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2009 NM NG Program Evaluation - nm2009ngprogramevaluation (New Mexico; Natural Gas State Program Evaluation)
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NM NG Program Evaluation, 2009, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2009 Natural Gas State Program Evaluation for NM PIPELINE SAFETY BUREAU Document Legend PART: O -- Representative Date and Title Information A -- General Program Qualifications B -- Inspections and Compliance - Procedures/Records/Performance C -- Interstate Agent States D -- Incident Investigations E -- Damage Prevention Initiatives F -- Field Inspection G -- PHMSA Initiatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 1#
NM NG Program Evaluation, 2009, page 22009 Natural Gas State Program Evaluation -- CY 2009 Natural Gas State Agency: New Mexico Rating: Agency Status: Date of Visit: 05/10/2010 - 05/14/2010 Agency Representative: Jason N. Montoya, PE, Bureau Chief PHMSA Representative: Patrick Gaume, State Liaison Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. David King, Chairman Agency: New Mexico Public Regulation Commission Address: 1120 Paseo de Peralta, 4th floor , P.O. Box 1269 City/State/Zip: Santa Fe, New Mexico 87504-1269 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2009 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual certification/agreement attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART F): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART F, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A General Program Qualifications 26 25 B Inspections and Compliance - Procedures/Records/Performance 24 21.5 C Interstate Agent States 0 0 D Incident Investigations 6.5 3 E Damage Prevention Initiatives 9 6 F Field Inspection 12 12 G PHMSA Initiatives - Strategic Plan 10 6.5 H Miscellaneous 3 3 I Program Initiatives 9 9 TOTALS 99.5 86 State Rating................................................................................................................................................... 86.4 DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 2#
NM NG Program Evaluation, 2009, page 3PART A - General Program Qualifications Points(MAX) Score 8 7 1 Did the state submit complete and accurate information on the attachments to its most current 60105(a) Certification/60106 (a) Agreement? (NOTE: PHMSA Representative to verify certification/agreement attachments by reviewing appropriate state documentation. Score a deficiency in any one area as "needs improvement". Attachment numbers appear in parenthesis) Previous Question A.1, Items a-h worth 1 point each Yes = 8 No = 0 Needs Minor Improvement = 3-7 Needs Major Improvement = 2 a. State Jurisdiction and agent status over gas facilities (1) b. Total state inspection activity (2) c. Gas facilities subject to state safety jurisdiction (3) d. Gas pipeline incidents (4) e. State compliance actions (5) f. State record maintenance and reporting (6) g. State employees directly involved in the gas pipeline safety program (7) h. State compliance with Federal requirements (8) SLR Notes: A.1 -IMPROVEMENT NEEDED-7 points. d. Attachment 4, two Significant Natural Gas Incidents were not reported. The record should show that there were four Natural Gas Incidents not two. The incidents missed are 20090162 and 20090124. NRC numbers associated with the incidents are 923895 and 915015. Incidents are reported at a $5000 loss to the State. Items a-c & e-h are fine. 2 Did the state have an adequate mechanism to receive operator reporting of incidents to ensure state compliance with 60105(a) Certification/60106(a) Agreement requirements (fatality, injury requiring hospitalization, property damage exceeding $50,000 - Mechanism should include receiving "after hours" reports)? (Chapter 6) Previous Question A.2 Yes = 1 No = 0 SLR Notes: A.2. Yes, in SOP. Also the web site is updated to show correct phone numbers. 1 1 3 Has the state held a pipeline safety TQ seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar or if 2 2 state requested seminar, but T&Q could not provide, indicate date of state request for seminar. Seminars must be held at least once every 3 calendar years.) (Chapter 8.5) Previous Question A.4 Yes = 2 No = 0 SLR Notes: A.3. Yes, past TQ Seminars were held June 13-15, 2005, Sept 24-26, 2008, and Oct 19-21, 2009. The next seminar is targeted for June 15-17, 2010. 4 Were pipeline safety program files well-organized and accessible?(NOTE: This also includes electronic files) (Chapter 5) Previous Question A.5 Yes = 1 No = 0 1 1 SLR Notes: A.4. Yes, files are kept in the Bureau of Pipeline Safety office area. (PSB is continuing to receive Operator Annual Reports as a courtesy. PSB has drafted a regulation to make submittal of annual reports mandatory, and plans to submit the proposed regulation to the New Mexico PRC Commissioners. Date is pending.) 5 Did state records and discussions with the state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? (Chapter 4.1, Chapter 8.1) Previous Question A.6 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: A.5. Yes, Bruno & Joe were in charge in 2009. Jason was hired in 2/2010. Jason N Montoya, the new Bureau Chief, is a Registered Professional Engineer. He lacks pipeline safety experience and needs to attend some T&Q classes. The PSB staff is well trained. 6 Did the state respond in writing within 60 days to the requested items in the Chairman's letter following the Region's last program evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8 Yes = 1 No = 0 SLR Notes: A.6. Yes, the PHMSA letter was sent Dec 18, 2009. The NM response was sent Feb 16, 2010. This is a timely response. 1 1 DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 3#
