Inspectionhistorical
PHMSA nm-2021-gas-program-evaluation
2021 NM NG Program Evaluation - nm-2021-gas-program-evaluation (New Mexico; Natural Gas State Program Evaluation)
Current as of source date Government source
RegulusPipeline researchRegulusPipeline researchPHMSA nm-2021-gas-program-evaluation
NM NG Program Evaluation, 2021, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2021 Gas State Program Evaluation for NM PIPELINE SAFETY BUREAU 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: 142199152 2021 Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 1#
NM NG Program Evaluation, 2021, page 22021 Gas State Program Evaluation -- CY 2021 Gas State Agency: New Mexico Rating: Agency Status: Date of Visit: 05/23/2022 - 05/27/2022 Agency Representative: Jason Montoya PHMSA Representative: Michael Thompson Commission Chairman to whom follow up letter is to be sent: Name/Title: Wayne Propst, Chief of Staff Agency: New Mexico Public Regulatory Commission Address: 142 W. Palace Avenue City/State/Zip: Santa Fe, New Mexico 87501 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 2021 (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 45 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 95 State Rating................................................................................................................................................... 95.0 DUNS: 142199152 2021 Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 2#
NM NG Program Evaluation, 2021, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score Were the following Progress Report Items accurate? (*items not scored on progress report) 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 Evaluator Notes: a. Reviewed information no issues. b. Compared Attachment 2 data with NMPRC inspection records. c. Attachment 3 seems to be accurate. d. Verified incidents with PDM e. Verified compliance actions with NMPRC data and found no issues. f. NMPRC keeps electronic records. g. Verified staff training and qualifications with TQ Blackboard. i. NMPRC listed their performance goals and damage prevention initiatives. h. The NMPRC has adopted all required federal regulations. Civil Penalties are $100,000.00 and $1,000,000.00 Total possible points for this section: 0 Total points scored for this section: 0 DUNS: 142199152 2021 Gas State Program Evaluation NM PIPELINE SAFETY BUREAU, Page: 3 New Mexico#
NM NG Program Evaluation, 2021, 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: A. Sections 1 and 3, have procedures for how to conduct Standard Inspections B. Sections 1 and 3, have procedures for how to conduct TIMP and DIMP Inspections C. Sections 1 and 3, have procedures for how to conduct OQ Inspections D. Sections 1 and 3, have procedures for how to conduct Damage Prevention Inspections E. Sections 1 and 3, have procedures for how to conduct On-Site Operator Training F. Sections 1 and 3, have procedures for how to conduct Construction Inspections G. No LNG Inspection Units in state 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: Section 1, VI covers A) Level of compliance from last inspection and town plant (inspection unit) operating history. (i.e., leak history, non- compliance, accidents, etc.) B) Length of time since last comprehensive inspection. C) Internal and external events affecting the inspection unit such as construction, changes in operator personnel or operating procedures, etc. D) Specialized inspections will be conducted as needed or as time permits. E) Mergers and Acquisitions F) Risk Assessments including: Miles of HCA's, Population Density, and threats such as Poor Leak History, Excavation Damage, Corrosion, Natural Forces, etc. See Policy 10-001 ? Identifying High Risk Inspection Units 3 (Compliance Procedures) Does the state have written procedures to identify steps to be 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 3 3 DUNS: 142199152 2021 Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 4#
NM NG Program Evaluation, 2021, page 5Evaluator Notes: Section 1, VIII has procedures for notifying company/government official of non compliance, procedures which requires to routinely follow up on open compliance actions to avoid breakdowns and procedures on closing outstanding probable violations. 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: Pipeline Incidents and Accident Investigation procedures are covered in Section 2 3 3 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 142199152 2021 Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 5#
NM NG Program Evaluation, 2021, 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: A. Random inspection reports were reviewed to verify that lead inspectors were qualified. B. DIMP/IMP lead inspectors have the required training. C. There are no jurisdictional LNG facilities in NM. D. Three inspectors have successfully taken the Root Cause Training course. E. There was no outside training in 2021. F. Reviewed Inspector Training in Black Board verifying Inspectors have obtained qualifications to lead applicable 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, a review of the states records and discussions with Jason Montoya, (Program Manager) indicate adequate knowledge of the PHMSA program and regulations. 3 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 142199152 2021 Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 6#
