Inspectionhistorical
PHMSA or-2018-gas-program-evaluation
2018 OR NG Program Evaluation - or-2018-gas-program-evaluation (Oregon; Natural Gas State Program Evaluation)
Current as of source date Government source
RegulusPipeline researchRegulusPipeline researchPHMSA or-2018-gas-program-evaluation
OR 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 OREGON PUC 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: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 1#
OR NG Program Evaluation, 2018, page 22018 Gas State Program Evaluation -- CY 2018 Gas State Agency: Oregon Rating: Agency Status: Date of Visit: 06/22/2019 - 06/25/2019 Agency Representative: Kevin Hennessy, Chief Pipeline Safety PHMSA Representative: David Lykken, State Liaison Commission Chairman to whom follow up letter is to be sent: Name/Title: Ms. Megan Decker, Chair Agency: Oregon Public Utilities Commission Address: 201 High Street SE, Suite 100 City/State/Zip: Salem, OR 97301-3398 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 9 B Program Inspection Procedures 13 13 C Program Performance 45 45 D Compliance Activities 15 15 E Incident Investigations 6 6 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 109 108 State Rating................................................................................................................................................... 99.1 DUNS: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 2#
OR 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 1 1 Evaluator Notes: No issues noted. Inspection Unit totals by operator type on Attachment 3 are consistent with the Inspection Unit totals on Attachment 1. Certain GD assets reclassified to GT based after submitting operator data into the PHMSA WMS. 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: Minimum number of inspection days required was 410. Actual was 430. The number of inspection days entered for each operator type and inspection type essentially match the records kept by the program. 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Reviewed PDM data including operator annual reports. No issues noted. 1 1 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: No re-portable incidents in CY2018. Information is consistent with the incident report information contained in PDM. 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 0 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Multiple entry errors. One-point deduction. Corrected PR submitted during evaluation. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Yes. No issues. All inspections kept in binders and electronically. Information readily available. 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: 1 1 Yes. Information verified through T&Q Blackboard training site. Training for personnel found to be complete and accurate. 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report 1 1 Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: No issues. Last adoption hearing was 2/2019 for amendments dated 4/2017. Discussed the need to conduct another in the near future due to recent amendments to Plastic Pipe rules. DUNS: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 3#
OR NG Program Evaluation, 2018, page 49 List of Planned Performance - Did state describe accomplishments on Progress Report in 1 1 detail - Progress Report Attachment 10 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The safety program met the inspection goals for 2018. A significant amount of construction took place in CY2018 on distribution systems. The program followed up on a number of state reportable events that met a lower reporting threshold ($5,000) than the federal minimum for incidents. Staff engages operators at Oregon Utility Safety Council meetings to train and advance shared safety goals outside of regular inspections. For damage prevention, the partnership with OHSA's safety program has reached the excavation community. 10 General Comments: Info Only = No Points Evaluator Notes: Question A-5: One-point deduction for multiple entry errors. Corrected PR submitted during evaluation. Info Only Info Only Total points scored for this section: 9 Total possible points for this section: 10 DUNS: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 4#
OR 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: OPUC's Guideline Procedures for Participating in the Pipeline Safety Program, Section V contains pre-inspection, inspection and post inspection procedures. This information is listed on pages 16 thru 31. 2 IMP and DIMP 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: Section V, chapters N and P on pages 25-26. 1 1 3 OQ 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: Section V, Chapter I. Page 23. 1 1 4 Damage Prevention 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: Section V, chapter N on pages 24-25. 1 1 5 Any operator training conducted should be outlined and appropriately documented as needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Section V, Chapter L on page 24. 1 1 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: Section V, Chapter H, pages age 21-23. 1 1 7 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement DUNS: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 5#
OR NG Program Evaluation, 2018, page 6b. 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: Yes. Addressed under Section IV - Inspection Planning pages 12 and 15. Time intervals listed on page 15. Program utilizes a "Inspection Unit Updated Worksheet" to document length of time between inspection types, document significant information such as incident history. List of factors for prioritizing inspections listed on page 14. 8 General Comments: Info Only = No Points Evaluator Notes: No point deductions under Part B. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 6#
OR 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): 430.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 3.64 = 801.17 Ratio: A / B 430.00 / 801.17 = 0.54 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: Yes. Total inspection days/ratio met. No issues. 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: Yes. a) OQ training necessary for conducting OQ inspections. b) Inspection staff who have conducted IM inspections as lead have completed all necessary T&Q training. c) Hennessy and Ivey have completed the T&Q Root Cause training. d) No outside training in CY2018 e) Inspectors who conducted standard inspections as lead have attend all necessary T&Q courses. 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 Evaluator Notes: Yes. No issues noted. PM is well acquainted with PHMSA program and regulations. 2 2 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: N/A. No response required. 2 NA 5 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: Program no longer participates in joint states seminar with WA and ID. Rather they attend and participate in monthly Oregon Utility Safety Committee (OUSC) meetings held regionally. PM has control of the OUSC agenda. Meetings cover Damage Prevention and Pipeline Related subject matter. Reviewed past agenda's, materials presented and attendance lists. Advantages to state program, pipeline operators, and broader utility audience in that meetings are more frequent, conducted in all regions of the state and information presented is current and reaches a broader audience. DUNS: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 7#