NM NG Program Evaluation, 2009, page 47 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the 1 1 previous year? Did actions correct or address deficiencies from previous year's evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8/A.9 Yes = 1 No = 0 SLR Notes: A.7. Yes, they gave a full response; all items were addressed point by point. They are still in a budget shortage, they hired a new Bureau Chief and have active notices two more positions, and they are committed to a well funded pipeline program but did apply for a waiver from the 3 year funding requirement. They have started issuing fines for one Call violations, they have taken action toward requiring operator annual reports, they have asked for advice concerning outside training, they corrected the annual reports to show 60105 status... Personnel and Qualifications 8 Has each inspector fulfilled the 3 year TQ training requirement? If No, has the state been granted a waiver regarding TQ courses by the Associate Administrator for Pipeline Safety? (NOTE: If the State has new inspectors who have not attended all TQ courses, but are in a program which will achieve the completion of all applicable courses within 3 years of taking first course (5 years to sucessfully complete), or if a waiver has been granted by the applicable Region Director for the state, please answer yes.) (Chapter 4.4) Previous Question A.10 Yes = 3 No = 0 3 3 SLR Notes: A.8. Yes, all inspectors with 3+ years of service have passed all TSI core courses, and the new inspectors are taking courses and are scheduled for the rest. 9 Brief Description of Non-TQ training Activities: Info Only = No Points Info Only Info Only For State Personnel: A.9. State- there was no non-TQ training in 2009. Most of the Staff attended the TQ Seminar. For Operators: Operators ? Provided 16 damage prevention seminars, 0 Master Meter training programs and 0 SIF training sessions. Hosted the TQ Seminar. For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: Non-operator/public ? There were no Public training events in 2009. SLR Notes: A.9. State- there was no non-TQ training in 2009. Most of the Staff attended the TQ Seminar. Operators ? Provided 16 damage prevention seminars, 0 Master Meter training programs and 0 SIF training sessions. Hosted the TQ Seminar. Non-operator/public ? There were no Public training events in 2009. I Encouraged increased focus on outside training opportunities in the 2009 review and in the year end letter. Firm plans for 2010 include Master Meter outreach training in Albuquerque, Santa Fe, Las Cruces, and Farmington, some of the trainings will include SIF. There are no firm plans for non TQ training of staff for 2010. Outside training can include, API 653 certified tank inspector, Certified welding inspector, NACE certification, Ultrasonic Inspection of welds (UT training), Guided Wave training, Plastic pipe training, etc. This sort of training almost always requires out-of-state travel. 10 Did the lead inspectors complete all required T&Q OQ courses and Computer Based Training (CBT) before conducting OQ Inspections? (Chapter 4.4.1) Previous Question A.12 Yes = 1 No = 0 SLR Notes: A.10. Joe Johnson, TSI 299 11/03; Isaac Lerma, 11/03; are the Lead OQ inspectors. They were also TSI 311 trained in 3/07 & 3/07. 1 1 11 Did the lead inspectors complete all required TQ Integrity Management (IMP) Courses/Seminars and CBT before conducting IMP Inspections? (Chapter 4.4.1) Previous Question A.13 Yes = 1 No = 0 1 1 SLR Notes: A.11. GIMP & LIMP Lead is Joe Johnson. He was trained in 6/05 TSI 297; 10/06 TSI 306; 3/07 TSI 307; 6/04 TSI 292; 5/05-7/05 GIMP CBT 1-6; & LIMP 8/02 TSI 294. No SHRIMP training has been announced. 12 Was the ratio acceptable of Total inspection Person-days to Total Person-days charged to the program by state inspectors? (Region Director may modify points for just cause) (Chapter 4.3) Previous Question B.12 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 5 5 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): Ratio: A / B DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 4#
NM NG Program Evaluation, 2009, page 5If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 SLR Notes: A.12. A=535 person days. B=5.59 man years * 220=1229.8 person days. A/B=.435. .435>.38 okay. 13 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Info Only Info Only Question B.13 Info Only = No Points SLR Notes: A.13. No, Staffing is still targeted for 11 employees. For most of 2009 there were 9.7 employees. There was one vacancy throughout 2009, Bruno Carrara left in August, 2009, and Deana Trujillo retired 12/31/09. Jason N Montoya was hired in February, 2010 and candidate lists have been provided from Human Resources to replace the two vacancies. 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: A.14. 811 and NM One-Call are fully implemented with all excavators and underground utilities participating as required. Effective 1st Qtr, 2010 the one-call center went 24-7-365 to address emergency tickets. Non-emergency advance notice remains 48 hr advance notice during regular (7am-5pm) business hours. During 2009 the first civil penalties were assessed on nine excavators totaling $4500 for failing to make one-calls or digging within 18" of unexposed marked facilities. This is the start of effective civil penalties for enforcement of the State Damage Prevention Program. The Governor proclaimed April, 2009 & 2010 as Damage Prevention Month, and emphasized the 811 One Call. Total points scored for this section: 25 Total possible points for this section: 26 DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 5#