NM NG Program Evaluation, 2021, page 7PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 3 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: A review of all types of inspections using the Random Operator Sample List showed that the state had not met the established inspection intervals set in their procedures. This included Standard, PAPI, D&A and OQ type inspections. A 2 point deduction. The state did meet the goal of 20% of inspection person days being Construction inspections at 22.4%. 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: The NMPRC uses PHMSA equivalent forms to conduct inspections. A review of inspections performed for operators on the Random Sample list showed all applicable portions of the inspections were completed. 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 NMPRC conducts OQ inspections using the proper forms to verify operator plans. 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? 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? 2 1 DUNS: 142199152 2021 Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 7#
NM NG Program Evaluation, 2021, page 8c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? Evaluator Notes: The state was not verifying the operator's integrity management programs annually to insure they are completing a full cycle of the IMP process. They will develop a short list of topics to be set as standing agenda items for discussion during their quarterly meetings with their largest operators. A deduction of 1 point. 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? Evaluator Notes: The NMPRC has an Addendum sheet on the inspection form which include NTSB and ADB questions. 2 2 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: The NMPRC has an Addendum sheet as part of their inspection form which includes NTSB and ADB questions. 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 8 DUNS: 142199152 2021 Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 8#
NM NG Program Evaluation, 2021, 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: State could not provide documentation that active compliance actions were routinely being reviewed or monitored. A 2 point deduction State Program Manager approves all compliance actions. 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? Evaluator Notes: Yes all Federally reportable incidents were investigated by the NMPRC. 10 10 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: PHMSA evaluation letter received 9/17/2021, Chairman's response mailed on 9/23/2021 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Info Only Info Only Years? Chapter 8.5 Info Only = No Points Evaluator Notes: Last seminar held on 10/26-28/2021 was a Common Ground Alliance seminar where the PM covered pipeline safety issues during the meeting. The New Mexico Gas Association who normally host the Safety Seminars has not held a meeting since the outbreak of Covid. However they are working on holding a meeting in 2022 or 2023. reviewed agenda for 10/2021 meeting. 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, inspection forms cover the NMPS submittals by operators. 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 1 1 DUNS: 142199152 2021 Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 9#
NM NG Program Evaluation, 2021, page 10Evaluator Notes: Yes, NMPRC website has pipeline safety information and also participate in conferences. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) 1 1 Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the NMPRC has worked with PHMSA to clear and close SRCRs and as of 8/2021 has responded and taken appropriate actions on all active reports. 14 Was the State responsive to: 1 1 Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? Evaluator Notes: Yes, the NMPRC responds to PHMSA and NAPSR surveys and requests, and does work in the WMS system to keep tasks updated. 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 The NMPRC has two waivers listed on the PHMSA web-site that are no longer active. The PM was provided the PHMSA waiver group email address to start the process to remove them. The email was sent at the time of the evaluation. 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes, the NMPRC keeps all records electronically. 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 Evaluator Notes: SICT ? 742 2021 Progress Report ? 749.5 7.5 more than SICT The state is working to make the SICT as accurate an estimate as possible. 3 3 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: ? Excavation Damages per 1000 Locate Tickets has remained fairly steady for the past 4 years at around 3.7 and has dropped just a little to the 3.5 level in 2020. ? Inspection days per 1000 miles of pipe have increased from 12.00 in 2019 to 19.0 in 2020 good trend. ? Inspection days per MMO/LPG have gone down from .50 in 2018 to .15 in 2020. ? Inspection days per 1000 miles of Hazardous liquid pipelines have increased from 61.00 in 2018 to 121.00 in 2019. ? Gas & Liquid Inspector core training has reduced in 2020, with a steady decline over the past 3 years. Cause of covid DUNS: 142199152 2021 Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 10#
NM NG Program Evaluation, 2021, page 11? Total Gas Distribution System Leaks eliminated per 1000 miles of pipe has dropped a little in 2020. ? Enforcement Program Evaluation is steady for both 2018 and 2019 for gas and liquid pipelines. 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, they have a question on their addendum form Info Only Info Only 20 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: D1. A deduction of 2 points. A review of all types of inspections using the Random Operator Sample List showed that the state had not met the established inspection intervals set in their procedures. This included Standard, PAPI, D&A and OQ type inspections. D4. A deduction of 1 point. The state was not verifying the operator's integrity management programs annually to insure they are completing a full cycle of the IMP process. They will develop a short list of topics to be set as standing agenda items for discussion during their quarterly meetings with their largest operators. D7. A deduction of 2 points. State could not provide documentation that active compliance actions were routinely being reviewed or monitored. Total points scored for this section: 45 Total possible points for this section: 50 DUNS: 142199152 2021 Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 11#
