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PHMSA nv-2018-gas-program-evaluation
2018 NV NG Program Evaluation - nv-2018-gas-program-evaluation (Nevada; Natural Gas State Program Evaluation)
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NV NG Program Evaluation, 2018, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2018 Gas State Program Evaluation for PUBLIC UTILITIES COMMISSION NEVADA Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 1#
NV NG Program Evaluation, 2018, page 22018 Gas State Program Evaluation -- CY 2018 Gas State Agency: Nevada Rating: Agency Status: Date of Visit: 08/19/2019 - 08/23/2019 Agency Representative: Paul Maguire, Neil Pascual PHMSA Representative: Michael Thompson Commission Chairman to whom follow up letter is to be sent: Name/Title: Stephanie Mullen, Executive Director Agency: Public Utility Commission of Nevada Address: 1150 E. William Street City/State/Zip: Carson City, NV 89701 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 2018 (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 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 10 10 B Program Inspection Procedures 13 13 C Program Performance 44 44 D Compliance Activities 15 15 E Incident Investigations 11 11 F Damage Prevention 8 8 G Field Inspections 10 10 H Interstate Agent State (If Applicable) 2 2 I 60106 Agreement State (If Applicable) 0 0 TOTALS 113 113 State Rating................................................................................................................................................... 100.0 DUNS: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 2#
NV NG Program Evaluation, 2018, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Accurate. Reviewed local documents and information on PHMSA portal. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Verified days thru review of inspection activities reports and forms. PUCN was using the number of form 13 D&A inspections as part of the total number of D&A inspections completed for the year. Advised them that the number is only made up of completed comprehensive inspections using form 3.1.11. This should be a good number in 2019. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Verified thru comparison with data on PHMSA PDM. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, verified with comparison to information on PHMSA PDM and reviewed local documents. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, reviewed inspection reports and compliance actions taken by the state to verify. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, all program records were well organized and easily reviewed. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, verified thru review of state documents and information on PHMSA TQ site (BlackBoard) 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Maximum Penalties: $200,000.00 per Incident with a maximum of $2,000,000.00 Part 191: All Adopted DUNS: 878878743 2018 Gas State Program Evaluation 1 1 Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 3#
NV NG Program Evaluation, 2018, page 4Part 192: All Adopted Part 193: All Adopted Part 198: All Adopted Part 199: All Adopted 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the PUCNV did a good job of its accomplishments on the 2017 progress report. 1 1 10 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only A2 - Verified days thru review of inspection activities reports and forms. PUCN was using the number of form 13 D&A inspections as part of the total number of D&A inspections completed for the year. Advised them that the number is only made up of completed comprehensive inspections using form 3.1.11. This should be a good number in 2019. Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 4#
NV NG Program Evaluation, 2018, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure 2 2 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, the inspection procedures for al types of inspections are found in Section 8.1 and 8.2 of the PUCNV manual. See Pages 54-97. The PSCNV added additional information about risk ranking inspections in this area also. 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the inspection procedures are found in Section 8.9 of the PUCNV manual. See Pages 89-91 for additional information beyond the general inspection procedures. 3 OQ Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the inspection procedures are found in Section 8.2 of the PUCNV manual. See Pages 85-86 for specific information beyond the general inspection procedures. 4 Damage Prevention Inspection procedures should give guidance to state inspectors that 1 1 insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the inspection procedures are found in Section 8.2 of the PUCNV manual. See Pages 96-97 for specifics beyond the general inspection procedures. 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, see Section 5.4, pg 25-30. Addresses the joint PHMSA/State seminar, when to do additional operator training. Examples: a small operator gets a new operations manager, new rulemaking, etc. and how to document the training. 6 Construction Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 Yes, inspection procedures found in section 6.3 page 35, section 7.3 pages 41-45 section 7.5 pages 48-49 and appendix D. 7 Does inspection plan address inspection priorities of each operator, and if necessary each unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 DUNS: 878878743 2018 Gas State Program Evaluation 6 6 Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 5#
NV NG Program Evaluation, 2018, page 6a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: The PUCNV added to their inspection procedures information and guidance to enhance the risk ranking of inspections by adding a process that includes the evaluation of leakage, incidents and compliance actions, excavation damage, corrosion, natural forces and outside forces. See section 4.7 pages 20-22. 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 6#