NM NG Program Evaluation, 2009, page 6PART B - Inspections and Compliance - Procedures/Records/ Performance Points(MAX) Score Inspection Procedures 1 Does the State have a written inspection plan to complete the following? (all types of operators including LNG) (Chapter 5.1) Previous Question B.1 + Chapter 5 Changes + Incorporate LNG Yes = 6.5 No = 0 Needs Improvement = 50% Deduction a Standard Inspections (Including LNG) (Max points = 2) b IMP Inspections (Including DIMP) (Max points = .5) c OQ Inspections (Max points = .5) d Damage Prevention (Max points = .5) e On-Site Operator Training (Max points = .5) f Construction Inspections (Max points = .5) g Incident/Accident Investigations (Max points = 1) h Compliance Follow-up (Max points = 1) SLR Notes: B.1. Yes, SOP Section 1 V & VI, Section 2, & Section 3. 6.5 6.5 Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement 2 Did the written Procedures for selecting operators adequately address key concerns? (Chapter 5.1) Previous 2 2 Question B.2, items a-d are worth .5 point each Yes = 2 No = 0 Needs Improvement = 50% Deduction a Length of time since last inspection Yes No Needs Improvement b History of Operator/unit and/or location (including leakage , incident and compliance history) Yes No Needs Improvement c Type of activity being undertaken by operator (construction etc) Yes No Needs Improvement d For large operators, rotation of locations inspected Yes No Needs Improvement SLR Notes: B.2. Yes, SOP Section 1 addresses items a, b, c, & d. Inspection Performance 3 Did the state inspect all types of operators and inspection units in accordance with time intervals established in its written procedures? (Chapter 5.1) Previous Question B.3 Yes = 2 No = 0 2 0 SLR Notes: B.3. No. 0 points. Of 366 Units, 186 were inspected in 2009. However, 2 Units were missed and went beyond the 3 year inspection cycle. In both cases it was a missed Standard Inspection. 4 Did the state inspection form cover all applicable code requirements addressed on the Federal Inspection forms? (Chapter 5.1 (3)) Previous Question B.4 Yes = 1 No = 0 SLR Notes: B.4 Yes, NM PRC uses the Federal Forms, current version. 1 1 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 1 1 Yes = 1 No = 0 SLR Notes: B.5. Yes, however, several Nat Gas & Haz Liq Standard Inspections were marked N/C for Public Awareness Program Procedures. NM PRC is strongly cautioned to get these several planned stand-alone Public Awareness Inspections done in a timely manner so as to not violate its own 3 year inspection rule. It was decided that henceforth Public Awareness Program Inspections will be done as part of Standard Inspections. 6 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.6 Yes = .5 No = 0 SLR Notes: DUNS: 142199152 2009 Natural Gas State Program Evaluation .5 .5 New Mexico NM PIPELINE SAFETY BUREAU, Page: 6#
NM NG Program Evaluation, 2009, page 7B.6. Yes, there was one SRCR in 2009, SRC 20090063. It was monitored and closed in a satisfactory manner. 7 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Previous Question B.7 Yes = .5 No = 0 SLR Notes: B.7. NA, there is no remaining cast iron in service in NM. .5 NA 8 Did the state review operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Previous Question B.8 Yes = .5 No = 0 SLR Notes: B.8. NA, there is no remaining cast iron in service in NM. .5 NA 9 Did the state review operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Previous Question B.9 Yes = .5 No = 0 .5 0 SLR Notes: B.9. No. 0 points. These addendums were reported to have been added to standard Inspections since 9/23/2008. Spot checks of inspections conducted during 2009 showed some of the inspection forms to lack this information. 10 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 192.617? (NTSB) Previous Question 1 1 B.10 Yes = 1 No = 0 SLR Notes: for accident response. B.10. Yes, the SOP directs review of the Operator Incident File while preparing for a Standard inspection So to insure the Operator has proper procedures Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous 1 1 Question B.14 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.11. Yes; Inspection reports are in the 'Unit' file, Violation letters & a copy of the Inspection Report are in the Unit 'Suspense' file, When the violation is resolved, it goes into the 'Resolved' file for a given calendar year. Effective April, 2010, all correspondence and inspection is being saved electronically. Electronic files will become the official files. 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a probable violation as specified in the "Guidelines for State Participating in the Pipeline Safety Program"? (Chapter 5.1) Previous Question D(1).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.12. Yes, in the SOP, Section 1. PSB is seeking Commission permission to directly assess small civil penalties. 1 1 13 Does the state have written procedures to notify an operator when a noncompliance is identified as specified in the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(4)) Previous Question D (1).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.13. Yes, in the SOP, Section 1. 1 1 14 SLR Notes: DUNS: 142199152 2009 Natural Gas State Program Evaluation Does the state have a written procedure for routinely reviewing the progress of compliance actions to prevent delays or breakdowns of the enforcement process, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(5)) Previous Question D(1).3 Yes = 1 No = 0 Needs Improvement = .5 1 1 New Mexico NM PIPELINE SAFETY BUREAU, Page: 7#
NM NG Program Evaluation, 2009, page 8B.14. Yes, in the SOP, Section 1. 15 Has the State issued compliance actions for all probable violations discovered? (Note : PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation) Previous Question D(1).4 Yes = 1 No = 0 SLR Notes: B.15. Yes, 108 in 2009, 105 in 2008, 109 in 2007, and 129 in 2006. 1 1 16 Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that prompt corrective actions were taken by operators, within the time frames established by the procedures and compliance correspondence, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? Previous Question D(1).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.16. Yes, the NM PRC PSB follows its own procedures. 1 1 17 If compliance could not be established by other means, did state pipeline safety program staff request formal action, such as a "Show Cause Hearing" to correct pipeline safety violations? (check each states enforcement procedures) Previous Question D(1).6 No = 0 Yes = 1 SLR Notes: B.17. Yes, it is in the SOP, section 1.VIII.c.1.b.3 & 4. 1 1 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question 1 1 D(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.18. Yes, Inspection reports are in the 'Unit' file and Unit 'Suspense' file, Violation letters are in the Unit 'Suspense' file, When the violation is resolved, it goes into the 'Resolved' file for a given calendar year. The Chief sends a final letter when a case has been resolved. Effective April, 2010, all correspondence and inspection is being saved electronically. Electronic files will become the official files. 