OR NG Program Evaluation, 2018, page 86 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. Inspection tracker in place and reviewed in addition to confirming through review of past CY inspections. Program has moved to IA for conducting inspections. 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 program utilized PHMSA IA equivalent inspection forms in CY2018. For CY2019 the program has moved to utilizing the IA to conduct their inspections. 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: N/A. No CI remaining in Oregon. 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: N/A. No CI remaining in Oregon 1 1 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. As in prior reviews questions asked in PHMSA Form-2 Gas Distribution Inspection Procedures-Emergency page 6. and PHMSA Form-1 Gas Transmission Std Inspections Procedures-Emergency Response. 11 Did the state review operator records of previous accidents and failures including 1 1 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: Yes. Tracked and reviewed annually with data pulled from the PDM, DIRT, and program's own investigative reports. Non- reportable event data utilized also. 12 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. Annual report data pulled from PDM and loaded into spreadsheet for historical reference, risk analysis, and inspection planning. Information shared with operators and during OUSC meetings. DUNS: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 8#
OR NG Program Evaluation, 2018, page 913 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 Evaluator Notes: Yes. Have suggested though that the program send out a annual reminder for consistency in messaging. 1 1 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. Five conducted in CY2018. Reminded program that use of the old PHMSA Form 13 while still okay on a state level but that comprehensive D&A inspections need to be completed using the form 3.1.11 not to exceed five years between inspections. 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. Zero days devoted to OQ plan reviews in CY2018. Program last reviewed written plans of their three LDC's back in CY2017. Field verification's are performed as part of standard comprehensive and DT&C inspections. 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. Six days devoted to TIMP activities in CY2018. Comprehensive plan reviews for two LDC's with HCA mileage conducted in 2015 and 2016. Any changes reviewed annually. 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. Last comprehensive reviews conducted in CY2016. Next scheduled for CY2020. State has no low pressure distribution systems in operation. 18 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 Evaluator Notes: Yes. Reviewed effectiveness inspection conducted in CY's 2016-2018. 2 2 19 DUNS: 933144107 2018 Gas State Program Evaluation Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). 1 1 Oregon OREGON PUC, Page: 9#
OR NG Program Evaluation, 2018, page 10Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Yes. State web site provides minimal information. Past inspection and enforcement history available through public records request only. Discussed during exit meeting. 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: One SRC reported and closed in CY2018 dated 8/2018. Reviewed documentation. 1 1 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. DIMP IA equivalent form is used for conducting written plan and field validation inspections. Past inspection results reviewed. 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. 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: One waiver still active. PHMSA 2012-0323 Alternative Strength Testing Methods for certain pipe segments. No action taken yet by operator. This waiver is not posted on the PHMSA web site. Program is monitoring. Reminder to provide monthly updates to Western Region even if no activity. 24 Did the state attend the NAPSR National Meeting in CY being evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: Yes., was attended by PM. Meeting held in Santa Fe, NM 1 1 25 Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. 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 AA's. The program has developed a partnership with Oregon ? OSHA's Safety Program. This partnership has generated eighty OHSA inspections related to underground installations. Aside from the worker safety component they recognize utility safety and damage prevention inspections are interconnected with PHSMA objectives, but not limited to: IMP mitigative measures, public awareness, emergency response, operator qualification and disqualification (for insufficient locate practices) and repair of the damaged pipeline facility. Their approach is to focus on the root of the issue and programs designed to prevent re-occurrence rather than just the repair itself. 26 DUNS: 933144107 2018 Gas State Program Evaluation Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT) Has the State updated SICT data? 1 1 Oregon OREGON PUC, Page: 10#
OR NG Program Evaluation, 2018, page 11No = 0 Yes = 1 Evaluator Notes: Discussed. Tool was updated in CY2018. No significant changes to inspections day calculation and have not identified any additional staffing needs. 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 Evaluator Notes: N/A no flow reversal, product changes, and/or conversion to service. 1 NA 28 General Comments: Info Only = No Points Evaluator Notes: No point deductions under Part C. Info Only Info Only Total points scored for this section: 45 Total possible points for this section: 45 DUNS: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 11#
OR 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: Yes. Same as last. OPUC Guideline Procedures; V Conducting Inspections, Section C General Code Compliance Inspection Guidelines Inspection Activities, Section S Notice of Probable Violation Tracking, and Section T Removal or Correction of Probable Violation. 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: Yes. 2018 Inspection reports sent to appropriate company officer. Probable Violations well documented. Tracks and reviews progress and resolution of PV's via Master Inspection List. 30 day and 90 day requirements to communicate findings met via exit interview which is performed at the end of each inspection and written notice via compliance letter to company officer or manager. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. Reviewed inspection documentation and associated correspondence. Compliance actions correlate with numbers submitted under revised Attachment 5 of the Progress Report. 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. Correspondence to operators outline procedures for challenging where a penalty or corrective action has been recommended. 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. PM is familiar with process. 2 2 DUNS: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 12#
OR NG Program Evaluation, 2018, page 136 Can the State demonstrate it is using their enforcement fining authority for pipeline safety 1 1 violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Civil penalties are considered. Last civil penalty issued in CY2013 in the amount of 40K. None issued CY2018. Discussed with the PM and senior administration during exit the importance of utilizing its fining authority for violations of pipeline safety regulations in addition to alternative enforcement methods used in the past. 7 General Comments: Info Only = No Points Evaluator Notes: No point deductions under Part D. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 13#