NV NG Program Evaluation, 2018, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 632.50 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 5.13 = 1128.60 Ratio: A / B 632.50 / 1128.60 = 0.56 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: 7 Total Drug and Alcohol Inspects 18 Days on OQ Inspections 271.5 Construction Inspections = .43 % of total 220 X 5.13 = 1128.6 ? 632.5/1128.6 = (.56) 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: All but two inspectors have completed the Root Cause course 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. Neil has all of the PHMSA Core Classes, all IMP and DIMP Classes and the majority of the specialty classes. Neil and Paul have been to multiple NAPSR Western and Annual meetings with PHMSA and understand State program requirements. Paul Maguire is also on the NARUC pipeline safety sub-committee which meets with PHMSA (including Zach Barrett) at every NARUC meeting. They have also been involved since 2012 in annual program reviews. Neil also attended NAPSR New Program Manager training at the 2016 & 2017 NAPSR Annual Meeting. 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct 2 2 or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: PUCN received evaluation letter on 12/26/2018 and no response was necessary, but confirmed receipt by letter on February 6th. DUNS: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 7#
NV NG Program Evaluation, 2018, page 85 Did State conduct or participate in pipeline safety training session or seminar in Past 3 1 1 Years? Chapter 8.5 Yes = 1 No = 0 Evaluator Notes: Yes, conducted a safety seminar on April 17th and 18th 2018. was held simile cast for all southern and northern located speakers where there are speakers in the southern meeting and in the northern meeting and they take turns presenting to the whole state. Reviewed Agenda, invitation and sign in sheets. 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Yes, A sample of all types of inspections were reviewed. The PUCN also keeps a spreadsheet of all inspection completed. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes./ The PUCNV Staff uses the PHMSA Inspection forms for scheduled/formal audits/inspections. They also use an additional form covering all NTSB recommendation questions. 8 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) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: 1 NA 9 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) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: 1 NA 10 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) Chapter 5.1 Yes = 1 No = 0 1 1 Evaluator Notes: Yes. The PUCN sent questionnaires to all operators in 2015 requiring a response. These questions are also part of the special PHMSA/NTSB check list created for standard inspections of procedures. 11 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? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: 1 1 Yes. PUCN has more stringent reporting requirements than PHMSA does. (outlined in Docket No. 17-01001) DUNS: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 8#
NV NG Program Evaluation, 2018, page 912 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes, PUCN reviews Operator Reports when they are filed and often issues questions and/or meets with operator to go over data that changes from prior years or that looks inconsistent. 13 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Yes, PUCNV Staff requests confirmation each year from transmission operators that each has submitted the required NPMS submittal. They also verify the numbers by reviewing the data in PDM. 14 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. PUCN performs D&A inspections periodically using the large Comprehensive D&A Form, for the Large LDC operators using a tracking spreadsheet. 15 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. PUCN performs OQ Program reviews and OQ Field inspection of operators and uploaded those to PHMSA database for 2018. 16 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually? Are replies to Operator IM notifications addressed? (formerly part of Question C-13)). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. PUCN staff performed TIMP Implementation Audits for two LDCs (Southwest Gas and NV Energt/Sierra Pacific) in 2018. 17 Is state verifying operator's gas distribution integrity management Programs (DIMP)? 2 2 This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). (Are the State's largest operators programs being contacted or reviewed annually?). 49 CFR 192 Subpart P Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. PUCN staff performed DIMP Implementation and program Audits for two LDCs (Southwest Gas north and south and NV Energt/Sierra Pacific) in 2018. 18 DUNS: 878878743 2018 Gas State Program Evaluation Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. PAPEI Effectiveness Inspections should be conducted every four years by operators. 49 CFR 192.616 Yes = 2 No = 0 Needs Improvement = 1 2 2 Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 9#
NV NG Program Evaluation, 2018, page 10Evaluator Notes: PUCN completed 5 PAPI inspections out of 12 in 2018. 19 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, all enforcement actions and audit summary letters are filed on a periodic basis on the PUCN website with access for the public and other operator review in annual Commission Dockets. Directions to find the information is posted on the PUCN Gas Safety website. Had the PM pull up the PUCN website and accessed the enforcement actions for 2018. 20 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No Safety Related Conditions for 2018. 1 NA 21 Did the State ask Operators to identify any plastic pipe and components that has shown a 1 1 record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. the PUCN added this question to their Special Check List called "PHMSA and NTSB Questions. Reviewed the check list. 22 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Neil Pascual and/or Paul Maguire typically try to respond to all surveys. (Examples) - Neil Pascual and/or Paul Maguire typically try to respond to all surveys (Examples) - NAPSR Survey Aug 10, 2018 "Multiple Operators Serving Same Territory" - NAPSR Survey April 24, 2018 "Policy Handling PHMSA T&Q Class Failures" - NAPSR Survey July 7, 2018 "Gathering Lines Survey" - NAPSR Survey July 9, 2018 "Gaps in MAOP Verification" - 2018 API RP 1162 PA Revision Survey 1 1 23 If the State has issued any waivers/special permits for any operator, has the state verified 1 1 conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: No Special Permits have been issued. Nevada had issued a total of 4 waivers, all of which have since been rescinded thru PHMSA. 24 Did the state attend the NAPSR National Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes, Neil Pasqual attended the national meeting in New Mexico. 1 1 25 DUNS: 878878743 2018 Gas State Program Evaluation Discussion on State Program Performance Metrics found on Stakeholder Communication site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 2 2 Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 10#