19 Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question D(1).8 Yes = .5 No = 0 SLR Notes: B.19. Yes. In the SOP, section 1, VIII, B. .5 .5 20 Did the compliance proceedings give reasonable due process to all parties? (check each states enforcement procedures) Previous Question D(1).9 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.20. Yes, due process is afforded all per the SOP & State Regulations. 1 1 Compliance - 60106(a) States 21 Did the state use the current federal inspection form(s)? Previous Question D(2).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.21-26. NA 1 NA 22 Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question D(2).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.21-26. NA 1 NA DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 8#
NM NG Program Evaluation, 2009, page 923 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Previous Question D(2).3 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: B.21-26. NA 24 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(2).4 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.21-26. NA 1 NA 25 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(2).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: B.21-26. NA 26 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Previous Question D(2).6 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: B.21-26. NA 1 NA 27 Part B: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: B.27 New Mexico has been recognized as being only one of 16 states where Damage Prevention is a joint effort with State Agencies, Utility owners, Federal DOT, and the Governor's Office. The PSB is discovering that the best way to find jurisdictional lines is when Operators self report or report on each other. We appreciate the decision to maintain the PSB in a robust state. The new Bureau Chief was hired in February, 2010, and the two positions advertised are about to be filled. Targeted staff is being maintained at 11 people. Total points scored for this section: 21.5 Total possible points for this section: 24 DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 9#
NM NG Program Evaluation, 2009, page 10PART C - Interstate Agent States Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Previous Question D(3).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: C.1-8. NA 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Previous Question D(3).2 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: C.1-8. NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Previous Question D(3).3 Yes = 1 No = 0 SLR Notes: C.1-8. NA 1 NA 4 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Previous Question D(3).4 Yes = 1 No = 0 SLR Notes: C.1-8. NA 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(3).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: C.1-8. NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(3).6 Yes = 1 No = 0 SLR Notes: C.1-8. NA 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Previous Question D(3).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: C.1-8. NA 1 NA 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: C.1-8. NA Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 10#
NM NG Program Evaluation, 2009, page 11PART D - Incident Investigations Points(MAX) Score 1 Are state personnel following the procedures for Federal/State cooperation in case of an incident? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6.1) Previous Question E.1 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: NTSB. D.1. Yes, is in the SOP sec 2; 1. Determine if safety violations occurred. 2. Determine root causes of the accident if asked by NTSB. 3. Cooperate with 2 Are state personnel familiar with the jurisdictional authority and Memorandum of Understanding between NTSB and PHMSA? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6 ? Appendix D) Previous Question E.2 Yes = .5 No = 0 SLR Notes: D.2. Yes, the MOU between NTSB and OPS is understood, and NM PRC fully cooperates with NTSB. .5 .5 3 Did the state keep adequate records of incident notifications received? Previous Question E.3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: D.3. Yes, 4 records out of 4 Federally reportable incidents. NM PRC has the records but two incidents were missed in the Nat Gas Certification. 4 If an onsite investigation of an incident was not made, did the state obtain sufficient information by other means to determine the facts and support the decision not to go on-site? Previous Question E.4 Yes = 1 No = 0 Needs Improvement = .5 1 .5 SLR Notes: D.4. Needs Improvement. 0.5 point. In 2009, all 4 federally reportable incidents were discussed with the Operator. They were not documented relative to violation review. The SOP directs that Pipeline Safety personnel review all notifications and obtain sufficient information to decide whether an on-site investigation is needed. 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? Previous Question E.5, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Observations and Document Review 2 0 b. Contributing Factors c. Recommendations to prevent recurrences where appropriate Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement SLR Notes: D.5. No, no, no. 0 points. Files were not created in a timely manner and were incomplete for 2009 incidents or accidents. [Typically the NM PRC uses the federal Form 11 for incident investigations. The events are documented and Appendix C is followed. A timeline and a narrative will also be created as needed.] 6 Did the state initiate enforcement action for violations found during any incident investigation(s)? Previous Question E.6 Variation Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: D.6, No, 0 points. No 2009 incidents or accidents were documented as reviewed for possible violations. 1 0 7 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports .5 NA to ensure accuracy and final report has been received by PHMSA? (validate annual report data from operators concerning incidents/accidents and investigate discrepancies) (Chapter 6) Previous Question E.7/E.8 Yes = .5 No = 0 SLR Notes: D.7. NA, the Federal region office made no requests in 2009. NM PRC is a partner with PHMSA to ensure that incident reports are accurate & updated. 8 Part D: General Comments/Regional Observations Info Only = No Points SLR Notes: DUNS: 142199152 2009 Natural Gas State Program Evaluation Info Only Info Only New Mexico NM PIPELINE SAFETY BUREAU, Page: 11#
