection was of adequate length. 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, all inspectors observed showed adequate knowledge of the pipeline safety program and regulations. 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, an exit interview was conducted at the end of the field inspection at the plant site. 1 1 6 Was inspection performed in a safe, positive, and constructive manner ? DUNS: 809588692 2022 Gas State Program Evaluation Info Only Info Only Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 12#
MT NG Program Evaluation, 2022, page 13Info 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) d. Other Evaluator Notes: A. No unsafe acts performed during the inspection. B. The inspectors reviewed records, documents and procedures for the operator's LNG system. And, observed the condition and safety functions of the plant site for compliance. C. D. 7 General Comments: Info Only = No Points Evaluator Notes: NONE Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 809588692 2022 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 13#
MT NG Program Evaluation, 2022, 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: Operator annual report data is analyzed each year as part of the states review of Annual reports. Staff looks for trends and operator specific issues by comparing previous years data and through conversations with operator staff. A data mine that was built in 2020 is used for this analysis. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 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: The state verifies that each operator has a system in place for analyzing excavation damages for the purpose of determining root cause and minimizing the impacts of future damages to their system. Montana PSC staff includes discussion with district managers for the purpose of understanding root cause variations across the state. There may be trends in the state beyond those associated with rapid growth in more metropolitan areas, and these trends are being discussed and compared with available data. 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation 4 4 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: Part D data are studied numerically, but the reported figures cannot currently be cross analyzed by MT PSC staff. MT PSC staff do not have access to the data required for a comparison study, staff can only review data that is made available by the operator in the form of annual report data. Those figures are compared to other operators data of similar size. 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? 2 2 DUNS: 809588692 2022 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 14#
MT NG Program Evaluation, 2022, page 15c. 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? Evaluator Notes: MTPSC staff does a damage per 1000 calculation on all of its operators. There are several operators who report less than 100 tickets, which skews figures some. Several operators have never reported a damage. In 2022 staff asked the question of several operators who never report damages and were told that none occur. A secondary source of data to collaborate these claims has not been found. Statistics on damage analyzed over 12 years in the state of Montana show a DAM/1000 of 3.327, in 2021 this figure was 3.72 out of 117000 tickets. Montana's largest operator's both reported DAM/1000 of 3.6, and the third largest operator reported 5.8 from 7200 tickets. Energy West Montana understands this is high, but they are trending in the right direction. It is understood that the PSC should put more emphasis into EWM's damage prevention program. 5 General Comments: Info Only = No Points Evaluator Notes: NONE Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 809588692 2022 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 15#
MT NG Program Evaluation, 2022, 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: MT PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. 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: MT PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. 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: MT PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. 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: MT PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. 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: MT PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: MT PSC is not an interstate agent and does not have a 60106 agreement with PHMSA. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 809588692 2022 Gas State Program Evaluation Montana MONTANA PUBLIC SERVICE COMMISSION, Page: 16#
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