NV NG Program Evaluation, 2018, page 11a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Evaluator Notes: Discussed the metrics with both Paul and Neil. Items covered; Damages per 100 locate tickets have dropped to their lowest level, (3.44) since starting to collect data in 2010. Inspection days per 1000 miles of pipeline has increased over 2015 to a little more than 8 inspection days for every 1000 miles of gas pipeline. Inspection days per MMO/LPG have dropped to one day per MMO/LPG operator in 2016 which is slightly down from 1.5 days in 2015. (with the reduction of master meter operators they have moved the days not doing MM's to the larger operators to not reduce the days in the field) Pipeline inspector qualification has improved dramatically over previous years. Gas distribution system leaks show that the number of leaks repaired per 1000 miles has down some from 2015 and the leaks repaired has stayed the same and leaks outstanding have gone down a little from 2015. Enforcement program evaluation score has stayed the same for 2014 and 2015. Incident investigation score has gone up significantly. 26 Discussion with State on accuracy of inspection day information submitted into State 1 NA Inspection Day Calculation Tool (SICT) Has the State updated SICT data? No = 0 Yes = 1 Evaluator Notes: Discussed the inspection days estimated on the State Inspection Calculating Tool (SICT) and their accuracy with both Paul and Neil. The SICT showed 421 days estimated for the 2018 year with 632.5 days reported on the 2018 progress report. The PUCN has been able to retain staff for the past few years which makes attaining the numbers easier and protects against the lose of inspectors. 27 Did the State verify Operators took appropriate action regarding Pipeline Flow Reversals, Product Changes and Conversions to Service? See ADP-2014-04 Needs Improvement = .5 No = 0 Yes = 1 1 NA Evaluator Notes: 28 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 44 Total possible points for this section: 44 DUNS: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 11#
NV NG Program Evaluation, 2018, page 12PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement c. Procedures regarding closing outstanding probable violations Yes No Needs Improvement Evaluator Notes: Reviewed procedures; A. = Section 8.6 B. = Section 8.7 & 8.8 C. = Section 8.12 and 9.7 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? (Incident Investigations do not need to meet 30/90 day requirement) Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Within 30 days, conduct a post-inspection briefing with the owner or operator of the gas or hazardous liquid pipeline facility inspected outlining any concerns; and Yes No Needs Improvement f. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. Yes No Needs Improvement Evaluator Notes: Reviewed a majority of the inspection records and followed all probable violations found thru the PUCN compliance process. No PVs were found in the inspection forms that did not make it into their compliance process. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes, all PVs discovered in inspection reports reviewed made it to a compliance action. 2 2 4 Did compliance actions give reasonable due process to all parties? Including "show 2 2 cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: Yes. All civil penalty actions in 2018 were resolved via a stipulation as explained in Attachment 5 of the Nevada 2018 Progress Report. 5 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Both Neil and Paul are very familiar with the states process for imposing civil penalties. 2 2 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? DUNS: 878878743 2018 Gas State Program Evaluation 1 1 Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 12#
NV NG Program Evaluation, 2018, page 13Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, There were $40,000.00 in civil penalties leveled in 2018, with all being collected during 2018. 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: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 13#
NV NG Program Evaluation, 2018, page 14PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ 2 2 accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: actions. Yes. Section 12 covers emergencies and section 12.3 page 113 of the PUCNV procedures manual covers these specific 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: Yes. Emergency phone numbers are provided to each operator via External Emergency Contact phone list at a minimum of once per year and on the change of staff. The PUCN requires positive voice confirmation on all Federal Reportable Incidents. The PUCN covers the MOU between NTSB and PHMSA in section 12.3 page 117, and will add additional language to enhance it to cover the Federal/State cooperation in case of incidents and accidents. 3 If onsite investigation was not made, did state obtain sufficient information from the operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes, the PUCN has covered this in section 12.3 pages 113 and 114. 1 1 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: Yes, the PUCN investigated all 4 federally reportable incidents and thoroughly documented their actions and conclusions and recommendations. 1. 1/15/2018 - Southwest Gas South, found 1 PV and a compliance action was taken in May of 2019 with civil penalties. 2. 3/22/2018, NV Energy, found 6 PVs and a compliance action was taken on August 9th with civil penalties. 3. 6/14/18 - Southwest Gas South, Investigation found no PVs and final report was closed on February 2019. 4. 9/20/2018 - Southwest Gas South, found 1 PV and a compliance action was taken in January 2019 without a civil penalty. 5 Did the state initiate compliance action for violations found during any incident/accident 1 1 investigation? Yes = 1 No = 0 Evaluator Notes: Yes, the PUCN investigated all 4 federally reportable incidents and thoroughly documented their actions and conclusions and recommendations. 1. 1/15/2018 - Southwest Gas South, found 1 PV and a compliance action was taken in May of 2019 with civil penalties. 2. 3/22/2018, NV Energy, found 6 PVs and a compliance action was taken on August 9th with civil penalties. DUNS: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 14#