NM NG Program Evaluation, 2009, page 12D.8. Incident & accident investigations were poorly documented in 2009. Total points scored for this section: 3 Total possible points for this section: 6.5 DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 12#
NM NG Program Evaluation, 2009, page 13PART E - Damage Prevention Initiatives Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? Previous Question B.11 Yes = 2 No = 0 Needs Improvement = 1 2 1 SLR Notes: E.1. Needs Improvement, 1 point. It is in the SOP and performed during standard inspections. This issue was reported to have been added as an addendum to standard Inspections since 9/23/2008. Spot checks of inspections conducted during 2009 showed some of the inspection forms to lack this information. 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? New 2008 Yes = 2 No = 0 2 2 SLR Notes: monthly report to the PSB. E.2. Yes, It is addressed under 192.614c and is on the Standard inspection form. NM PRC requires Pipeline Operators to report ALL 3rd party damages in a 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to 2 2 its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.7 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: E.3. Yes, a 2 day seminar was conducted in May, 2007 where 811 was advertized. It was sponsored by NMPRC, One-Call, NUCA, & NM Gas Assoc. These organizations are the original members to create the NM Regional Common Ground Alliance. Attendees included major, middle and small pipeline companies, municipal systems, master meter operators, excavators, & other underground facility operators. Another Seminar was held August 19-20, 2008. In addition 35 two hour seminars were conducted throughout 2008 at locations throughout the State. The 2009 CGA meeting was held August 18-20, 2009 and 16 two hour seminars during 2009. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? New 2008 Yes = 1 No = 0 1 1 SLR Notes: E.4. Yes. PSB has access to all locate requests and all damage reports. Evaluations concerning type of damage, hits per alleged violator, cost to repair, injuries, by date, & hit frequency have been done. PSB applied for permission to enter into an information sharing contract with NM One-Call to further enhance data analysis and data collection, and to get the information entered into DIRT (Damage Information Reporting Tool). The contract with NM One- Call was signed in December, 2009 and data is being entered into DIRT. 5 Did the state review operators' records of accidents and failures due to excavation damage to ensure causes of failure are addressed to minimize the possibility of recurrence as required by 192.617? Yes = 2 No = 0 2 0 SLR Notes: E.5. No, not yet. 0 points. PSB is capturing damage reports which include incidents and failures, but is not getting mitigation options from the Operators. It is being discussed that the damage reports may need to be revised to include mitigation options. PSB has started getting this information in 2010 and initial review indicates severe under-reporting by some operators 6 Part E: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: E.6. During the last four years PSB has worked to implement the improvement of Public Awareness, the launching of 811, the creation of the NM Regional Common Ground Alliance, the improvement of NM One-Call, Exercising authority over excavators, Enforcing One-call requirements on Operators and Excavators, Issuing fines for One-Call violations to excavators and all underground utility operators, and participating in nation wide data gathering efforts like DIRT. Effective in December, 2009, the PSB entered into a contract with NM One-Call for information sharing with One-Call to improve your data resources and enhance your field enforcement capabilities. This contract will increase PSB's access to more detailed data and analysis to more fully address and analyze 3rd party hits. Also effective in the 2nd half of 2009 was the delegated authority for PSB personnel to issue written tickets for on-site One-Call violations. It's a 4 part ticket with the white original going to the violator on-site, the yellow copy is sent to the violator's home office, the pink copy goes to the PSB files, and the Canary copy stays as a permanent copy in the ticket book. Fines are typically $500. Fine authority up to $5000 for first offense & $25,000 for subsequent offence has been delegated to the PSB and is usually exercised by the Director of Transportation. An appeal of the fine would be handled by the PRC Commission. More is needed! Several FTEs could be filled solely for One-Call enforcement. One of the 2010 pending hires will be used to address One-Call enforcement. Total points scored for this section: 6 Total possible points for this section: 9 DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 13#