OR 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: Yes. Part VI Investigation of Incidents, Section F Specific Investigation Issues including On-site Incident/Accident Investigations addressed. 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. Stated in OPUC Guideline Procedures; Part VI Investigation of Incidents Section B, page 33-35. Program maintains 24hr Pipeline Emergency Reporting number. 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: No reportable incidents in CY2018 but program does investigate other non-reportable events. 1 1 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 NA 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: N/A. No reportable incidents in CY2018. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: N/A. No reportables in CY2018. 1 NA 6 Did the state assist Region Office or Accident Investigation Division (AID) by taking 1 NA 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: No reportables in CY2018. Program has demonstrated in the past of maintaining good communications with both AID and WR. 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) DUNS: 933144107 2018 Gas State Program Evaluation 1 1 Oregon OREGON PUC, Page: 14#
OR NG Program Evaluation, 2018, page 15Yes = 1 No = 0 Evaluator Notes: groups- no issues. Yes. Program shares their "state-of-the-state" during regional NAPSR meetings and relevant state and local stakeholder 8 General Comments: Info Only = No Points Evaluator Notes: No point deducted under Part E. Info Only Info Only Total points scored for this section: 6 Total possible points for this section: 6 DUNS: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 15#
OR 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 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: State addresses in the summary of their standard compliance and operations inspections. 2 2 2 Did the state inspector verify pipeline operators are following their written procedures 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. No issues noted. 2 2 3 Did the state encourage and promote practices for reducing damages to all underground 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. Program is actively involved with the Oregon Utility Notification Center. 2 2 4 Has the agency or another organization within the state collected data and evaluated 2 2 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: Yes. As in past the state has collected damage data on larger operators and performed sufficient analysis to understand target areas for enhancing excavation safety. 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: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 16#
OR NG Program Evaluation, 2018, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Name of Operator Inspected: Northwest Natural Gas Name of State Inspector(s) Observed: Ray Muller, David Hoy Location of Inspection: Coos Bay, OR Date of Inspection: 7/24/2019 Name of PHMSA Representative: David Lykken Evaluator Notes: Info Only Info Only A inspection of facilities associated with both the Coos County Transmission Pipeline & Coos Bay Distribution system. 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 company was notified and was represented during the inspection. 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: Yes. The IA was used to plan and conduct this inspection. 2 2 4 Did the inspector thoroughly document results of the inspection? 2 2 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The inspectors do an excellent job of documenting inspections with respect to observations made in the field and other substantive comments to support the inspector's rational for determining compliance including both satisfactory and unsatisfactory results. 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: Yes. Inspectors verified instrument calibration checks where necessary as well as checking the general condition of equipment used by the operator such as pressure gauges, CGI's, Fluke Meters, half cells, and odorization level testing equipment. 2 2 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: DUNS: 933144107 2018 Gas State Program Evaluation Yes. Inspectors had copies of operator's written procedure for conducting valve operations and maintenance and for performing CP reads at various test sites and rectifiers. Records were reviewed prior to the state evaluation visit. Oregon OREGON PUC, Page: 17#
OR 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, the lead inspector appeared to have a good working knowledge of the pipeline safety program and relevant regulations. 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: Final exit interview not observed since inspection is ongoing. Observations were addressed after completion of valve operation task. 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: Potential PV identified concerning not following written procedures when performing the valve operation task. Other concern expressed concerning operator's "SCADA Control Pack Panel" switches which have a habit of becoming inoperable due to environmental conditions the switches are exposed to. Switches need to be replace regularly. Breakdowns prevent operator from performing line valve actuation when following procedure. 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 Info Only Info Only DUNS: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 18#
OR NG Program Evaluation, 2018, page 19A. 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 Evaluator Notes: The quality of questions asked and ancillary probing by the inspectors was proportionate to their respective training and experience. Inspectors did a good job communicating issues that were observed. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 19#
OR 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: Does not have a interstate agent agreement. 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: Does not have a interstate agent agreement. 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: Does not have a interstate agent agreement. 1 NA 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: Does not have a interstate agent agreement. 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? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Does not have a interstate agent agreement. 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: Does not have a interstate agent agreement. 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: Does not have a interstate agent agreement. 1 NA 8 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: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 20#
OR 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: Does not have a 60106 certification. 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: Does not have a 60106 certification. 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: Does not have a 60106 certification. 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: Does not have a 60106 certification. 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: Does not have a 60106 certification. 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: Does not have a 60106 certification. 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: 933144107 2018 Gas State Program Evaluation Oregon OREGON PUC, Page: 21#
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