NV NG Program Evaluation, 2018, page 153. 6/14/18 - Southwest Gas South, Investigation found no PVs and final report was closed on February 2019. 4. 9/20/2018 - Southwest Gas South, found 1 PV and a compliance action was taken in January 2019 without a civil penalty. 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking 1 1 appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. Worked with PHMSA AID on all 4 incidents reported in 2018 by keeping them informed on the progress of the response and investigation of the incidents. 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: 1 1 at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 Evaluator Notes: Yes. The PUCNV shares incident investigation information at the NAPSR Western Region meeting during their State of the State report. 8 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: E-2; Yes. Emergency phone numbers are provided to each operator via External Emergency Contact phone list at a minimum of once per year and on the change of staff. The PUCN requires positive voice confirmation on all Federal Reportable Incidents. The PUCN covers the MOU between NTSB and PHMSA in section 12.3 page 117, and will add additional language to enhance it to cover the Federal/State cooperation in case of incidents and accidents. Total points scored for this section: 11 Total possible points for this section: 11 DUNS: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 15#
NV NG Program Evaluation, 2018, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. They complete this during their procedures inspection audit using a form that they developed to address all special/ NTSB type questions. 2 Did the state inspector verify pipeline operators are following their written procedures 2 2 pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. A list of participating operators is independently requested from the One-Call Center (USA North) at the beginning of each year and that list is checked to ensure each jurisdictional operator is an active member. 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. The PUCN worked with its 4 largest operators to have them begin reporting to the CGA DIRT (Southwest Gas, NV Energy, Wendover Gas and Prospector Pipeline) damage data as these are these are the most likely entities to receive tickets and actually have damages. Operators report quarterly and the reports are reviewed for accuracy and actions. 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? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes. This data is tracked by the PUCN and a report submitted to the Commission in Feb/March of each year. 5 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 16#
NV NG Program Evaluation, 2018, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: NV Energy Name of State Inspector(s) Observed: Kelly everson and Daniel Adesina Location of Inspection: Reno/Sparks and Rainbow Bend, NV Date of Inspection: 8/20/2019 Name of PHMSA Representative: Michael Thompson Evaluator Notes: Inspectors did field portion of inspection. Covered different maintenance activities at regulator stations, cathodic protection PS stations/rectifier/bonds and odorant sampling sites. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? Yes = 1 No = 0 Evaluator Notes: Yes. the operator was notified in advance in writing. 1 1 3 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: The inspectors used form 15. 2 2 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. Both inspectors kept hand written notes and requested copies of records for their inspection. 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.) Yes = 1 No = 0 Evaluator Notes: 1 1 Yes. The inspector requested the calibration information on pressure gauges and leak detection equipment used on the job. 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: Records were reviewed on the previous day. 2 2 DUNS: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 17#
NV NG Program Evaluation, 2018, page 187 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 Yes. Both inspectors showed adequate knowledge of the pipeline safety program and regulations during the inspection. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 NA interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: The inspectors did not conduct an exit interview on this day, but completed it on the following day after questions the operator was asked had been addressed. 9 During the exit interview, did the inspector identify probable violations found during the 1 NA inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: The inspectors did not conduct an exit interview on this day, but completed it on the following day after questions the operator was asked had been addressed. 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. 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 u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping Info Only Info Only DUNS: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 18#
NV NG Program Evaluation, 2018, page 19D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 19#
NV NG Program Evaluation, 2018, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PSC Nevada is NOT an interstate agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PSC Nevada is NOT an interstate agent. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PSC Nevada is NOT an interstate agent. 1 1 4 Were 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.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PSC Nevada is NOT an interstate agent. 1 1 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PSC Nevada is NOT an interstate agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PSC Nevada is NOT an interstate agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PSC Nevada is NOT an interstate agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 2 Total possible points for this section: 2 DUNS: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 20#
NV NG Program Evaluation, 2018, page 21PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PSC Nevada does NOT have a 60106 agreement. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PSC Nevada does NOT have a 60106 agreement. 1 NA 3 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.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PSC Nevada does NOT have a 60106 agreement. 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PSC Nevada does NOT have a 60106 agreement. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PSC Nevada does NOT have a 60106 agreement. 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: PSC Nevada does NOT have a 60106 agreement. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 878878743 2018 Gas State Program Evaluation Nevada PUBLIC UTILITIES COMMISSION NEVADA, Page: 21#
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