NM NG Program Evaluation, 2009, page 14PART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: New Mexico Gas Company Name of State Inspector(s) Observed: Mike Smith Location of Inspection: 604 West Elm Street, Farmington, New Mexico Date of Inspection: 4/19-20/2010 Name of PHMSA Representative: Dale Bennett SLR Notes: Joe Johnson was present during this inspection. Info Only Info Only 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? New 2008 Yes = 1 No = 0 SLR Notes: New Mexico Gas Company was notified on 2/25/2010, and 7 personnel participated in this inspection. 1 1 3 Did the inspector use an acceptable inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Previous Question F.2 Yes = 2 No = 0 SLR Notes: The inspector used PHMSA'S inspection form for a standard inspection of a natural gas operator. 2 2 4 Did the inspector thoroughly document results of the inspection? Previous Question F.3 Yes = 2 No = 0 SLR Notes: The inspector checked the boxes as he progressed through the inspection form. 2 2 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps, pyrometer, soap spray, CGI, etc.) New 2008 Yes = 1 No = 0 SLR Notes: The inspector insured the operator had the necessary equipment needed to performe the task in the field. 1 1 6 What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) New 2008 Info Only = No Points SLR Notes: The inspector completed a standard inspection in the field. Info Only Info Only 7 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) New 2008, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities/Facilities d. Other (Please Comment) 2 2 SLR Notes: DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 14#
NM NG Program Evaluation, 2009, page 15The inspector compared the site specific procedures to the field activities. 8 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Liaison will document reasons if unacceptable) Previous Question F.8 Yes = 2 No = 0 SLR Notes: The inspector has attended the minimum number of T&Q courses to lead a natural gas pipeline safety inspection. 2 2 9 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) Previous Question F.10 Yes = 1 No = 0 SLR Notes: The inspector briefed the operator at the conclusion of the inspection. 1 1 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous 1 1 Question F.11 Yes = 1 No = 0 SLR Notes: The inspector informed the operator that no probabe violations were found during the inspection. He made several recommendations to the operator. 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector Info Only Info Only performed) Info Only = No Points SLR Notes: The inspectors observations in the field included valves, locks, fences, signs, CP, line markers, atmospheric corrosion, overpressure monitors, overpressure regulators, odorization, rectifiers and ROW. 12 Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only = No Points SLR Notes: There were no best practices identified that should be shared with other states. Info Only Info Only 13 Field Observation Areas Observed (check all that apply) Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings Info Only Info Only DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 15#
NM NG Program Evaluation, 2009, page 16u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other SLR Notes: The list of items the inspector checked in the field. 14 Part F: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: The inspector conducted an inspection of the New Mexico Gas Company system operations of Farmington, New Mexico. There were no issues found that prevented awarding full amount of points for part F. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 16#
NM NG Program Evaluation, 2009, page 17PART G - PHMSA Initiatives - Strategic Plan Points(MAX) Score Risk base Inspections - Targeting High Risk Areas 1 Does state have process to identify high risk inspection units? Yes = 1.5 No = 0 1.5 0 Risk Factors (criteria) to consider may include: Miles of HCA's, Geographic area, Population Density Length of time since last inspection History of Individual Operator units (leakage, incident and compliance history, etc.) Threats - (Excavation Damage, Corrosion, Natural Forces, Other Outside Forces, Material or Welds, Equipment, Operations, Other) SLR Notes: G.1. No, not yet, 0 points. This new requirement could not be applied retroactively to 2008 work and its development was too late to apply to 2009 work. PSB has created a formal evaluation process for risk factors and is applying some of the risk factors during 2010. 2 Are inspection units broken down appropriately? (see definitions in Guidelines) Yes = .5 No = 0 SLR Notes: G.2. Yes, as per the State Guidelines. .5 0.5 3 Consideration of operators DIMP Plan? (if available and pending rulemaking) Info Only = No Points SLR Notes: G.3. Not yet. Operators are still preparing their DIMP Plans. Info Only Info Only 4 Does state inspection process target high risk areas? Yes = .5 No = 0 SLR Notes: G.4. Yes. It references, length of time, incident & violation histories, miles of HCA, geography, and population. .5 0.5 Use of Data to Help Drive Program Priority and Inspections 5 Does state use data to analyze effectiveness of damage prevention efforts in the state? (DIRT or other data, etc) Yes = .5 No = 0 SLR Notes: G.5. No, not yet. 0 points. Resources and contracts are in place to start this in 2010. .5 0 6 Has state reviewed data on Operator Annual reports for accuracy? Yes = .5 No = 0 SLR Notes: G.6. Yes. Fee and Grant monies are dependant on these reports, and they are therefore reviewed closely. .5 0.5 7 Has state analyzed annual report data for trends and operator issues? Yes = .5 No = 0 SLR Notes: .5 G.7. Yes, they are reviewed for completeness, miles of pipe, and leak history. The reports are compared with prior year reports. 0.5 8 Has state reviewed data on Incident/Accident reports for accuracy? Yes = .5 No = 0 SLR Notes: G.8. No, 0 points. This was not done for 2009 incidents or accidents. .5 0 DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 17#