NM NG Program Evaluation, 2021, 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: A. Standard Inspection B. 2018 C. Yes, Engineer=Jon W, Jones, Consulting Technician = Ronnie Reynolds, EMW General Manager = Eddie O'Brien and EMW Field Support = Scott Davis 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 form is state generated and has PHMSA questions for Transmission and Distribution. 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. Procedures were reviewed on both Monday and part of Tuesday. Both Transmission related and distribution procedures were looked at. B. Records for Construction, corrosion, welding and maintenance were requested and reviewed. C. Inspectors reviewed procedures for all field activities observed. E. Yes 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 2 2 Evaluator Notes: As lead Kevin showed he had adequate knowledge of the pipeline safety program and the regulations. Members of the team also had input during the inspection that showed they had adequate knowledge also. 5 Did the inspector conduct an exit interview, including identifying probable violations? (If 1 1 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, the lead inspector conducted an exit interview with the operator and their representatives an the last day of the inspection. DUNS: 142199152 2021 Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 12#
NM NG Program Evaluation, 2021, page 136 Was inspection performed in a safe, positive, and constructive manner ? Info Only Info Only 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) d. Other Evaluator Notes: A. No unsafe acts were preformed during the inspection. B. Inspectors observed regulator station maintenance, Locating, valve maintenance and cathodic protection reads. C. N/A 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 142199152 2021 Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 13#
NM NG Program Evaluation, 2021, 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: The NMPRC review and analyze Annual Report and incident data to risk rank their operators. They also assess an annual pipeline safety fee and require additional information that is reviewed annually. The information is stored as part of the Large Operators reports. 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 NMPRC has enforcement authority over Damage Prevention and conducts investigations of every damage to pipeline facilities reported. The NMPRC tracks repeat offenders thru their enforcement efforts. Repeat offenders are assessed civil penalties in accordance with the states process and procedures. 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: A.Yes. Annual report issues discovered during a standard audit are included with that case number assigned by the lead inspector. B.Yes. This is a collaborative effort among the PSB, NM811, and New Mexico Regional Common Ground Alliance. The PSB's online reporting system allows for the investigator to select alleged violations consistent with One-Call Notification Practices Not Sufficient. C.Yes. This is a collaborative effort among the PSB, NM811, and New Mexico Regional Common Ground Alliance. The PSB's online reporting system allows for the investigator to select alleged violations consistent with Locating Practices Not Sufficient D.Generally yes. If a locator fails to comply the PSB expects operators to suspend OQ's, retrain, and requalify. E.Yes. This is confirmed during OQ audits. F.Yes. DP inspectors are investigating all damages reported and lead inspectors review the data during standard inspections. G.Yes. DP inspectors are investigating all damages reported and lead inspectors review the data during standard inspections. H. Yes. NM811 also requires operators to update maps annually per their membership agreements. I. Yes J.Yes. This is a collaborative effort among the PSB, NM811, and New Mexico Regional Common Ground Alliance. The DUNS: 142199152 2021 Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 14#
NM NG Program Evaluation, 2021, page 15PSB's online reporting system allows for the investigator to select alleged violations consistent with Excavation Practices Not Sufficient. 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: Yes, this is a collaborative effort amongst NM811, New Mexico Regional Common Ground Alliance, and Pipeline Safety Bureau. Data is submitted to CGA and included in their analysis as well. Contractors continue to be the highest contributor to damages resulting from excavation and the top three remain to be failure to call 811 before digging, failure to maintain marks, failure to maintain 18" tolerance zone with mechanical equipment. All damages are investigated and determined causes are published in NM's 3rd party damage reporting tool, KorInsight. 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 142199152 2021 Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 15#
NM NG Program Evaluation, 2021, 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: The NMPRC is not an Interstate Agent 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: The NMPRC is not an Interstate Agent 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: The NMPRC is not an Interstate Agent 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: The NMPRC is not an Interstate Agent 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: The NMPRC is not an Interstate Agent Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: The NMPRC is not an Interstate Agent Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 142199152 2021 Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, 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.