NM NG Program Evaluation, 2009, page 189 Does state do evaluation of effectiveness of program based on data? (i.e. performance measures, trends, etc.) .5 0 Yes = .5 No = 0 SLR Notes: G.9. No, not yet, 0 points. With annual reports, inspection results, and One-Call data, there is enough information to start the process for 2010. 10 Did the State input all operator qualification inspection results into web based database provided by PHMSA in a timely manner upon completion of OQ inspections? Previous Question B.15 Yes = .5 No = 0 .5 0.5 SLR Notes: G.10. Yes, most of the OQ inspections were done in 2005 and they have been uploaded. In 2007, 18 of 18 OQ inspections have been uploaded, 128 of 128 protocol 9 inspections were uploaded in 2008, and 124 of 124 protocol 9 inspections were uploaded in 2009. 11 Did the State submit their replies into the Integrity Management Database (IMDB) in response to the Operators notifications for their integrity management program? Previous Question B.16 Yes = .5 No = 0 SLR Notes: G.11. Yes, received and uploaded the results of one violation notice in September, 2009, .5 0.5 12 Have the IMP Federal Protocol forms been uploaded to the IMDB? Previous Question B.17 Yes = .5 No = 0 SLR Notes: G.12. Yes, the 2008 GIMP inspection was uploaded. There were no GIMP inspections in 2009. .5 0.5 13 Did the State ask Operators to identify any plastic pipe and components that has shown a record of defects/leaks and what those operators are doing to mitigate the safety concerns? Previous Question B.18 Yes = .5 No = 0 SLR Notes: G.13. Yes. NM asked one operator and they chose not to respond. They stated they will do it when it is required. .5 0.5 14 Has state confirmed transmission operators have submitted information into National Pipeline Mapping System (NPMS) database along with any changes made after original submission? Yes = .5 No = 0 .5 0 SLR Notes: G.14. No, 0 points. This is a new question, and was not an area of emphasis before. It is being emphasized starting with the 2010 inspections. Accident/Incident Investigation Learning and Sharing Lessons Learned 15 Has state shared lessons learned from incidents/accidents? (i.e. NAPSR meetings and communications) .5 0.5 Yes = .5 No = 0 SLR Notes: G.15. Yes, NMPRC makes a report during the SW Region NAPSR Meeting, and responds as appropriate to email correspondence. There were no noteworthy accidents/incidents in 2009. 16 Does the State support data gathering efforts concerning accidents? (Frequency/Consequence/etc) .5 0.5 Yes = .5 No = 0 SLR Notes: G.16. Yes, reports are received, followup is made, paperwork is checked, lessons learned are derived, Accident causes and regulatory compliance are determined, and site visits are usually made. Inspector duties are outlined in SOP section 2. 17 Does state have incident/accident criteria for conducting root cause analysis? Info Only = No Points Info Only Info Only SLR Notes: search for probable cause. G.17. NMPRC does not have a criteria for a formal Root Cause Analysis at this time. Several inspectors are scheduled for the Root Cause class. They do 18 Does state conduct root cause analysis on incidents/accidents in state? DUNS: 142199152 2009 Natural Gas State Program Evaluation Info Only Info Only New Mexico NM PIPELINE SAFETY BUREAU, Page: 18#
NM NG Program Evaluation, 2009, page 19Info Only = No Points SLR Notes: G.18. NMPRC usually determines a probable cause to an incident, but does not do formal Root Cause Analysis at this time. 19 Has state participated on root cause analysis training? (can also be on wait list) Yes = .5 No = 0 .5 0.5 SLR Notes: G.19. Yes, 2 inspectors have attended Root Cause Analysis Class. Other inspectors are scheduled or on a wait list. Transparency - Communication with Stakeholders 20 Other than pipeline safety seminar does State communicate with stakeholders? (Communicate program data, pub awareness, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: G.20. Yes, through the NM Regional Common Ground Alliance, also by conducting seminars, making presentations at Trade Meetings, at Construction Industry Board Meetings, & at special meetings for Construction Industry Boards & their staffs. Also Master Meter Outreach presentations and Security & Integrity Foundation (SIF) training sessions. 21 Does state share enforcement data with public? (Website, newsletters, docket access, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: G.21. Yes, the public has access to PSB records of inspections, violations, and etc. There are plans to place some records on the web. 22 Part G: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: G.22. NMPRC has plans to place some records on the web site, and became a more data driven Organization during 2009. Total points scored for this section: 6.5 Total possible points for this section: 10 DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 19#
NM NG Program Evaluation, 2009, page 20PART H - Miscellaneous Points(MAX) Score 1 What were the major accomplishments for the year being evaluated? (Describe the accomplishments, NAPSR Activities and Participation, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: H.1. Yes. PSB entered into a data sharing contract with NM One-Call. PSB received authority to issue ticket violations for One-Call violations. They developed a process to start demanding 3rd party damage reports from operators. The New Mexico Governor's Office has joined with the PSB, Utility owners, and the Federal DOT to create a strong Damage Prevention program. The NM PRC has committed to maintain a well funded and fully staffed PSB. Quantitative indicators show a continual increase in the use of NM One-Call. PSB personnel participated on the NAPSR DIMP and GAP committees. 2 What legislative or program initiatives are taking place/planned in the state, past, present, and future? (Describe initiatives (i.e. damage prevention, jurisdiction/authority, compliance/administrative, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: Call violations. H.2. Yes. Implemented State wide bi-lingual excavator training for compliance with One-Call. PSB received authority to issue ticket violations for One- 3 Any Risk Reduction Accomplishments/Projects? (i.e. Cast iron replacement projects,bare steel,third-party damage reductions, etc.) Yes = .5 No = 0 .5 0.5 SLR Notes: H.3. Continuing a program that was started in 2003 to replace bare main, PVC, and ABS pipelines. Project shows 142.02 miles replaced through 2008, 4.47 miles replaced in 2009, and 108.3 miles remaining to be replaced. 4 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 SLR Notes: H.4. Yes. All e-mails and surveys are responded to. 1 1 5 Sharing Best Practices with Other States - (General Program) Yes = .5 No = 0 SLR Notes: H.5. the NM Regional CGA has been very successful, and reports have been presented to NAPSR. .5 0.5 6 Part H: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: H.6. The NM Regional CGA and NM One-Call have been successful. PSB received authority to issue ticket violations for One-Call violations. The bi- lingual excavator training has been beneficial. Work continues to enhance public access through the web site. Total points scored for this section: 3 Total possible points for this section: 3 DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 20#
NM NG Program Evaluation, 2009, page 21PART I - Program Initiatives Points(MAX) Score Drug and Alcohol Testing (49 CFR Part 199) 1 Has the state verified that operators have drug and alcohol testing programs? Yes = 1 No = 0 SLR Notes: I.1. Yes, Operators and their contractors have been inspected. 1 1 2 Is the state verifying that operators are conducting the drug and alcohol tests required by the operators program (random, post-incident, etc.) Yes = .5 No = 0 SLR Notes: I.2. Yes, Operators are being evaluated against federal guidelines and their own program. .5 0.5 3 Is the state verifying that any positive tests are responded to in accordance with the operator's program? Yes = .5 No = 0 SLR Notes: I.3. Yes, all documentation was fully reviewed. .5 0.5 Qualification of Pipeline Personnel (49 CFR Part 192 Subpart N) 4 Has the state verified that operators have a written qualification program? Yes = 1 No = 0 SLR Notes: I.4. Yes, Operators have developed their OQ Plans. 1 1 5 Has the state reviewed operator qualification programs for compliance with PHMSA rules and protocols? .5 0.5 Yes = .5 No = 0 SLR Notes: I.5. Yes, in 2005 & 2006. Also catching new Operators as they are created or move into the State. PSB has decided to enter a requirement into its SOP that full OQ inspections of each operator are required every 6 years. Protocol 9 inspections are required of each Unit every 3 years and are usually done as part of a standard inspection. 6 Is the state verifying that persons who perform covered tasks for the operator are qualified in accordance with the operator's program? Yes = .5 No = 0 SLR Notes: I.6. Yes, through the standard OQ inspection and the Field OQ inspection. .5 0.5 7 Is the state verifying that persons who perform covered task for the operator are requalified at the intervals specified in the operator's program? Yes = .5 No = 0 SLR Notes: I.7. Yes, through follow up OQ inspections. .5 0.5 Gas Transmission Pipeline Integrity Management (49 CFR Part 192 Subpart O) 8 Has the state verified that all operators with transmission pipelines have either adopted an integrity management program (IMP), or have properly determined that one is not required? Yes = 1 No = 0 1 1 SLR Notes: I.8. Yes, all operators have received a protocol A inspection, and those with HCAs have received a full IMP inspection. 9 Has the state verified that in determining whether a plan is required, the operator correctly calculated the potential impact radii and properly applied the definition of a high consequence area? Yes = .5 No = 0 SLR Notes: DUNS: 142199152 2009 Natural Gas State Program Evaluation .5 0.5 New Mexico NM PIPELINE SAFETY BUREAU, Page: 21#
NM NG Program Evaluation, 2009, page 22I.9. Yes, HCA determinations and impact radii calculations are reviewed. 10 Has the state reviewed operator IMPs for compliance with Subpart O? (In accordance with State Inspection plan) Yes = .5 No = 0 SLR Notes: I.10. Yes. Subpart O and the Federal Protocols are followed. .5 0.5 11 Is the state monitoring operator progress on the inspections, tests and remedial actions required by the operator's IMP, including that they are being done in the manner and schedule called for in its IMP? Yes = .5 No = 0 SLR Notes: I.11. Yes, It is part of the violation process. .5 0.5 12 Is the state verifying that operators are periodically examining their transmission line routes for the appearance .5 0.5 of new HCAs? Yes = .5 No = 0 SLR Notes: I.12. Yes, there is a policy in place to check for HCAs whenever an operator acquires new pipe. Also discussed plans to check for HCAs whenever there is new construction, new pipe by some other means, or when there is a discrepancy in NPMS. Public Awareness (49 CFR Section 192.616) 13 Has the state verified that each operator has developed a continuing public awareness program? (due date was .5 0.5 6/20/06 for most operators, 6/20/07 for certain very small operators,6/13/08 for master meters) Yes = .5 No = 0 SLR Notes: I.13. Yes. Performed the initial inspections, monitored the clearing house results, and performed the Clearing House follow ups. Also doing it during Standard Inspections or as Stand alone Inspections. 14 Has the state reviewed the content of these programs for compliance with 192.616 (by participating in the Clearinghouse or by other means)? Yes = .5 No = 0 SLR Notes: I.14. Yes. It is part of the inspection process. .5 0.5 15 Is the state verifying that operators are conducting the public awareness activities called for in its program? Yes = .5 No = 0 SLR Notes: I.15. Yes. It is part of the inspection process. .5 0.5 16 Is the state verifying that operators have evaluated their Public Awareness programs for effectiveness as described in RP1162? Info Only = No Points Info Only Info Only SLR Notes: I.16. Yes, Public Awareness has been an area of focus, and performance of those inspections has been a priority. Now that the program is well established it will have slightly less attention, but will continue to be inspected. 17 Part I: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: I.17 Public Awareness inspections will usually be part of Standard Inspections. Operator compliance with NMPS requirements will be given increased emphasis. Many operators will start being OQ re-inspected starting in 2011. Drug and Alcohol inspections are being conducted as stand-alone operator inspections. Total points scored for this section: 9 Total possible points for this section: 9 DUNS: 142199152 2009 Natural Gas State Program Evaluation New Mexico NM PIPELINE SAFETY BUREAU, Page: 22#
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